This chapter of the Environmental Statement (ES) sets out the approach taken to the Environmental Impact Assessment (EIA) of the project. The chapter also includes details of the consultation undertaken to date and the overall approach to the assessment of the likely effects of the project. Further details of topic specific methodologies, such as survey methods, are provided in each topic chapter of this ES.
Scoping is the process of identifying the issues to be addressed during the EIA process. Scoping is an important preliminary procedure, which sets the context for the EIA process.
Regulation 15 of the EIA Regulations allows an applicant to request that the local planning authority sets out its opinion (known as a Scoping Opinion) as to the issues to be addressed in the ES. Whilst there is no formal requirement in the EIA Regulations to seek a Scoping Opinion prior to submission of an ES, it is recognised as best practice to do so.
A scoping request was submitted. The Scoping Report that accompanied the request is provided at Appendix 4.1 of this ES.
The Scoping Opinion was provided by the Council and is also provided at Appendix 4.1 of this ES.
Appendix 4.2 of this ES provides a more detailed overview of the key points raised in the Scoping Opinion or by consultees for each topic area, together with a response to these. The ES topic chapters also provide a summary of the topic-specific key points raised during consultation with both statutory and non-statutory consultees.
The scoping exercise highlighted a number of areas that consultees wished to see addressed within the ES. Taking into account the nature, size and location of the project, the information provided within the Scoping Opinion and other consultation responses provided throughout the EIA process, the following topics have been identified as requiring consideration within this ES:
The structure of this ES is set out in Chapter 1: Introduction.
The design of the project has evolved since the submission of the Scoping Report to the Council as described in Chapter 3: Need and Alternatives. However, it is considered that the scope of the EIA and the responses made in the Council’s Scoping Opinion remain valid and relevant to the current design.
Climate Change Resilience
Resilience to future climate change has been considered during the design process. The design has taken into account, for example, future flood risk and resilience to extreme weather events. The conceptual surface water drainage strategy for the project has been designed to take into account the 1 in 100-year flood risk event, plus a 40% allowance for climate change. Further details are provided in Chapter 2: Project Description and the Flood Risk Assessment (FRA).
Changes to Future Environmental Conditions
Consideration of predicted changes in baseline environmental conditions, including changes resulting from climate change, has been set out within each ES topic chapter (Chapter 5), where robust information is available at the time of writing. Details are provided in the methodology section of this chapter.
The assessment of effects for each topic has taken into account identified trends or changes predicted to arise as a result of climate change.
Effects of the Project on Climate
Atmospheric emissions associated with operation of the project are assessed within a chapter not presented within this demonstration site. These include emissions from construction and operational traffic.
Effects on other aspects of the environment are not likely to be significant. The topics scoped out of the assessment are set out in the Scoping Report (provided at Appendix 4.1) and summarised below.
Planning Policy
The ES provides an overview of relevant legislative and planning policy context within each topic chapter. The assessment has had regard to national and local policy documents, where relevant. A separate chapter on planning policy has not been included within the ES. However, a Planning Supporting Statement has been prepared to support the planning application.
Material Assets
The EIA Regulations refer to ‘material assets’, including architectural and archaeological heritage aspects. The phrase ‘material assets’ has a broad scope, which may include assets of human or natural origin, valued for socio-economic or heritage reasons. Material assets are in practice considered across a range of topic areas within an ES, in particular historic environment and socio-economics. Socio-economic, community and recreation effects are assessed within a chapter not presented within this demonstration ES, while effects relating to historic environment have been scoped out, as set out below. Therefore, no separate consideration of material assets is considered necessary.
Radiation and Heat
Given the nature of the project, no significant radiation or heat effects are anticipated, and these effects have been scoped out of the assessment.
Effects of the Project on Climate/Greenhouse Gas Emissions
As outlined above, the effects of climate change on the assessment conclusions have been considered within a section of each ES topic chapter.
In addition, the project constitutes a residential development with some commercial units, and so will not directly include any sources of greenhouse gas emissions. It is also not possible to ascertain if the indirect emissions as a result of traffic movements and energy use associated with the project would be surplus to those that would have otherwise occurred regardless at other locations, whether or not the project is built out.
On this basis no further assessment of greenhouse gas emissions is considered to be required and a separate chapter for climate change is not considered necessary.
Built Heritage and Buried Archaeology
The project site is not subject to any statutory or non-statutory heritage designations. There are no listed buildings, Scheduled Monuments or World Heritage Sites within the site or immediately adjacent to the site boundary.
An Archaeological Desk Based Assessment (DBA) was produced on 12 April 2020. The DBA concluded that there would be no visual impact of the project on the listed building located approximately 200 m to the north east of the site.
Additionally, the DBA identified minimal archaeological points of interest and concluded that, apart from these heritage assets, the potential for unknown archaeological remains of all other periods is low. The absence of archaeological features in other parts of the site indicates a low potential for archaeological features and activity being present at the site. As such, the potential heritage assets within the site are not likely to be significant enough to warrant preservation in-situ prior to construction works. A Written Scheme of Investigation and an Archaeological Evaluation Report have been produced for the site.
As such, a separate chapter assessing the built heritage and buried archaeology effects generated by the project is not considered necessary. Further detail of built heritage and buried archaeology at the site are summarised in a chapter not presented in this demonstration ES.
Hydrology and Flood Risk
The majority of the site is located within Flood Zone 1, which is an area of low probability of flooding (less than 1 in 1,000 annual probability). A small area on the eastern side of the site located in Flood Zone 2 (between 1 in 1,000 – 1 in 100 annual probability) and Flood Zone 3 (1 in 100 annual probability or greater) near the Main River.
As the site is greater than 1 hectare, a FRA, including a drainage strategy, has been produced for the project of this ES. A summary of the findings is provided in a chapter not presented in this demonstration ES.
During the construction phase, standard industry best practice measures would be in place, such that contamination to surface and groundwater as a result of spills and contaminated runoff is unlikely to occur. Such measures would be implemented through a Code of Construction Practice (CoCP), which would be produced prior to construction. Any effects of contamination during the operational phase of the project would be controlled through Sustainable Drainage System (SuDS) measures in the drainage strategy, such that significant effects to water quality are not likely to be significant.
As no significant effects are likely, a separate Hydrology and Flood Risk chapter has not been provided.
Hydrogeology and Contamination
The site is not located within any statutory or non-statutory designations related to geological interest or within a groundwater Source Protection Zone. The project site is underlain by unproductive bedrock which the Environment Agency defines as having ‘a low permeability that have a negligible significance for water supply or river base flow’. As such, significant effects to geology and hydrogeology as a result of the project are considered to be unlikely.
As the project site is mainly, bar a number of farm buildings, undeveloped, significant sources of contamination are not likely to be present at the site. Construction would follow standard best practice implemented through a CoCP. The CoCP would be produced prior to construction in line with prevailing legislation and Environment Agency guidance, such that risk of contamination/pollution is minimised. Should any previously unidentified contamination be detected at the site during the construction phase, work in the area would cease. A suitably qualified environmental consultant would be consulted and would attend the site to advise on an appropriate remediation, if required.
On this basis, a separate chapter assessing the effects in relation to hydrogeology and contamination is not considered necessary for this ES.
Agriculture
The site is wholly located in Grade 3 ‘Good to Moderate’ agricultural land as defined by the Agricultural Land Classification (ALC) produced by the Department for Environment, Food and Rural Affairs (Defra). The screening opinion received from the Council identified that the site does not comprise Best and Most Versatile land. As such, the loss of Grade 3 agricultural land is not considered to be significant and has therefore, been scoped out of the EIA process.
Major Accidents and Disasters
The EIA Regulations require consideration of a project’s vulnerability to major accidents and/or disasters. The proposed use of the site is predominantly residential and therefore, is unlikely to give rise to major accidents or disasters. The risks associated to this use are set out in Chapter 2: Project Description of the ES and within each topic chapter, therefore, a separate chapter assessing the risk of major accidents and disasters is not considered necessary.
Waste
Regulation 18(3) of the EIA Regulations requires consideration of the production of waste. As set out in Chapter 2: Project Description of the ES, the project comprises residential development and therefore, would not be of a type to give rise to production of process waste or hazardous waste.
The estimated waste types and volumes likely to be generated during the construction phase of the project would be identified and set out within a waste management plan prior to construction. The plan would also include a series of measures to manage waste in accordance with best practice and the waste hierarchy.
Guidance on the design principles for waste storage provision for new residential development is provided in the Guidelines for Recycling and Refuse Storage in New Development Supplementary Planning Document (SPD) (Council, 2017). The project would be required to meet the requirements of the SPD. As such, a separate waste chapter is not considered necessary.
Daylight, Sunlight and Overshadowing
Due to the nature and scale of the project, it is unlikely that effects of daylight, sunlight and overshadowing would be significant. As such the assessment of daylight, sunlight and overshadowing have been scoped out of the EIA process.
Consultation Responses
The table below provides a summary of the consultation which has been undertaken in relation to the topics scoped out of the EIA process. The table below also outlines, where relevant, how and where these comments have been addressed within the ES.
| Consultee and Issues Raised | How/ Where Addressed |
|---|---|
| Council Screening Opinion
Planning Policy Context: No concern of this topic being scoped out of the ES was raised by the council, subject to submission of a Planning Statement alongside the application. Each section of the ES should provide an overview if the policy and legislation relevant to each topic. | The approach to addressing planning policy is outlined in this chapter. Each topic chapter of this ES provides an overview of the relevant legislation and policy. |
| Council Screening Opinion
Material Assets: The Council agrees that matters falling under ‘material assets’ is covered in other chapters within the ES and therefore can be scoped out of the EIA process. | The justification as to why Material Assets has been scoped out of the EIA process is provided in this chapter. |
| Council Screening Opinion
Climate Change: The Council agrees that the approach to addressing climate change throughout the ES, rather than a standalone chapter is considered acceptable. | Climate change is considered throughout the ES, within each of the topic chapters of the ES. Details on how climate change has been considered within the ES is provided in this chapter.
Further detail of the project’s approach to addressing climate change is provided in Chapter 2: Project Description of the ES. |
| Council Screening Opinion
Built Heritage and Buried Archaeology: The Council’s Senior Archaeologist was consulted and has confirmed that she is happy with the proposed approach for archaeology and the historic environment. There are no listed buildings on site and the nearest heritage assets have been identified. | The proposed approach to scoping out Built Heritage and Buried Archaeology is provided in a chapter not presented in this demonstration ES. |
| Council Screening Opinion
Hydrology and Flood Risk: The approach to the consideration of effects to hydrology and flood risk are considered acceptable. | The proposed approach to scoping out Hydrology and Flood Risk is provided in a chapter not presented in this demonstration ES. Further details of drainage and flood risk are provided in Chapter 2: Project Description of this ES. |
| Council Screening Opinion
Hydrogeology and Contamination: The approach to scope out hydrogeology and contamination is considered acceptable. | The reasoning as to why Hydrogeology and Contamination has been scoped out of the EIA process is provided in this chapter. |
| Council Screening Opinion
Major accident and Disasters: The approach to scope out major accidents and disasters is considered acceptable. | Major Accidents and Disasters is considered throughout the ES, within each of the topic chapters of the ES. As such it is not considered necessary to include a separate chapter related to Major Accidents and Disasters in the ES. |
| Council Screening Opinion
Radiation and Heat: The approach to scope out radiation and heat is considered acceptable. Due to the nature of the project, it is agreed that this matter does not need to form a separate chapter to the ES. | The reasoning as to why Radiation and Heat, as a separate chapter, has been scoped out of the EIA process in provided in this chapter. |
| Council Screening Opinion
Daylight, Sunlight and Overshadowing: The approach to scope out daylight, sunlight and overshadowing is considered acceptable. | The reasoning as to why Daylight, Sunlight and Overshadowing, as a separate chapter, has been scoped out of the EIA process in provided in this chapter. |
Relevant EIA Guidance
The EIA process has taken into account relevant government or institute guidance, including:
Other topic specific legislation and good practice guidance, including the National Planning Policy Framework (NPPF) (Ministry of Housing, Communities and Local Government, 2019b) has been considered and details of these can be found in the topic chapters within this ES.
The assessment of each environmental topic forms a separate chapter of the ES. For each environmental topic, the following have been addressed:
Methodology and Assessment Criteria
Each topic chapter provides details of the methodology for baseline data collection and the approach to the assessment of effects. Each environmental topic has been written by a specialist in that area (see Appendix 1.3: Statement of Expertise).
Each topic chapter defines the scope of the assessment within the methodology section, together with details of the study area, desk study and survey work undertaken and the approach to the assessment of effects. The identification and evaluation of effects have been based on the information set out in Chapter 2: Project Description of this ES, EIA good practice guidance documents and relevant topic-specific guidance, where available.
Description of the Environmental Baseline Conditions (Including Future Baseline Conditions)
The existing and likely future environmental conditions in the absence of the project are known as ‘baseline conditions’. Each topic based chapter includes a description of the current (baseline) environmental conditions. The baseline conditions at the site and within the study area form the basis of the assessment, enabling the likely significant effects to be identified through a comparison with the baseline conditions.
The baseline for the assessment of environmental effects is primarily drawn from existing conditions during the main period of the EIA work in 2019.
The baseline for the assessment should represent the conditions that will exist in the absence of the project at the time that the project is likely to be implemented. The anticipated start date for construction is early 2021. The programme of construction would be of approximately nine years duration (including enabling works). Full operation of the site has been assumed to take place in 2030. Further information about the construction programme assessed as part of the EIA process can be found in Chapter 2: Project Description of this ES.
Consideration has been given to any likely changes between the time of survey and the future baseline for the construction of the project from 2021 and for the operation of the project from 2030. In some cases, these changes may include the construction or operation of other planned developments in the area. Where such developments are built and operational at the time of writing and data collection, these have been considered to form part of the baseline environment. Where sufficient and robust information is available, such as expected traffic growth figures, other future developments have been considered as part of the future baseline conditions. In all other cases, planned future developments are considered within the assessment of cumulative effects.
The consideration of future baseline conditions has also taken into account the likely effects of climate change, as far as these are known at the time of writing. This has been based on information available from the UK Climate Projections project (UKCP18), which provides information on plausible changes in climate for the UK (Environment Agency and Met Office, 2018) and from published documents such as the UK Climate Change Risk Assessment 2017 (Committee on Climate Change, 2016).
Climate data from the UKCP18 database has been compiled for a 25 km² grid square containing the site, based on a medium emissions scenario (RCP6.0) . Parameters such as mean air temperature and annual average precipitation data for the period 2070-2099 have been used to inform the consideration of how environmental conditions may change at the site and within the study area in future.
Limitations of the Assessment
Each topic chapter identifies any limitations identified in the available baseline data and whether there were any difficulties encountered in compiling the information required.
Mitigation Measures Adopted as Part of the Project
During the EIA process, environmental issues have been taken into account as part of an ongoing iterative design process. The process of EIA has therefore been used as a means of informing the design.
The project assessed within this ES therefore includes a range of measures that have been designed to reduce or prevent significant adverse effects arising. In some cases, these measures may result in enhancement of environmental conditions. The assessment of effects has taken into account measures that form part of the project.
The topic chapters set out the measures that form part of the project and that have been taken into account in the assessment of effects for that topic. Chapter 2: Project Description also provides a summary of the general and topic-specific mitigation measures proposed as part of the project. These include:
Assessment of Effects
The EIA Regulations require the identification of the likely significant environmental effects of the project. This includes consideration of the likely effects during the construction and operational phases. The assessment is based on consideration of the likely magnitude of the predicted impact and the sensitivity of the affected receptor. The process by which effects have been identified and their significance evaluated is set out within each individual topic chapter. The overarching principles are set out below.
Sensitivity or Importance of Receptors
Receptors are defined as the physical or biological resource or user group that would be affected by a project. For each topic, baseline studies have informed the identification of potential environmental receptors. Some receptors will be more sensitive to certain environmental effects than others. The sensitivity or value of a receptor may depend, for example, on its frequency, extent of occurrence or conservation status at an international, national, regional or local level.
Sensitivity is defined within each ES topic chapter and takes into account factors including:
Sensitivity is generally described using the following scale:
In some cases, a further category of very high has been used.
Magnitude of Impact
Impacts are defined as the physical changes to the environment attributable to the project. For each topic, the likely environmental impacts have been identified. For each topic the likely environmental change arising from the project has been identified and compared with the baseline (the situation without the project). Impacts are divided into those occurring during the construction and operational phases.
The categorisation of the magnitude of impact is topic-specific but generally takes into account factors such as:
With respect to the duration of impacts, the following has been used as a guide within this assessment, unless defined separately within the topic assessments:
The magnitude of an impact has generally been defined using the following scale:
In some cases, a further category of ‘no change’ has been used.
Significance of Effects
Effect is the term used to express the consequence of an impact (expressed as the ‘significance of effect’). This is identified by considering the magnitude of the impact and the sensitivity or value of the receptor.
The magnitude of an impact does not directly translate into significance of effect. For example, a significant effect may arise as a result of a relatively modest impact on a resource of national value, or a large impact on a resource of local value. In broad terms, therefore, the significance of the effect can depend on both the impact magnitude and the sensitivity or importance of the receptor.
Significance levels are defined separately for each topic. Unless separately defined in the topic chapters, the assessments take into account relevant topic specific guidance, based on the following scale and guidance:
The terms minor, moderate and major apply to either beneficial or adverse effects. Effects may also be categorised as direct or indirect, secondary, short, medium or long term, or permanent or temporary as appropriate.
Each chapter defines the approach taken to the assessment of significance. Unless set out otherwise within the chapter, topic chapters use the general approach set out in the table below. For some topics, a simplified or quantitative approach is considered appropriate.
Unless set out otherwise in each topic chapter, effects assessed as moderate or above are considered to be significant in terms of the EIA Regulations within this assessment.
Further Mitigation and Future Monitoring
Where required, further mitigation measures have been identified within topic chapters. These are measures that could further prevent, reduce and, where possible, offset any adverse effects on the environment.
Where relevant and necessary, future monitoring measures have been set out within the topic chapters.
Assessment of Cumulative Effects
The EIA Regulations require consideration of cumulative effects, which are effects on a receptor that may arise when the project is considered together with other proposed developments in the area.
The cumulative effects of the project in conjunction with other proposed schemes have been considered within each topic chapter of the ES. Other developments considered within the cumulative assessment include those that are:
It is noted that developments that are built and operational at the time of submission are considered to be part of the existing baseline conditions.
Details of the developments included as part of the cumulative assessment are provided in Appendix 4.3.
Inter-relationships
Each topic chapter considers whether or not there are any inter-related effects with other topics included within the EIA that have not already been considered in order to identify any secondary, cumulative or synergistic effects.
Summary Tables
Summary tables have been used to summarise the effects of the project for each environmental topic chapter.
The project team has undertaken consultation with, or requested information from, a number of organisations, including (but not limited to):
A summary of consultation undertaken to date is provided at Appendix 4.2 of the ES.
Local Planning Authority
The project lies within the administrative area of the Council. A number of pre-application meetings and correspondence have been undertaken between January 2019 and October 2019 in relation to the following topics/themes:
Further to the above, topic specialists have consulted the relevant experts within the Council and their consultees on their approach to the EIA through the scoping process. Further information regarding consultation with topic specific organisations is detailed within the individual topic chapters.
Meetings have been undertaken throughout the EIA and design process in order to agree methodologies and request and share information regarding existing environmental conditions.
Public Consultation
As part of the consultation process, the applicant has engaged with the local community in order to inform local people about the project, to explain the development and its likely effects and to take on board any concerns or issues raised. The methods of pre-application public consultation undertaken to date are listed below:
Newsletters
Approximately 320 newsletters were sent out to all households within approximately 0.8 km (approximately half a mile) radius of the project site. The newsletter was also sent to key stakeholders.
The newsletter contained information of the project, details of public exhibitions and contact details including details of the project-specific website.
Stakeholder Meetings
Group or one-to-one meetings were held or requested with a number of key stakeholders, including the tenant farmer, councillors and planning officers of the Council. This includes a consultation meeting at County Hall on November 2019 with which was attended by 35 to 40 planning officers and councillors.
Media
The County Press and the Observer were contacted by the project team as part of the key strategy to proactively engage with local residents.
Radio stations were also contacted by the project team to broadcast details of the project and details how to attend the public exhibitions.
Public Exhibitions
The public exhibition events ran over two days in October 2019. The two events were held at different times to ensure that the exhibition was accessible to all residents. The events were held at the accessible locations, both of which provided disabled access and ample parking facilities.
The event featured information about the project via the means of exhibition boards, backdrop panels presenting a number of drawings of the project, and presentations given by project team members.
Approximately 80 people, including local residents and members of Council, attended the exhibitions over the two events. Comment cards were handed out to attendees at the end of the exhibition events to provide them with the opportunity to comment on the project, as well as current housing and community provisions in the local area.
Comment Cards
A total of 35 comment cards were completed during the two exhibition events. Of the 35 people who responded, 66% agreed that more homes were needed for local people. Approximately 77% of people agreed that the new doctor’s surgery was important to the community, but of those, approximately 74% of people raised concerns about the issue of recruiting doctors on the island.
Website
An online element of public consultation was included as part of the strategy to ensure that accessibility of information on the project was maximised. The website presented details of the project proposals alongside images. The website also enabled visitors to leave comments. A total of eight people commented on the website with 50% of people supporting the project and the remaining 50% raising concerns of the proposals.
Conclusions of Public Consultation
A Statement of Community Involvement (SoCI) has been submitted with the application providing further details of the findings of the exhibitions and website responses. The main issues that were identified throughout the consultation process included:
A number of positive comments were also identified during the consultation process and included the following key themes:
These comments have been taken into account by the design team in the preparation of the planning application and, where relevant, in the EIA process.