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Chapter 4
Approach to Environmental Impact Assessment
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## CONTENTS
4. Approach to Environmental Impact Assessment.....2
4.1 Introduction.....2
4.2 EIA Regulations.....2
4.3 Environmental Impact Assessment.....4
4.4 Environmental Baseline.....9
4.5 Assessment Methodology.....10
4.6 Assumptions and Limitations.....14
4.7 Cumulative and In-Combination Effects.....15
4.8 Residual Effects.....22
4.9 Consultation and Engagement.....23
4.10 References.....24
## TABLES
Table 4-1: Compliance with EIA Regulations.....2
Table 4-2: Items Scoped out of the EIA.....6
Table 4-3: Generic Guidelines for the assessment of value/ sensitivity.....11
Table 4-4: Generic Guidelines for the assessment of magnitude.....12
Table 4-5: Classification of effects.....12
Table 4-6: Projects considered with the cumulative assessment.....16
## FIGURES
Figure 4.1: Developments to be Considered in Cumulative Assessment
## APPENDICES
Appendix 4.1: Scoping Report
Appendix 4.2: Scoping Opinion
Appendix 4.3: Consultation Responses
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### 4. Approach to Environmental Impact Assessment
### 4.1 Introduction
4.1.1 The purpose of this chapter is to provide a more detailed description of the EIA process, as well as outlining the methodology and relevant guidance used to undertake the preliminary EIA and the structure of the remainder of this PEIR.
### 4.2 EIA Regulations
4.2.1 The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (the ‘EIA Regulations’) require an EIA to be carried out in respect of any development listed in Schedule 1 to the EIA Regulations (‘Schedule 1 development’). The Project is a Schedule 1 development as it is a thermal generating station with a heat output1 of 300 MW or more as listed in Schedule 1, paragraph 2(1) of the EIA Regulations.
4.2.2 The Project falls under the EIA Regulations and not the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (EIA Regulations 2017). This is because a scoping opinion was requested from the Secretary of State under the EIA Regulations before the commencement of the EIA Regulations 2017. This means that, in accordance with the transitional arrangements at Regulation 37 of the EIA Regulations 2017, the EIA Regulations will continue to apply to the Project.
## a) Compliance with EIA Regulations
4.2.3 The information to be included in an ES is set out in Schedule 4 of the EIA Regulations. Part 1 of the Schedule details the information that the applicant can reasonably be required to provide, whilst Part 2 identifies the information that the applicant must provide. This information is highlighted in Table 4-1 below, which also provides confirmation of where the information is provided within this PEIR.
| Required Content of Environmental Statements | Relevant Chapter of this ES |
| Part 1 |
| 1. Description of the development, including in particular (a) a description of the physical characteristics of the whole development and the land-use requirements during the construction and operational phases; | Chapter 3: Project Site and Description |
| (b) a description of the main characteristics of the production processes, for instance, nature and quantity of the materials used; | Chapter 3: Project Site and Description |
| (c) an estimate, by type and quantity, of expected residues and emissions (water, air and soil pollution, noise, vibration, light, | Detail provided in Technical Chapters 6 - |
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| Required Content of Environmental Statements | Relevant Chapter of this ES |
| heat, radiation, etc.) resulting from the operation of the proposed development. | 15 |
| 2. 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. | Chapter 5: Alternatives Considered. |
| 3. 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 inter-relationship between the above factors. | Detail provided in the Technical Chapters 6 – 15 |
| 4. 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. | Detail provided in Technical Chapters 6 – 15 |
| 5. A description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment. | Detail provided in Chapter 3, Technical Chapters 6 – 15 and Chapter 16 (including Mitigation Schedule – Appendix 3.1) |
| 6. A non-technical summary of the information provided under Paragraphs 1 to 5 of this Part. | Separate Non-Technical Summary Report |
| 7. An indication of any difficulties (technical deficiencies or lack of know-how) encountered by the applicant in compiling the required information. | Detail provided in Chapter 4 and Technical Chapters 6 – 15 and Mitigation Schedule (Appendix 3.1) |
| Part 2 |
| 1. A description of the development comprising information on the site, design and size of the development. | Chapter 3: Project and Site Description |
| 2. A description of the measures envisaged in order to avoid, reduce and, if possible, remedy significant adverse effects | Mitigation detailed in Chapter 3, Technical Chapters 6 – 15 and Chapter 16 |
| 3. The data required to identify and assess the main effects which | Baseline data provided in Technical Chapters 6 |
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| Topic / Scope | Justification |
| Transboundary Effects | Due to the design, proposed mitigation and implementation of best practice measures, it is considered that there will be no significant transboundary effects caused by the Project that will affect any other European Economic Area State. A Transboundary Screening assessment has been undertaken by the SoS which confirms this approach. |
| Air Quality [Electrical or Gas Connections] | No impacts on local air quality are anticipated from the operation of the Electrical or Gas Connections and therefore this has not been assessed. The SoS agreed with this approach in the Scoping Opinion (paragraph 3.8, Appendix 4.3). |
| Vibration | The identified plant/equipment items to be used are not recognised as sources of high levels of vibration and therefore operation and decommissioning vibration has not been assessed. The SoS did not disagree with this approach in the Scoping Opinion (Appendix 4.3). |
| Noise [Electrical or Gas Connections] | The Gas and Electrical Connections will be buried underground and therefore it is not anticipated that they will generate any noise or vibration during operation. Therefore, these elements have not been assessed. The SoS partly agreed with this approach in the Scoping |
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| Topic / Scope | Justification |
| Opinion (paragraph 3.8, Appendix 4.2) but requested further justification of the approach. Further justification is set out in Chapter 7: Noise and Vibration. |
| Landscape [Gower AONB] | The Gower AONB is physically remote from the Project Site, being 10 km away and visually separated from the Project Site by intervening topography, and views are diminished by distance. It has therefore been scoped out of the assessment due to the physical and visual separation and this is shown on Figure 11.8. |
| Landscape [Brecon Beacons National Park] | The Brecon Beacons National Park lies over 15 km to the north of the Project Site and, due to the intervening distance, is both physically and visually separate. Both protected landscapes have been scoped out of the assessment due to the physical and visual separation. This approach has been agreed with the Brecon Beacons National Park Authority at the request of the SoS (paragraph 3.66, Appendix 4.3). |
| Water Quality and Resources [Electrical or Gas Connections] | Effects on water quality and resources during operation and decommissioning of the Gas and Electrical Connections are unlikely to occur and have been scoped out of the chapter (Chapter 9: Water Quality and Resources). Ground levels along the route corridor of the Gas and Electrical Connections will be very similar to existing levels and any ongoing maintenance will be negligible, as described in Section 3.9. The impacts during the operation phase are therefore considered to be limited to the presence of the trench if it has different hydraulic properties to the surrounding natural ground. This can be mitigated through careful selection and placing of bedding and backfill material to try and match the natural ground as far as possible. Transport of pollutants associated with previous land uses is addressed in Chapter 10: Geology, Ground Conditions, and Hydrogeology. |
| Water Quality and Resources [AGI] | The AGI will have a small footprint and the design will include appropriate SuDS measures for control and treatment of surface water runoff in accordance with the drainage strategy for the Project Site. There will be no effluent discharges for the Gas Connection. The Gas Connection lies north of the Generating Equipment Site where flood risks are low, and will be mitigated through raised ground levels where necessary. No comments were received at Scoping stage therefore this has been scoped out of the assessment. |
| Carbon Capture Readiness | With a rated electrical output of less than 300MW, the Project will be below the threshold set out in Directive 2009/31/EC (as transposed by The Carbon Capture Readiness (Electricity Generating Stations) Regulations 2013) and NPS EN-1 and EN-2. Operators of combustion plants which are above this threshold are required to have assessed the feasibility of: a storage site, transport facilities and economic considerations of the capture of CO2 produced as a result of the combustion process. As a result it is not necessary to assess the viability of CO2 capture in this PEIR. |
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## b) Preliminary Environmental Information Report
4.3.13 Under Regulation 10(b) of the EIA Regulations the applicant must consult on preliminary environmental information relating to the Project. In 2014, this information was compiled into a Preliminary Environmental Information Report (2014 PEIR) (Ref. 4.1), which provided the environmental information collected part of the way through the EIA process as well as an assessment, on a preliminary basis, of the likely significant environmental effects of the Project.
4.3.14 The 2014 PEIR was compiled along with the 2014 PEIR NTS to accompany APL's statutory consultation with both the local community and prescribed consultees in advance of submitting its DCO Application.
4.3.15 Feedback received during the consultation process has helped further inform and refine the development of the design of the Project and the EIA process. More detailed analysis of this will be included within the Consultation Report to be submitted with the proposed DCO Application however a summary of a selection of the main themes is as follows:
- Site selection;
• Landscape;
Transport and traffic;
• Socio-economics;
• Air quality and Noise; and
• Water.
4.3.16 This PEIR has evolved from the 2014 PEIR. This PEIR includes an updated preliminary environmental assessment and provides more information on how the Project has developed since the Phase 1 consultation in 2014.
4.3.17 In order to aid the reader, this PEIR highlights where the technical assessments have been updated, either as a result of the Project evolution and / or due to an update in environmental baseline information which has been collated since 2014. Within the Introduction section to each technical chapter, a short summary of any changes which have been undertaken has been included where necessary. Further detailed information on the design changes to the Project is included in Chapter 5: Alternatives Considered.
4.3.18 All chapters provide a technical conclusion to the impact assessment in this PEIR. However the following chapters provide a “Next Steps” section which identifies any further or outstanding works which will be undertaken between the publication of this PEIR and the DCO Application:
Chapter 8: Ecology
Chapter 11: Landscape & Visual;
Chapter 12: Traffic, Transport and Access; and
Chapter 13: Historic Environment.
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### 4.4 Environmental Baseline
4.4.1 In undertaking an EIA for any project, it is important to identify the environmental baseline for the potential receptors which may be affected. This has allowed the effects of the Project to be compared and/or combined with the existing baseline in order to ensure an informed assessment of the potential effects of the Project and to allow the identification of the most appropriate mitigation which could be employed to minimise any identified likely significant adverse effects.
4.4.2 To establish the baseline, a study area that is appropriate for each assessment topic is identified which takes into consideration the surrounding context and the likely scale and range of potential significant effects. Next, a range of environmental data has been gathered from a combination of sources in respect of the study area in order to inform the preliminary assessment. This has included:
- Documentary information on the Project Site, Gas Connection and Electrical Connection, and their surroundings within each relevant study area, including information available from the previous EIA work for other projects;
- Field survey information, including: Phase 2 ecological surveys; landscape character assessments; background noise levels; ground conditions/contaminated land assessments, location of sensitive receptors and traffic levels on the road network; and
Data held by both statutory and non-statutory consultees.
4.4.3 It is anticipated that the construction of the Project will commence in early 2020. The assessment has therefore used a '2020 baseline' to provide a future baseline against which the assessment is undertaken. As such a number of developments are considered in the assessment of effects, where those already have planning permission and are expected to be constructed in the next three years. Cumulative Projects have been agreed with CCS and are listed in Table 4-6.
### 4.5 Realistic Worst Case Scenario for Assessment
4.5.1 In accordance with PINS Advice Note 9 (Rochdale Envelope) (Ref. 4.2), the assessments presented in the PEIR are based on an assessment of the realistic 'worst case' scenario arising from the Project parameters described in Table 3-3. This allows flexibility for APL whilst ensuring that the likely significant environmental effects are identified and adequately assessed. The realistic worst case scenario is set out in each topic chapter for clarity and transparency.
4.5.2 Taking the above into consideration, it has been determined that for all topic areas to be addressed in the EIA except air quality, the highest stack height (45 m) represents the 'worst case'. For air quality the minimum stack heights of 35 m represent the 'worst case' due to lower dispersion. The PEIR contains an explanation in each chapter of why the scenario assessed represents the worst case for that topic.
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4.5.3 For the assessment, it has been assumed that the Generating Equipment will operate for a worst case of 2,250 hours per year in the noise and air quality assessments, although actually running for 1,500 hours over an average of 5 years. In the noise assessment, it is assumed that the Generating Equipment will operate at night to represent the worst case scenario. Where there is the possibility that intermittent operation could give rise to more significant effects than continuous operation (for example start-up noise) this has been considered in the noise and air quality assessments, as well as disturbance to ecological receptors in the ecological assessment. This issue is not relevant to any other topic chapters.
### 4.6 Assessment Methodology
4.6.1 Methodologies for each subject area are presented within each of the technical chapters. These methodologies are based upon recognised good practice and guidelines specific to each subject area, and take into account any consultation responses relating to the methods used in the 2014 PEIR, the SoS Scoping Opinion and any additional requirements that have been identified in connection with the Project.
## a) Assessment of Effects
4.6.2 The approach is broadly the same for all specialist topic areas with some variation in the descriptions of assessment criteria. For each topic, the assessment of significance will be informed by the sensitivity of the existing or baseline environmental conditions or character, and the magnitude of the change to the existing conditions or baseline character which occur as a result.
4.6.3 The determination of the significance of the likely environmental effects arising from development is a key stage in the EIA process. To assess the overall significance of an effect it is necessary to establish the magnitude of the effect occurring (i.e. the change to the existing baseline conditions as a result of the Project) and the sensitivity or importance of the receiving environment or receptor. Assessment of significance for environmental topics will combine professional judgement with the consideration of a number of factors including:
The probability of the effect occurring based on the scale of certain, likely or unlikely;
- The sensitivity and value of the resource or receptor under consideration;
- The magnitude of the impact in relation to the degree of change which occurs as result (which includes the duration of the effect – short medium or long term);
Reversibility of the effect;
- Comparison with legal requirements, policies and standards; and
- Comparison with applicable environmental thresholds.
4.6.4 The value of the receptors is assessed according to the relative importance of existing environmental features on or near to the site, or by the sensitivity of receptors i.e. whether they are likely to be robust enough to be unaffected by the
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Project or alternatively are highly susceptible to the type of effects likely to occur. Criteria for the determination of sensitivity or value of receptors are established based on approved guidance, legislation, statutory designation and/or professional judgment.
### i. Sensitivity or value of Receptors
4.6.5 Table 4-3 provides general definitions of the sensitivity criteria used within the assessment. In each specialist chapter of the PEIR, criteria will be explained with reference to that particular discipline.
| Value/sensitivity | Guidelines |
| Very High | The receptor has little or no ability to absorb change without fundamentally altering its present character, is of very high environmental value, or of international importance. |
| High | The receptor has low ability to absorb change without fundamentally altering its present character, is of high environmental value, or of national importance. |
| Medium | The receptor has moderate capacity to absorb change without significantly altering its present character, has some environmental value, or is of regional importance. |
| Low | The receptor is tolerant of change without detriment to its character, is low environmental value, or local importance. |
| Negligible | The receptor is resistant to change and is of little environmental value. |
### ii. Magnitude of Effect
4.6.6 The magnitude of potential effects on environmental baseline conditions is identified through consideration of the Project taking into account the scale or degree of change from the existing situation as a result of the effect; and the duration and reversibility of the effect, as well as consideration of relevant legislative or policy standards or guidelines.
4.6.7 Table 4-4 provides general definitions of effect magnitude criteria. In each specialist chapter of the PEIR, effect magnitude criteria will be explained with reference to that particular discipline.
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| Planning Application | Name | Description |
| Under Construction |
| 1 | 2006/0773 (varied by 2009/1520 and 2011/1143 ) and consecutive temporary planning permissions 2007/2513, 2009/0062, 2009/1585, 2011/1311 and 2014/0913 (varied by 2016/1270 ) | Felindre Business Park | Strategic business park for B1 and B2 uses to accommodate emerging industries, high tech manufacturing, high level services, ancillary uses, associated car parking, landscaping and access roads (outline). The site has been laid out and is effectively a serviced site, however no buildings have been constructed.
Park and ride schemes also operate on match days to the Liberty football stadium; and for car parking for the Driver and Vehicle Licensing Agency (DVLA) site in Longview Road, Morriston. |
| 2 | 2013/0135 | Abergelli Solar Farm | Installation of ground mounted array of solar panels, inverter substations and 2.4 m high fencing on land at Abergelli Farm. This development will be located adjacent to the Gas Connection. |
| 3 | 2013/0865 | Cefn Betingau Phase 1, Morriston | Construction of 9MW solar park consisting of installation of up to 135,000 photovoltaic panels and 9 inverter/transformer cabins and a single control building |
| 4 | 2014/0739 | Gelliwern Isaf solar park | 6MWe solar park at Gelliwern Isaf Farm -installation of a solar PV array, construction of a storage room, inverter cabin, a substation, switchgear building and fencing |
| 5 | 2014/1022 | Brynwhilach Solar Park | Construction of 12.69MWe solar park consisting of installation of up to 47,000 photovoltaic panels and 8 inverter/transformer stations, 2 substations, storage container, new access tracks, security fencing/cctv and associated equipment and infrastructure work. |
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| Planning Application | Name | Description |
| 6 | 2007/1250 (varied by 2017/0325/S73) | Former J R Steelworks, Bryntywod | Retention of use of land as timber recycling centre including processing of wood, wooden materials, associated plant and machinery and previously tipped inert material together with on-site storage of wood chip material, construction of building for the dry storage of recycled wood waste and the creation of a 1m high clay bund around southern, western and northern boundaries of the site without complying with conditions 2, 3, 5, 9, 10, 11, 14 and 16 of planning permission 2007/1250 granted 11th December. |
| 7 | 2012/1221 | Mynydd y Gwair Wind Farm | Installation of 16 wind turbines (maximum height to blade tip of 127 m with a hub height of 80 metres), with a maximum generating capacity of 48MWe, associated tracks and ancillary infrastructure. |
| Permitted but not implemented |
| 8 | 2013/0795 | Tyle Coach Mawr Wind Farm | Installation of four 5 kW wind turbines 20.7 m to tip and associated infrastructure. |
| 9 | 2013/1835 | Felindre Business Park | Construction of park and ride/share car park (approximately 480 spaces) with new vehicular access, security office, toilet, engineering and associated works, including lighting, fencing, drainage attenuation and landscaping. |
| 10 | 2015/1529 (appeal ref 4369653) | Llettyr Morfil Farm | Construction of a 4.9 MW solar park (approx. 8.8 ha) including photovoltaic panels, four inverter stations, centre station, new access tracks, security fencing, security cameras and associated equipment and infrastructure works. Allowed on appeal in June 2016 |
| 11 | 2015/0308 | Plot 8 Felindre Strategic Business Park | Two/three storey private hospital development with associated landscaping, site roads and car parking |
| 12 | 2016/1522 | Griffiths Waste Management Site, Bryntywod Llangyfelach Swansea SA5 7LP | Demolition of existing waste management facility buildings and construction of replacement buildings and associated infrastructure |
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| Planning Application | Name | Description |
| 13 | 2008/0912 | Former Walters Yard Pontliw Swansea | Construction of 67 dwellings with associated access, roads, parking, open space and demolition of existing buildings. Approved with S106 in March 2016. |
| Submitted but not determined |
| 14 | 2011/0345 | Land at Llewellyn Road, Penllergaer | Construction of up to 200 residential units with associated access (outline). |
| 15 | 2012/0721 | Royal Fern Golf Resort | Application to vary Condition 8 of Outline Planning Permission 2008/0154 to extend the period for the submission of the reserved matters for a further three years in relation to the proposed development of 18 hole championship and 9 hole par 3 golf courses, golf club house including health facilities, sauna, swimming pool, gymnasium, golf school and academy, 80 golfing lodges, approximately 135 housing plots, green keepers flat, associated infrastructure, car parking and landscaping (outline). |
| 16 | 2014/0977 | Parc Ceirw, Cwmrydydyceirw Quarry, Swansea | Proposed cessation of landfill and other operations enabled by residential development of circa 300 dwellings, public open space and associated highway and ancillary works (outline) |
| 17 | 2017/1822/OUT | Land West Of Llangyfelach Road Tirdeunaw | Outline planning application (with all matters reserved apart from strategic access junctions) for residential led mixed use development, to be developed in phases, including up to 1950 dwellings, link road, local centre provision of a primary school, community facilities, Public Open Space including facilities for children, and areas of landscaping (including sustainable drainage systems), outdoor sports provision including playing pitches, associated services, infrastructure and engineering works including new vehicular access, improvements to the existing highway network, new roads, footpaths / cycleways, and ancillary works. |
| 18 | 2016/1478 | Land North Of Garden Village Swansea | Hybrid planning application (with all matters reserved apart from strategic access) for residential-led mixed use development, to be developed in phases, including approximately 750 residential units; provision of 1 no. Primary school; circa 280m2 - 370m2 flexible A1-A3 / D1 floorspace; open space including |
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| Planning Application | Name | Description |
| | | parks; natural and semi natural green space; amenity green spaces; facilities for children and young people; outdoor sports provision including playing pitches; associated services, infrastructure and engineering works including new vehicular accesses, improvement works to the existing highway network, new roads, footpaths/cycleways; landscaping works (including sustainable drainage systems), ecological mitigation works and ancillary works. Submitted in July 2016 and currently pending determination. (The application would be referable to Welsh Ministers if the Council are minded to approve). |
| 19 | 2017/0986/FUL | Former Civic Centre Penllergaer Swansea SA4 9GH | Construction of 80 no. residential units with associated access and landscaping |
| Identified / Allocated (and not referenced above) |
| 20 | UDP Policy EC1(3) | Swansea Vale Strategic Mixed-Use Site | 25 ha allocated employment land |
| 21 | UDP Policy EC1(10) | Land at Bryntywod, Felindre (Local Employment Site) | 15.8 ha allocated employment land |
| 22 | UDP Policy EC1(12) | Penllergaer Business Park (Local Employment Site) | 8.2 ha allocated employment land |
| 23 | UDP Policy HC13 | West of Morriston Hospital | Hospital related activities |
| 24 | LDP Policy SD G | Northwest of M4 J46, Llangyfelach | Comprehensive mixed use development of up to 850 homes during the Plan period, incorporating a mix of low-medium and high density residential, a new district centre with commercial units, primary school, a mix of public realm, open space and play provision, new community buildings, and a strategic business park |
| 25 | LDP Policy SD A | South of Glanffrd Road, | Comprehensive, residential led, development of up to 720 homes, incorporating a primary school, leisure and recreation facilities, public open space and |
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| Planning Application | Name | Description |
| | Pontarddulais | appropriate community facilities, employment and commercial uses |
| 26 | LDP Policy SD C | South of A4240, Penllergaer | Comprehensive, residential led, mixed use development of up to 750 homes during the Plan period (and up to 1,000 homes beyond the Plan period), incorporating primary school, leisure and recreation facilities, public realm, public open space and appropriate community and commercial uses |
| 27 | LDP Policy SD E | North of Clasemont Road, Morriston | Comprehensive, residential led, mixed use development of up to 675 homes during the Plan period, incorporating primary school, leisure and recreation facilities, public realm, public open space and appropriate community and commercial uses |
| 28 | LDP Policy SI 4 | Morriston Hospital | Land adjacent to Morrison Hospital is safeguarded solely for the future development and expansion of the Hospital. Development at this location is restricted to healthcare related uses in association with the beneficial use of Morriston Hospital. Proposals must be delivered alongside appropriate new and enhanced highway infrastructure that will significantly improve the existing substandard road access leading to the site. A new access road is proposed as part of this proposal (Strategic Transport Strategy Table 9.2) to resolve road capacity issues from the roundabout immediately north of M4 J46. |
| 29 | LDP Policies
RP7 and RP8 , paragraph 2.14.28 (Preferred Locations) | Former Tip Site, Felindre | Preferred areas for new waste management facilities include the former Tip site at Felindre. The site at Felindre is identified specifically for the potential to accommodate a Combined Heat and Power (CHP) Facility which could provide heat or power for adjacent proposed developments. |
| 30 | LDP Policy H1.11 | Land at Ramsey Road, Clydach | 60 dwellings |
| 31 | LDP Policy H1.21 | Land east of Pontarddulais Road, Gorseinon | 90 dwellings |
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