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Viridor Waste Management Limited May 2008

EfW Facility, Oxwellmains ES (Revised) RPS Planning & Development SAW0602/SN/DRH Final

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Appendix 1 – Scoping Letter and Report

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Our Ref: SN/am/SAW0602 E-mail: [email protected] Tel No: 0131 555 5011 Date: 20 June 2007 Mr Peter Collins Head of Planning East Lothian Council John Muir House Haddington East Lothian EH41 3HA Dear Mr Collins TOWN AND COUNTRY PLANNING (SCOTLAND) ACT 1997 ENVIRONMENTAL IMPACT ASSESSMENT (SCOTLAND) REGULATIONS 1999 REQUEST FOR SCOPING OPINION PROPOSED ENERGY RECOVERY FACILITY, DUNBAR Further to our recent conversation please accept this letter as a formal request for a scoping opinion in respect of the above project. Viridor Waste Management Limited (Viridor) is seeking consent to develop an Energy Recovery Facility at Dunbar. RPS has been instructed to act for Viridor, to conduct the Environmental Impact Assessment and produce the Environmental Statement necessary to secure this consent. The purpose of the Environmental Statement, as set out in the above regulations, is to ensure that environmental considerations have been taken into account prior to granting planning permission for a development likely to have significant impacts on the environment. Energy Recovery Facilities are listed in the regulations as developments that may have such environmental impacts. At this stage, RPS is determining the scope of the Environmental Impact Assessment for the proposed development. This includes the aspects of the environment likely to be affected by the development, and methods that will be used to assess these impacts. This scope has been determined following preliminary consultation with technical specialists, consultation bodies and stakeholders. RPS would like to invite you to comment on the proposed development. A scoping report has been enclosed with this letter providing a brief description of the nature and purpose of the development and its location. The report outlines the proposed scope of works and methodologies to be used to investigate the nature and significance of environmental effects. Please provide responses to myself at the above address, or by email, by 20 July 2007. Your comments will be used to inform the scope of the Environmental Impact Assessment, and to ensure a robust and comprehensive assessment is carried out. Results from the assessment will be used to improve the design of the development and to avoid or reduce any harmful effects caused to the environment. Local knowledge that you can supply is especially important in making the assessment relevant to the Dunbar region.

Peter Collins 20 June 2007

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If you require any further information, please do not hesitate to contact me at the above address. Many thanks for taking time to help us in this exercise. Yours sincerely for RPS Steve Newlands Associate Director Enc Scoping Report

O:\Projects\0602SAW\Scoping Report\Scoping Report v 4.0 Final 03.05.07.doc

Viridor Waste Management Ltd

Dunbar Energy Recovery Facility

Scoping Report

(Environmental Impact Assessment Regulations 1999)

Prepared by: Checked by: Alanna Malcolm David Harper Steve Newlands 45 Timberbush Bernard Street Leith Edinburgh EH6 6QH Tel: 0131 555 5011 Fax: 0131 555 4911 Email [email protected]

Planning and Development

© This Report is the copyright of RPS Planning and Development. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

Viridor Waste Management Ltd May 2007

Scoping Report RPS Planning and Development 0602SAW/SN/DRH Final

Contents

1. Introduction .................................................................................................... 1

1.1 Background .................................................................................................... 1 1.2 Need For and Benefits of the Development ................................................. 1 1.3 Environmental Impact Assessment.............................................................. 3 1.4 Scoping Exercise ........................................................................................... 4 1.5 Next Steps in the EIA ..................................................................................... 4 1.6 Report Structure............................................................................................. 5

2. Scoping Strategy............................................................................................ 7

2.1 Requirement for Scoping............................................................................... 7 2.2 Consultations ................................................................................................. 7

3. Site Selection and Project Description......................................................... 9

3.1 Site Selection.................................................................................................. 9 3.2 Site Description ............................................................................................ 10 3.3 Planning Authority and Relevant Policies.................................................. 11 3.4 Project Description ...................................................................................... 18

4. Proposed Methodologies............................................................................. 21

4.1 Air Quality ..................................................................................................... 21 4.2 Archaeology and Cultural Heritage ............................................................ 22 4.3 Aviation ......................................................................................................... 23 4.4 Ecology ......................................................................................................... 24 4.5 Human Health ............................................................................................... 25 4.6 Hydrology and Hydrogeology ..................................................................... 28 4.7 Land Contamination and Ground Conditions............................................ 32 4.8 Landscape and Visual.................................................................................. 32 4.9 Needs, Alternatives and BPEO.................................................................... 36 4.10 Noise and Vibration...................................................................................... 38 4.11 Transport and Traffic Assessment ............................................................. 40 4.12 Amenity Issues ............................................................................................. 42 4.13 Socio-Economic Impacts............................................................................. 43 4.14 Cumulative Impacts ..................................................................................... 45

5. Further Information ...................................................................................... 47

Appendix 1 – List of Consultees........................................................................... 48 Appendix 2 – Glossary........................................................................................... 50 Appendix 3 – Figures ............................................................................................. 53



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1. Introduction 1.1 Background

Viridor Waste Management Ltd (‘Viridor’), owned by the Pennon Group, is part of a major Plc focussed on the water and waste management industries. Viridor is currently one of the UK’s leading waste management companies, and at present operates 22 regional landfill sites, numerous regional recycling facilities and 158 waste processing sites1. Viridor is playing a major role within the UK in helping to reach ever more demanding waste treatment and disposal targets. The Company aims to become an exemplary secondary materials recycler by continuing and developing its methods in new approaches to materials recycling. This is built on economic, social and environmental sustainability principles. Waste management services offered by Viridor include: �� Materials Recycling Facilities (MRF); �� bulking and transfer stations; �� materials collection; �� glass reprocessing; �� composting; �� green and In-Vessel Composting (IVC); �� waste treatment; �� transportation; �� Household Waste Recycling Centres (HWRC); �� product destruction/recovery; �� residual waste disposal; �� landfill gas utilisation; and �� Energy Recovery Facilities (ERF). Viridor is proposing to develop an ERF at Dunbar Landfill, Oxwellmains, approximately 4.5km south of Dunbar town centre (Figure 1). The site is located within a non-hazardous landfill, which it owns and operates. The site benefits from excellent road and rail access, and is relatively remote from sensitive receptors. This report marks the first formal stage of the application, and is a request to East Lothian Council to consider the scope of works proposed to carry out the Environmental Impact Assessment (EIA).

1.2 Need For and Benefits of the Development Need for the Development The facility will have the potential to serve the following local authorities: �� City of Edinburgh Council; �� East Lothian Council; �� Midlothian Council; �� West Lothian Council; and

1 http://www.viridor-waste.co.uk/index.php?id=38&menu=aboutus



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�� Scottish Borders Council. The Scottish Executive is proposing to provide funding to Local Authorities to meet their long term contractual requirements from the Strategic Waste Fund and to receive funding they require that groupings of authorities work together in partnership. As such, the five authorities named above have been grouped together under the Lothians and Borders Public Private Partnerships (PPP) project, although any procurement will probably now follow the “Competitive Dialogue Procedure”. Although a formal tender process has not commenced, and is not expected to do so until at least mid 2007, the Dunbar project is being progressed in anticipation of the procurement process, or to serve the target authorities in any event if the process is not taken forward for any reason. The key aim of the proposed facility is to ensure the Local Authorities meet their required targets for diverting Municipal Solid Waste (MSW) from landfill, as outlined in the National Waste Plan: Scotland (NWP) and legislated for in the Waste Emissions and Trading (WET) Act 2003, and as more particularly required by the Landfill Directive (1999/31/EC). Benefits

The ERF and the site at Dunbar offer the following benefits:

�� the site is already located within a fully operational landfill, complete with a dedicated rail siding. Using a rail link significantly reduces the need for traffic movements;

�� the site has excellent access to the road network, namely the A1; �� a large proportion of the residual waste from the target area is already coming

to Dunbar Landfill; �� the site will be situated on land already restored as part of past quarry

operations and the backdrop to the facility will be a large cement works and Torness Nuclear Power Station;

�� the site is situated 4.5km to the south of Dunbar town centre and as a result a

limited number of dwellings are in relatively close proximity to the site; �� the prevailing wind is from west to east, i.e. out to sea; �� the site will produce approximately 26 MWel2 of electricity annually to be used

to power the facility and also to be fed to the National Grid; �� there is the potential for a District Heating System (DHS) to be provided to the

community. This may provide reduced energy costs due to increased energy efficiency;

�� if used as a heating and energy source, it will conserve fossil fuels; and

2 Information provided by Keppel Seghers



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�� development of the site will provide employment for approximately 473 permanent staff and additional contract/temporary staff. This is described in greater detail in Section 3.5.

1.3 Environmental Impact Assessment

Environmental Impact Assessment (EIA) is legislated for under The Environmental Impact Assessment (Scotland) Regulations 1999. These regulations implement the European EIA Directive (85/337/EEC, as amended by 97/11/EC). The Regulations state that certain classes of development listed in Schedule 1 require an assessment of the environmental impacts of the development to be submitted as a precondition of any planning application. EIA is a process which identifies the potential environmental effects of a development and then seeks to avoid, reduce or offset any adverse effects through mitigation measures. EIA follows a series of stages, namely: �� site selection and project initiation; �� screening – is an EIA required?; �� pre-application discussions; �� scoping – consultation on proposed scope and methodology; �� environmental baseline studies – establish what is there; �� assessment of effects – determine the potential effects; �� mitigation – modify proposals to incorporate mitigation measures and re-

assess residual effects; �� preparation of an Environmental Statement; �� submission of a Planning Application with Environmental Statement; �� consideration of the application and environmental information by East

Lothian Council and consultees; �� decision to refuse or grant consent (with or without conditions); and �� implementation and monitoring. The stage covered by this report is presented above in bold. However, the EIA process is both iterative and cyclic, and runs in tandem with project design. As potential adverse effects are identified, the design of the project will be adjusted and mitigation measures proposed. Consultation, a vital component of the EIA process, continues throughout each stage and contributes both to the identification of potential effects and to the mitigation measures.

This report forms Viridor’s written request to the Local Planning Authority, East Lothian Council, under Regulation 10 of the Environmental Impact Assessment (Scotland) Regulations 1999, for its opinion as to the information to be provided in the Environmental Statement (a ‘Scoping Opinion’). It also aims to confirm the Council’s approval of the overall impact assessment methodology and Stakeholder involvement.

The document also informs East Lothian Council that Viridor intends to submit a planning application under the Town and Country Planning (Scotland) Act 1997, and an accompanying Environmental Statement.

3 Feasibility Report, May 2006



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1.4 Scoping Exercise Scoping is an integral component of the EIA process, to ensure that the investigation of any environmental impacts of the proposed project is robust and comprehensive. It highlights the key issues that are anticipated to be associated with the development and enables the finalisation of the scope of the EIA by taking into account the concerns of Stakeholders. By taking these concerns into account at an early stage of the project, any potential impacts can be investigated, predicted and assessed and, where necessary and practicable, means to avoid them can be built into the design. Therefore, this report is important in ensuring that environmental issues are fully addressed and integrated into the final design of the proposed development.

The scoping response received from East Lothian Council and other consultees will be used to inform the next stages of the EIA. The Scoping Exercise is described in detail in Section 2 of this report.

1.5 Next Steps in the EIA Technical Assessments The technical assessments for the EIA will be designed to determine the impact of potential effects identified during the scoping stage. These assessments will determine the current baseline environmental conditions, predict environmental impacts deriving from the proposed development, and assess their significance, taking into account the sensitivity of the surrounding environment, any potential receptors and cumulative effects arising from similar developments in the immediate area. Proposals to avoid or reduce these impacts will be made. Assessments to be carried out and proposed methodologies to be used are described in Section 4 of this report. Environmental Statement The findings of the EIA will be presented in an Environmental Statement (ES). Information that must be provided in this statement is specified in the Environmental Impact Assessment (Scotland) Regulations 1999. The ES will address the following issues in relation to the proposed development: �� Introduction and Background; �� EIA Process and Scoping; and �� Project Description. At this stage, it is anticipated that the ES will report on the significance of the impact of the proposed development, and propose mitigation against adverse effects on the following:

�� air quality; �� archaeology and cultural heritage; �� aviation; �� ecology; �� human health;



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�� hydrology and hydrogeology; �� land contamination and ground conditions; �� landscape and visual; �� needs, alternatives and Best Practicable Environmental Option (BPEO); �� noise and vibration; �� traffic and transport; �� socio-economic impacts; �� amenity issues; and �� cumulative impacts. The ES will be produced as a single document and accompanied by a Non-Technical Summary (NTS), a Planning Statement, Design Statement, Transport Statement, Human Health Assessment and Technical Assessments as required. The NTS will summarise the key points and recommendations arising from the EIA and seek to present the main findings and proposed mitigation measures in a non-technical and easily understandable manner. Planning Application and Submission The ES will be submitted to East Lothian Council, for consideration along with the planning application and following the relevant Notification and Certification. The application will include a detailed Planning Statement that will consider and justify the proposals in the context of the extant Development Plan and other Material Considerations. A “Statement of Community Involvement” will also be included as part of the overall Planning Application. PPC Application In addition to requiring planning consent, the proposed ERF will require a permit to operate from the Scottish Environmental Protection Agency (SEPA) under the Pollution Prevention and Control (PPC) (Scotland) Regulations 2000. As is recommended practice for new facilities, the PPC application is being prepared in parallel with the planning application. This will permit the data gathering and assessment stages required to determine the impacts of the proposed facility to inform both applications. In addition to demonstrating that the facility will not give rise to significant impacts, the PPC application must justify how the proposed techniques to be employed during the operational life of the plant represent Best Available Techniques (BAT). SEPA will only permit the operation of the facility when it is satisfied that the proposed facility will meet both of these criteria i.e. it will not give rise to significant impacts and will also operate BAT.

1.6 Report Structure Section 2 of this report describes the scoping and consultation process, putting it into its regulatory context. Section 3 describes the process by which the site for Viridor’s ERF was chosen, and gives information about the site and its context, and a description of the proposed development. Section 4 describes the approach and methodologies to be used by the topic specialists to assess and quantify any effects on the environment deriving from the



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proposed development. This assessment will allow determination of the significance to the environment of the various effects. As Viridor is committed to encouraging comment and input into the EIA process, Section 5 of this report acts as an Invitation to Comment on its content, and to draw to the attention of the EIA team any areas of concern that have been omitted. These can then be included for consideration at the next stage of the EIA.



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2. Scoping Strategy 2.1 Requirement for Scoping

Scoping is recommended in the Environmental Impact Assessment (Scotland) Regulations 1999. Under Regulation 10, a developer may ask the Planning Authority or Scottish Ministers for their formal opinion on the information to be supplied in the ES. There is no obligation on the developer to consult as to the information to be included in an ES. However, as the Planning Authority and Consultation Bodies will possess local and specialised information, their involvement at an early stage is likely to be beneficial to the EIA and the project design processes. They are also likely to be able to provide preliminary advice on those areas of the project that are likely to be of concern.

In order to provide its considered opinion, the Authority must be provided with: �� a plan indicating the proposed location of the development; �� a description of the nature and purpose of the development; �� a description of its possible environmental effects; and �� a broad indication of the likely scale of these effects. These are provided in Figures 1, 2 and 3 and Sections 3 and 4 of this report.

Although not a mandatory requirement, the scoping consultation exercise is an essential step in the EIA process. This view is reinforced by Planning Advice Note 58 Environmental Impact Assessment (September 1999), which states that scoping is a critical exercise that, if done well, can lay the foundations for a comprehensive ES.

2.2 Consultations

The list of consultees to be consulted during the Scoping Exercise is presented in Appendix 1. Several of these have been consulted as part of the pre-application discussions carried out by Viridor. The consultation exercise provides an opportunity for organisations to raise concerns or issues with regard to the proposed development that they would like to see addressed as part of the EIA. They can also provide local and specialised information or advice to assist the compilation of the ES. Any such advice in conjunction with the feedback on concerns will help to define the approach and scope for the assessments undertaken during the EIA. By conducting the exercise as early as possible it is proposed that the overall project planning and design can take account of any alterations or measures that will act to resolve potential issues and minimise possible impacts of the proposed development.

Further consultation is planned as an integral part of the EIA process and will continue post planning. The consultees include non-statutory bodies and individuals who will not automatically be consulted by the Planning Authority. However, these bodies and individuals may also possess local knowledge and information useful in compiling the



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ES. For example, local community groups and community councils will be consulted as part of the exercise planned by Viridor. A Public Information Programme is also planned prior to submission of the planning application. This will act as a means for local people to express their views, and Viridor intend to use this input and any legitimate public concerns arising from the exercise to inform the application.



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3. Site Selection and Project Description 3.1 Site Selection

In seeking to find an appropriate location for the ERF the site search considered a significant number of possible locations within the Edinburgh, Lothians and the Scottish Borders (ELSB) area. An initial review narrowed 143 identified sites down to 59 sites across the area. This review considered the sites’ potential, in terms of planning designation, site size, proximity to waste arisings, proximity to transportation networks and proximity to housing. The final conclusion of the review has resulted in a short list of 8 potential site locations. A second review assessed these 8 sites in more detail, looking at the following aspects: �� location and description; �� neighbouring land use; �� planning application and proposals; and �� co-location with existing infrastructure.

These aspects were used to determine which of the short–listed sites were most suitable for the development of the ERF. This phase was conducted as a desk study based on maps, local plans and discussions with the relevant Councils. Certain neighbouring land uses could reduce the potential of developing an ERF at particular sites. Where this was the case the site was not investigated further. Such neighbouring land uses included, education facilities (schools and colleges), airfields, food manufacturers and hospitals. Current Planning Applications and proposals for the short-listed sites were also researched to ensure that there were no conflicting applications pending that would prevent the ERF development. Where planning permission has already been given or is likely to be given for activities that would conflict with the development of the ERF on the site, the site was eliminated from further review. The sites were also examined to determine whether there was potential to co-locate the ERF with existing waste management infrastructure operated by Viridor (in accordance with the advice contained in Draft Scottish Planning Policy 10 (SPP10) Planning for Waste Management). The outcome of the second review was a short list of 3 preferred sites namely: �� Millerhill Marshalling Yards; �� Marine Esplanade, Leith; and �� Oxwellmains Landfill Site, Dunbar. The site selection process concluded that the site located at Oxwellmains, Dunbar is the most suitable location for the proposed Energy Recovery Facility (ERF). The conclusion was reached with consideration being given to the principal requirements of current legislation, recommended best practice and overall potential environmental impact, in respect of site selection for facilities of this type. A CHP feasibility study was carried out as part of the site selection and the following conclusions were reached for the site at Dunbar.



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Connection to new developments is generally considered to be more viable than to buildings which are already in place, this is especially the case with residential housing where properties are already connected to a heating network. Therefore it is prudent to consider proposed developments within the vicinity of the Dunbar site. Dunbar has been identified as an appropriate area for increased housing development, and as a result many new houses have been built on the southern periphery of the town, increasing the population substantially. Due to its proximity to Edinburgh, and the rising cost of property in the city, many families are relocating to Dunbar and other East Lothian towns. The Local Plan identifies the need for 700 homes in Dunbar and the extension to local schools. An extension to Spott Road Industrial Estate is also planned for the near future. This offers some opportunity to integrate a CHP scheme at the site.

3.2 Site Description

The proposed site is located to the south of Dunbar in East Lothian, as shown in Figure 1. The proposed site will cover approximately 8-10 hectares and is located within the boundary of Viridor’s existing operations at Dunbar Landfill (Figure 2). The site is generally flat lying, gently sloping from west to east, and lies approximately 20 metres below surrounding ground level.

Surrounding Land The City of Edinburgh is located 40km to the west of the site and Dunbar lies approximately 4.5km to the north. This is the nearest town, although the small village of Innerwick is located approximately 1km to the south. The farms of Little Pinkerton, Meikel Pinkerton, and Easter Pinkerton are located less than 500m to the west of the site and the A1. A Lafarge cement works is located directly to the north of the application site. The site had been previously worked for limestone and was subsequently backfilled with the waste from the quarrying operations. Further to the north is agricultural land and the coastline of Barns Ness, which is a designated geology trail. To the north east of the site adjacent to the coastline is a caravan and camping park. The main Edinburgh to London rail line, which is linked to the site, borders the area to the north and east of the site. Beyond this lies farmland and the coastline. The A1 is situated directly to the south and west of the site and Dunbar is connected to this from the A1087. The majority of the land to the west is agricultural. The site is situated in a generally semi-rural area, with agricultural land dominating the surrounding landscape. However, the location of the site within a landfill, with the Lafarge cement works and Torness Power Station in the surrounding 5km gives the site an industrial background. Land to the south of the site is generally less populated than that to the north, with Dunbar (population 6, 3544) being the largest community within 5km. Part of the coastline is a designated Site of Special Scientific Interest (SSSI), known as Barns Ness Coast. An area to the southwest, Woodhall Dean and Lammermuir Deans are also SSSIs and are located within 4km of the site, as illustrated in Figure 3.

4 Census, 2001



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There are several areas of small woodland surrounding the site, and a small wooded area lies within the site boundary to the west. There are several scheduled monuments within 5km of the proposed development, including Listed Buildings and Scheduled Ancient Monuments, as can be seen in Figure 3. Proposed Site

The site is situated between the A1, to the west, and the main rail line from Edinburgh to London, to the east.

The site was originally part of the Oxwellmains South Quarry, from which limestone was quarried for the nearby cement works. The Lafarge cement works (previously Blue Circle Cement) is still in operation and is actively quarrying to the north west of the site. The quarry was in-filled with waste from the quarrying process and consists of spoil, over burden and quarry reject material. The site was developed by Viridor for the landfilling of non-hazardous waste. The waste input is 300,000 tonnes per annum and comprises of household and industrial wastes brought in by rail and road. At present four cells have been landfilled in the south of the site. The rail link to the east of the site currently brings in 150,000 tonnes of MSW per annum. The Dry Burn is an intermittent stream, which runs along the eastern and southern boundary of the site. The watercourse flows in a general north easterly direction and is reported to be dry during the summer. Blue Circle (now Lafarge) diverted the burn in 1977 to its current position to allow quarrying in the current landfill area. This burn drains into the North Sea approximately 1km east of the site. Access to the site at present is directly off a new stretch of road adjoining the A1. Waste is currently brought in from this junction and by the rail terminal. Past Workings

As mentioned previously, Oxwellmains South was quarried for limestone which was used at the adjacent cement works, which began operating in 1960. However, from historical maps it can be seen that quarrying has been carried out on site since before 1896 in the form of Lime Works to the far west.

3.3 Planning Authority and Relevant Policies

A National Planning Framework For Scotland sets out a vision for Scotland in which other plans and programmes can share and to which they can contribute. It is not an economic development strategy but complements the Scottish Executive's Framework for Economic Development in Scotland, highlighting the importance of place and identifying priorities for investment in strategic infrastructure to enable each part of the country to play to its strengths in building a Scotland which is competitive, fair and sustainable. It is not intended to be a prescriptive blueprint, but will be a material consideration in framing planning policy and making decisions on planning applications and appeals.



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Section 25 of the Town and Country Planning (Scotland) Act 1997 requires development to be in accordance with the Development Plan unless material considerations indicate otherwise.

The relevant Development Plan that covers the area comprises the Edinburgh and Lothians Structure Plan 2015 (approved, 2004) and the East Lothian Local Plan (adopted, 2000). The East Lothian Local Plan is currently in the process of being replaced by the emerging East Lothian Local Plan 2005. It is currently at the Local Plan Inquiry stage and is not expected to be adopted until some time later in 2007. The four Lothian authorities (including East Lothian Council) had previously identified the need to undertake a Structure Plan Review, and accordingly an Issues Paper was published in March 2006. However, on the 23rd of March 2007, the Scottish Ministers approved the Joint Lothian Structure Plan Council’s request for abandonment of the Structure Plan Review. In doing so, the Ministers highlighted their concerns with regard to housing land supply in the Structure Plan area.

Approved Structure Plan

The approved Structure Plan includes the following policies that cover the site at Dunbar Landfill, Oxwellmains: �� Policy ENV1E: Features of Local Importance; �� Policy ENV1F: Environmental or Biodiversity Assessments; �� Policy ENV1G: Design of New Development; �� Policy ENV3: Development in the Countryside; �� Policy ENV4: Landscape; �� Policy ENV5: The Coast; �� Policy ENV6: Renewable Energy; �� Policy ENV11: Waste Management; �� Policy IMP4: Planning Agreements; �� Policy TRAN1: Safeguards for Transport Schemes; �� Policy TRAN2: Location of Major Travel Generating Developments; �� Policy TRAN5: Transport Implications of New Developments; and �� Policy TRAN6: Freight movements. Adopted Local Plan The adopted Local Plan includes the following policies that are relevant to the proposal: �� NRG2: Torness Consultation Zone – …All relevant planning applications

received within a 4km radius of the Torness Generating Station will be referred to Scottish Nuclear for their observations. The site lies within 4km of Torness Power Station.

�� DC1: Countryside and Undeveloped Coast

Part 1 of the Policy outlines Business and Leisure Operations and states that the Council should be satisfied that there is an operational need for a countryside or undeveloped coastal location and that where possible such development should be located in an existing business/industrial area. The



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proposal should also have no significant adverse impacts on nearby land uses and housing.

Part 3 outlines the General Requirements and states:

a. Prime Agricultural Land

…The development must not result in the permanent loss of prime agricultural land.

b. Design and Landscape Setting

…The development must be well integrated into the landscape by virtue of its design and siting, its respect for the physical characteristics of the wider location and, where relevant, its use of trees and woodland to provide an appropriate landscape setting. Development will not be permitted if it appears intrusive, incongruous or exposed, or by virtue of its scale, materials, colour or design harms the character or appearance of the landscape (including the landscape setting of towns and villages), or has an adverse impact on nature conservation.

c. Privacy and Amenity

…The development must provide the occupants of both new and existing uses with an appropriate level of privacy and amenity.

d. Infrastructure

…The development must be capable of being served by necessary infrastructure e.g. vehicle access, water, drainage.

Emerging Local Plan

In addition to the above, the emerging Finalised East Lothian Local Plan (2005) must also be taken into account, although at present it is not part of the adopted Development Plan. However, it does constitute the Council’s most up to date policy statement and is therefore a particularly strong material consideration. It was the subject of a Local Plan Inquiry towards the end of last year and the Reporter’s Report is awaited imminently. The policies highlighted in the adopted Local Plan are largely repeated in this finalised document, although a further Policy W1 is also included and it relates directly to the site at Dunbar. It states that:

…Oxwellmains, Dunbar is supported as a site for waste treatment and disposal. Development that restricts its continued operation will not be permitted.

The pretext to this policy states:

…In respect of all proposals for waste disposal, the Council supports the proximity principle whereby provision is made for the deposition of waste as close as practicable to the point of production. Further proposals for such facilities in accordance with this principle will be considered positively provided that the Council is satisfied an operational need exists and the natural and built environment is adequately safeguarded.

Table 3.1, below, outlines the key provisions of the relevant Development Plans.



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TABLE 3.1 – KEY PROVISIONS WITHIN THE DEVELOPMENT PLAN ENV1E: Features of Local Importance ENV1F Environmental or Biodiversity Assessments ENV1G: Design of New Development ENV3: Development in the Countryside ENV4: Landscape ENV5: The coast ENV6: Renewable Energy ENV11: Waste Management IMP4: Planning Agreements TRAN1: Safeguards for Transport Schemes TRAN2: Location of Major Travel Generating Developments TRAN5: Transport Implications of New Developments

Edinburgh and Lothians Structure Plan 2015 (2004)

TRAN6: Freight movements NRG 1: Torness Consultation Zone East Lothian Local Plan (adopted,

2000) DC1: Countryside and Undeveloped Coast Finalised Lothian Local Plan (2005)** W1: (Oxwellmains, Dunbar)

** Emerging Local Plan, not adopted.

National Planning and Policy Guidance (NPPG) 10) NPPG10 sets out the role and responsibility of planning authorities in developing policy and identifying sites for waste management facilities, ensuring that ‘priority is given to the reduction of waste at source, its re-use, its recovery by recycling and to the use of waste as a source of energy’ (Para 1). Paragraph 6 identifies the need to move towards sustainable waste management based on the proximity principle; self-sufficiency; the precautionary principle; the polluter pays principle; and best practicable environmental option (BPEO). The UK sustainable development strategy also supports the development and use of renewable energy resources where they have prospects of being economically attractive and environmentally acceptable, including Energy from Waste (EfW) (para 39). Para 57 sets out the need for the planning system to take account of new waste management technologies, including energy recovery from waste. Scottish Planning Policy (SPP) 10 – Consultation Draft

This document was published on 14 August 2006 and the initial consultation phase will expire on 6 November 2006. The collation of consultations is still ongoing, although when finalised it will replace NPPG10. It acknowledges that to date a number of planning authorities have failed to take account of the need for waste management infrastructure in their local plans. There is now a need for a better fit between development plans and Area Waste Plans (AWPs) to secure shared Ministerial objectives and to reflect SEPA's policy role in waste management. SPP10 is seen as a catalyst to that end. SPP10 supports a planned approach to the identification of sites for installations using a range of technologies. It focuses on industrial land and promotes a model policy for planning authorities to adopt in their development plans. Landfill will continue to be required and should continue to be safeguarded by development plans.

Planning Advice Note (PAN) 63 – Waste Management Planning

PAN63 complements NPPG10. It also builds on the information given on land use planning for waste management in the National Waste Strategy: Scotland.



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Para 22 specifies that the most appropriate locations will have the least adverse impacts on the local population and the environment. For waste management facilities there are clear advantages to combining facilities. However, for larger facilities the following examples are specified for potential locations:

�� working and worked out quarries. Landfill is commonly used in quarry

restoration but there may be opportunities for other types of waste management facilities;

�� existing landfill sites where, for instance, EfW, materials reclamation or composting facilities may be conveniently located;

�� existing or redundant sites or buildings which could be used, or adapted for incineration or materials reclamation facilities, or composting operations;

�� sites previously occupied by other types of waste management facilities; and �� other suitable sites located close to railways or water transport wharves, or

major junctions in the road network. As the site is already located within a landfill this is in accordance with Para 44 of PAN63, which states that sites for EfW facilities should be:

…sought only on land that is located within permitted or allocated waste management sites or on other suitable previously developed land including degraded, contaminated or derelict land…

Scottish Planning Policy 6: Renewable Energy

Due regard will be given to SPP6, which sets out the Scottish Executive’s planning policies for renewable energy developments that planning authorities should consider when preparing development plans and when determining planning applications. The planning framework set out in the draft SPP aims to ensure the delivery of renewable energy targets as well as facilitating the development of a viable renewables industry in Scotland. The SEA makes reference to biomass under ‘Non wind based renewable energy sources’ with comment as follows: ‘For other non-wind technologies (hydro, biomass, energy from waste), all of these have the potential to give rise to a range of positive outcomes in relation to the SEA objectives. The extent to which they will do so will largely depend on their uptake by developers. For these technologies draft SPP6 is promoting a combination of Option B and local contributions. Biomass perhaps offers the greatest potential in terms of uptake and therefore contribution to the SEA objectives’. The Executive's strategy for renewable energy is set out in 'Securing a Renewable Future: Scotland's Renewable Energy' which confirms a target of 18% of electricity generated in Scotland coming from renewable sources by 2010, rising to 40% by 2020. Under the existing guidance provided by SPP6, renewable energy capacity already installed, plus consented capacity not yet built, is likely to be sufficient to meet the Executive's 2010 target.

Material Considerations – Other Plans & Policies Other material considerations include The National Waste Strategy: Scotland (2003) (NWS) which aims to move towards sustainable waste management using the principles of proximity, self-sufficiency, precaution and polluter pays as well as the waste hierarchy.



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The Waste Hierarchy provides a framework for the national strategy in which the waste management options are set out in order of most preferred to least preferred, as follows: �� reduce; �� re-use; �� recovery (this can therefore be divided again into recycling, composting and

energy recovery in order of preference); and �� disposal. The NWS outlines that energy recovery from waste will play a full part in recovering value from waste streams and is in four broad categories: �� direct incineration of waste; �� use of waste as a substitute fuel; �� heat treatment of waste to produce fuel gas; and �� anaerobic digestion to produce methane, either directly from biodegradable

material or through capturing landfill gas.

The Lothian and Borders Area Waste Plan (AWP), 2003 This document recognises that other technologies including EfW may be needed in order to meet statutory targets for diversion of biodegradable waste from landfill. However, the Lothian and Borders Best Practicable Environmental Option (BPEO) appraisal group and Waste Strategy Area Group have ruled out mass burn incineration from any future BPEO consideration of sustainable waste management options for the Lothians and Borders. At the time it was acknowledged that the future for EfW may lie within emerging technologies, such as pyrolysis, gasification or anaerobic digestion. Energy recovery technologies would need careful waste pre-treatment and in 2003 when the document was published the Waste Strategy Area Group felt that EfW did not present a suitable solution for the short to medium term of the plan. The plan also specified that consideration will be given to:

…incorporating appropriate segregated wastes or refuse derived fuel as an alternative fuel source to fossil fuels in suitable industrial processes, e.g. cement manufacture.

SEPA Guidelines for Thermal Treatment of Municipal Waste (August 2004) This document sets out SEPA’s views on the role of thermal treatment in dealing with municipal waste within the context of the NWS. It acknowledges that the current practice of landfilling 90% of Scotland’s municipal waste is unsustainable and must change. There are 4 main policy guidelines stipulated in the document, 2 of which are most pertinent to the site at Oxwellmains: Guideline 1:

…Where thermal treatment with energy recovery is appropriate, it must play an integrated role with other waste management methods. These methods could include waste prevention, reuse, biological treatment, recycling and landfill.



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Guideline 2:

…Thermal treatment of appropriate segregated waste, with efficient energy recovery (for example, combined heat recovery and power generation), may be an appropriate method for management of waste.

In terms of practical implementation of the guidelines, it is stated that (other than in exceptional circumstances) thermal treatment plants should, inter alia: �� take only residual waste after segregation; and �� have energy recovery systems. SEPA encourages the submission of planning and PPC permit applications simultaneously, with the former taking cognisance of the NWS, AWP and the National Waste Plan in the application. Such issues should be considered during the determination process of the application. The proposed ERF would accord with these guidelines as intensive segregation of waste is anticipated to take place at the kerbside with waste streams being diverted to appropriate waste management facilities (for example MRF or IVC) as part of an integrated waste management system. In addition, the provision of heat recovery is being actively considered and will form part of the final process design. Strategic Environmental Assessment of Lothian and Borders Area Waste Plan A Scoping Report was issued in July 2006, which outlined proposed alterations to the AWP. Changes to the AWP have been proposed due to the production of an Outline Business Case (OBC) and SEPA is of the view that when OBC proposals result in changes to the AWP, a Strategic Environmental Assessment (SEA) should be undertaken. A series of modelled solutions have been proposed within the OBC. Most of the models include an element of EfW, and some of the models are consistent with the proposal for the ERF at Dunbar Landfill. In particular, Model 2a states:

…The model would expect a successful bidder to: �� provide and operate an Energy from Waste solution; �� market the products which come out of the Energy from Waste

Solution; and �� landfill residual wastes.

The SEA will be carried out in parallel with a BPEO. The BPEO is a decision making process that SEPA uses when developing or reviewing any Area Waste Plan. This process reviews social, economic and environmental factors, which can influence the waste strategy and management options for the future. If the alterations to the AWP are accepted this is expected to be in place by January 2007.

The above policies and guidelines, as well as the underlying strategies will be taken into account in the EIA and also addressed through a comprehensive Planning Statement in due course.



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3.4 Project Description Site Layout

The proposed site boundary is shown in Figure 2. The ERF will be located within cells 9 and 10 of Dunbar Landfill, Oxwellmains, which instead of being in-filled, will be set-aside for the purposes of the facility. Plant Capacity The proposed capacity of the plant will be 450,000 tonnes per annum and will be made up of the following: �� 300,000 tonnes of MSW arising from the target authorities of City of

Edinburgh, East Lothian, West Lothian, Midlothian and the Scottish Borders; and

�� 150,000 tonnes of industrial and commercial waste from the target area. The facility will have three lines each capable of processing 150,000 tonnes per annum. It is proposed to install the lines in a staged approach with two lines installed at the outset with the infrastructure in place to install the third line as and when demand requires it.

Process Description The ERF process equipment will be entirely enclosed within a new building. The trucks delivering waste will be weighed on entering the facility and then delivered to the waste reception hall by tipping their contents backward via one of the grates into the refuse bunker. Operators will use grab cranes positioned over the bunker to blend the waste so that the feed to the furnace is relatively uniform and the waste will be fed at a controlled rate. The waste is burnt at high temperatures on a moving grate, which combines vertical and horizontal movement to mix the waste. The resulting heat will be recovered in the form of steam and then be used to generate electricity. Emissions will be treated using gas-cleaning equipment. The steam produced by the two lines will be used in a steam turbine generator to produce approximately 26MW of electricity (gross). The steam cycle will be used in such a way to allow for Combined Heat and Power (CHP) production. The turbine will be equipped with several extractions, one of which can be used for process steam or district heating purposes. Project Duration

Construction The construction phase is likely to last over a period of three years and involve approximately 200 workers. The cost for the development is estimated at approximately £140 million. Operational The facility is expected to have an operational life of approximately 25 years with commissioning commencing in late 2010.



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Access and Transport Access to the site is gained from an improved new junction on the A1. Railway sidings located to the east of the site provide an additional means of access to the site for transporting waste. Under an existing contract agreement with City of Edinburgh Council, approximately 150,000 tonnes of waste will be transported to the site by rail, although in 2010 this will be reduced to 110,000 tonnes. Currently any additional waste to be brought to the site is transported via the A1. It is anticipated that further options with regards to using the rail network will be assessed.

Site Infrastructure The ERF will, in general, comprise the following5:

�� a dedicated internal site access road with weighbridge and office; �� a waste reception area comprising of a tipping hall and bunkers; �� silos (if dry process); �� two boilers and grates (with the option of a third); �� a flu gas treatment system; �� a stack; �� a turbine/generator; �� air cooled condensers; �� an electrical connection, to provide access to the National Grid; and �� additional areas reserved for ancillary pre-treatment facilities. The proposals will also include site offices and amenity block, compound area, storage areas, parking, lighting and fencing. There will be 476 staff employed by Viridor on the site. This is detailed in Table 3.2 below. The site will be operational 24 hours a day, 7 days a week. TABLE 3.2 – STAFFING ANALYSIS Employee Position No. of Employees Plant Manager 1 Operations Manager 1 Maintenance Manager 1 Ops & Maintenance Planning 1 Laboratory & Environmental Compliance 1 Electrical/ ICA Supervisor 1 Mechanical Supervisor 1 Technicians 10 Tipping Hall Control 1 Labourers 4 Shift Manager 5 Shift Process Controller 5 Shift Plant Operator 10 Shift Crane Driver 5 TOTAL 47

5 Information from KeppelSeghers 6 Feasibility Report, May 2006



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Grid Connection Discussions have been held with ScottishPower Plc and a connection is feasible and will be the subject of a separate planning application (under s37 Electricity Act) at an appropriate time before the development takes place.



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4. Proposed Methodologies

This section introduces the areas of the environment likely to be impacted by the development, and presents the methodologies proposed to assess these impacts.

4.1 Air Quality

Introduction

The objective of this assessment is to ensure that air quality in the area would not be adversely affected by the development. An air quality modelling assessment will be undertaken in line with good practice methodologies to derive results for comparison against relevant UK and EU air quality legislation, as well as SEPA’s Environmental Assessment Levels (EALs). Results will be assessed against current and future air quality standards. Sensitive receptors in the locality include those where the public are present for significant periods of time, e.g. residential properties, schools, and hospitals. European sites designated for the protection of ecology, including the Firth of Forth, River Tweed and St Abb’s Head to Fast Castle and the nearby coastal SSSI, will be considered within the assessment. The output from the air quality assessment will also form an important component of, and input to, a health risk assessment which will be carried out. The study will be designed to satisfy these requirements. Baseline The proposed ERF lies wholly within the East Lothian Council’s area although the required air quality study area (extending to 15 km around the site centre) also encompasses the Scottish Borders Council area. A review of published information on existing air quality has been undertaken and revealed that neither Council has declared an Air Quality Management Area (AQMA). Meteorological data and locally obtained data from Dunbar Landfill will used to undertake modelling at the site and address the possible issue caused by coastal haar’s. Based on the information currently available, air quality is expected to achieve the relevant air quality objectives and limit values although concentrations of NO2 and PM10 were close to the objectives at roadside locations in several heavily trafficked streets in the assessment area. This will require further review following consultation with the Councils. Proposed Scope of Assessment The air quality assessment will be as far as possible developed for consistency with the requirements of a PPC permit application and the Local Authorities’ air quality “Review and Assessment process”. This will involve the following: �� current versions of the atmospheric dispersion models ADMS7 and AERMOD8

will be utilised as appropriate, having regard to guidance issued by SEPA for this type of assessment;

7 ADMS: Atmospheric Dispersion Modelling System 8 AERMOD: American Meteorological Society/Environmental Protection Agency Regulatory Model



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�� local meteorological and complex dispersion considerations will be identified and the stack height of the facility optimised through dispersion modelling taking account of terrain, local buildings, and meteorology, using 5-10 years of hourly sequential meteorological data from an agreed recording station;

�� cumulative effects will be assessed having regard to assessments undertaken

by local industrial operators and the local authorities, on the basis of a review of reports held on the public register;

�� consultations will be held with SEPA and local authorities to confirm the

scope of available information, and to discuss and clarify the approach proposed;

�� construction phase impacts will be assessed using a mainly qualitative

approach; and

�� off-site impacts from traffic emissions will be quantified using the Design Manual for Roads and Bridges (DMRB) Screening Methodology.

Fugitive emissions from sources at the facility will also be dealt with, including odorous emissions, dust emissions from materials handling, and bio-aerosols, on the basis of a review of local sensitivities and the proposed design solutions. The facility will be designed to comply with the requirements of the Waste Incineration Directive (EU Directive 2000/76/EC) (WID), in accordance with the Best Available Technique (BAT) for the prevention of emissions at source, and will comply with other applicable legislative requirements. For WID compliant facilities, the dominant pollutant is expected to be NOx. This pollutant is of concern at some roadside locations in the study area due to road traffic emissions. There are a number of sources of published data for background concentrations of NOx and other relevant pollutants, which will be utilised to establish the baseline position. Relevant local bodies will be consulted regarding the proposed development and its impacts. These will include SEPA and East Lothian Council. This will establish the scope of the available base data from existing sources. Interaction with the project ecologist and health impact assessor will be an important feature of the assessment of impacts to ensure that cumulative effects and potential impacts on ecosystems and human health are addressed appropriately. Aerial deposition at ecological and human health receptors will be considered as part of the assessment.

4.2 Archaeology and Cultural Heritage

Introduction

As the proposed development is already on an area that has been quarried and backfilled with quarry waste, it is unlikely that the site itself will have any impacts on archaeology.

Relevant Guidelines The cultural heritage studies will follow the approaches and procedures recommended in NPPG5 (Planning and Archaeology) and NPPG18 (Planning and the Historic Environment). Assessment of impacts on the setting of sites will follow



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Historic Scotland’s (2005) Assessment of impact on the setting of historic environment resources: general considerations. Methodology

Consultation Relevant cultural heritage bodies will be consulted regarding the proposed development and its impacts. These will include East Lothian Council’s Archaeologist and local interest groups.

Baseline Surveys A systematic search will be undertaken of all readily available and relevant documentary sources. This will involve a search of both national and local archives and include: �� Local Authority Sites and Monuments records; �� Scheduled Monument, Conservation Area, Historic Parks and Gardens and

Listed Building information; �� aerial photographs; �� OS Map Coverage from 1st Edition onwards; �� early cartographic sources; and �� relevant bibliographic and documentary sources.

An assessment will be made from the information gathered regarding the heritage resources, statutory designations and local listings. To further inform the study, a walkover survey will be conducted of the site and its environs, with sensitive sites outwith the development area visited and assessed for visual and other indirect impacts. Impact Assessment and Mitigation The potential impact of the development on the cultural heritage resource will be assessed. This assessment will include both direct impacts of the ERF on individual sites and the wider, indirect, impact of the development on the setting of sensitive cultural heritage sites. Accordingly, appropriate mitigation measures will be recommended.

4.3 Aviation

Introduction

The aviation study will identify all items of significance to the safety of aviation within approximate radii of 15km and 30km of the site (15km for small aerodromes, 30 km for international aerodromes, radar sites, navigation beacons etc). The stack height may be of concern to low flying aircraft and large buildings can cause shadow areas resulting in blind spots on radar. Also of concern is the risk of interference to radio and navigation beacons. Relevant Guidelines The standards and guidance to be used are the Civil Aviation Publications (CAP) 168 (obstacles) and CAP 670 (navigation aids) and their military equivalent (JSP 554).



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CAP 493 (Air Traffic Management) may also be consulted. This list is not exhaustive and other standards will be addressed as appropriate. Methodology

Consultation

The discussion of any issues will be carried out with the relevant bodies including National Air Traffic Services (NATS), Defence Estates (Ministry of Defence) and Aerodrome operators. Baseline Surveys

The following will be undertaken:

�� reference to appropriate maps and charts; and �� identified items will be listed and studied for their potential to be interfered

with or suffer a reduction in performance due to the proposed facility.

The items found and the restrictions that they may require on the proposed facility will be reviewed. Impact Assessment and Mitigation The limitations required by the above bodies (if any), together with the legal significance of those limitations, will then be discussed with the plant development team, and possibly the environmental team for example in respect of looking at airborne emissions (mainly heat thermals and smoke) and solutions sought.

4.4 Ecology

Introduction

The two main areas of potential concern will stem from potential noise and air pollution. Disturbance due to noise can potentially impact on local bird populations and other species in close proximity to the site (within 500m), during construction and, to a lesser extent, the operational phase. Air quality issues relate to the potential deposition of particulate matter on ecologically sensitive areas. The relationship between the potential for deposition and possible bioaccumulation and biomagnification effects will be reviewed for protected sites within 10km of the proposed development. Relevant Guidelines

An Appropriate Assessment will assess the implications of the proposal against the conservation objectives of protected sites and determine whether there will be an adverse effect on the integrity of the sites. This process is established by S48 (1) of the Conservation (Natural Habitats, &c.) Regulations 1994. The approach to the environmental assessment will be to carry out all ecological work to a standard that could be utilised to inform an Appropriate Assessment should one be required by the competent authority.



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Methodology

Consultation

In order to augment the baseline study further approaches will be made to appropriate bodies that might hold information on the flora, fauna and habitats of the site (e.g. Scottish Natural Heritage (SNH), Royal Society for the Protection of Birds (RSPB), Scottish Wildlife Trust (SWT), Scottish Ornithologists Club (SOC), local bat and badger groups and any other relevant groups). Baseline Surveys

Viridor will be carrying out Phase 1 habitat surveys, which will be reviewed to provide an indication of the baseline conditions of the environment. A review of the Phase 1 habitat survey will be used to determine the need for further survey work such as: �� breeding or wintering bird surveys; �� protected mammal and amphibian surveys; and �� bat roost and activity assessment. It is considered that the most important receptor in the vicinity of the proposed development in terms of conservation interest is the Firth of Forth Special Protection Area (SPA), designated for its outstanding assemblage of wintering water birds. As part of this SPA is located within 10km of the proposed development, scoping would require that any effect on bird assemblages on this site and any other designated sites within close vicinity to the proposed development, such as Barns Ness SSSI, be reviewed for any potential effects of deposited emissions to the SPA or SSSI. The baseline information from the air quality and noise teams will also be reviewed. The results of these surveys will be used to produce a desk study with recommendations for further surveys (if required). Impact Assessment and Mitigation The impact assessment will comprise a review of the existing data, in conjunction with the Council and other ecologists. Further surveys considered necessary to complete an assessment of the impact of the proposed development on the ecology of the site will be carried out, as agreed with East Lothian Council. The assessment will take into account the results of those other surveys. Potential cumulative impacts in conjunction with other developments within the surrounding area will be identified and assessed, and mitigation measures recommended where appropriate. Mitigation would be agreed in consultation with the relevant authorities.

4.5 Human Health

Introduction The human health risk assessment will be undertaken following the standard tiered approach, beginning with a screening level assessment followed by quantitative assessment where required. The key aim of the screening assessment is to conduct a generic level assessment of the risks posed to human health and the environment by the contaminants emitted



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from the site. The risk assessment procedure utilises the source-pathway-receptor concept in constructing a conceptual site model and assessing potential risks. The conceptual model will be based on an initial evaluation of available data that characterises the sources of contamination and identifies all possible pathways connecting the sources to sensitive receptors surrounding the site under relevant current and future land use scenarios. The source-pathway-receptor ‘pollutant linkage’ scenario will provide the basis for developing a conceptual site model, to identify critical pathways for more detailed quantitative analysis. The purpose of the first stage of the generic assessment process is to determine the key contaminant(s) of concern, followed by the most likely pathways that these contaminants would take in the environment and finally the potential receptors of concern. It is anticipated that the CLEA9 values and model will be used for preliminary analysis. For determinants that are not included in CLEA, the SNIFFER10 framework will be employed to assess the risk, based on nationally recognised toxicological data. To assess exposure scenarios that are not covered by the CLEA and the SNIFFER methodology, such as risk to farms and potential impact on humans through the food chain (ingestion of meat, milk, vegetable produced on these farms), the USEPA11 methodology will be used as appropriate. Relevant Guidelines In the absence of UK protocols for this type of assessment, the USEPA methodology Human Health Risk Assessment Protocol for Combustion Facilities, 1998 will be used. The exposure parameters and toxicological data will, however, change to those used in the UK where available. The Department of Environment, Food and Rural Affairs (DEFRA) common framework for risk assessment and management will be used as the guidelines for the assessment and appraisal of potential impact on human health from the proposed facility. These guidelines set out some basic principles which the regulators would normally intend to use in the assessment and management of environmental risks and which are recommended for all public-domain risk assessments. They are intended to provide decision-makers, practitioners and the public with a consistent language and approach for environmental risk assessment and management. The guidelines provide a framework for a tiered approach to environmental risk assessment and management where the level of effort put into assessing each risk is proportionate to its priority (in relation to other risks) and its complexity (in relation to an understanding of the likely impacts). Methodology Consultations A number of assumptions with respect to the utilised assessment parameters will be made. For example, the biotransfer/bioconcentration factors that dictate the transfer

9 CLEA: The UK Contaminated Land Exposure Assessment 10 SNIFFER: The Scotland and Northern Ireland Forum for Environmental Research 11 USEPA: United States Environmental Protection Agency



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of contaminants from the soil to receiving media such as plants and consequently from plant to other media such as meat/egg following ingestion of plant by farm animal, and for transfer and partitioning coefficients that dictate concentration of contaminants in soil solution will need to be made. This will be undertaken in consultation with the statutory bodies. Baseline Survey and Assessment The assessment of the potential impact on human health from waste management facilities on receptors, including residents and workers within the surroundings of the facilities (excluding the site workers), commonly follows air emission and dispersion modelling. The receptors of this kind of exposure may also be subdivided into those that are at risk through acute (short-term event or fault driven) exposure and those that are at risk through chronic (long term) exposure. The Site Specific Risk Assessment is conducted within a staged approach, consistent with the current UK risk assessment guidelines as presented below: Development of Conceptual Model of the Site The risk assessment procedure utilises the source-pathway-receptor concept in constructing a Site Conceptual Model (SCM) and assessing potential risks. The source-pathway-receptor ‘pollutant linkage’ scenario provides a useful basis for generating a site conceptual model, which can be used to identify critical pathways upon which a quantitative analysis may be based. The SCM will establish, in a qualitative manner, the following: �� principal sources of contamination on the site – emissions from the proposed

development; �� contaminants of primary concern – airborne substances; �� behaviour of the contaminants within the contaminated media, for example

airborne, deposited on soils, taken up by home grown vegetables; �� potential receptors; and �� location of potential exposure points. Plausible pathways connecting sources of contamination and sensitive receptors, including inhalation, accidental ingestion of soil and contaminated home grown vegetable, dermal exposure, and other routes of exposure through the food chain will be considered.

Hazard Identification and Assessment This will include identification of: �� the hazardous substance in terms of type and spatial distribution; �� the media containing the hazardous material; �� the concentration of the hazardous substance in the identified media; �� exposure scenarios, whether residential, industrial; �� exposure routes, ingestion, skin contact; and �� exposure factors for each scenario and route.



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Risk Characterisation and Assessment This includes: �� identification of the toxicity of the identified contaminants of concern with

relevance to acute and chronic exposures; �� identification of the nature of potential effect (threshold or non-threshold

effect); and �� calculation of the magnitude of risks/derivation of risk based criteria using a

site specific risk assessment model to evaluate the significance of harm from exposure to identified contaminants of concern with consideration to sensitive receptors.

Risk Control and Management At this stage of the assessment, strategies to control and manage potential risks through appropriate mitigation measures are identified. This may be achieved through the management of the source or the exposure pathways to prevent the exposure of the receptors.

4.6 Hydrology and Hydrogeology

Introduction The hydrological and hydrogeological impacts of the proposed development will be considered and the following issues will be addressed: Hydrology Flood Risk Assessment (FRA) This will be carried out as a two-stage process, comprising an initial scoping phase and then a second phase for a full FRA. The full extent of the requirements will be determined following the outcome of consultations with SEPA and East Lothian Council. It is likely that the full FRA and drainage mitigation strategy will include some or all of the following: �� prepare of a full FRA report with associated plans and or drawings; �� obtain hydrology data from SEPA and from databases and verify its suitability

for use at this site; �� based on flowpath and hydrological analyses it may be necessary to calculate

modelled flows and flood levels (using a hydrological modelling package called HECRAS12) in the Dry Burn (nearest watercourse to site) and/or its western tributary upstream of the site, for the 100-year event and indicate potential flow paths to the site;

�� demonstrate the extent of the floodplain for the 100-year flow scenario for the

existing site and including future climate change scenario;

12 HECRAS: Hydrologic Engineering Centre River Analysis Suite. This is a hydrodynamic modelling package, which is used to estimate flows in watercourses.



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�� determine the nature of flood risk at the site (extents and depths of inundation under various flow scenarios, nature of flow paths etc), identifying and evaluating any necessary mitigation measures;

�� consider a more extreme flood event and the consequences of the flooding to

the site;

�� prepare a flood mitigation strategy to incorporate the following:

1. floodplain storage compensation (if required); 2. setting floor level for the development with freeboard (if required); and 3. dry access routes (if practicable);

�� assess the potential for surface water flooding from adjacent sites, including a brief analysis of sheet flow;

�� assess the existing and proposed surface water runoff rates for the site and

the natural drainage pathways off the site;

�� assess the surface water attenuation requirements; �� propose a surface water mitigation strategy that will include SUDS13

measures as appropriate using Planning Advice Note (PAN) 61 - Planning and Sustainable Urban Drainage Systems as a guide. Assessment of the surface water runoff rates from the development and a conceptual design for a mitigation strategy where necessary, including SUDS measures to attenuate to agreed discharge rates with SEPA, Scottish Water, and East Lothian Council. Conceptual designs of SUDS measures will be made in line with the master plan;

�� incorporate into the surface water mitigation strategy would be the long-term

proposals for management of the final landform; and �� liaise with Scottish Water to investigate options for connection to existing

sewer networks/watercourses. Water Quality It will be necessary to undertake water quality sampling on the Dry Burn and for the two drainage ditches adjacent to the site to establish the baseline water quality at this location. The surface water management and quality of discharges from the development will need to have a neutral, as a minimum, impact on the water quality. It is likely that the water quality assessment will include some or all of the following: �� liaison with SEPA to obtain any relevant water quality data; �� site walkover with baseline spot sampling of the Dry Burn, two drainage

ditches on the south and northern site boundaries and the existing ponds adjacent to the site. The water quality monitoring programme would be developed in accordance with input from both SEPA and Viridor;

�� review of existing water management;

13 SUDS: Sustainable Urban Drainage Systems. This term is used for drainage systems which try to mimic as far as possible the natural drainage regime



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�� assessment of the proposed water management strategy including the relocation of existing water quantity/quality facilities;

�� assessment of the impacts of the proposed development and operational regime on the quality of the water within the surface water features - watercourses, ponds etc;

�� surface water management system to control the rate and quality of water discharging from the site by the use of SUDS or other on site attenuation or treatment measures;

�� outline input to a water monitoring strategy; and �� liaison with SEPA and Scottish Water.

Water Quality Monitoring Strategy

A water quality monitoring strategy would be prepared for the site. The following elements are envisaged: �� review of baseline water quality data and sampling; �� further two rounds of water quality sampling; and �� assessment of water quality risk for the scheme. Preparation of a water quality monitoring strategy report with associated plans/drawings for submission and agreement with SEPA. Hydrogeology The key issues at the site are: �� the potential for groundwater rebound at the proposed site; �� the presence of any designated or non-designated water dependant features

in groundwater and hydrological catchment area of the proposed site; �� the existence or otherwise of a monitoring network in place that is sufficient to

define baseline conditions; and �� the identification and design of further site investigation works if the

monitoring network is deemed insufficient. A desk-based study will identify any deficiencies in the available data sets required in order to define baseline conditions and to assess the impacts. This will include the following: �� conceptual hydrogeological model; and �� identification of potential Source-Pathway-Receptor pollutant linkages.

Any further work required to delineate the baseline conditions and confirm the conceptual model will be discussed with the relevant authorities as necessary. Relevant Guidelines The likely impact of activities at the proposed site will be determined following a risk-based approach. Mitigation measures will be suggested in line with current accepted remedial techniques, industry best practice and appropriate regulatory guidelines such as PAN 61.



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Methodology Consultation Consultation will be a major part of the hydrological and hydrogeological assessments. Considerations of SEPA, SNH, British Geological Survey (BGS) and Scottish Water will be taken into account in the finalisation of the scope of the assessment. Initially a qualitative assessment is considered to be sufficient to determine the baseline environment and assess the impacts of the proposed project on the hydrological and hydrogeological status of the site. Any necessary further work will be agreed with consultees prior to the completion of the EIA.

Baseline Surveys A desk based scoping exercise will be undertaken to identify any deficiencies in the data available required to define baseline conditions and to assess any potential impacts. The review will cover the following data: �� assessment of findings of other consultants (e.g. ecological receptors); �� hydrological, hydrogeological and geological maps; �� other geological and hydrogeological data, including geological memoirs; �� meteorological data; �� review of scientific literature (as required); and �� existing site data from Dunbar Landfill. Findings from the desk study will be used to inform the baseline study and develop the conceptual model. This will include: �� assessment of monitoring data (groundwater levels, groundwater quality and

surface water quality); �� assessment of data obtained from borehole cores; and �� assessment of the permeability values for the area. A site walkover and survey of water features will be required to inform the Hydrological and Hydrogeological assessments. Impact Assessment and Mitigation Following the review of monitoring data and findings of the baseline study, the impact assessment for the construction, operation and restoration phases of the site can be finalised and potential mitigation measures proposed. Any further works will be discussed and agreed with relevant consultees, including SEPA and East Lothian Council. The assessment will result in the following information: �� site plan and monitoring network; �� screening of existing hydrological and hydrogeological monitoring networks; �� hydrogeological cross section across site; �� groundwater levels contour map based on available data;



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�� preliminary impact identification; �� conceptual hydrological and hydrogeological models, focusing on the water

balance for the area, local groundwater regime and sensitive receptors; �� production of a detailed scope of any necessary additional work; �� mitigation design and input into restoration strategy; and �� residual impacts assessment.

4.7 Land Contamination and Ground Conditions

Introduction

A section will be included to provide a summary of the ground conditions encountered and the potential impacts of the proposed development. In order to establish the existing ground conditions and the potential constraints, a review of existing documents will be undertaken.

Methodology

Baseline Survey

To establish the baseline conditions of the site, the following will be undertaken:

�� a review of published geological and hydrogeological information to determine the likely ground conditions and environmental site sensitivity;

�� a site walkover to make a visual assessment of potential contamination/ground constraints;

�� a review of existing reports of the site; and �� enquiries with the Local Authority to obtain information on land quality issues.

Impact Assessment and Mitigation

The impacts of the proposed facility will be undertaken from the information gathered on the baseline survey and mitigation measures proposed. Any residual impacts will also be considered.

4.8 Landscape and Visual

Introduction The preferred site for the development of the ERF is adjacent to the Lafarge cement works and the A1, south of Dunbar in East Lothian. The site itself is the old limestone quarry (for cement), which is being used as a landfill site. Landscape impacts can be on the physical landscape or on the landscape character. As a reclaimed landscape, it is not anticipated that the direct impacts on the landscape from the development will be significant. The treatment and establishment of a new landscape on this site will be of more relevance to this assessment. Potential indirect impacts on the landscape result from changes to the character of the landscape and the way that landscape is perceived. Visual impacts are a consequence of the change to the view from the introduction of the proposed development and the impact this has on the overall visual amenity. The potential height of the stack is a key consideration in determining the extent of the study area, as this is likely to be the tallest element of the proposal, and its visual



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prominence may be increased in the event of a visible plume being emitted. The eventual height for the stack will be developed through the design and EIA process, with the assessment of air quality of particular relevance. Experience with similar developments suggests the stack height is likely to be within the range of 60m to 100m tall. The building itself may be as tall as 40m. Should there be a visible plume from the stack this would further increase the height, with implications for the visibility of the development. The visual properties of the plume are dependant on the technology used and the weather conditions. The technology to be used within this development will be informed by this and other assessments within the EIA process. Although it is anticipated that the landscape and visual effects will be most significant within the immediate vicinity of the site, the size of the building and stack may result in effects within a wider area. Based on recent discussions with SNH relating to a similar type of development, it is proposed that a detailed study area for the assessment of landscape and visual effects extends to 5km from the site. The assessment of sequential and cumulative effects would be limited to this inner study area. In addition, a wider study area up to 20km radius would also be reviewed to identify sensitive receptors within this wider area to include within the assessment. Relevant Guidelines It is proposed that the methodology for the assessment will follow the recommendations and guidance set out in the following reports: �� guidelines for Landscape and Visual Impact Assessment, 2nd Edition, edited

by the Landscape Institute and Institute of Environmental Management and Assessment (2002); and

�� Landscape Character Assessment Guidance for England and Scotland, Countryside Agency in conjunction with SNH (2002).

Methodology Consultation Zone of Theoretical Visibility (ZTV) diagrams will be produced for the stack and the building. These will be used to inform the selection of viewpoint locations. The proposed viewpoint locations will be confirmed through consultation with East Lothian Council, Scottish Borders Council and SNH at a later stage in the process, once details of the design of the building and the stack have been established. It is proposed to take a visual record from up to 15 viewpoints, and an assessment of the view from these locations will be undertaken. It is not proposed to prepare any photomontages as part of the assessment of visual effects. Baseline Survey

A desk study and site survey of the proposed area will be carried out. The desk study will review relevant Development Plan policies within the proposed study area to determine the development plan constraints. Ordnance Survey mapping at various scales will be reviewed to provide a preliminary understanding of the topography and land cover in the vicinity of the site.



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Relevant landscape assessments will be reviewed to identify broad landscape character areas. The proposed study area is covered by The Lothians landscape character assessment, SNH Review No 91 (1998) by ASH Consulting Group, and is located within the Dunbar Plain landscape type. The landscape is characterised by the transition between the hill-slopes of the Lammermuir Hills and the sea. It is predominantly open, with little woodland, and extensive views over the plain and the sea. In the vicinity of the site at Oxwellmains, existing industrial developments such as the cement works, landfill site and Torness Power Station, and transport infrastructure of the A1 and East Coast Main Line are prominent elements. These reduce the landscape and visual sensitivity of the area, but create the potential for cumulative effects from this proposal. The site survey will expand and verify desk study findings; identify sensitive landscape and visual receptors; establish effects on landscape resource; take a visual record from agreed viewpoint locations; and establish impacts on visual resource. The baseline survey will be in two parts: 1. Landscape Appraisal

The landscape character appraisal will make use of relevant guidance and existing assessments. This will be supported by a survey of the existing land use and any landscape assets as designated in development plans to establish the landscape character of the site within the local landscape resource.

2. Visual Appraisal

This will identify important viewpoints from within the site and towards the proposed area from potential sensitive receptors within the immediate surrounding landscape, including local transportation routes. Viewpoint assessment within the wider study area will focus on public viewpoints and designated areas identified within the Local Plans. The landscape and visual impact assessment will describe the visual properties of the plume, and an additional ZTV for an average plume height will also be produced to inform the assessment process, once the properties of the plume can be established.

Impact Assessment and Mitigation The report will include a brief introduction setting out the scope of the landscape and visual impact assessment, and the methodology used. It will provide detailed baseline information for the study area comprising a description and analysis of the landscape and visual resource. It will draw on the information gathered during the desk study and site surveys. �� The assessment will determine the sensitivity of the landscape, i.e. the

measure of its capacity to accommodate change without loss of character; and the sensitivity of the agreed visual receptors.



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�� It will describe the nature of the predicted effects from the proposed development on the landscape and visual resource, and determine the predicted magnitude of change.

�� An informed judgement will be made regarding the significance of the

landscape and visual effects based on the sensitivity of the receptor and the magnitude of change.

The report will review the landscape and visual effects. It is unlikely, given the scale of the development, that conventional mitigation measures such as screening will be effective. A description of the mitigation factors relevant to landscape and visual considerations will be presented. Design Statement The process of site selection, site layout and materials used in the design, are relevant considerations in the overall mitigation of the development. The evolution of the design, the design principles applied, the final design solution and an explanation of the rationale behind the final design solution will be described through a combination of text and supporting graphics within the Design Statement. This will be produced as a separate document, and will take cognisance of the advice within PAN68: Design Statements. Cumulative Impacts The assessment will review the cumulative effects of the proposed development in combination with the existing Lafarge cement works, ultimate landform created by the Dunbar Landfill site and Torness Power Station and associated major infrastructure. Graphic material will include: �� landscape character plan (OS based); �� ZTV diagrams (OS based); �� viewpoint location plan (OS based); and �� selected viewpoints illustrating the existing site and any potential important

landscape features analysing the potential visual impacts. Summary Table 4.1 summarises the scope requests for the landscape and visual impact assessment. TABLE 4.1 – SUMMARY OF SCOPE REQUESTS Methodology Confirmation of proposed methodology Consultation process

Ongoing dialogue regarding design process.

Detailed landscape and visual assessment study area to extend to 5km from site boundary.

Confirmation of study area requested.

Extended study area to identify sensitive receptors within the wider landscape to extend to 20km from site boundary.

Confirmation of study area requested.

Up to 15 viewpoint locations to be selected, based on the theoretical visibility of the site derived from the Zone of Theoretical Visibility drawings.

Confirmation of proposed number of viewpoints.

Viewpoint assessment will be based on existing views and not visualisations.

Confirmation that visualisations are not required.



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TABLE 4.1 – SUMMARY OF SCOPE REQUESTS Cumulative assessment to consider Lafarge cement works, Dunbar Landfill and Torness Power Station, and associated infrastructure.

Confirm developments to be considered within cumulative assessment.

4.9 Needs, Alternatives and BPEO

Introduction

The assessment of need for the development of sustainability issues should take into account an assessment of social, economic and environmental factors. The Best Practicable Environmental Option (BPEO) is the option which provides the most benefit or least damage to the environment as a whole at an acceptable cost in both the long and short term. Under the plan-led system, East Lothian Council and, ultimately, Scottish Executive support for proposals should be determined in accordance with the development plan and any other material planning circumstances. Furthermore, need for a development in a particular location is a substantive material consideration.

Relevant Guidelines

BPEO is a fundamental part of Scottish Executive policy towards the strategic management of waste streams, albeit there has been a recent move towards SEA which encompasses the principles behind BPEO. Identifying the BPEO can be a complex task in the context of integrated waste management systems. In principle, however, it should only be as complicated as it needs to be. Any BPEO assessment and process requires assessing the performance of options against a number of objectives, and resolving the conflicts between these objectives by making trade-offs.

Methodology

Consultation Consultations will be undertaken with East Lothian Council, the Scottish Executive and SEPA. However, this is not definitive. Baseline Surveys Appropriate information relating to Need and Alternatives should be addressed within the planning applications in the context of: �� the demand for the proposal based on waste arisings, national policy and the

Area Waste Plan; �� reviewing different options that could meet this demand; and �� reviewing alternative sites. Option/Scenario Development A BPEO assessment requires that a range of options are assessed against objectives and criteria. If the assessment was being carried out by a waste planning authority it would necessarily take a regional approach, locking in the facilities and services already in place, and then developing a range of scenarios/options with a mix of technologies (type and scale) as part of the BPEO process. The baseline would necessarily have to recognise and include the existing waste contract that is in place with Viridor. It would also need to factor in any penalties, and other relevant



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commercial considerations into the assessment, for any scenario that varied from the terms of the existing contract. An alternative first step is to undertake a basic ‘commercially focused’ BPEO analysis, developing the scenarios around the options that are available to Viridor to treat the residual waste that it receives. Such options would consider residual waste treatment technologies, and would include: landfill; Mechanical Biological Treatment; energy recovery from waste; and other thermal treatment options (gasification, etc). Impact Assessment and Mitigation

The approach would identify and assess in broad terms the relative aspects and impacts of the alternative scenarios including for example: environmental issues; legal and policy compliance; costs; practicality/deliverability; status of technology (proven/emerging) and associated risks, including bankability. Assessing the impacts of development (energy recovery is higher in the waste hierarchy than landfill, potential for district heating, possibility of basic materials recovery at the plant in the form of metals), compared against other options available to Viridor to treat the waste, will involve key stakeholders for example the local authorities forming the Edinburgh, Lothian and Borders Area Waste Group, the Scottish Executive and SEPA. In undertaking the BPEO assessment it will be important to understand the wider waste policy and planning background. The National Waste Strategy: Scotland (1999) supports energy recovery above disposal, and the current Lothian and Borders Area Waste Plan (2003) recognises that new facilities including EfW may be needed to meet landfill diversion targets for diversion of biodegradable municipal waste from landfill. However, the Lothian and Borders BPEO Appraisal Group and Waste Strategy Area Group ruled out mass burn incineration. Since then SEPA has published Guidelines for Thermal Treatment of Municipal Waste (August 2004) which emphasize that thermal treatment must form part of an integrated waste management approach, and support ‘efficient energy recovery’ (for example, combined heat and power). At a European level, there have been proposals to introduce an energy efficiency threshold, to distinguish between recovery and disposal operations. Again, how such a proposal will finally emerge remains to be seen, it does support the principle of combined heat and power as an element of energy recovery from waste. Most recently, a Scoping Report for a Strategic Environmental Assessment of Lothian and Borders Area Waste Plan was issued in July 2006. The Outline Business Case on which the SEA is based includes a series of models that include an element of EfW. Overall therefore, the proposed ERF appears to be broadly in accordance with waste policy and the developing waste planning context. These are supportive of energy recovery, in particular where efficiencies are maximised as far as possible. An element of the BPEO assessment will therefore be to develop scenarios that consider potentially qualifying uses for heat recovery from the thermal treatment processes, as well as further materials recovery from the residual wastes.



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4.10 Noise and Vibration Introduction Once baseline levels at selected sensitive receptors have been determined, noise levels which are likely to be produced during both the construction and operational phases will be predicted and their significance at Noise Sensitive Receptors (NSR) determined. Potential operational and construction vibration impacts will also be assessed.

Relevant Guidelines

Guidance documents relevant to the assessment include, but are not limited to, the following: �� ISO 9613: Acoustics – Attenuation of Sound During Propagation Outdoors,

1993; �� BS 4142: Method for rating Industrial Noise Affecting Mixed Use Residential

and Industrial Areas, 1997; �� BS 5228: Noise and Vibration Control on Construction and Open Sites, 1997; �� BS 7445: Description and Measurement of Environmental Noise, 2003; �� BS 8233: Sound Insulation and Noise Reduction for Buildings, 1999; �� BS 6472: Guide to Evaluation of Human Exposure to Vibration in Buildings (1

Hz to 80 Hz), 1992; �� BS 7385: Evaluation and Measurement for Vibration in Buildings, 1993; �� World Health Organisation: Guidelines for Community Noise, 2000; �� PAN56: Planning and Noise, 1999; and �� Department of Transport (DoT): Calculation of Road Traffic Noise, 1988. Methodology Consultation An initial consultation will be conducted with East Lothian Council to confirm its requirements for baseline noise assessment (location, number and duration of the surveys) and the prediction methods and criteria to be adopted for the determination of significance. Consultations will also take place with SNH to identify any sensitive ecological sites that may be affected by noise from the proposed facility. It will be confirmed whether a cumulative impact assessment is likely to be required to consider noise from other operations and whether an environmental noise assessment of road and rail traffic noise is required.

Baseline Surveys Noise monitoring will be undertaken at a representative number of NSRs in accordance with BS 7445 and as agreed with East Lothian Council. Assessment The potential noise and vibration impacts due to the construction and operation of the proposed facility will be predicted.



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The prediction methods used will incorporate the following: Construction BS 5228: Parts 1 & 4: 1997 and 1994 ‘Noise and Vibration Control on Construction and Open sites'. This standard provides methods for predicting noise and vibration from plant operating on construction and open sites. The predictions will be carried out using a noise-modelling package, either “SiteNoise” or “SoundPLAN”. Vibration from site activities that may generate significant levels, primarily piling and/or dynamic compaction, will be assessed using methods contained in BS 5228 Part 4 and/or recent BRE guidance on vibration levels from construction plant and activities.

Operation

The operational elements of the proposed facility with any noise emissions that could potentially be significant will be modelled using ”SoundPLAN” noise modelling software, implementing ISO 9613. Road Traffic – Construction and Operational Phases ‘Calculation of Road Traffic Noise’, DoT, 1988 (CRTN) – Methods defined in this document will be used to predict road traffic noise levels at sensitive receptors due to the additional vehicles associated with the construction and operation of the facility. Rail Traffic ‘Calculation of Railway Noise’, DoT, 1995 (CRN) – The methods set out in this document will be used to predict any potential noise impacts associated with rail traffic accessing the site during the operational phase of the facility. For the determination of significance, the following guidance will be used: Construction The significance of noise levels will be assessed using a method developed by RPS to assess impacts from major schemes. This is based upon the amount the construction noise exceeds ambient noise levels for the periods of activity and whether levels are likely to exceed noise levels at which noise insulation is sometimes provided. For vibration, guidance defined in BS 7385, BS 6472 and BS 5228: Part 4 will be adopted. Operation BS 4142: 1997 Method for rating industrial noise affecting mixed residential and industrial areas. This standard describes a method for assessing whether the noise produced by an industrial development is likely to give rise to complaints. Significant vibration levels are unlikely to arise from the operational phase assuming access roads and the public highway are maintained in good condition. The likelihood of significant ground-borne vibration due to rail operations will depend on the nature of the terrain and rail traffic activity. Guidance defined in BS 7385 and BS 6472 will be adopted to determine significance.



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Impact Assessment and Mitigation Where necessary, mitigation measures will be recommended to reduce noise and vibration levels to below the thresholds of significance. For construction, any impacts predicted will be transitory but they will need to be reduced as far as is reasonably practicable. Noise levels will be predicted from a plant or equipment inventory, together with details of the proposed hours and methods of working and programme. Once an initial assessment has been completed plant or activities causing impacts can be identified and low noise alternatives suggested. For the operational phase, from the modelling undertaken, it will be possible to identify the key noise sources, and additional mitigation, such as enclosures or silencers, can be specified to reduce levels to acceptable limits. Potential cumulative impacts in conjunction with other developments within the surrounding area will be identified and assessed, and mitigation measures recommended where appropriate.

4.11 Transport and Traffic Assessment

Introduction The overall accessibility and the logistical requirements of operations will play an important part in the long-term success of the development. The site is already serviced by rail, and road access can be gained directly from the A1. The route taken by vehicles to Dunbar Landfill must therefore be determined, to ensure minimum disruption to surrounding communities, and the existing road network. The Transport Assessment (TA) will summarise and detail the existing conditions and establish any impacts associated with the operation of the scheme. This will be included in the EIA as a technical appendix.

Relevant Guidelines

The Transport Assessment will be undertaken in accordance with the Guidelines for Traffic Impact Assessment produced in September 1994 by the Institution of Highways and Transportation (IHT), the UK Government’s Transport White Paper A New Deal For Transport: Better for Everyone, and the Scottish Executive’s Guide to Transport Assessments. Methodology

Consultation Consultation is considered to be an important part of the Transport Assessment, as consideration of local communities and local knowledge of the existing road network is vital to ensure appropriate and safe routes to and from the site are established. The traffic assessment will initiate discussions with the relevant highway authorities to establish the broad scope of a transport assessment and the parameters and constraints relating to car parking, highway standards, pedestrian facilities and other highway related aspects of the proposed development.



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Through close discussion with Viridor, the extent of existing waste haulage to the Dunbar Landfill site by road borne traffic and rail will be ascertained. Additionally, envisaged traffic volumes relating to the construction of the new ERF and volumes of traffic once the plant is operational will be established. An investigation into committed development will be included in the TA, to be agreed with the highway authority. This will include consideration of future operations at the adjacent Lafarge cement works. Consultation will be undertaken with the Highways Department of East Lothian Council in order to establish the precise scope of the TA, and the parameters and constraints regarding access and other highway related aspects of the proposed operation. This will include the agreement of the geographical area of interest. The necessity for further data collection will also be discussed. Baseline Surveys

A site visit will be undertaken to observe existing conditions and to provide supporting photographic evidence. Information will be gathered on the following for the TA: �� the extent and availability of traffic count data in the areas of interest. Areas

requiring additional information will be identified; �� details of landownership and the highway boundary in order to identify the

constraints in relation to the design of the highway accesses; and �� review access by other modes, including rail and/or water for transportation of

material.

Impact Assessment The following will be undertaken as part of the TA: �� liaise with the client to clarify any outstanding queries and gather available

background information; �� commission traffic surveys to supplement the available traffic data, if required; �� undertake a full inspection of the site and surrounding highway network, to

establish details such as carriageway width, visibility splays, speed limits, location of any street furniture, pedestrian/cycle provision, public transport routes. Opportunities for improvements to access proposals, sensitive properties e.g. schools and dwellings, potential receptors for environment impact from traffic noise would also be considered;

�� determine traffic movements within the area of interest arising from committed

developments, based upon either available reports or through the use of the TRICS14 database;

�� establish the trip generation of the proposed development. The figures

produced will cover the normal weekday peak periods and also the average daily flows. An important aspect of the trip generation will be the level of HGV traffic associated with the site;

14 TRICS: Trip Rate Information Computer System. An analysis package used extensively for transport and planning and development control.



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�� obtain three-year accident history for the study area and provide commentary on the likely impact of the development upon road safety;

�� identify the junctions where impacts are considered to be material, as

recommended in the ‘Guidelines for Traffic Impact Assessment’ (Institution of Highways and Transportation, 1994);

�� obtain, if required, 1:1250 Ordnance Survey data in digital format for the

highway network to be assessed; �� produce an outline design for the access point to the development site, giving

consideration to the preliminary site layout, land ownership constraints and local design standards;

�� advise on the suitability of the site layout to accommodate operational traffic;

�� assess the capacity and operational adequacy of the site access and those

junctions where a material impact is identified. This will be undertaken at the year of opening and a design year either 10 or 15 years hence depending on the necessity for highway improvements;

�� advise on the need for upgrading the highway network to cater for increased

traffic, and prepare outline mitigation measures. This includes for the reassessment of capacity and operational adequacy of the improved junctions;

�� consider the policy context in relation to transport and access for the site; �� consider and comment on public transport, pedestrian and cycling provision

for the proposal, including links and facilities within the site itself; �� consider the role of rail (and water) for the transportation of material; and �� consider and comment on parking provisions for the development, and

provide supporting information as required. Mitigation The impacts of the proposed development on the highway capacity will be assessed and any adverse impacts which result in shortfalls in highway capacity and congestion will need to be addressed by highway improvements or management of the delivery of materials to avoid congested periods. Adopting the relevant highway improvements and/or operating procedures will mitigate the highway impact of the proposed development resulting in no discernible increases in congestion as a result of the proposal development. This will also help towards the mitigation of the transport related noise and air quality impacts of the proposed development.

4.12 Amenity Issues

Introduction

In addition to the air quality and noise issues, waste management facilities also have the potential to cause environmental nuisance due to the generation of litter or through the attraction of vermin and other pests to the site.



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The principle means of control over these issues will be through the PPC Permit rather than the planning regime. Nevertheless, for information purposes, the proposed potential impacts and mitigation will be summarised. Relevant Guidelines

The amenity issues will follow guidelines relating to PPC such as The Environmental Protection Act 1990, The Pollution Prevention and Control (Scotland) Regulations 2000 and NPPG10. Methodology

Consultation

Consultations will be carried out with East Lothian Council and SEPA as part of the PPC Permit Application process and will establish the appropriate waste management strategy for the site. Baseline Studies During the course of the EIA a range of baseline information will be gathered in relation to the waste management of the site and potential effects on the wider area. Relevant information for the site and its surrounding potential receptors will be drawn from the PPC Permit Application process and any associated studies. Impact Assessment and Mitigation

A summary of the assessment carried out as part of the PPC Permit Application process will be summarised and relevant site-specific mitigation measures recommended. All mitigation measures will be in accordance with the relevant Pollution Prevention Guidelines (PPG) as published by SEPA.

4.13 Socio-Economic Impacts

Introduction The proposed development has the potential to impact upon local communities both positively and negatively. Therefore, the socio-economic impacts of the development need to be assessed as part of the EIA process. The assessment of these impacts will involve the collation of a range of baseline economic data in relation to the location of the proposed development and the development itself. The assessment will then consider their relative significance, and means of mitigating against negative impacts and promoting positive ones.

Methodology

Consultation

East Lothian Council, local community groups and local interest groups will be consulted as part of the EIA process. Possible mitigatory measures will be established and agreed as part of these consultations.

In addition, a Public Information Exhibition will allow comment and input from local people otherwise not involved in the consultation process. This will inform the design



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process, and maximise beneficial aspects of the development, while minimising those damaging or disruptive to the community. The full extent of the Stakeholder Engagement is dependant on a programme to be determined. Baseline Surveys

The current socio-economic status of the communities surrounding the site will be described using Council and National data.

During the course of the EIA a further range of baseline information will be gathered in relation to the socio-economic conditions of the wider area. This information will include: �� population (numbers and profile); �� economic activity; �� unemployment; �� occupations, qualifications and average earnings; �� deprivation; �� business mix; �� proposed indirect employment during construction; �� information relating specifically to energy production and supply; and �� the potential to provide a District Heating System (DHS) to development

areas at Dunbar. This information will be drawn from a range of sources and consultations, as required. It may include information from Local Plans and data produced by, for example, the local education authority and NHS. It is considered that there are likely to be positive impacts on socio-economics from the development.

Discussions with the Council will assess which data they consider to be relevant and important in this area.

Impacts are expected to include:

�� direct and indirect employment; �� contribution to the local economy; �� DHS; and �� impact on other industries. Impact Assessment and Mitigation

Potential impacts of the development will be reviewed, in collaboration with the Council and local groups.

Assessment of the baseline information will allow conclusions to be drawn in relation to the socio-economic impacts, in particular relating to economic gain and employment impact.

In order to reach these conclusions, the following assessments will be undertaken:

�� Assessment of Project Need. The requirement for the project will be

outlined and established via the assessment of baseline data. This will include an assessment of potential benefits/impacts and market and legislative requirements. This will also take into account potential commercial



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effects and regeneration benefits as well as environmental gains of the ERF to its end-users.

�� Qualitative Appraisal. A Qualitative Appraisal of the following factors will be

undertaken:

�� construction cost; �� income; �� energy production levels; �� investment; �� construction impact; �� employment creation; and �� gross value added.

The significance of any identified impacts will be determined, using information acquired from the Council and other sources.

Local concerns will also be taken into account. Any major impacts, or any considered to be unacceptable to the communities will be addressed, and mitigation suggested to reduce the extent of the impact, or to offset it with planning gain elsewhere in the proposals, such as DHS.

4.14 Cumulative Impacts

Introduction Cumulative impacts may occur when an impact from the project under consideration occurs at the same time as similar impacts from other developments e.g. an increase in noise from the proposed ERF occurring at the same time as that from other developments.

Relevant Guidelines

Schedule 4, Part I, [4] of the Environmental Impact Assessment (Scotland) Regulations 1999 requires that cumulative impacts be considered as part of the EIA. The regulations do not provide a definition of cumulative impacts. Methodology Consultation Consultations will be undertaken with East Lothian Council to confirm the requirement for a cumulative impact assessment across a range of topic areas. Baseline Studies

Developments to be considered within the assessment will be confirmed with East Lothian Council and are likely to include: �� Dunbar Landfill site; �� Lafarge cement works; and �� Torness Power Station.



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Cumulative impacts will be considered in each technical Chapter of the ES and a summary of the overall cumulative impact assessment will be included in a separate Chapter. Any additional effects of the proposed ERF will be put into the context of the area as a whole.



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5. Further Information

The scope of works detailed in the above sections is not exhaustive and will be subject to further consideration by Viridor, the project team, other Stakeholders, the general public and consultees. RPS, on behalf of Viridor, is now seeking consultees’ views on the proposed ERF facility at Dunbar Landfill, in order to incorporate these into the EIA process. Comments are invited on the findings of this scoping exercise, the methodologies proposed and any concerns considered not to have been addressed in this document. This information will influence and inform the scope and approach to the Environmental Impact Assessment.

All responses should be addressed to:

Steve Newlands RPS Planning Transport and Environment 45 Timberbush Bernard Street Leith Edinburgh EH6 6QH Tel: (0131) 555 5011 Fax: (0131) 555 4911 or e-mail response to: [email protected]



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Appendix 1 – List of Consultees



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1. Statutory Consultees - these are issued direct by East Lothian Council:

East Lothian Council - including: Head of Planning Environmental Health Officer Highways Department Development Plan Officer Natural Heritage Planner Head of Waste Management Council Archaeologist Landscape Officer Biodiversity Officer Scottish Natural Heritage SEPA Historic Scotland Scottish Executive Transport Scotland Scottish Water Scottish Executive Environment and Rural Affairs Department (SEERAD) Scottish Power Health and Safety Executive Scottish Borders Council – Landscape Architect Coal Authority British Airway Authority /Civil Aviation Authority

2. Non-Statutory Consultees - these will be issued direct by RPS:

Local Community Councils: Dunbar Community Council West Barns Community Council Lammermuir Community Council

Local Interest Groups: East Lothian Local Access Forum Lothian Bat Group Lothian Birding East Lothian Biodiversity NHS Lothian Network Rail Site Liaison Group – Dunbar Landfill

National Interest Groups:

Scottish Wildlife Trust RSPB Other:

Lafarge cement works Torness Power Station BGS



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Appendix 2 – Glossary



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ADMS Advanced Dispersion Modelling System am Ante meridian (before noon) Approx. approximately AWP Area Waste Plan BAT Best Available Technology BGS British Geological Survey BPEO Best Practicable Environmental Option BS British Standard CAP Civil Aviation Publications CLEA Contaminated Land Exposure Assessment CRTN Calculation of Road Traffic Noise DEFRA Department of Environment, Food and Rural Affairs DMRB Design Manual for Road and Bridges EAL Environmental Assessment Level EEC European Economic Community EIA Environmental Impact Assessment EfW Energy from Waste e.g. (exempli gratia) for example ELSB Edinburgh the Lothians and the Scottish Borders ERF Energy Recovery Facility ES Environmental Statement EU European Union FRA Flood Risk Assessment GLVIA Guidelines for Landscape and Visual Impact Assessment Ha Hectare HGV Heavy Goods Vehicle HERCAS Hydrologic Engineering Centre – River Analysis Suite i.e. (id est) that is IHT Institution of Highways and Transportation Km Kilometre M Metre MBT Mechanical Biological Treatment MSW Municipal Solid Waste MW Mega Watt NATS National Air Traffic Services NHS National Health Service NMRS National Monuments Record of Scotland NPPG National Planning Policy Guidance NWS National Waste Strategy NO2 Nitrogen dioxide NTS Non Technical Summary NSR Noise Sensitive Receptor OBC Outline Business Case OS Ordnance Survey PAN Planning Advice Note PM Particulate Matter pm Post meridian (afternoon) PPC Pollution Prevention Control PPG Pollution Prevention Guidelines PPP Public Private Partnerships Ramsar site Site protected under the Ramsar Convention on Wetlands (1971) RCAHMS Royal Commission on the Ancient and Historical Monuments of Scotland RSPB Royal Society for the Protection of Birds SCM Site Conceptual Model SEA Strategic Environmental Assessment



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SEPA Scottish Environment Protection Agency SEERAD Scottish Executive Environment and Rural Affairs Department SOC Scottish Ornithologists Club SNH Scottish Natural Heritage SNIFFER The Scotland and Northern Ireland Forum for Environmental Research SPA Special Protection Area SPP Scottish Planning Policy SSSI Site of Special Scientific Interest SUDS Sustainable Drainage Systems TA Transport Assessment TRICS Trip Rate Information Computer Systems UK United Kingdom USEPA United States Environmental Protection Agency WID Waste Incineration Directive ZTV Zone of Theoretical Visibility % percent



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Documents

Appendix 1 – Scoping Letter and Reportviridor-consultation.co.uk › UserFiles › 0508_Technical... · 2009-09-22 · Viridor Waste Management Ltd May 2007 Scoping Report RPS Planning