MILLERHILL RECYCLING AND ENERGY RECOVERY CENTRE (RERC)
PROPOSED DEVELOPMENT OF AN INTEGRATED WASTE RECOVERY FACILITY ON LAND OFF AT THE
FORMER MILLERHILL MARSHALLING YARDS, WHITEHALL ROAD, MILLERHILL, DALKEITH
ENVIRONMENTAL STATEMENT VOLUME 1 - MAIN REPORT
MARCH 2015
This report is submitted in support of a detailed planning application for the above
project. The application has been co-ordinated by AXIS with technical inputs from:
AXIS – Project Management / Co-ordination, Planning Policy & Need, Traffic &
Transportation, Landscape & Visual Effects, Surface Water & Flood Risk and
General Environmental Matters
Environmental Compliance – Air Quality, Human Health
GSDA – Architectural Design
NVC – Noise
Argus – Ecology and Nature Conservation
AOC – Archaeology and Heritage
TerraConsult – geology, Hydrogeology and Ground Conditions
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CONTENTS
FOREWORD
LIST OF ACRONYMS
1.0 INTRODUCTION ............................................................................................... 1
1.1 Introduction ........................................................................................................ 1
1.2 The Proposal ..................................................................................................... 1
1.3 The Site and Its Context ..................................................................................... 4
1.4 Background to the Scheme and Compliance with the extant PPiP ..................... 7
1.5 The Applicant ................................................................................................... 12
1.6 This Document ................................................................................................. 12
2.0 SCOPE OF THE ENVIRONMENTAL ASSESSMENT ..................................... 14
2.1 Scope .............................................................................................................. 14
2.2 Baseline for the Environmental Impact Assessment ......................................... 20
2.3 Assessment of Environmental Effects .............................................................. 23
2.4 Cumulative Effects ........................................................................................... 24
2.5 Structure of the Environmental Statement ........................................................ 25
3.0 NEED AND ALTERNATIVES .......................................................................... 27
3.1 The Need for the Scheme ................................................................................ 27
3.2 Alternatives Considered ................................................................................... 31
4.0 SCHEME DESCRIPTION ................................................................................ 43
4.1 Introduction and Scheme Overview ................................................................. 43
4.2 Permanent Development ................................................................................. 45
4.3 Proposed Site Operations ................................................................................ 60
4.4 Energy Recovery ............................................................................................. 72
4.5 Operational Environmental Management ......................................................... 77
4.6 Proposed Contingency Plans ........................................................................... 81
4.7 Waste Inputs .................................................................................................... 81
4.8 Energy (Heat and Power) Connectivity ............................................................ 84
4.9 Construction Methods ...................................................................................... 85
5.0 PLANNING POLICY CONTEXT ...................................................................... 94
5.1 Introduction ...................................................................................................... 94
5.2 Policy Context .................................................................................................. 94
6.0 TRAFFIC AND TRANSPORTATION ............................................................... 97
6.1 Introduction ...................................................................................................... 97
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6.2 Assessment Modelling ................................................................................... 100
6.3 Baseline Highway Network Conditions ........................................................... 104
6.4 Assessment of RERC Operational Traffic Issues ........................................... 109
6.5 Assessment of Development Construction Traffic Issues ............................... 116
6.6 Additional Mitigation Measures ...................................................................... 120
6.7 Impact Summary ............................................................................................ 121
7.0 LANDSCAPE AND VISUAL EFFECTS ......................................................... 123
7.1 Introduction .................................................................................................... 123
7.2 Methodology .................................................................................................. 129
7.3 Baseline ......................................................................................................... 131
7.4 Assessment of Effects ................................................................................... 138
7.5 Additional Mitigation ....................................................................................... 156
7.6 Residual Effects ............................................................................................. 156
7.7 Conclusions ................................................................................................... 156
7.8 References .................................................................................................... 157
8.0 ECOLOGY AND NATURE CONSERVATION ............................................... 159
8.1 Introduction .................................................................................................... 159
8.2 Methodology .................................................................................................. 166
8.3 Baseline ......................................................................................................... 171
8.4 Assessment of Effects ................................................................................... 187
8.5 Mitigation and Enhancement Measures ......................................................... 199
8.6 Residual Impacts ........................................................................................... 201
8.7 Conclusions ................................................................................................... 202
8.8 References .................................................................................................... 203
9.0 GEOLOGY AND GROUND CONDITIONS .................................................... 204
9.1 Introduction .................................................................................................... 204
9.2 Methodology .................................................................................................. 206
9.3 Baseline ......................................................................................................... 210
9.4 Assessment of Effects ................................................................................... 220
9.5 Additional Mitigation ....................................................................................... 234
9.6 Residual Effects and Conclusions .................................................................. 242
9.7 Conclusions ................................................................................................... 243
9.8 References .................................................................................................... 246
10.0 SURFACE WATERS AND FLOOD RISK ...................................................... 247
10.1 Introduction .................................................................................................... 247
10.2 Methodology .................................................................................................. 247
10.3 Baseline ......................................................................................................... 250
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10.4 Assessment of Effects ................................................................................... 251
10.5 Residual Effects and Conclusions .................................................................. 255
10.6 Conclusions ................................................................................................... 256
11.0 NOISE AND VIBRATION .............................................................................. 258
11.1 Introduction .................................................................................................... 258
11.2 Legislation, Policy and Guidance ................................................................... 261
11.3 Assessment Methodology .............................................................................. 270
11.4 Baseline ......................................................................................................... 282
11.5 Assessment of Effects ................................................................................... 289
11.6 Additional Mitigation ....................................................................................... 302
11.7 Residual Effects ............................................................................................. 303
11.8 Summary and Conclusions ............................................................................ 305
11.9 References .................................................................................................... 309
12.0 AIR QUALITY ................................................................................................ 311
12.1 Introduction .................................................................................................... 311
12.2 Methodology .................................................................................................. 318
12.3 Baseline ......................................................................................................... 327
12.4 Assessment of Effects ................................................................................... 330
12.5 Additional Mitigation ....................................................................................... 339
12.6 Residual Effects ............................................................................................. 340
12.7 Conclusions ................................................................................................... 340
12.8 References .................................................................................................... 341
13.0 ARCHAEOLOGY AND CULTURAL HERITAGE ........................................... 343
13.1 Introduction .................................................................................................... 343
13.2 Methodology .................................................................................................. 347
13.3 Baseline ......................................................................................................... 357
13.4 Assessment of Effects ................................................................................... 361
13.5 Additional Mitigation ....................................................................................... 396
13.6 Residual Effects and Conclusions .................................................................. 397
13.7 References .................................................................................................... 398
14.0 SOCIO-ECONOMIC EFFECTS ..................................................................... 400
14.1 Introduction .................................................................................................... 400
14.2 Methodology .................................................................................................. 401
14.3 Baseline ......................................................................................................... 405
14.4 Assessment of Effects ................................................................................... 413
14.5 Additional Mitigation ....................................................................................... 423
14.6 Residual Effects and Conclusions .................................................................. 424
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14.7 Conclusions ................................................................................................... 427
15.0 CUMULATIVE EFFECTS .............................................................................. 430
15.1 Introduction .................................................................................................... 430
15.2 Methodology .................................................................................................. 431
15.3 Baseline ......................................................................................................... 434
15.4 Assessment of Effects ................................................................................... 440
15.5 Mitigation Measures ....................................................................................... 443
15.6 Residual Effects and Conclusions .................................................................. 443
15.7 Conclusions ................................................................................................... 443
16.0 ENERGY EXPORT CONNECTIONS ............................................................. 445
16.1 Introduction .................................................................................................... 445
16.2 Description of Development ........................................................................... 447
16.3 Approach to Assessment ............................................................................... 451
16.4 Residual Effects and Conclusion .................................................................... 456
17.0 HUMAN HEALTH .......................................................................................... 457
17.1 Introduction .................................................................................................... 457
17.2 Methodology .................................................................................................. 463
17.3 Baseline ......................................................................................................... 467
17.4 Assessment of Effects ................................................................................... 468
17.5 Additional Mitigation ....................................................................................... 478
17.6 Residual Effects ............................................................................................. 479
17.7 Conclusions ................................................................................................... 479
17.8 References .................................................................................................... 480
18.0 SUMMARY OF EFFECTS ............................................................................. 481
18.1 Introduction .................................................................................................... 481
18.2 Traffic and Transportation .............................................................................. 481
18.3 Landscape and Visual Impact ........................................................................ 483
18.4 Ecology and Nature Conservation .................................................................. 486
18.5 Geology and Hydrogeology ............................................................................ 487
18.6 Surface Waters and Flood Risk ...................................................................... 489
18.7 Noise and Vibration ........................................................................................ 490
18.8 Air Quality and Human Health ........................................................................ 492
18.9 Cultural Heritage ............................................................................................ 493
18.10 Socio-Economic Effects ................................................................................. 494
18.11 Cumulative Effects ......................................................................................... 496
18.12 Energy Export Connection ............................................................................. 496
18.13 Human Health ................................................................................................ 497
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18.14 Summary ....................................................................................................... 498
FIGURES
Figure 1.1 Site Location
Figure 1.2 Approved Shawfair Masterplan
Figure 2.1 Zero Waste Parc Layout (Option A)
Figure 2.2 Baseline Developments
Figure 2.3 Surrounding Development Proposals
Figure 2.4 Overlay of PPiP and Millerhill RERC Development
Figure 4.1 Site Layout
Figure 4.2 Roof Plan
Figure 4.3 Existing Site Sections
Figure 4.4 Proposed Site Sections
Figure 4.5 South Elevation
Figure 4.6 West Elevation
Figure 4.7 North Elevation
Figure 4.8 East Elevation
Figure 4.9 Section C - C
Figure 4.10 Section D - D
Figure 4.11 Visitor Centre and Staff Accommodation Elevations and Plans
Figure 4.12 Gatehouse Elevations and Plans
Figure 4.13 Crew Welfare Elevations and Plans
Figure 4.14 Bale Storage Elevations
Figure 4.15 Cycle Store, Bin Store and Smoking Shelter Elevations and Plans
Figure 4.16 Fencing and Gating Plan
Figure 4.17 Schematic Flow Diagram
Figure 7.1aL Landscape Character and Designations (5km radius)
Figure 7.1b Landscape Character and Designations (2.5km radius)
Figure 7.2 Zone of Theoretical Visibility
Figure 7.3a Viewpoint Sheet 1
Figure 7.3b Viewpoint Sheet 2
Figure 7.3c Viewpoint Sheet 3
Figure 7.3d Viewpoint Sheet 4
Figure 7.3e Viewpoint Sheet 5
Figure 7.3f Viewpoint Sheet 6
Figure 7.3g Viewpoint Sheet 7
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Figure 7.3h Viewpoint Sheet 8
Figure 7.3i Viewpoint Sheet 9
Figure 7.3j Viewpoint Sheet 10
Figure 7.3k Viewpoint Sheet 11
Figure 7.3l Viewpoint Sheet 12
Figure 7.3m Viewpoint Sheet 13
Figure 7.4 Indicative Landscape Masterplan
Figure 8.1 Statutory Designated Sites and Ancient Woodlands
Figure 10.1 Schematic Drainage Layout
Figure 11.1 Baseline Noise Monitoring Positions (2014 and 2015 Surveys)
Figure 13.1 Heritage Assets within 2km of Proposed Development
Figure 13.2 Heritage Assets within 5km of Proposed Development
Figure 14.1 Midlothian Wards 1999 to 2007
Figure 14.2 Midlothian Wards 2007 onwards
Figure 15.1 5km Area of Search
Figure 16.1 Heat Connection Route
Figure 16.2 Electricity Connection Route
TECHNICAL APPENDICES (BOUND SEPARATELY AS VOLUME 2)
Appendix 1-1 Planning Permission in Principle (reference: 11/00174/PPP)
Appendix 2-1 EIA Scoping Report
Appendix 2-2 Historic Scotland Consultation Response
Appendix 2-3 Minutes of Meetings
Appendix 6-1 Transport Assessment
Appendix 7-1 Landscape and Visual Impact Assessment Methodology
Appendix 7-2 Viewpoint Selection
Appendix 7-3 Effects on Landscape Character
Appendix 7-4 Effects on Viewpoints
Appendix 8-1 Extended Phase 1 Habitat Survey
Appendix 10-1 Greenfield Run-off Information
Appendix 10-2 Surface Water Attenuation Calculations
Appendix 11-1 Basic Acoustic Terminology
Appendix 11-2 Noise Survey Details
Appendix 11-3 Background Noise Survey Results
Appendix 11-4 Construction Plant Inventory
Appendix 11-5 Assumed Noise Levels for Site
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Appendix 11-6 Noise Mapping
Appendix 11-7 Vibration Terminology
Appendix 11-8 Vibration Monitoring Details
Appendix 12-1 Air Quality Assessment
Appendix 13-1 Site Gazetteer
Appendix 13-2 Guide for Contextualised Aesthetic Appreciation of Monuments
Appendix 13-3 Cultural Heritage Plates
Appendix 14-1 Socio-Economic GVA Estimates
Appendix 15-1 Local Authority Baseline Data
Appendix 17-1 Human Health Risk Assessment
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FOREWORD
This Environmental Statement (ES) supports and accompanies the planning application
for the construction and operation of the Millerhill Recycling and Energy Recovery
Centre; an integrated waste recovery facility, located on land at the former Millerhill
Marshalling Yards, Whitehill Road, Millerhill, Dalkeith. The ES comprises the following
documents.
The Environmental Statement (ES) Main Report (Volume 1), which contains the
detailed project description; an evaluation of the current environment in the area
of the proposed development; the predicted environmental impacts of the
scheme; and details of the proposed mitigation measures which would alleviate,
compensate for, or remove those impacts identified in the study. Volume 1 also
includes a summary of the overall environmental impacts of the proposed
development and all relevant schematics, diagrams and illustrative figures;
Technical Appendices (Volume 2), which include details of the methodology and
information used in the assessment, detailed technical schedules and, where
appropriate, raw data; and
Non-Technical Summary (Volume 3), containing a brief description of the
proposed development and a summary of the ES, expressed in non-technical
language.
Copies of the documents, as a three volume set, are available at a cost of £250 from
FCC Environment’s planning agent by writing to the following address: AXIS, Camellia
House, 76 Water Lane, Wilmslow, Cheshire, SK9 5BB. Cheques should be made
payable to AXIS P.E.D. Ltd. Alternatively, the Non-Technical Summary can be
purchased on its own from the same point of contact for £20. An electronic copy of the
Non-Technical Summary is also available free of charge via email:
[email protected] In addition, all of the planning application
documentation, including the ES can be downloaded from:
http://www.fccenvironment.co.uk/edinburgh-mid-lothian-efw.html
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 ix
LIST OF ACRONYMS
ACC Air Cooled Condensers AD Anaerobic Digestion ADD Average Daily Dose AGLV Area of Great Landscape Value AOD Above Ordinance Datum APC Air Pollution Control APIS Air Pollution Information Service AQ Air Quality AQA Air Quality Assessment AQDD Air Quality Daughter Document AQMA Air Quality Management Area As Arsenic BAT Best Available Technique BCT Bat Conservation Trust Bgl Below Ground Level BOCC Birds of Conservation Concern BTO British Trust for Ornithologists CAA Civil Aviation Authority CAR Control of Asbestos Regulations CCTV Close Circuit Television Camera Cd Cadmium CEMP Construction Environment Management Plan CERE Cambridge Environmental Research Consultants CHP Combined Heat and Power C&I Commercial and Industrial Waste CIBSE Chartered Institution of Building Services Engineers CIEEM Chartered Institute of Ecology and Environmental Management CIfA Chartered Institute of Archaeologists CL Critical Loads CLO Compost like Product CMLI Chartered Member of the Landscape Institute Co Cobalt CO Carbon Monoxide CO2 Carbon Dioxide COPCs Compounds of Potential Concern COT Committee of Toxicity Cr Chromium Cu Copper DEFRA Department for Food and Rural Affairs DNO District Network Operator DTM Digital Terrain Model EA Environment Agency EAL Environmental Assessment Level EC European Commission ECC Edinburgh City Council EcIA Ecological Impact Assessment EfW Energy from Waste ELC European Landscape Convention ELSP Edinburgh and Lothian’s Structure Plan ELVs Emission Limit Values EMP Environmental Management Plan EMS Environmental Management System
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EPAQs Expert Panel on Air Quality Standards EPS European Protect Species EQS Environmental Quality Standards ERC Energy Recovery Centre ERF Energy Recovery Facility ES Environmental Statement EU European Union EUNIS European Nature Information System FCS Forestry Commission Scotland FGT Flue Gas Treatment GLC Ground Level Concentrations GSDA Gary Stewart Design Associates HCI Hydrogen Chloride HF Hydrogen Fluoride Hg Mercury HGV Heavy Goods Vehicle HHRA Human Health Risk Assessment HHRAP Human Health Risk Assessment Protocol HMIP Her Majesty’s Inspectorate of Pollution HPR Heat Plan Report HQ Hazard Quotient hr Hour HS Historic Scotland HSE Health and Safety Executive IED Industrial Emissions Directive IGCB Interdepartmental Croup of Costs and Benefits IGDL Inventory of Historic Gardens and Designated Landscapes ILE Institute of Lighting Engineers IMS Integrated Management System Km Kilometre Kv Kilo voltage LBAP Local Biodiversity Action Plan LBS Local Biodiversity Site LCA Landscape Character Assessment LCL Local Critical Load LEMP Landscape Environmental Management Plan LVIA Landscape and Visual Assessment MAFF Ministry of Forest and Fisheries MBAP Midlothian Biodiversity Action Plan MBT Mechanical Biological Treatment MDR Metal Deposition Rates MLC Midlothian Council Mn Manganese MSW Municipal Solid Waste MT Mechanical Treatment MW Mega Watt MWe Mega Watt electrical MWh Mega Watt hour NH3 Ammonia Ni Nickel NMRS National Monuments Record for Scotland NOx, Nitrogen Oxides NO2 Nitrogen Dioxide NPF National Planning Framework NTS Non-Technical Summary
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 xi
NVC National Vegetation Classification PAD Planning Application Document PAH Polyaromatic Hydrocarbons PAN Planning Advice Note PAS Publically Available Specification Pb Lead PC Process Contribution PPC Pollution Prevention Control PCBs Polychlorinated Biphenyls PEC Predicated Environmental Concentration Pm Particulate Matter PPiP Planning Permission in Principle RDF Refused Derived Product RHI Renewable Heat Incentive RIGs Regional Geological Site SAC Special Area of Conservation Sb Antimony SBL Scottish Biodiversity List SEI Supplementary Environmental Information SEPA Scottish Environmental Protection Agency SESplan South East Scotland Plan SHEP Scottish Historic Environment Policy SLA Special Landscape Area SM Scheduled Monument SNCD Shawfair New Community Development SNCR Selected Non-Catalytic Reduction SNIFFER Scotland and Northern Ireland Forum for Environmental Research SNH Scottish Natural Heritage SO2 Sulphur Dioxide SPA Special Protection Area SPP Scottish Planning Policy SRF Solid Recovered Fuel SSSI Site of Special Scientific Interest TA Transport Assessment TDI Tolerable Daily Intake TEQ Toxicity Equivalent TI Thallium TOC Total Organic Carbon tpa Tonnes Per Annum TWIC The Wildlife Information Centre USEPA United States Environmental Protection Agency UK United Kingdom UWS Urban Wildlife Site V Vanadium VOCs Gaseous and Vaporous Organic Substances WFD Waste Framework Directive WHO World Health Organisation WPA Waste Planning Authority ZTV Zone of Theoretical Visibility ZWF Zero Waste Facility ZWP Zero Waste Plan
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1.0 INTRODUCTION
1.1 Introduction
1.1.1 This Environmental Statement (ES) has been submitted in support of the
planning application for the construction and operation of the Millerhill
Recycling and Energy Recovery Centre (hereafter referred to as the Millerhill
RERC or Proposed Development); an integrated waste recovery facility,
located on land at the former Millerhill Marshalling Yards, Whitehill Road,
Millerhill, Dalkeith.
1.1.2 The ES describes the proposal and provides an assessment of the likely
significant environmental effects that may arise from the construction and
operation of the Proposed Development.
1.1.3 This introductory chapter describes the background to the Proposed
Development, provides an outline description of the proposal, a description of
the development site and its surrounding context, details of the applicant and
defines the structure of the ES.
1.2 The Proposal
1.2.1 The Proposed Development would comprise four principal elements, all of
which would be contained within a main building, they are:
A waste reception hall;
Primary Treatment: a Mechanical Treatment (MT) process to recover
recyclables, remove reject material and produce a Solid Recovered Fuel
(SRF);
Secondary Treatment: a Energy from Waste (EfW) process (Energy
Recovery Centre – ERC) to recover energy and heat from the SRF. The
SRF would either be sourced from the on-site MT facility or other
suitably licensed pre-treatment or recycling facilities; and
Management of products and outputs from the primary and secondary
treatment processes.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 2
1.2.2 The Proposed Development would receive up to 195,000 tonnes per annum
(tpa) of residual waste. The waste material that would be processed at the
facility would comprise non-hazardous municipal solid waste (MSW) and
similar commercial and industrial (C&I) wastes sourced primarily from within
Edinburgh, Midlothian and adjoining administrative areas.
1.2.3 Of the 195,00tpa of residual waste material received at the facility 135,000tpa
would be waste received through the Edinburgh and Midlothian residual waste
contract (contract waste), with the remaining 60,000tpa comprising SRF
received from either commercial and industrial sources or municipal sources
from neighbouring local authority areas.
1.2.4 The 135,000tpa of contract waste received at the site would be transferred to
the MT process which would recover ferrous and non-ferrous metals (circa
2,740tpa) and other ‘reject’ materials that are unsuitable for thermal treatment
(circa 2,798tpa). The remaining material would comprise an SRF which would
be directed, by conveyor, to the ERC for thermal treatment. The circa
60,000tpa of non-contract SRF received from third parties or other local
authorities would be transferred directly to the ERC for thermal treatment, it
would not need to be the subject of MT, having already undergone such a
process in advance of being delivered to the site.
1.2.5 The Proposed Development would be a combined heat and power (CHP)
station. Through the combustion of SRF it would generate heat energy in the
form of steam. A proportion of this steam would be used to generate electricity
with the balance exported as heat in the form or either steam or, more likely,
hot water. The maximum electricity generation capacity would be 13.45MW of
electricity (MWe). A small portion (circa 2.36MWe) of this would be used to
power the RERC itself, with the majority circa 11.09MWe exported to the local
electricity grid. Based upon maximum electricity output, the Proposed
Development would export circa 87,012MWe hours per annum. This is
sufficient to meet the domestic electricity needs of over 26,000 homes.
1.2.6 Heat generated by the Proposed Development would be exported by
underground insulated pipes direct to local users which could include nearby
institutional, commercial and residential developments.
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1.2.7 Several existing sites offer clear potential to form part of a district heating
network including the Royal Infirmary of Edinburgh, the new Anaerobic
Digestion (AD) Facility to the north and Queen Margaret University. In
addition, there is a number of other developments (existing, proposed or
under construction) in the surrounding area and of these, the Shawfair New
Community Development (SNCD) (comprising over 3,500 new houses, shops,
leisure, community and commercial outlets) offers considerable potential. FCC
Environment has consulted the Shawfair developers regarding the proposed
development and they have expressed a strong interest in the use of heat
generated by the Proposed Development. Further details are provided the
Heat and Power Plan contained within Part 6 of the Planning Application
Document (PAD) and within Chapter 16.0 of this ES.
1.2.8 The biogenic content of waste, circa 50 – 55% of the total waste, is
recognised as a renewable source of energy. Thus, around 50 - 55% of the
energy, whether it is heat or electricity, produced by the Proposed
Development would be classed as renewable energy.
1.2.9 The Proposed Development would be based around a main building which
would contain both the waste reception area and the primary and secondary
treatment process, described above, together with the following elements:
A building containing administration offices, staff welfare and visitor
facilities;
A baled waste storage hall (for the storage of baled waste during
planned mechanical shut down);
Air cooled condensers; and
A 75m high emissions stack (which would be integrated within the main
building).
1.2.10 It would also include a range of ancillary infrastructure including:
A weighbridge office and weighbridges;
Transformer and Emergency Generator buildings;
Ammonia Store;
Rain Water Harvesting / Fire Water Tanks and Pump House;
Vehicle Crew Building and WC;
Vehicle access and internal site circulation roads;
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 4
Car parking and cycle stores;
Various silos and storage tanks for fire water, consumables and process
residues;
Utilities and services;
Lighting and CCTV;
SUDS Drainage Balancing Pond; and
Security fencing, gates and landscaping.
1.2.11 The operation of the proposed facility would comply fully with relevant
European Union (EU), Scottish and United Kingdom (UK) Government
legislation.
1.2.12 On the basis that the planning application is approved in mid-2015, the
planned opening date for the Proposed Development is early 2018. It would
have a design life of approximately 25 years although, in reality, many
elements of the plant would last beyond this period. For the avoidance of
doubt planning permission is being sought for a permanent development and
therefore as elements of the facility require repair / refurbishment /
replacement this would be carried out.
1.2.13 A more detailed description of the Proposed Development is provided within
Chapter 4.0 of this ES.
1.3 The Site and Its Context
1.3.1 The Application Site is located on part of the former Millerhill Marshalling
Yards, which were developed by British Rail during the 1950s. It is located
circa 6km south east of Edinburgh City Centre and circa 900m to the north of
Millerhill village (see Figure 1.1). It is located entirely in the administrative area
of Midlothian Council, but is also in close proximity to the administrative
boundaries of the City of Edinburgh Council and East Lothian Council.
1.3.2 The application site itself covers an area of circa 5.7 hectares (ha), it is
broadly rectangular in shape and generally flat, lying generally between 42.5m
Above Ordnance Datum (AOD) and 43.5m AOD. It is predominantly covered
by vegetation comprising self-seeded trees (primarily Silver Birch) and shrubs.
Those areas of the site which remain bare comprise packed soil consistent
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 5
with its historic use as a marshalling yard and railway sidings. It is understood
that the site has not been subject to remediation work which reflects its
disused and partly-derelict state. The site is not the subject of any specific
ecological or other environmental designations. However, it has been
classified as a Native Woodland in the Forestry Commission Scotland’s Native
Woodlands Scotland Survey 2013.
1.3.3 In terms of its immediate context, the site is located to the west of the live
railway lines, train maintenance and stabling yard which forms its eastern
boundary. To the west, the site is bounded by derelict land formerly occupied
by Monktonhall Colliery. To the south is more land associated with the former
Millerhill Marshalling Yard and rail sidings which also comprises a continuation
of the low‐level tree vegetation which subsists within the site itself. To the
immediate north is the site of Alauna Renewable Energy’s AD facility, which is
in the process of being constructed, together with an access road and bridge.
1.3.4 To the immediate west of the site is the land associated with the former
Monktonhall Colliery, which has for some time been earmarked as the location
for the development of a new community, known as Shawfair. The
development is proposed to comprise over 3,500 homes with associated
infrastructure, some industrial / commercial, community (new school and
leisure centre) and amenity uses. The SNCD is a ‘committed development’
within the 2008 adopted Midlothian Local Plan and in August 2014 Midlothian
Council formally granted PPiP for the development. The approved masterplan
for the Shawfair development is shown on Figure 1.2.
1.3.5 In addition to the Shawfair development, and also to the immediate west of the
site, is a section of the new Borders Railway line (former Waverley line), it
intersects with the Zero Waste site north of the AD Facility and then passes in
a north – south direction through the site of the SNCD, within which a new
station has already been constructed. The new Borders Railway will re-
establish passenger railway services between Edinburgh and Tweedbank and
is due to be completed in the autumn of 2015. The route of the new railway
line and the location of the new station are also illustrated on Figure 1.2.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 6
1.3.6 In terms of the wider context:
To the east of the site, beyond the train maintenance, cleaning and
stabling depot, is a series of fields which presently appear to be within
an agricultural use. The fields are allocated for industrial and residential
development in the emerging East Midlothian Local Plan. Further to the
east (circa 1km from the nearest site boundary) is the minor settlement
of Old Craighall, beyond this is the roundabout junction of the A1 and
A720;
To the south, beyond the site of the former Millerhill marshalling yard
and rail sidings and circa 850m from the site boundary is the settlement
of Millerhill, beyond which (circa 1.7km from the site boundary) is the
A720 City of Edinburgh By-pass and Dalkieth Country Park;
To the west is the site of the former Monktonhall Colliery / Sharwfair new
community development and the route of the new Borders Railway,
which is presently under construction. Beyond these and circa 1.6km
from the nearest site boundary is the settlement of Danderhall; and
To the north of the aforementioned Alauna AD Facility is Whitehill Road,
beyond which is a narrow belt of plantation woodland and the A1 dual-
carriageway. To the immediate north of the A1 and circa 750m from the
nearest site boundary, is the settlement of Newgraighall. The Fort
Kinnard retail park and commercial centre is located Circa 1km to the
north west and the Queen Margaret University campus is circa 750m to
the north east (albeit on the opposite side of the A1).
1.3.7 The Application Site would be accessed using the new access and bridge that
has been constructed to the north. This comprises a new priority junction off
Whitehill Road and a bridge crossing of the new Borders Railway Line.
Whitehill Road connects to Newcraighall Road in the Fort Kinnard commercial
area, circa 1.2km to the northwest. This, in turn, provides a direct connection
to the north and southbound carriageways of the A1.
1.3.8 The nearest existing residential properties to the site are Shawfair Farm and
cottages (circa 350m to the west) and Whitehall Mains Farm (located circa
450m to the north‐west of the site boundary and immediately adjacent to the
site access and AD facility). In addition, the approved masterplan for the
SNCD proposes new residential development immediately adjacent to the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 7
site’s western boundary. For the purposes of preparing the ES, it has been
assumed that the SNCD has been completed and is therefore included in the
baseline for the assessment (although the reality is that the totality of the
scheme will take in excess of 10 years to deliver). As such, the properties that
are proposed to the west would comprise the nearest residential properties to
the Application Site. More detailed discussion regarding the proposed
baseline and the approach to the EIA is provided in Chapter 2.0 of this ES.
1.3.9 It must be noted that this sub-section is only intended to provide an overview
of the Application Site and its context and any specific receptors and other
important considerations are taken into account, where relevant, within the
individual Chapters of this ES.
1.4 Background to the Scheme and Compliance with the extant PPiP
1.4.1 In December 2014 FCC Environmental was awarded appointed ‘Preferred
Bidder’ status on a 25 year residual waste management contract with
Edinburgh City Council (ECC) and Midlothian Council (MLC). The main
element of infrastructure the Company is proposing in order to meet the
contract requirements is the development of the Millerhill RERC on land at the
former Millerhill Marshalling Yards.
1.4.2 The site of the proposed Millerhill RERC already benefits from Planning
Permission in Principle (PPiP) for the development of an integrated waste
recycling and treatment facility which was granted on 19th January 2012
(reference: 11/00174/PPP – Appendix 1-1). The application was submitted by
Zero Waste, which is a joint enterprise between MLC and ECC, to procure
facilities for the treatment of residual waste in response to the Scottish
Government’s aim to make Scotland a zero waste society.
1.4.3 The extant PPiP is for a facility capable of processing 230,000tpar annum of
predominantly, but not exclusively, household residual waste, comprising the
following waste management facilities:
Mechanical Biological Treatment (MBT);
EfW including CHP Plant; and
An AD Facility.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 8
1.4.4 The approved development is collectively referred to as the ‘Zero Waste
Facility’ and the development proposals for the site as a whole the ‘Zero
Waste Parc’.
1.4.5 Following approval of the Zero Waste Facility, MLC subsequently submitted a
detailed planning application (reference: 12/00060/DPP) for the formation of a
road from Whitehill Road and the erection of a road bridge over the Borders
Railway line, with the express purpose of providing access to the Zero Waste
Parc site. This application was approved on 6th March 2012 and the access
road and bridge have subsequently been constructed. The planning consent
for the access road and bridge also partly addressed some of the matters
specified in Condition 5 of the PPiP.
1.4.6 In addition to the above, Alauna Renewable Energy has progressed with the
development of the proposed AD Facility and submitted a planning application
for the Approval of Matters Specified in Conditions (AMSC) in the PPiP on 25th
January 2013. The application for the AMSC was subsequently granted
consent with an additional condition relating to landscaping on 12th June 2013
(reference: 13/00077/MSC). At the time of writing Alauna Renewable Energy
is in the process of constructing the AD Facility.
1.4.7 FCC is proposing the development of the Millerhill RERC on the Zero Waste
Parc to the immediate south of the site of the Alauna AD Facility. The location
of the development and the AD Facility is provided on Figure 2.1.
1.4.8 Whilst the Millerhill RERC development would have a number of important
similarities with the PPIP proposal, including mechanical treatment and energy
recovery by way of a CHP Plant, the technology proposed by FCC differs in
other regards. The main differences arising from the technology change are
the scale of the development, specifically::
The maximum height of the tallest building (the boiler house) would be
41.60m compared to 20m on the facility benefitting from PPiP;
The height of the stack would be 75m which is 10m taller than that
proposed as part of the facility benefitting from PPiP;
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 9
The development footprint would be 5.70ha this is circa 6.87 (circa 55%)
less than the MBT and EfW elements of Option A of the Zero Waste
Facility. An overlay of the two proposals is provided on Figure 2.2;
Tonnage throughput of the facility would be 195,000tpa which in
combination with the AD Facility to the north (30,000tpa) would be
225,000tpa. This would be 5,000tpa less than the facility benefitting from
PPiP, that being for facilities with a combined capacity of 230,000tpa;
This application proposes a combined facility, comprising a MT facility
and ERC using a moving grate technology, rather than the MBT and
EfW using Gasification technology that is proposed in respect of the
facility benefitting from PPiP.
1.4.9 The reasons for the change in technology can be summarised as follows:
Energy recovery from mixed non-hazardous waste is a complex
engineering process requiring substantial financial investment and
expertise. Consequently, technology choice is critical to securing project
funding, securing an award of contract and ultimately delivering a
successful scheme that functions in accordance with the requirements
of the particular project.
Conventional combustion plants, as proposed by FCC, are a fully
proven technology with circa 30 operating plants within the UK and
something in the order of 500 plants across Europe.
Conversely, gasification technology has seldom been used for the
thermal treatment of mixed non-hazardous waste in the UK. At the time
of writing, there are only two commercial scale, fully operating
gasification facilities in the UK, although other proposals are under
construction. There is very limited application of gasification for the
thermal treatment of non-hazardous waste across Europe.
Gasification technologies are theoretically available in a wide range of
scales and sizes, although typically gasification proposals are smaller
than combustion plants and are proposed in the 35,000tpa to
135,000tpa range.
Whilst there is great variety in the physical scale of gasification plant
technologies (noting that most technologies are only theoretical / non-
proven at a commercial scale anyway), as a general rule, and based on
like for like capacity, a gasification plant will have a larger footprint, but
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 10
lower maximum height when compared to a combustion plant. However,
the majority (if not all) of the gasification plants that have and are being
developed are relatively tall and well in excess of the 20m that was
consented for the gasification proposals consented under the PPIP for
the Zero Waste facilities.
Most of the gasification facilities that have been built to date have not
operated in a reliable and consistent manner. The only gasification
facility that was fully built out and Permitted in Scotland was the Scotgen
gasification scheme at Dumfries. Despite a number of years of
attempting to operate the plant, this was never successfully achieved in
terms of prolonged operation with energy recovery. The facility
ultimately had its PPC permit withdrawn and the operating company
went into liquidation.
At this point in time, Viridor is in the process of building a gasification
plant in Scotland at Polmadie in Glasgow. This is using a proven
Energos technology which operates in a very similar manner to
conventional combustion and only has a capacity of 130,000tpa.
Based on the foregoing, and in order to provide Edinburgh and
Midlothian with a proven, robust long term waste management solution,
FCC has elected to use a conventional grate combustion technology for
the Zero Waste contract. FCC believes that this is the optimum technical
solution for the waste tonnages that are proposed to be treated. This
proposal has been accepted by the authorities following extensive
evaluation and appropriate due diligence checks. The authorities’
decision to choose such a technology is entirely consistent with that
made by the majority of other UK authorities who have commissioned a
residual waste thermal treatment facility. It is also notable that the
second place bidder for the Edinburgh and Midlothian residual waste
contract was also proposing an identical grate thermal treatment
technology.
1.4.10 Having selected conventional combustion technology as the only proven form
of thermal treatment, at the scale proposed and for the treatment of mixed
non-hazardous waste, it is important to understand why the RERC boiler
house is as high as it is i.e. 41.6m.
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1.4.11 In order to meet Part 4 of the Industrial Emissions Directive (formerly the
Waste Incineration Directive) it is a mandatory requirement that non-
hazardous waste material (the combustion gas) is fully combusted within the
boiler at a temperature of 8500C for a duration of two seconds. As the
combustion gases rise during the combustion process, to ensure the two
second residency time, the boiler needs to be a defined height. The boiler
itself then needs to be housed with sufficient maintenance space to allow
access to the top of the boiler, where, amongst other things, the superheater
bundles are located. These require regular access. In combination, these
factors determine the overall boiler house height.
1.4.12 As a 190,000tpa thermal treatment plant with a single stream (or processing
line), the ERC component of the RERC is typical in height when compared to
other similar facilities. In fact it is slightly lower than most, with, for example,
FCC’s recently completed North Hykeham EfW facility (Lincolnshire) having a
throughput capacity of 150,000tpa and a maximum height of 47m and Viridor’s
Dunbar proposal having a process line capacity of 150,000tpa (noting it has
two lines at this capacity) and also having a maximum height of 47m.
1.4.13 Accordingly, FCC believes it is demonstrably the case that the technology
proposed for the RERC is the most proven, robust and reliable technology for
the waste types that would be treated and the throughput capacity proposed.
Furthermore, that the height and scale of the building, particularly the boiler
house, is essential for this type of technology and is no taller than needs to be
the case from an operational perspective.
1.4.14 Following consultation with MLC, FCC has concluded that the RERC, whilst
conforming to the approved description of the development and the use of
land, would fall outside the ambit of what was approved for the Zero Waste
Facility. Consequently, it has been agreed that FCC submit a new detailed
planning application for the Proposed Development, rather than pursuing the
development through an application for the AMSC.
1.4.15 Notwithstanding, the planning permission for the Zero Waste Facility remains
extant and establishes the general acceptability of this site for a development
of the type proposed. It is therefore a material consideration in the
determination of the planning application and an important consideration when
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 12
assessing the environmental effects of the proposed development. Further
discussion on this is provided within Chapter 2.0 below.
1.5 The Applicant
1.5.1 The applicant FCC Environment (FCC) is one of the largest waste
management companies within the United Kingdom and provides treatment,
recycling, energy recovery and waste disposal services to a wide range of
local authorities and private commercial customers.
1.5.2 FCC Environment operates facilities for the reception, recycling and disposal
of waste, including a network of waste transfer and recycling centres, energy
recovery facilities and strategically-situated landfill sites. It is also one of the
largest operators of civic amenity sites on behalf of local authorities for use by
the general public.
1.5.3 In December 2014 FCC was appointed Preferred Bidder by Zero Waste:
Edinburgh and Midlothian to design, build, finance, and operate a new
recycling and energy recovery facility (the Millerhill RERC). The award of the
contract by the joint authorities is part of their continued commitment to
increasing recycling and reducing the amount of waste set to landfill in their
administrative areas.
1.5.4 Further information on FCC Environment can be found on their website at
www.fccenvironment.co.uk.
1.6 This Document
1.6.1 This document is the ES, which has been prepared to accompany the
planning application. It describes the potential environmental effects of the
proposed development, both during its construction and operation. It has been
prepared in accordance with European Community (EC) Directives on the
assessment of the effects of certain projects upon the environment
(85/337/EEC updated by 97/11/EEC). This legislation is now manifest in
Scotland through the Town and Country Planning (Environmental Impact
Assessment) (Scotland) Regulations 2011, with which this report is fully
compliant.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 13
1.6.2 Following on from this introduction the remainder of the ES is structured as
follows:
Chapter 2.0 of the ES outlines the approach to the assessment
describing the scope and structure of the ES;
Chapter 3.0 summarises the need for the proposed Millerhill RERC
development and the alternatives considered;
Chapter 4.0 provides a detailed scheme description and provides an
outline of the construction methods;
Chapter 5.0 provides an outline description of the planning policy
context relevant to the determination of the planning application.
Chapters 6.0 to 15.0 and 17.0 assess the potential environmental
impacts of the proposal during its construction and operation, including
proposed mitigation measures;
Chapter 16.0 provides an assessment of the impacts of potential options
to connect the proposed Millerhill RERC development to the local
electricity grid network, which is a discrete element of the scheme and
does not form part of the planning application which this ES supports;
and
Chapter 18.0 summarises the assessment findings.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 14
2.0 SCOPE OF THE ENVIRONMENTAL ASSESSMENT
2.1 Scope
2.1.1 EIA is the process culminating in the production of this report, the ES. The
objective of the process is to identify and evaluate all significant, direct and
indirect environmental effects of the proposed development, during both
construction and operation, on the environment.
2.1.2 In the context of the Town and Country Planning (Environmental Impact
Assessment) (Scotland) Regulations 2011 (EIA Regulations) the proposed
development constitutes development requiring an EIA, being classified under
Schedule 1: “(10) Waste disposal installations for the incineration or chemical
treatment (as defined in Annex I to Directive 2008/98/EC under heading D9) of
non-hazardous waste with a capacity exceeding 100 tonnes per day.”
2.1.3 As such, the proposed development is deemed to be a Schedule 1
development and therefore an EIA is mandatory for this project.
2.1.4 The scope, or requirements, of an ES are set out in Schedule 4 of the EIA
Regulations. Part 1 of the Schedule details the information that the applicant is
reasonably required to provide, whilst Part 2 identifies the information that the
applicant must provide, these are set out below. References to Chapters in
the ES where information relevant to these requirements can be found are
also listed below.
PART I
1. Description of the development, including in particular:
a) A description of the physical characteristics of the
whole development and the land-use requirements
during the construction and operational phases;
Chapter 4
b) A description of the main characteristics of the
production processes, for instance, nature and
quantity of the materials used;
Chapter 4
c) An estimate, by type and quantity, of expected
residues and emissions (water, air and soil pollution,
Chapters
4, 10, 11,
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 15
noise, vibration, light, heat, radiation, etc.) resulting
from the operation of the proposed development.
12 and 17
2. An outline of the main alternatives studied by the
applicant or appellant and an indication of the main
reasons for his choice, taking into account the
environmental effects.
Chapter 4
3. A description of the aspects of the environment likely to
be significantly affected by the development, including,
in particular, population, fauna, flora, soil, water, air,
climatic factors, material assets, including the
architectural and archaeological heritage, landscape and
the inter-relationship between the above factors.
Chapters 6
to 17
4. A description of the likely significant effects of the
development on the environment, which should cover
the direct effects and any indirect, secondary,
cumulative, short, medium and long-term, permanent
and temporary, positive and negative effects of the
development, resulting from:
Chapters 6
to 17
(a) The existence of the development;
(b) The use of natural resources;
(c) The emission of pollutants, the creation of
nuisances and the elimination of waste, and the
description by the applicant of the forecasting
methods used to assess the effects on the
environment.
5. A description of the measures envisaged to prevent,
reduce and where possible offset any significant
adverse effects on the environment.
Chapters 6
to 17
6. A non-technical summary of the information provided
under paragraphs 1 to 5 of this Part.
Volume 3
7. An indication of any difficulties (technical deficiencies or
lack of know-how) encountered by the applicant in
compiling the required information.
Chapters 6
to 17
PART II
1. A description of the development comprising information Chapter 4
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 16
on the site, design and size of the development.
2. A description of the measures envisaged in order to
avoid, reduce and, if possible, remedy significant
adverse effects.
Chapters 6
to 17
3. The data required to identify and assess the main effects
which the development is likely to have on the
environment.
Chapters 6
to 17
4. An outline of the main alternatives studied by the
applicant or appellant and an indication of the main
reasons for his choice, taking into account the
environmental effects.
Chapter 3
5. A non-technical summary of the information provided
under paragraphs 1 to 4 of this Part.
Volume 3
2.1.5 This ES is fully compliant with these requirements.
Consultation
2.1.6 Under Regulation 14 of the EIA (Scotland) Regulations, potential applicants
may request a Scoping Opinion from the local planning authority, in this case
MLC. This is a written confirmation as to the information that would need to be
provided in the ES. On 23th January 2014 FCC submitted an informal request
for a Scoping Opinion from MLC. The request was made on an informal basis
given FCC’s on-going involvement in the bidding process for the Edinburgh
and Midlothian Residual Waste Contract, and a desire for the consultation to
be carried out a commercially confidential basis. The request was
accompanied by an Environmental Scoping Report which provided
confirmation of the issues that FCC considered would need to be covered in
the ES. The Scoping Report submitted to MLC is contained within Appendix 2-
1.
2.1.7 Following the aforementioned screening request, MLC failed to adopt an
informal Scoping Opinion and only one response was received from technical
consultees and specifically Historic Scotland. A copy of their consultation
response is provided within Appendix 2-2 and a summary is provided in Table
2.1 over the page.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 17
Table 2.1: Summary of Scoping Consultations
Consultee Key Comments
Historic Scotland
Confirmed that they were content with the principle of the proposed development. They confirmed that there are no assets in their remit within the development site and that it is unlikely (based upon the information contained within the informal Scoping Report) that the development would result in significant adverse impact on the setting of other assets within their remit.
2.1.8 Notwithstanding the lack of formal responses from MLC and other technical
consultees to the informal Scoping Request, the extent of potential
environmental matters to be included within the ES is already well understood
by the project team, by virtue of the information that was required in connection
with the PPiP application prepared for the Zero Waste Facility development.
This existing knowledge has been supplemented by extensive scoping with a
variety of technical officers from MLC and other regulatory consultees,
including the Scottish Environmental Protection Agency (SEPA), Scottish
Natural Heritage (SNH), Transport Scotland and Architecture + Design
Scotland (A+DS). This has included several meetings with MLC and other
regulatory consultees that were held on 29th January 2014, 27th February 2014
and the 28th October 2014. Minutes from these meetings are provided in
Appendix 2-3.
2.1.9 There have also been a number of subsequent consultations with the Planning
Officer at MLC which were held on the 8th January 2015, 6th February 2015 and
6th March 2015 to discuss various aspects of the Proposed Development.
2.1.10 The aforementioned process, along with experience from similar projects, has
informed the scope of the subjects to be addressed within the EIA and the
methods and assumptions used to undertake assessments. A summary of the
consultations held is provided within Table 2.2 over the page.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 18
Table 2.2: Summary of Key Scoping Consultations
Consultee Key Comments
MLC Highways Initial e-mail contact was made with the highways officer on the 30th
October 2014 and a subsequent telephone discussion immediately thereafter. During these discussions the Officer specifically suggested that, based on the results of the comparative development trip generation exercise, there would be no requirement for any updated baseline traffic surveys to be undertaken; no off-site network safety or capacity assessment would be required; and that there is no requirement for detailed environmental assessment.
The highways officer was provided with a TA scoping note on 19th
November 2014 and the officer confirmed that he was satisfied with the proposed scope of work.
Following this initial agreement the proposed throughput of the facility was changed from 170,000tpa to 195,000tpa and an updated TA scoping note was issued to reflect this. The Officer had no further comments on this and the Transportation Assessment and the ES chapter have been prepared in line with the updated scoping note.
Transport Scotland Transport Scotland (via their agents JMP) was provided with a copy of the updated TA scoping note (195,000tpa) on the 10
th February 2015,
following initial telephone discussions.
They confirmed in an e-mail of the 26th February 2015 that: “We agree
with the conclusions of your scoping note that these new proposals should not have any greater impact on the trunk road network compared to the previous consented proposals (ref: 11/00174/PPP), and as such, your proposal for a simple Transport Statement would be sufficient from Transport Scotland’s perspective.”
MLC, East Midlothian Council and ECC
Landscape Officers
Given the Millerhill RERC site is located close to the administrative boundaries of MLC, East Midlothian Council and ECC, it has been necessary to consult with the landscape officers at each of the authorities to agree viewpoint locations for the Visual assessment.
All of the Officers were e-mailed a plan on the 3rd
December 2014 which suggested viewpoint locations. All of the officers responded and each suggested alternative or additional view that should be considered. Following this a revised viewpoint plan was issued to the landscape officer at MLC (the determining authority) for formal agreement. It was also submitted to officers at the other authorities for information.
The updated viewpoint plan was subsequently agreed by all parties and it is those viewpoints which have formed the basis for assessment in this ES.
The Scottish Environmental
Protection Agency (SEPA)
The SEPA was consulted with regard to all aspects of the air quality modelling study. This includes the stack height assessment, receptor locations, modelling inputs and sensitive habitats.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 19
Consultee Key Comments
MLC EHO – Noise
Following consultation with the EHO at MLC and their appointed noise consultant, the areas surrounding the site were examined and the following suitable locations for noise monitoring
The Local Authority advised that the noise assessment should be designed to achieve a design criteria similar to that imposed on the AD Facility being developed north of the Application Site. The condition relates to the following limits:
Daytime: Fixed and mobile plant (including site vehicles): 0800-2100 hours 40dB LAeq1hr (free field).
Evening: Fixed plant: 2100-2300 hours 39dB LAeq1hr (free field)
Night-time: Fixed plant: 2300-0800 hours 39dB LAeq5mins (free field) and internal level with windows open of NR25.
All reversing alarms to be of the broadband type (restricted between 0800-2000 hours).
Construction noise (all site operations): 70dB LAeq12hr (1m façade) `best practicable means’ applied at all times in accordance with BS5228 guidance.
Construction (piling): 75dB LAeq1hr (1m façade), 80dB LA01(1hr) `best practicable means’ applied at all times in accordance with BS5228 guidance.
Construction (Community Relations): A community liaison representative will be appointed to: ensure (a) availability of information and (b) complaints are dealt with expeditiously.
Architecture and Design Scotland and
Scottish Natural Heritage (SNH)
Two workshops have been held with A+DS / SNH which have informed the design and layout of the proposed development. Further details of the specific discussions held are contained within the Design and Access Statement Contained within Part 2 of the Planning Application Document.
MLC / The Wildlife Information Centre
(TWIC)
Were consulted regarding the need to carry out further reptile surveys art the site. TWIC, on behalf of MLC, confirmed that further reptile surveys were not necessary to inform the Millerhill RERC application.
MLC, Edinburgh Council and East Lothian Council
Provided information on developments that should be considered in the assessment of cumulative effects.
2.1.11 All of the aforementioned points raised during the EIA Scoping and
subsequent scoping carried out on individual topic areas have been taken into
consideration in the EIA and the preparation of this ES.
2.1.12 The information and knowledge required to produce this ES was acquired
from a number of varied sources to ensure that all impacts, whether explicit
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 20
from the outset, or coming to light during the projects development, were
assessed. These sources included:
a) Discussions with technical consultees;
b) Review of public files and records;
c) Review of historical mapping and aerial photography;
d) Site surveys undertaken by the applicant;
e) Specialist studies, such as computer modelling of potential noise
impacts; and
f) Expert knowledge from the consultancy team.
2.2 Baseline for the Environmental Impact Assessment
2.2.1 As discussed within Chapter 1.0 the Application Site benefits from PPiP for a
large scale waste treatment facility (the Zero Waste Facility) and numerous
developments are either in the process of coming forward, or are about to be
developed in the surrounding area. The most significant of which are the new
Borders Railway, Alauna Renewable Energy’s AD Facility (both of which are
presently under construction) and the SNCD, which has recently obtained
PPiP and is actively being cleared and promoted for new development. The
Shawfair development is very large and complex and there is considerable
uncertainty as to which elements of the scheme will come forward and when.
2.2.2 Given the planning status of the development site and the presence of the
existing and proposed developments, it has been necessary to give careful
consideration to the baseline for the preparation of the EIA. This matter was
discussed in a pre-application meeting with MLC on the 28th October 2014
and the following approach has been agreed.
The Baseline for the Application Site
2.2.3 The EIA for the Millerhill RERC has been undertaken with reference to the
current baseline conditions at the Application Site (i.e. an undeveloped
brownfield site). However, as the site also benefits from an extant PPiP for a
similar type of development (a combined AD, MBT and EfW Facility) (see
Figure 2.4 for an overlay of the PPiP and Proposed Development), in
considering factors that mitigate the effects of the proposed Millerhill RERC
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 21
developed or, to be more precise, the ‘likely future baseline’ / ‘do nothing’
position at the site, reference will be made to the PPiP development.
2.2.4 Whilst the proposed development must be considered in relation to its impact
on existing environmental conditions, it is also entirely appropriate to note
within the assessment that a major development has been granted consent at
the site. The approach to this is discussed within Paragraph C8.4 of the
Scottish Natural Heritage (SNH) Handbook on Environmental Impact
Assessment (4th Edition – 2013), it states (our emphasis):
“The significance of the effects of a proposed development should be
considered in the context of changes that will occur regardless of
whether the project goes ahead or not, the ‘do nothing alternative’. The
‘do-nothing’ comparison, or in some cases, such as road improvements, the
‘do-minimum’ comparison, is a projection of the existing data to provide a
baseline for comparison to show how the site would change if the
project did not go ahead. The ‘do nothing’ comparison examines trends
currently occurring at the site, including likely management, land use
changes, effects of climate change (e.g. species migration) or other
interventions, and assesses the significance of these changing
conditions. The ‘do-nothing’ comparison, however, should be used in a
reasonable way. It should genuinely predict likely change, on a realistic
basis, for example by including the effects of projects which already have
consent but are not yet implemented. It should not take the best possible
comparison for the purpose of the Environmental Statement, in order to
try to demonstrate that the project proposed would have less adverse, or even
beneficial, effects over a ‘do nothing’ prediction that is not likely to materialise.
2.2.5 With regard to the SNH guidance:
1. There is a reasonable prospect that in the event the Millerhill RERC
development is not progressed the extant PPiP development could be
developed. Indeed, the AD element of the PPiP scheme is already in the
process of being constructed to the north of the Application Site; and
2. The information contained within the ES prepared in relation to the PPiP
development will provide a reasonable basis for comparison within the
ES for the Millerhill RERC development.
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2.2.6 In light of the foregoing, each Chapter of this ES will assess the potentially
significant environmental effects of the Proposed Development on the existing
site baseline and include a ‘sensitivity test’ which compares the proposed
development against the Zero Waste Facility (i.e. the ‘do nothing’ / ‘future
baseline scenario’).
2.2.7 For example, if the ES prepared in support of the application for the Zero
Waste Facility identifies that the site contains archaeological remains, and
assesses the impact of the development on the remains as being moderate /
major etc. The sensitivity test would note that as the Proposed Development
would have a smaller footprint the Zero Waste Facility development and will
be developed entirely within the proposed built footprint for that development,
the impact on buried archaeology would either be ‘beneficial’ or, at worst,
‘neutral’ when compared against the future baseline.
2.2.8 It must be noted that whilst it is the intention to carry out this ‘sensitivity test’
within the ES, it is not possible to adopt this approach in connection with all of
the ES chapters. The chapters where this approach has not, or cannot be
applied and why, is set out in Table 2.4 below.
Table 2.4: ES Chapters where there is no Comparison with Future Baseline
Scenario
ES Topic Commentary
Traffic and Transportation
In pre-application discussions and during the scoping of the Transport Assessment and ES Chapter, it was agreed that it would only be necessary
Cumulative Effects
Whilst the ES prepared in support of the PPiP application included an assessment of potential cumulative effects, the development proposals considered in the assessment of cumulative effects differ to those which will be the subject of assessment for the Proposed Development. This is on the basis that many of the schemes considered have now either been built (and form part of the baseline) or, in the case of the SNCD, are being considered differently in the assessment of environmental effects. In light of this, there is no reasonable basis for comparison with the PPiP development.
Energy Export Connections
Assessment of the potential environmental effects of the Energy Export Connections was not carried out in the ES prepared in support of the application for PPiP. As a consequence, there is no basis for comparison with the Millerhill RERC development.
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The Baseline Relating to Other Development Proposals
2.2.9 With regard to the existing baseline, it was agreed at the pre-application
meeting with Midlothian Council on the 28th October 2014 that, for the purpose
of the EIA, the following should be assumed:
The AD Facility, site access and bridge over the Borders Railway, which
are being constructed to the north of the site, are finished and
operational;
The Borders Railway, which is being constructed to the north and west
of the site, is completed and operational; and
The SNCD is built in accordance with the approved masterplan.
2.2.10 The reason that this approach has been agreed in relation to the SNCD is that
there is too much uncertainty as to which elements of the scheme will come
forward and when, to accurately consider them in any assessment cumulative
effects. It was agreed that a more appropriate proxy for assessment would be
to assume that SNCD is built in accordance with the site masterplan. Of
particular significance in reaching this decision is the fact that the masterplan
envisages that there will be residential development up to the western
boundary of the Millerhill RERC site, thereby representing a worst case
scenario for the assessment of environmental effects upon sensitive
residential receptors.
2.2.11 In order to carry out the assessment on this basis, where necessary,
reference has been made to the environmental assessments submitted in
relation to the aforementioned schemes, along with other published
information (i.e. the timetable for the operation of the railway).
2.3 Assessment of Environmental Effects
2.3.1 The approach to environmental impact assessment is not standardised but
there are established and recognised approaches set out by professional
institutions regarding the methods that are to be used in the assessment of
environmental effects. Where appropriate the environmental effects of the
proposed development have been assessed quantitatively using definitive
standards, legislation and guidance applicable to each of the technical areas
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 24
covered within this ES. Where quantitative assessment has not been possible,
qualitative evaluation of significance based on professional judgement has
been applied. In general terms the significance of environmental effects have
been judged by comparing the sensitivity of a particular receptor with the
magnitude of effect, taking into account the nature of the impact being
assessed.
2.3.2 Methodologies for defining the significance of environmental effects are not
prescribed by law. However, when assessing the significance of impacts each
discipline has taken into account relevant legislative requirements, standards
and best practice.
2.3.3 Where available and appropriate the impact assessments have followed
impact assessment criteria and methodology set out by the relevant
professional institution (i.e. Institute of Ecology and Environmental
Management (IEEM), Landscape Institute etc.). Where such guidance is not
available or prescriptive methods are not set out by the relevant professional
body, then assessment criteria have been developed by the technical
specialists to enable a clear and structured approach to the assessment to be
undertaken. In order to understand and clearly communicate likely significant
effects of the project each technical discipline has set out the threshold above
which the effects of the project are considered to be ‘significant’ in EIA terms.
2.4 Cumulative Effects
2.4.1 The EIA regulations require that a description of the likely significant effects of
the development on the environment should be included in the Environmental
Statement, including cumulative effects. The EIA regulations do not define
cumulative effects, however, a commonly accepted definition is: “Impacts that
result from incremental changes caused by other past, present or reasonably
foreseeable actions together with the project.” (EC, 1999)
2.4.2 Chapter 15.0 of this ES provides an assessment of the potential cumulative
effects of the proposed development with other developments in the wider
vicinity. The other developments that have been considered to have the
potential to give rise to cumulative impacts with the proposed development
are:
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The Millerhill Marshalling Yard, Whilthill Road, Dalkeith; and
The Edinburgh Royal Infirmary, 51 Little France Crescent, EH16 4SA.
2.4.3 The location of the aforementioned sites is provided on Figure 15.1 contained
within this ES. Further detail of the methodology used and the findings of the
assessment are provided in Chapter 15.0 of this ES.
2.5 Structure of the Environmental Statement
2.5.1 The format of this ES is described below.
2.5.2 Volume 1 (Main Report) provides an introduction to the project and details the
technical assessments that have been undertaken to determine the likely
impacts of the project. The Chapters of the Main Report are as follows:
Chapter 1.0: Introduction.
Chapter 2.0: Scope of the Environmental Assessment.
Chapter 3.0: Need
Chapter 4.0: Scheme Description.
Chapter 5.0: Planning Policy Context.
Chapter 6.0: Traffic and Transportation.
Chapter 7.0: Landscape and Visual Effects.
Chapter 8.0: Ecology and Nature Conservation.
Chapter 9.0: Geology, Hydrogeology and Ground Conditions.
Chapter 10.0: Surface Waters and Flood Risk.
Chapter 11.0: Noise and Vibration.
Chapter 12.0: Air Quality and Human Health.
Chapter 13.0: Cultural Heritage.
Chapter 14.0: Socio Economic Effects.
Chapter 15.0: Cumulative Effects.
Chapter 16.0: Energy Export Connections.
Chapter 17.0: Human Health.
Chapter 18.0: Summary of Effects.
2.5.3 Bound separately to this volume is a series of Technical Appendices (Volume
2). These include details of the methodology and information used in the
assessment, detailed technical schedules and, where appropriate, raw data.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 26
2.5.4 The ES covers a large number of issues and, in doing so, uses a significant
quantity of technical terms. Consequently, all the Chapters are summarised in
a Non-Technical Summary (NTS) (bound separately as Volume 3) to provide
a review of the development proposals and the possible environmental
implications, in concise lay terms.
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3.0 NEED AND ALTERNATIVES
3.1 The Need for the Scheme
3.1.1 The need for the Millerhill RERC is described in detail within Section 4.0 of the
Planning Statement (PS) (that forms Part 3 of the PAD). The conclusions from
section are provided in the following paragraphs.
3.1.2 The need for the Millerhill RERC (and the benefits arising from the scheme)
has been considered in the context of a number of strategic waste policy
documents and the current waste management position within the South East
Scotland Strategic Development Plan (SESplan) area and Edinburgh and
Midlothian administrative area. In addition, it has also been evaluated in
terms of national, regional and sub-regional renewable energy policy and
need. The assessment has established the following:
The Need for Waste Management Infrastructure from a European and
National Perspective
i) The ZWP sets a number of challenging targets to reduce the quantities
of biodegradable waste sent to landfill which are focussed on recovering
value from waste through higher levels of recycling and composting. It is
accepted within the national guidance that the balance of waste that
cannot offer greater environmental and economic benefits through reuse
or recycling will need to be managed further down the waste hierarchy
with a preference for energy recovery over landfill disposal.
ii) From a national (and indeed regional) perspective, all relevant extant
and emerging policy and strategy documents support the thermal
treatment of waste with energy recovery.
iii) The ZWP and SPP and the NPF3 identify a need for additional facilities
for the treatment and recycling of municipal and commercial and
industrial waste if the targets set out within the ZWP are to be met. In
this regard the ZWP specifically states that: “moving to zero waste
means more facilities will be required to collect, sort, reuse, recycle and
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process waste” and that: “there will also be opportunities to harness
heat and power generated from the energy recovery process.”
iv) It is clear given published waste figures for MSW and C&I waste within
Scotland and the number of EfW facilities that are either built and
operational or in the process of being built, there is a very significant
shortfall in energy recovery infrastructure within Scotland. In this context
the Proposed Development would deliver clear benefits in terms of
conserving valuable resources by way of recycling, the generation of
renewable energy and the diversion of waste from landfill. All of these
benefits would contribute, to a greater or lesser degree to the Scottish
Government’s objectives for managing and combating climate change.
Regional Waste Management Need
v) The PPIP for the ‘Zero Waste Facility’ was granted for facilities with the
treatment capacity of 230,000tpa. On the basis that the AD plant
presently under construction has a capacity of 30,000tpa, the balance of
the ‘approved’ capacity is 200,000tpa (which could all constitute thermal
treatment capacity). The Proposed Development has an overall capacity
of 195,000tpa (and circa 190,000tpa for the ERC element) and is
therefore less than the capacity for which PPIP has already been
granted and a need established.
vi) In terms of the SES Region, it has been established, using conservative
assumptions on the amount of waste available for waste treatment, it
has been established that circa 563,000 tonnes of residual waste would
be available for treatment at the Proposed Development.
vii) Only one other EfW facility is being developed in the Region which is the
Dunbar facility in East Lothian. This has a capacity of 300,000tpa,
leaving in excess of 260,000tpa of suitable waste requiring thermal
treatment in the region. This requirement materially exceeds the
maximum capacity that the Proposed Development would provide.
Accordingly, there is a demonstrable quantitative case of need for the
Proposed Development from a regional and local waste management
perspective.
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viii) It is clear that the Proposed Development would contribute to
addressing the shortfall of waste management facilities that are needed
to meet the ZWP targets.
The Need for Energy / Renewable Energy Infrastructure
ix) Energy generation is identified as one of the main sources of
greenhouse gas emissions, the reduction of which is a key challenge in
addressing climate change. Accordingly, national policy seeks for
making the most of renewable energy potential and encouraging power
and heat generation from clean, low carbon sources; it is acknowledged
that biomass from waste can make a positive contribution to renewable
energy targets and the mitigation of climate change.
x) Extant strategy, policy and legislation documentation contains numerous
and very challenging renewable energy and climate change targets that
are either applicable to the UK as a whole or Scotland.
xi) The ERC facility would (taking into account a proportion of energy need
in the operation of the facility) export 11.09 MWe to the local grid of
which 55% would be considered renewable. In addition, the combustion
process would produce heat, which could be exported to a local district
heating network, in the form of stream hot water. Accordingly the ERC
element of the Proposed Development would contribute towards
meeting the challenging renewable energy targets and thus a
demonstrable need for new renewable energy (heat and power)
generation capacity.
Climate Change
xii) The development proposal has been found to accord with the
Government’s key planning objectives for combating climate change.
Including:
a. contributing towards the Scottish Governments target of a 42%
reduction in greenhouse gas emissions by 2020 and a 80%
reduction by 2050;
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b. Diverting waste from landfill;
c. Off-setting the consumption of fossil fuels; and
d. Contributing to recycling.
Socio-Economic Benefits
xiii) The economic benefits of the scheme include
a. The proposed development would be consistent with and
supportive of the Government Economic Strategy through its
employment generation within a low carbon setting.
b. It would also contribute towards the achievement of the targets set
out in the NPF / SPP and ZWP aimed at reducing the amount of
waste sent to landfill and increasing the amount of electricity
generated from renewable sources.
c. A range of community benefits would be delivered by the proposal
including direct and indirect employment creation, skills
development, supplier contracts, social enterprise contracts and
education benefits.
d. The creation of approximately 39 permanent jobs together with a
maximum of 300 temporary jobs during the construction phase
(180-200 on average) of the development;
e. Creating new local apprenticeships, FCC Environment operate its
own apprenticeship programme and the Proposed Development
will create up to 3 apprenticeships on an on-going basis;
f. Opportunities to deliver annual fiscal benefits in the order of £0.4m
to Midlothian Council, through the retention of business rates;
g. Opportunities to ensure that local residents and businesses have
access to the employment and business supply chain
opportunities which may emerge;
h. Opportunities to create further value in the waste processing chain
through the sorting of recyclable materials and the utilisation of
process by-products which can be used in other sectors (i.e.
bottom ash in the construction sector); and
i. The potential creation of 50 FTE direct, indirect (local supply
chain) and induced jobs in the impact area. These jobs could
support around £3.8m of GVA per annum.
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3.1.3 In conclusion, there is a clear, demonstrable and overriding need for the
Proposed Development and the benefits it would bring relate to both its
contribution towards delivering sustainable waste management and combating
climate change through renewable energy production. Given that both
Scotland and the SES Region have a paucity of sustainable waste
management and renewable energy infrastructure, the opportunity presented
by the proposal must not be missed. The scheme offers very significant
benefits of regional significance and, in accordance with the identified policy
framework these should be afforded very significant positive weight (in
planning terms).
3.2 Alternatives Considered
3.2.1 The requirement to consider alternatives stems from the Town and Country
Planning (Environmental Impact Assessment) (Scotland) Regulations 2011.
Schedule 4 of the Regulations identifies the information for inclusion in
Environmental Statements. Parts 1 (2) and 2 (4) include: “An outline of the
main alternatives studied…and an indication of the main reasons for this
choice, taking into account the environmental effects.”
3.2.2 Paragraph 95 of Circular 3/2011 which accompanies the Environmental
Impact Assessment (Scotland) Regulations 2011, notes that: “Where
alternative approaches to development have been considered, paragraph 4 of
Part II of Schedule 4 requires the applicant to include in the ES an outline of
the main alternatives, and the main reasons for his choice. Although the
Directive and the Regulations do not expressly require the applicant to study
alternatives, the nature of certain developments and their location may make
the consideration of alternative sites a material consideration. In such cases,
the ES must record this consideration of alternative sites. More generally,
consideration of alternatives (including alternative sites, choice of process,
and the phasing of construction) is widely regarded as good practice, and
resulting in a more robust application for planning permission. Ideally, EIA
should start at the stage of site and process selection, so that the
environmental merits of practicable alternatives can be properly considered.
Where this is undertaken, the main alternatives considered must be outlined in
the ES.”
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3.2.3 As is evident from the above, there is no formal requirement for applicants to
consider alternatives, rather the imperative is to outline any main alternatives
where (i.e. if) they have been considered. In the case of this planning
application, and specifically the work undertaken leading up to the application,
only a limited number of alternatives have been considered as there is
particularly strong justification for the site that has been selected, the
technologies that have been adopted and the approach to scheme design.
This justification, together with the environmental reasons why key decisions
have been made, is set out below under the following headings:
Site Selection;
Waste Management Technology; and
Design Philosophy.
Site Selection
3.2.4 Scottish waste management policy and guidance, most notably Scottish
Planning Policy (SPP) (June 2014), the Zero Waste Plan (ZWP)1 and the
SEPA Guidance Note 62 provide criteria for consideration on locating waste
management facilities. At a local level, the extant and emerging development
plan provides policy and guidance on site-specific considerations. Accordingly,
the proposed development site has been critically appraised for its suitability
for the proposed use against these criteria and from an operational
perspective, from which it was determined that:
The site already benefits from PPiP for the development of the Zero
Waste Facility which is a large scale waste management facility
including mechanical treatment and an Energy from Waste facility;
Strategic Development Plan for Edinburgh and South East Scotland
(July 2013) specifically allocates and safeguards the site for the
development of a waste management facility.
o Figure 2 of the Plan identifies key strategic infrastructure
improvements required to facilitate existing and future
development across the SDP area. The Millerhill Waste Facility is
identified under the Regional Core sub-area as one of the key
strategic infrastructure improvements required; and
1 Scotland’s Zero Waste Plan, published June 2010, by The Scottish Government 2 SEPA Guidance Note 6: Land Use Planning System, published 22 March 2012 by SEPA (Version 3)
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o Figure 3 relates to the Regional Core sub-area and specifically
identifies the ‘Millerhill Marshalling Yards’ for the development of a
waste management facility. The associated supporting text
identifies that the site will be safeguarded for waste treatment. In
addition paragraph 46 states: “Land will be safeguarded within the
LDP (Midlothian) for the development of a waste treatment facility
at Millerhill which is likely to include energy from waste technology,
and potentially an eco-park with complementary waste recycling /
renewable industries.”
The site is also safeguarded within the emerging Midlothian Local
Development Plan. Policy WAST2 ‘Millerhill’ states: “The site indicated
on the Proposals Map [the Application Site] is safeguarded for waste
processing uses. The Council supports the formation of further waste-
related or economic uses on the economic land adjacent to the waste
treatment facility (but without prejudice to the formation of other
employment uses on this site).
The proposed development would deliver the redevelopment of a
redundant / derelict previously-developed (brownfield) site. The Millerhill
Marshalling Yards were created in 1962 and formally opened in 1963.
They were primarily used for freight such as new cars and trucks from
Bathgate and for cement and chemical trucks. At the same time, two
sidings were also laid to service Monktonhall Colliery. When the
Waverley line to the South was closed in 1969, the use of the ‘down
yard’ declined and it was eventually closed in 1983. All the tracks were
lifted apart from the two siding lines into the colliery. The colliery itself
closed in 1997. The redevelopment of degraded, derelict and redundant
land is a key principle of sustainable development supported within
national waste and planning policy, as well as the extant and emerging
development plan.
One of the most significant factors affecting site selection relates to the
fact that the Millerhill RERC development would generate energy in the
form of heat and electricity and in order to maximise the energy
efficiency of any such plant, it is important that it be co-located with
potential, viable heat users. As identified previously, a separate Heat
Plan Report (HPR) has been prepared in support of the application (see
Part 6 of the PAD). This sets out the latest identified proposals for heat
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 34
export together with the steps required to maximise benefits in this
regard. The HPR has identified four potential heating zones within close
proximity of the Millerhill RERC site. Paragraph 183 of SPP required
that: “Any sites identified specifically for energy from waste facilities
should enable links to be made to potential users of renewable heat and
energy. Such schemes are particularly suitable in locations where there
are premises nearby with a long-term demand for heat.” Furthermore,
Section 8 of the emerging Midlothian LDP states under sub-heading 8.1
‘Edinburgh (Shawfair) Committed Development includes Development
Considerations’ that (our emphasis): “Millerhill is the site of the Zero
Waste Project – a joint scheme between Midlothian and the City of
Edinburgh Council. The project will occupy two plots across 8 ha. The
first phase (an anaerobic digester, which will turn food waste into
biogas) is under construction. The partners are considering bids for the
2nd stage which will handle unsorted waste and might include an energy
from waste plant (incineration). This project could provide a waste
heat opportunity for use in Shawfair, or further afield. As such, the
Millerhill RERC development, in its proposed location, offers a major
opportunity to deliver a highly efficient energy recovery scheme.
The site has a good standard of access to the strategic highway network
with access via Whitehill Road to the A1. A TA has been undertaken to
accompany the planning application (see Appendix 6-1 of the ES) which
concludes that that: “…the day-to-day operation of the Millerhill RERC
scheme would be acceptable and not give rise to material traffic related
operational or environmental effects” (paragraph 7.55) and “there would
be no requirement for local highway network operational or
environmental improvements over and above existing / committed
provision to accommodate the predicted levels of temporary
construction traffic demand.”
The site is appropriately located (almost centrally) within the identified
waste arisings catchment. This is consistent with the principles set out
within the ZWP which states that: “… proximity for waste management
facilities should be considered strategically as the achievement of a
sustainable strategy may involve waste crossing planning boundaries
within Scotland”;
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The site is relatively remote from sensitive receptors and significant
environmental constraints, such that measures can be integrated into
the scheme that would satisfactorily mitigate potential for nuisance or
harm;
The site is of suitable shape, size and topography to accommodate the
proposed development, operational requirements and landscaping
proposals; and
The site is being brought forward by FCC to provide a facility for the
management of Edinburgh and Midlothian’s residual waste. The site
owned by the Council’s and as such, does not represent a constraint to
the development.
3.2.5 Accordingly, it was concluded that the Application Site is both available and
suitable for the Proposed Development.
Waste Management Technology
3.2.6 The main driver for the selected waste management technology was meeting
the requirements of the Scottish Government’s Zero Waste Policy.
3.2.7 The process began with evaluating a ‘long-list’ of potential waste technology
solutions that included permutations of the following:
Landfill;
Autoclave;
Advanced thermal treatment (e.g. pyrolysis, gasification);
Mechanical biological treatment;
In-vessel composting;
Open windrow composting;
Modern thermal treatment (also referred to as energy from waste - EfW);
Anaerobic digestion; and
Plasma arc.
3.2.8 These technologies were the subject of a two-stage appraisal. First they were
considered against the following high level criteria and the most feasible
options were then taken forward for further appraisal:
National policy / legislation;
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Product marketability;
Efficacy: proven technology; and
Economic viability.
3.2.9 Those technologies surviving the stage-one appraisal were subject to a second
evaluation examining the planning, environmental and deliverability risks
associated with each of the technology options. The criteria used in this second
options appraisal exercise were:
Planning risks associated with technology;
Track record of the technology;
Flexibility and adaptability of the technology to changes in waste
composition / volume;
Climate change implications of the technology option;
Health effects of emissions from technology;
Contribution of the technology to recycling / composting and demand the
technology makes on primary materials extraction; and
Net energy generation / use of the technology.
3.2.10 The outcome of this analysis produced a shortlist of technology options as
follows:
Modern Thermal Treatment (EfW) with combined heat and power
(CHP);
Mechanical Treatment (MT) producing a fuel to power dedicated CHP
plant(s);
Mechanical Biological Treatment (MBT) producing a fuel to power
dedicated CHP plant(s);
MBT producing a biologically stabilised material that is sent to landfill;
Autoclave producing an active fibre fuel that is sent to power dedicated
CHP plant(s); and
Advanced thermal treatment with syngas used for electricity production
and recovery of heat energy.
3.2.11 A more detailed review was undertaken on the suitability of the short-listed
technologies. The technologies reviewed are discussed in the following
sections.
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Modern Thermal Treatment (EfW) with combined heat and power (CHP)
3.2.12 Direct waste combustion in a modern thermal treatment (EfW) facility with CHP
is a proven technology capable of delivering a flexible and sustainable waste
management solution. EfW facilities are used throughout the UK and Europe
for the management of MSW and C&I waste, and are established as an
efficient way to recover energy, especially where CHP can also be delivered
from the plant. The technology also demonstrates consistently high reliability
and is, by a very significant margin, the most widely deployed waste recovery
solution in Europe (with circa 500 operating plants). Such a facility would be
capable of managing the predicted waste volumes and effectively treat the
likely composition of the waste predicted to remain after achieving recycling
and composting targets. Given, the technology is well proven, it is also
significantly less complex to fund. On this basis, the use of a modern EfW
facility was considered to be an appropriate waste management option for the
treatment of residual waste which cannot practically be recycled.
Mechanical Treatment (MT)
3.2.13 MT plants are often used where there is likely to be materials in the waste
which could be extracted as recyclables prior to the residual stream being sent
for further treatment. MT plants rely on several well proven and reliable
mechanical operations such as over-band magnets, eddy current separators,
trommels and windsifters. MT plants can separate the feed waste stream into
individual streams including recyclables such as paper, plastics grades, metals
and glass. An MT plant ensures that the processing of waste follows the waste
hierarchy, allowing recycling to occur before recovery or disposal. ECC and
MLC already have effective kerbside recycling and a number of other recycling
facilities. However, treatment of the waste in a MT plant prior to sending it to
the ERF would ensure that the level of recycling from their residual waste
would be maximised. This arrangement is therefore consistent with the goals of
the ZWP. A MT plant is considered an integral part of the Millerhill RERC
development.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 38
Mechanical Biological Treatment (MBT)
3.2.14 Mechanical Biological Treatment (MBT) technology is usually adopted instead
of an MT facility where there is a large proportion of organic material in the
mixed municipal waste, which could be removed as an organics stream (in the
MT part of the process) and then treated and stabilised in a biological process
such as composting or AD. This would produce a stabilised Compost-Like
Output (CLO) product. Biological processes applied to organics removed from
mixed municipal waste are often unreliable due to the poor quality of the
organics stream compared with a source-segregated organic stream.
Contamination of the organics stream from small plastic pieces and fine inert
material often leads to a build-up of inorganic materials in biological process
vessels, decreasing the digestion efficiency and reducing plant availability
because the contamination needs to be cleaned out periodically. The intention
of the ZWP is to move towards increased source-segregation of organics. This
means that the organic content of the municipal waste would decrease, which
in turn makes the contamination issue more pronounced. Furthermore,
because the organic stream is derived from mixed municipal waste as opposed
to source-segregated, the CLO produced would not meet the industry standard
PAS110 specification, meaning there is a higher possibility that it would be un-
marketable and would need to be landfilled. The SEPA has stringent rules on it
being spread to land.
3.2.15 ECC and MLC have separate organic / food waste collections and have
successfully tendered a contract for the management of this waste. The
proposed solution for the management of organic waste is the AD Facility that
is in the process of being constructed on land to the immediate north of the
Milerhill RERC site. In light of this, given the small amount of organics that
would be contained within the mixed municipal waste it would be more cost
effective for it to be retained within the residual stream produced by the MT
facility, in order that that its energy can be recovered as heat and electricity in
the ERF.
Autoclave
3.2.16 Autoclaves are not in themselves a residual waste treatment solution and only
offer an interim process which results in the production of a fuel (generally
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 39
referred to as a SRF or refuse derived fuel (RDF)), or a CLO. The SRF / RDF
then require a separate facility / process, such as the ERF proposed, in order
for energy to be recovered. Furthermore, an autoclave facility on its own is a
significant net user of energy. The CLO produced by autoclaves from mixed
residual waste has very little application and the SEPA has complex and
stringent rules on it being dispersed on land. At best it can be mixed with soils
and used in landfill (or occasionally contaminated land) restoration. However,
in reality the demand for CLO is extremely limited and it often ends up being
landfilled. Accordingly, it was considered that there were insufficient benefits in
autoclaving as a technology when compared to other options and therefore it
was dismissed.
Advanced Thermal Treatment
3.2.17 With regard to Advanced Thermal Treatment (e.g. pyrolysis and gasification)
there is very limited experience of successfully using these technologies for the
processing of MSW and C&I waste at the scale proposed at the Millerhill
RERC. Pyrolysis and gasification processes are more complex than other more
widely deployed technologies and more prone to operational problems. As a
consequence, they are more difficult to fund and were therefore rejected.
Alternative Thermal Treatment Technologies
3.2.18 Direct waste thermal treatment facilities can be delivered through a variety of
sub-technologies. Consideration was given to these technologies and a
synopsis of this assessment is set out below.
Fixed Hearth
3.2.19 This type of furnace is generally not considered to be suitable for the
management of large volumes of mixed waste and is best suited to low
volumes of consistent waste. As a consequence, they have not been used for
the combustion of municipal waste in the UK.
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Pulsed Hearth
3.2.20 Pulsed hearth technology has been used for municipal waste in the past, as
well as other solid wastes. However, there have been difficulties in achieving
reliable and effective burnout of waste and it is considered that the burnout
criteria required by the European WID would be difficult to achieve.
Rotary Kiln
3.2.21 Rotary Kilns have achieved good results with clinical waste, but they are not
commonly used in the UK for MSW (or similar wastes). There is a rotary kiln in
use on municipal waste at Grimsby, which has a design throughput of 56,000
tonnes per annum. In general this technology is suitable only in the throughput
range of 40,000 to 80,000tpa and thus would not be appropriate for the
proposed waste throughput at this facility. Furthermore, the energy conversion
efficiency of a rotary kiln is lower than that of a moving grate (see below) due
to the large areas of refractory lined combustion chamber.
Fluidised Bed
3.2.22 Fluidised bed technology has been used for municipal waste at a very few
sites in Europe. In the UK, there are only two operating facilities which are
located in Dundee and at Allington in Kent. The former has a history of
significant operational difficulties.
3.2.23 Fluidised bed technology has a number of advantages over moving grate
technology, including lower nitrogen oxide (NOx) formation, slightly higher
thermal efficiency and the lack of moving parts within the combustion
chamber. However, there are also a number of disadvantages:
The waste stream needs to be homogenised to provide consistent
fluidisation and therefore would need to be pre-treated (beyond the pre-
treatment achieved in an MT plant) before feeding to the fluidised bed.
This would lead to additional energy consumption and a larger building.
The additional energy consumption tends to outweigh the combustion
efficiency advantage;
High fluidisation velocities can lead to the carryover of fine particulate
material. This can lead to a higher particulate loading in the flue gases,
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 41
so leading to higher quantities of flue gas treatment residues, which
need to be disposed of as waste. However, the bottom ash tends to be
of better quality;
Although less NOx would be formed, additional NOx abatement
equipment would still be required to meet the limits imposed by the WID.
Therefore, there would be very little difference in NOx levels overall;
The operational and capital costs of a fluidised bed are higher than the
equivalent costs for a moving grate incinerator; and
Reliability in UK fluidised bed plants is lower than for other thermal
treatment options.
Moving Grate
3.2.24 This is the leading technology in the UK and Europe for the combustion of
municipal and similar wastes, being installed on virtually all UK incinerators
and some 98% of European incinerators. It is a proven and developed design,
with a number of suppliers available. The various designs are proven to
achieve the burnout requirements for Industrial Emissions Directive (IED)
compliance.
Conclusion
3.2.25 In summary, the selected technology scheme for the Proposed Development
is a MT plant removing more recyclable material and producing a residual
stream (SRF) which is fed to an ERF employing moving grate technology to
recover the residual energy as electricity and heat. This technology is readily
available and well-proven for the treatment and combustion of municipal and
similar wastes.
Design Philosophy
3.2.26 The applicant has appointed Gary Stewart Design Associates (GSDA), an
architectural practice with specific experience in the design of waste
management facilities. Their experience covers the design and construction of
a wide range of energy and waste related projects and they are noted for the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 42
design quality of their work which stems from their contextual and sustainable
approach.
3.2.27 The rationale behind the chosen design / architectural solution is described in
detail within the Design and Access Statement (DAS) which is contained
within Part 2 of the PAD.
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4.0 SCHEME DESCRIPTION
4.1 Introduction and Scheme Overview
4.1.1 This Chapter provides a description of the layout and design of the proposed
development, together with details regarding its construction and operation.
4.1.2 As described briefly in Chapter 1.0, the Millerhill RERC development would
comprise a combination of a MT process to recover recyclable materials and
an ERC to recover energy from SRF. The SRF would be sourced from the on-
site MT facility and other suitably licensed pre-treatment or recycling facilities.
4.1.3 The Proposed Development would receive up to 195,000 tonnes per annum
(tpa) of residual waste. The waste material that would be processed at the
facility would comprise non-hazardous municipal solid waste (MSW) and
similar commercial and industrial (C&I) wastes sourced primarily from within
Edinburgh, Midlothian and adjoining administrative areas.
4.1.4 Of the 195,00tpa of residual waste material received at the facility 135,000tpa
would be waste received through the Edinburgh and Midlothian residual waste
contract (contract waste), with the remaining 60,000tpa comprising either SRF
received from either commercial and industrial sources or municipal sources
from neighbouring local authority areas.
4.1.5 The 135,000tpa of contract waste received at the site would be transferred to
the MT process which would recover ferrous and non-ferrous metals (circa
2,740tpa) and other ‘reject’ materials that are unsuitable for thermal treatment
(circa 2,798tpa). The remaining material would comprise an SRF which would
be directed, by conveyor, to the ERC for thermal treatment. The circa
60,000tpa of non-contract SRF received from third parties would be
transferred directly to the ERC for thermal treatment, it would not need to be
the subject of MT, having already undergone such a process in advance of
being delivered to the site.
4.1.6 The ERC would generate energy in the form of heat and electricity. The
biodegradable (or biomass) content of the waste is recognised as a renewable
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 44
source of energy. Thus around 50-55% of the energy produced by the ERC,
whether it be heat or electricity, would be classed as renewable energy.
4.1.7 The Proposed Development would be a combined heat and power (CHP)
station. Through the combustion of SRF it would generate heat energy in the
form of steam. A proportion of this steam would be used to generate electricity
with the balance exported as heat in the form or either steam or, more likely,
hot water. The maximum electricity generation capacity would be 13.45MW of
electricity (MWe). A small portion (circa 2.36MWe) of this would be used to
power the RERC itself, with the majority circa 11.09MWe exported to the local
electricity grid. Based upon maximum electricity output, the Proposed
Development would export circa 87,012MWe hours per annum. This is
sufficient to meet the domestic electricity needs of over 26,000 homes.
4.1.8 Heat generated by the Proposed Development would be exported by
underground insulated pipes direct to local users which could include nearby
institutional, commercial and residential developments.
4.1.9 The need for the proposed facility is described in detail within Section 4.0 of
the PS, which forms Part 3 of the PAD. This sets the proposed Millerhill RERC
and the benefits arising from the scheme in the context of national (Scottish
and UK Government) strategic waste and renewable energy policy documents
and the current waste management position within Edinburgh & Midlothian
and the wider SESplan area.
4.1.10 In addition, the proposals represent a £144 million investment in the
Edinburgh and Midlothian area. The economic benefits of the scheme include
the creation of approximately 40 permanent jobs together with up to 300 - 350
temporary jobs during the construction phase of the development, providing
local employment and apprenticeship opportunities. Furthermore, social and
community benefits would arise from the new education and visitor centre
facilities which would enable the community and schools to learn about waste
management and how they can take more responsibility for their own waste.
4.1.11 The need assessment contained within the PAD concludes that there is a
clear and demonstrable need for the proposed Millerhill RERC development.
The benefits arising from the scheme relate to contributing towards delivering
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 45
sustainable waste management (in accordance with the ZWP), combating
climate change through low carbon and renewable energy production and
economic investment with job creation.
4.2 Permanent Development
Main Building
4.2.1 The proposed development would be based around a main building located
centrally within the site on a broadly north to south axis with ancillary
structures, e.g. air cooled condensers, ammonia store and water tanks to the
to the east, an emergency generator, transformer and baled waste store to the
west, an internal access road to the south of the main building and ancillary
vehicle access to / from the building on both the east and west elevations, and
the main vehicular access, manoeuvring area, gatehouse and car parking to
the north of the site near the new site entrance. Provision is also made for the
construction of surface water attenuation ponds to the south and west of the
site. The development is illustrated in plan and elevation form on Figures 4.1 –
4.16.
4.2.2 The main building would contain the following areas:
Waste Reception Hall;
Waste Bunker;
Mechanical Pre-treatment Hall;
Boiler Hall;
Flue Gas Treatment (FGT) facility;
Flue stack;
Turbine Hall;
District Heating Centre; and
Bottom Ash (Storage and Loading) Hall.
4.2.3 The building would have a total length of circa 136.04m and range in width
from circa 55m wide, through the main body of the building, to circa 72.65m
wide where the Boiler Hall / Bottom Ash facility extends out of the main body
of the building to the east.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 46
4.2.4 The height of the main building would also vary reflecting the operational
heights required for the various elements of process equipment housed
therein. The highest part of the main building would house the Boiler Hall /
FGT facility to the south where the roof (to the top of the parapet) would
measure circa 41.6m above ground level down to circa 18.2m for the roof of
the tipping hall and 12.3m for the bottom ash storage and collection hall.
4.2.5 The principle material finishes for the building are as follows:
Metal composite horizontally spanning wall cladding with integral louvres
(colour – Anthracite);
Metal composite roof cladding (colour – Anthracite & Light Grey);
Polycarbonate translucent cladding system (colour – crystal/opal);
Windows in PPC aluminium frames with double glazing (colour – Merlin
Grey)
4.2.6 A full tabulated schedule of all of the materials and finished that are to be
included on the Proposed development are provided in the Design and
Access Statement contained within Part 2 of the Planning Application
Document (PAD).
4.2.7 The flue stack would extend from within the main building envelope and would
measure 75m in height.
4.2.8 Prior to the submission of this planning application FCC entered into
consultation with both the Civil Aviation Authority (CAA) and Edinburgh Airport
Ltd to establish whether any specific airfield safeguarding measures need to
be adopted in connection with the facility and specifically aircraft warning
lights on the stack. They have confirmed that no safeguarding measures
would be required in connection with the facility and as such, no airfield
safegurading light is proposed on the stack.
Other Buildings and Ancillary Structures
4.2.9 In addition to the main building, the facility would also include a number of
ancillary buildings these would comprise a baled waste store, site office /
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 47
visitor centre building, gatehouse and driver welfare facility. Each is described
below.
Baled Waste Store
4.2.10 When the ERC is undergoing planning maintenance there is a requirement for
incoming waste to be baled within the MT facility and stored until operations
resume, with the baled waste thereafter being re-introduced to the process.
4.2.11 The proposed baled waste store would comprise a portal framed structure
located to the west of the main building and directly opposite the entrance to
the MT facility. The building would have a single roller shutter door on its
eastern elevation, and personnel doors on its northern and southern
elevations. There would also be a series of louvers on all elevations. The
building would measure circa 52.5m long by circa 20.5m wide by circa 9m
high. It would be constructed of the same composite metal wall cladding as
the main building and in the same anthracite grey colour (RAL7016).
Site Office and Visitor Centre
4.2.12 The main site office, staff welfare and visitor facilities would be located within
a self-contained structure which would be located to the immediate west of the
main building opposite the main stairwell and lift shaft. The building would
include the office reception, conference room, administration and staff welfare
facilities, visitor reception and education and visitor centre facilities. The
building would measure circa 38.2m long by circa 15.7m wide by circa 4.725m
high (to the top of the parapet). It would be constructed of the same composite
metal roof and wall cladding as the main building, including polycarbonate
translucent wall cladding on the northern and southern elevations.
Gatehouse
4.2.13 The Gatehouse would be located near the site’s entrance to the south of the
site. The building would measure circa 14m long by circa 3m wide by circa
3.10m high (to the top of parapet) and would include office and welfare
facilities. The Gatehouse would include a painted metal door on its western
elevation and aluminium framed windows on all other elevations. It would be
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 48
finished with the same composite metal wall cladding as the main building and
in the same anthracite grey colour (RAL7016).
Driver Welfare Building
4.2.14 The Driver Welfare Building would be located within the northern part of the
site, near the site entrance and to the immediate east of the out-going
weighbridge. The building would measure circa 16m long by circa 4m wide by
circa 4m high (to the top of parapet) and would include a waiting room and
welfare facilities. The building would include a painted metal personnel door
on its southern elevation and aluminium framed windows on the same
elevation. It would also be finished with the same composite metal wall
cladding as the main building and in the same anthracite grey colour
(RAL7016).
4.2.15 In addition to the aforementioned buildings there would also be a number
ancillary structures and plant associated with the facility, these comprise:
Air Cooled Condensers (ACC) - typically comprising a steel frame
structure measuring approximately circa 36.3m long x circa 14.7m wide
x circa 16m high (18m to the top of the pipe), housing the ACC units.
The frame would accommodate 3 No ACC units;
Step up transformer and emergency generator;
Ammonia store;
Electrical sub-station;
Bin-store / smoking shelter and cycle store (see Figure 4.15)
Fuel oil tanks.
4.2.16 The development would also include the following ancillary infrastructure, the
layout and design of which is described more fully under the following
headings below:
Vehicle Access and Site Circulation;
Parking Provision;
Drainage;
Utilities and Service Connections;
Fire Break Water Tank and Pumping Facilities;
Lighting and CCTV;
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 49
Security Fencing and Gates; and
Landscaping.
4.2.17 The Millerhill RERC would have a design life of approximately 25 years,
although, in reality, many elements of the plant would last beyond this period.
Planning permission is being sought for a permanent development and
therefore as elements of the facility require repair / refurbishment /
replacement this would be carried out as necessary.
Vehicle Access and Circulation
4.2.18 The Millerhill RERC development would be served via two new dedicated
vehicle access points to the internal site access road. The first would allow for
public vehicle access to the staff / visitor car and coach parking area. The
second would provide the main HGV access to the weighbridge and
operational areas of the plant. The layout and arrangement of the junctions is
illustrated on Figure 4.1.
4.2.19 Staff / visitors entering the site would proceed along a dedicated access road
to a turning area to the immediate north of the main site office and visitor
centre. A coach parking bay would be provided to the east of the turning area
and car parking to the west and within a central reserve.
4.2.20 Under site operating procedures, all operational HGV vehicles would ‘weigh in’
at a dedicated site entry weighbridge before proceeding to the relevant
delivery / reception areas within the main building. The layout of the proposed
operational access road is such that queuing vehicles approaching the site
entry weighbridge would be accommodated within a widened on-site queuing
area capable of catering for at least 6 full size articulated HGV units. A parallel
‘bypass lane’ would be available for emergency vehicles to avoid any delay /
conflicts with queuing operational HGV traffic.
4.2.21 From the weighbridge HGV’s and other service vehicles would be directed
around the main building in a clockwise direction. A service yard would be
constructed at the northern end of the site, outside the waste reception /
tipping hall to provide for HGV manoeuvring associated with the disposal of
waste and SRF. A series of other service areas would be provided along the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 50
eastern elevation of the main building providing access to the bottom ash
collection building, silos for the delivery and collection of reagents and
residues respectively.
4.2.22 All main service vehicles lanes within the site would be suitable to
accommodate a maximum size articulated HGV unit.
4.2.23 All operational HGV service vehicles exiting the site would be required to
‘weigh-out’ at the dedicated exit weighbridge. This exit area also includes for a
parallel bypass lane. Vehicles exiting the site would proceed onto the internal
access road to the junction with Whitebridge Road to the north.
4.2.24 A series of internal pedestrian footpaths would enable safe movement within
the site.
4.2.25 All heavily-trafficked internal access roads would be surfaced in asphalt with
associated lay-bys and car parking area surfaced in either tarmac or a semi-
permeable treatment. The service yards would be constructed and surfaced
with concrete. Pedestrian footpaths would be surfaced in concrete block
paving.
Parking Provision
4.2.26 Provision would be made for 32 car parking spaces (including 3 disabled
spaces) adjacent to the entrance to the site office and visitor facility. This
level of car parking has been provided to accommodate the proposed staffing
level, taking into account shift change requirements.
4.2.27 In addition, a coach drop-off / parking bay would be provided to accommodate
one coach within the visitor car park and a shelter would be provided for both
bicycles and motorcycles adjacent to the entrance to the site office and visitor
centre.
Drainage
4.2.28 The site is located in an area where the risk of flooding from all sources is low.
However, the proposed development would give rise to a significant increase
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 51
in surface water runoff from roads, vehicle parking areas, building roofs and
hardstandings, when compared to the undeveloped state.
4.2.29 The RERC development plot is served by foul and surface water drainage
infrastructure, approved and installed pursuant to the Zero Waste PPiP
scheme, via satellite manholes on or within the boundaries of the site.
4.2.30 The off-site surface water network has been designed to accommodate
regulated flows from the RERC, equivalent to ‘greenfield’ rates (i.e. 3.6/l/s/Ha
or 19.8l/s for the developable area of the plot).
4.2.31 This necessitates an on-site Sustainable Urban Drainage Scheme (SUDS)
which serves to regulate runoff to the prescribed rates, removes pollutants,
and demonstrates that surface water flows can be satisfactorily
accommodated. The scheme would drain surface water via drainage
channels, trapped gullies and a network of pipework, with oil / petrol
interceptors provided in areas susceptible to pollution (e.g. roads and parking
areas), to two interconnected attenuation ponds located in the southern
portion of the development plot. A schematic layout of the proposed drainage
arrangements is provided in Figure 10.1).
4.2.32 Designed to accommodate a design storm with a statistical frequency of 1%
occurrence each year (often referred to as the 1 in 100 year event), together
with a 20% allowance for the effects of climate change, these ponds will
provide in excess of 1,250m3 of storage and act as part of the ‘treatment train’,
in terms of surface water quality.
4.2.33 Domestic foul flows attributable to the proposed development would be
collected by a separate arterial system of below-ground pipework (as
illustrated in Figure 10.1), which would discharge into the existing proprietary
treatment facility, located to the north of the development plot, via an on-site
satellite manhole.
4.2.34 Effluent attributable to the RERC plant itself would include water from the de-
mineralisation plant, condensate and residues from the ash quenching
process. This effluent would be collected in a separate drainage network and
recycled for use in the ash quenching process. As such, there would be no
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 52
requirement for the disposal of these wastewaters to the off-site treatment
system.
4.2.35 It is proposed that the detailed design of the drainage scheme be developed in
accordance with the principles set out in the schematic layout subject to
agreement with the SEPA’s and Midlothian Council’s drainage services team.
It is proposed that the detailed drainage design be controlled by a suitably-
worded planning condition.
Utilities and Service Connections
4.2.36 The proposed development would require connection into a number of utilities.
Connections include sewer, water, telecommunications, gas and electricity.
Services are to be provided by Midlothian Council in the new access road that
is being constructed along the eastern boundary of the Application Site.
Fire Break Water Tank and Pumping Facilities
4.2.37 Provision would be made for the storage and pumping of water for emergency
use in the event of fire at the facility. Water would be stored within two Fire
Break Water Tanks (Sprinkler Tank) which would also collect rainwater from
the roof of the main building. Each would comprise a vertical cylinder of circa
5m diameter and 5m high located to the east of the main building, adjacent to
the Waste Reception Hall.
4.2.38 The pumping equipment would be housed within a building and located
immediately adjacent to the water tanks.
Internal and External Lighting and CCTV
4.2.39 Once commissioned, the Millerhill RERC facility would operate on a
continuous (24 hour / 7-day per week) basis. During hours of darkness / low-
level natural illumination there would be a need for lighting commensurate with
health and safety requirements to ensure a safe working environment for
operatives on site.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 53
4.2.40 There are a number of relevant documents and guidance which should be
followed when developing internal and external lighting systems, which
comprise:
Guidance Notes for the Reduction of Obtrusive Light’, Institute of
Lighting Engineers (ILE) 2000;
Application Guide to Lighting in Hostile & Hazardous Environments,
CIBSE 1983;
Guidance Note 4: Lighting Requirements of Building Regulations Part L,
CIBSE 1996
Lighting Guide 6: Lighting The Outside Environment , CIBSE 1992
Lighting Guide 12: Emergency Lighting Design Guide, CIBSE 2004
Lighting Guide to the Industrial Environment, CIBSE 1999
4.2.41 These documents and guidance have been used in determining the principles
of the internal and external lighting arrangements for the Millerhill RERC
development.
Internal Lighting
4.2.42 During night time operations there will be a degree of lighting inside the ERC
which would be necessary to support the 24 hour processing of waste. The
internal lighting will offer an overall low lux level, with directional task lighting
of areas where improved illumination is required for activities such as reading
of gauges and inspecting equipment.
4.2.43 General and specific lighting would also be provided within the Waste
Reception Area and MT building, to supplement the natural lighting that would
be afforded by roof lights.
4.2.44 Manually switched, fixed position high bay induction lighting, would be
installed in the Waste Reception Hall, ERC and MT building. The lighting
would be centrally controlled from a point near to the staff entry / exit door.
4.2.45 The High Bay internal lighting would also be controlled by daylight sensors
and presence sensors located within the building with features allowing for
isolation, testing and manual override functions. The control system shall
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 54
offer, without exception, a two channel control, presence and daylight sensors,
with manual over-ride.
4.2.46 Internal lighting would be designed and installed to provide lighting levels that
comply with the CIBSE Code for Interior Lighting and relevant lighting guides
and British Standards to illuminate all internal areas.
4.2.47 Lighting within the Switch Room in the ERC and all common areas / office
areas within the process building would be IP65 rated and controlled from a
point near to the staff entry / exit door. The internal lighting to the above areas
would also be controlled by daylight and presence sensors.
External Lighting
4.2.48 Lighting during operations is required to ensure a safe working environment
for traffic (including manoeuvring HGVs), pedestrians and staff on site. The
facility would have consent to operate on a 24/7 basis and whilst the bulk of
deliveries and visits will be made during daylight hours, operations may
continue outside of these hours, particularly at times of year when daylight
hours are reduced. At all times of the year, the external lighting would be
adequate for safe operations.
4.2.49 This requirement for safe working conditions would be balanced against the
requirement to reduce any unwanted visual prominence of the development at
night. Further, any ecological constraints, such as bat flight paths, would be
considered in the lighting design.
4.2.50 An initial lighting strategy has been developed for the site, based on the
following core principles:
Illumination for safety, particularly along roads, at weighbridges, and
pedestrian areas, when dark during operational hours;
design / architectural lighting of the building;
The application of mitigation measures as part of the lighting design to
avoid unnecessary and unwanted light spillage.
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Principals of the External Lighting Strategy
4.2.51 The guidance contained in CIBSE Lighting Guide 6: Lighting The Outside
Environment, suggest appropriate lux levels for various components of
developments, those of relevance to the Proposed development are
summarised in Table 4.1 below.
Table 4.1: Recommended lux levels
Area Recommended lux level
Entrance Signage 100
Feature Lighting 100
Vehicle Routes 10-30
Staff/ Visitor Car Park 5-20
Building exits/ entrances 50-100
Loading areas/ Weighbridge Area 50
4.2.52 It is proposed that the lighting scheme for the Proposed Development is within
the levels recommended within the CIBSE Lighting Guide 6: Lighting the
outside Environment. Whilst detailed assessment is yet to be carried out, it is
considered that the following levels could be realistically achieved:
General roadways / car parking, low lux level (circa 10-30 lux);
Footpaths / pedestrian routes, very low lux level (circa 5-20 lux);
Building entrance / focal points, medium lux levels (circa 20 lux); and
Process / specialist areas, high lux level (circa 50-100 lux).
Architectural / Feature Lighting
4.2.53 As discussed in more detail in the DAS (Part 2 of the PAD) and Chapter 7.0 of
this ES the upper elevations of the Proposed Development would be
constructed of a translucent polycarbonate material. This would allow internal
lighting to be partially visible to create a low intensity ‘glow’ from the building
during hours of darkness. This is purely a design feature and would not be of
such a level that it could cause disturbance to surrounding properties or
ecological impacts (bats etc.).
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 56
Mitigation Measures associated with External Lighting
4.2.54 The lighting design would incorporate the following mitigation measures:
The use of low level lights as far as possible (maximum 14m high
columns) to reduce the visibility of site lighting;
The use of carefully sited directional lighting incorporating light shields to
avoid unwanted light spray / upward light and possible glare effects;
Digital programmable switches including timers and / or movement
sensors;
Avoid unnecessary or unplanned lighting of the building façade;
Site lighting to be concentrated in locations essential to night operations;
and
Low level lighting bollards with low energy fittings to reduce the scale
around the offices, visitor centre and pedestrian routes.
4.2.55 Other measures associated with the reduction of intrusive light spillage on site
could also include the use of a surface finish to the road with very low
reflectivity; the use of kerbs with inbuilt reflectors to assist night time
navigation of the roads, and thereby reducing the overhead illumination
requirement.
4.2.56 FCC has carried out pre-application consultation with the CAA and Edinburgh
Airport Ltd which has confirmed that there is no need for the stack to be
illuminated for the purposes of airfield safeguarding.
4.2.57 It is suggested that the detailed lighting design is the subject of a planning
condition.
CCTV
4.2.58 A CCTV system will be installed then maintained and operated in accordance
with British Standard 7958:2005 - Closed Circuit Television {CCTV}
Management and Operation [Code of Practice] and CCTV cameras will be
positioned to give clear surveillance around the perimeter of the development.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 57
4.2.59 This will be monitored 24/7 to ensure the security of the site and management
of the site is not compromised.
4.2.60 CCTV cameras will be mounted on lighting columns, canopies and to the
building where appropriate to ensure that comprehensive coverage is
achieved.
Security Fencing and Gates
4.2.61 The site layout has been designed with the following considerations:
A 2.4m anti-climb welded mesh security fence will provide a secure
barrier preventing access into the operational site beyond the
designated access control point in front of the gatehouse which will also
have gated control for securing the site during out of hours;
A secondary 2.4m high anti climb welded mesh security fence will
secure the staff/visitor access road and car park from the perimeter
multi-use path but will be open during daytime operations adjacent to
the front entrance to the Visitor Centre and via gates opening over the
Visitor Centre terrace and ornamental pond;
With a large part of the site being made accessible as public amenity
area the main security fence is set some way back from the sites part-
west/south/part-eastern boundaries and an additional 1.2m high timber
post and rail fence will be located along the sites perimeter in that
instance;
A further 1.2m high metal estate railing fence will separate the 3m wide
multi-use path and the publically accessible landscaped area and run
from the sites south west corner up to the Visitor Centre.
4.2.62 Details of the fencing and gating proposed on the site are provided on Figure
4.16.
Landscaping
4.2.63 The development includes a comprehensive landscape scheme the indicative
layout of which is illustrated on Figure 7.4.
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4.2.64 The landscape scheme has been developed with the aim of achieving a
number of objectives including:
To provide an appropriate setting for the operational development
including security measures and drainage infrastructure;
To create accessible public space which assists in integrating the facility
into the surrounding landscape, provides an amenity for the community
and a resource for staff and visitors;
To maintain and where possible enhance levels of biodiversity across
the site.
4.2.65 Much of the site is currently covered with native semi-natural woodland and is
indeed listed by the Forestry Commission Scotland as an area of lowland
broadleaved deciduous woodland, a priority habitat. In reality, the woodland is
of poor quality, consisting of mainly silver birch with frequent goat willow and
occasional Scots pine. The age of the trees ranges from saplings to
approximately 20 to 25 years. The trees are growing on impoverished soils
(largely railway ballast) and range from fair to predominantly poor condition
showing signs of the effects of growing in a derelict industrial and disturbed
environment.
4.2.66 The majority of the site would be cleared in advance of construction (as was
proposed for the PPiP scheme). In order to preserve as much of the existing
biodiversity as possible, it is proposed that following felling of trees, the upper
soil layers (not topsoil as such, but rather remnant post-industrial substrates
with whatever organic matter has built up over time) would be ‘scraped’ to a
depth of around 200mm and the arising’s deposited in mounds for later re-
use. The aim of this process would be to safeguard the organic matter,
existing seedbank and existing soil fauna etc. There is no existing topsoil
resource on site and it is not anticipated that any would be imported. Instead,
existing site material will be site blended with imported organic matter (green
waste compost or similar) to create manufactured soils suitable for vegetation
establishment. Such material would be loose tipped to the required depths
over prepared (free draining and de-compacted) ground in order to ensure
that a functional rooting zone is created. It is anticipated that the stockpiled
surface material would be used for loose spreading at the surface and that it
would be used preferentially within areas proposed for woodland and
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 59
grassland. Specific measures would be incorporated to accommodate
particular ecological interest. For example building wood and stone habitat
piles to encourage common lizard, which is known to occur in the wider area.
4.2.67 An important element of the landscape scheme proposals is the manner in
which security has been delineated in order to allow a greater degree of public
access. Achieving a secure site is a requirement of waste management site
licensing. On this basis, the operational area is enclosed by a 2.4m high
weldmesh fence. The applicant has worked to ensure that this secure area is
drawn as tightly as possible around the operational components of the
Proposed Development in order to allow as much as possible of the site to be
fully accessible to the public. Consequently, an area of approximately two
hectares of new public open space would be created alongside the Proposed
Development. A key component of the new public space would be its
connectivity. A new pedestrian link around the west and north site boundaries
would provide access to and from the Proposed Development for staff and
visitors, but would also provide a new physical link between the existing and
emerging Shawfair communities to the west of the site (including the recently
constructed Borders Railway station) and destinations to the east and north of
the site, including the settlement of Musselborough and emerging employment
land allocations. This connectivity and the resultant increase in use of the site
throughout the day and night will improve the natural safety and security of the
new facility through active use and the attendant passive surveillance.
4.2.68 The Visitor Centre is described in more detail above. The building has been
positioned with a south facing terrace looking along an ornamental water
body. The landscape to the south of the visitor centre would host further
ponds that would function as the sites sustainable drainage system and
provide attenuation during storm events. A network of footpaths would provide
recreational routes through a variety of woodland, grassland and wetland
habitats, with planting of trees, hedgerows and woodland around the periphery
of the open space partially screening the security measures whilst still
allowing some intervisibility with the operational site. There is potential for the
new open space to become part of the visitor centre offer, with an interpreted
nature trail laid out along the path network to provide an additional activity for
school parties. There is good potential for this new open space to be part of a
larger open space utilising land to the west and south. Development proposals
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 60
for these off-site areas are not yet finalised but the applicant is open to
discussion regarding the final treatment of the south and west boundaries of
the Proposed Development in order to accommodate a joined up solution.
4.2.69 North of the Visitor centre there would be a car park for use by staff and
visitors with provision for groups arriving by bus or coach. The car park would
be reached using a tree lined driveway linked to the site entrance at the north
east corner of the Proposed Development site. The boundary between the
arrival zone and the operational site, whilst secured by a 2.4m fence, is
deliberately left open to allow clear views of the vehicle movements that are
fundamental to the sites operation.
4.2.70 There would be a substantial area of woodland habitat (approximately half a
hectare), within the security line to the east of the facility. This would consist of
a mix of retained existing tree cover and new planting and would be actively
managed for the duration of the operation of the Proposed Development
alongside the public habitat areas. New planting would replicate the existing
species mix in order to perpetuate habitat suitable for the existing bird
populations. The secure nature of this part of the site is likely to be beneficial
to wildlife in providing a refuge, with considerably less disturbance than would
occur in the publically accessible areas.
4.2.71 It is suggested that the detailed design of the landscape scheme be controlled
through a suitably worded planning condition.
4.3 Proposed Site Operations
4.3.1 The following text describes the operations and processes that would be
undertaken at the Millerhill RERC and should be read in conjunction with the
schematic process flow diagram shown on Figure 4.17.
Waste Reception and Handling
4.3.2 Incoming refuse collection and bulk transport vehicles would enter the site
from the internal access road which provides access from Whitehill Road.
Having entered the site vehicles would proceed to the weighbridge, where the
quantity of incoming waste would be checked and recorded. Vehicle loads
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 61
would be inspected periodically at the weighbridge to confirm the nature of the
incoming wastes.
4.3.3 A dedicated quarantine area would be provided at the site entrance
(immediately after the inbound weighbridge) for any unacceptable or rejected
waste material. This material would be loaded into open-top containers,
covered and transported to a suitable disposal facility.
4.3.4 After weighing, the vehicles would continue along the internal site road that
leads to the northern side of the main building. Vehicles delivering waste
would proceed to the northern elevation of the main building to the enclosed
waste reception / tipping hall. When ready to tip, the lorries would be directed
to reverse into a vacant tipping bay to discharge their load into the waste
bunker. On completion of the tipping operation, the vehicles would leave the
waste reception / tipping hall. The vehicles would then proceed on the internal
site road, in the opposite direction to their arrival, to the outbound weighbridge
to record the weight of the vehicle prior to leaving the site.
4.3.5 The tipping hall would be approximately 44.9m wide and 19.8m in depth and
incorporate 6 tipping bays, each about 4m wide. The entry and exit doors
would be equipped with manually operated ‘rapid closing’ vertical folding
doors, which would be kept closed when delivery of waste is not taking place.
4.3.6 The refuse bunker would be of a concrete construction and housed within the
bunker hall in the main building. The refuse bunker would measure
approximately 14m by 30.10m and extend approximately 8m below ground
level. The bunker would be capable of accommodating 3,371m3 or
approximately 1,264 tonnes of waste.
4.3.7 The bunker would be split into two distinct areas, one area for the receipt of
contract waste and another for the receipt of direct delivered SRF. Upon
delivery to the site the contract waste would be directed to the MT facility
where further recyclable and reject material would be removed and the waste
formed into an SRF. Once formed into an SRF, the waste material would be
returned to the bunker with the direct-delivered SRF material for thermal
treatment. The MT process is described in more detail later in this sub-section.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 62
4.3.8 Above the storage bunkers would be two overhead travelling cranes equipped
with petal grabs, each with a capacity of approximately 6 tonnes (including the
weight of the hoist and grab). One of the cranes would be used for the transfer
of material into the hopper for the MT facility, the other would be used to mix,
stack and load the SRF into the feed chutes for the furnaces. The cranes
would be operated by dedicated crane operators, located in an operations
room overlooking the bunkers. CCTV cameras would be installed above the
furnace charging chute to ensure maximum visibility.
4.3.9 Odour and dust in the tipping hall would be controlled by forced draught fans
located above the bunker. These would draw air from the bunker hall and
boiler hall into the furnace to feed the combustion process creating a slight
negative pressure which would prevent odours, dust or litter from escaping
from the building. Anaerobic conditions within the refuse bunkers, which could
cause odour, would be prevented by regular mixing of the waste by the crane
operators.
4.3.10 Following loading into the feeding chute by the petal grabs, the SRF would be
transferred onto the grate by hydraulically powered feeding units. The
backward flow of combustion gases or the premature ignition of the SRF
would be prevented by keeping the chute full of waste and by keeping the
furnace under negative pressure. A level detector would monitor the amount
of SRF in the feed chute and an alarm sounded if the level of SRF falls below
the safe minimum level. Secondary air would be injected from nozzles in the
walls of the furnace to control flame height and the directions of air and flame
flow. The feed rate to the furnace would be controlled by a combustion control
system.
Mechanical Treatment Process
4.3.11 The MT facility would have a dual function by recovering recyclable materials
(specifically ferrous and non-ferrous metals) from the incoming waste and the
preparation of the waste as a SRF for use in the ERC.
4.3.12 The MT process has been specifically designed to recover ferrous and non-
ferrous metals from the incoming residual waste material, sort them into their
separate fractions and remove any reject materials that are unsuitable for
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 63
either recycling or the thermal treatment process. Following the MT process
the recyclable elements would be sent for onward transhipment to appropriate
reprocessing facilities, the reject materials sent to a suitable disposal facility
and the remaining material forming an SRF which would be conveyed back
into the waste bunker prior to transfer into the ERC.
4.3.13 The process would comprise a series of conveyors with mechanical sorting
equipment, such as screens and automatic sorters. A description of the typical
components of the MT facility and likely process line is provided below.
The contract waste would be deposited in the waste bunker where any
prohibited material or material unsuitable for processing through the MT
or thermal treatment processes would be removed. Any materials that
could not be re-used, recycled or recovered would be disposed of at
landfill (in accordance with the waste hierarchy);
The waste would then be fed from the waste bunker into a hopper and
coarse shredder;
The shredded material would be passed through a trommel screen to
remove undersized (<120mm) and oversized (>120mm) material for
metal extraction;
The undersized material would pass underneath an over-band magnet
to recover ferrous metals which would then be conveyed to the ferrous
metal collection container;
The remaining undersized material would pass through an Eddy Current
Separator to remove aluminium particles which would then be conveyed
to the non-ferrous (aluminium) collection container;
The oversized material would also pass underneath an over-band
magnet to recover ferrous metals, which would then be conveyed to the
ferrous metal collection container;
After the metals have been removed the remaining, treated, material
would be conveyed (as an SRF) to the SRF bunker; and
The MT facility would also include a Baler which would allow for the
treated SRF material to be wrapped and baled for storage (in the on-site
bale store) during periods of planned maintenance.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 64
4.3.14 The precise internal arrangement of the equipment would be determined by
the contractor at the detailed design stage to optimise the use of space and to
give adequate access to the equipment for repair and maintenance.
Shredders
4.3.15 The shredder at the start of the MT process would reduce input waste to a
particle size of less than 300mm in order to make it a more manageable for
other process equipment. Components of the shredders requiring frequent
maintenance would be easily accessible, easily removable and replaceable.
Conveyors
4.3.16 The conveyor system would be designed so that material flow is uniform
across and along the conveyors and there is minimal spillage or accumulation
of debris in / or around the equipment. The number and types of conveyor
would be kept to a minimum. Access under conveyors with clearance heights
of greater than 2.7m would be designated unrestricted access ways. Access
under conveyors with a clearance height less than 2.7m would be designated
restricted access ways and guards would be put in place. Debris dropout
points would be designed such that material cannot fall onto operational staff.
The dropout points would be positioned such that debris can be removed
easily and safely without staff accessing moving parts.
Trommel
4.3.17 A Trommel would be installed with variable speed control. Safe access would
be provided to the internal parts of the Trommel to enable maintenance and
cleaning. This would screen the material according to size and in this case
into material that is greater or less than 120mm.
Overband Magnet
4.3.18 The overband magnet would remove ferrous metal from the waste stream and
eject it into a container for recovery. All areas before and after the overband
magnet, including all guards, shoots and fixings would be constructed from
non-magnetic material. The overband magnets would be designed to remove
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 65
circa 90% by weight of ferrous metal entrained within the input material
stream.
Eddy Current Separator
4.3.19 The Eddy Current Separator uses a powerful magnetic field to induce a
change in magnetic flux into cans / other aluminium material when they fall off
the end of the conveyor. Powerful magnets contained within the discharge
head roll of the conveyor move against each other and affect the Eddy current
force causing the change in Magnetic Flux. The ‘swirling currents’ created
then act to oppose the change in magnetic field being applied which causes
the aluminium material to be thrown to the far end of the discharge chute and
deposited onto a conveyor and the aluminium collection container. The other
material passing through the eddy current would be conveyed to the SRF
Bunker.
Baler
4.3.20 The baler will allow for SRF to be wrapped and stored, whilst the ERC is
undergoing maintenance. The baler would be capable of processing up to 30
tonnes of waste each hour. Finished bales would be ejected onto a bale
conveyor that holds up to 3 finished bales before being transferred to the Bale
Store.
Combustion Process
4.3.21 The proposed facility would use a moving grate which comprises inclined fixed
and moving bars that move the waste from the feed inlet to the residue
discharge. The grate movement turns and mixes the waste along the surface
of the grate to ensure that all waste is exposed to the combustion process.
The start-up burners (which typically operate for up to 16 hours during a start-
up event) would be gas fuelled using low sulphur gas oil. There should be only
two start-ups per year following planned maintenance activities.
4.3.22 Primary air for combustion is fed to the underside of the grate by a single
inverter-driven fan. Secondary air is also admitted above the grate to create
turbulence and ensure complete combustion with minimum levels of oxides of
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 66
nitrogen (NOx). The volume of both primary and secondary air is regulated by
a combustion control system.
4.3.23 The combustion control system regulates combustion conditions (and thereby
minimises the levels of pollutants and particulates in the flue gas before flue
treatment) and controls the boiler. The furnace is also fitted with auxiliary
burners, fuelled by low sulphur gas oil, which would automatically maintain the
temperature above 850oC, should temperatures start to fall below this level.
However, this rarely occurs. Combustion chambers, casings and ducts, and
ancillary equipment are maintained under slight negative pressure to prevent
the release of gases. The plant would meet the requirements of the Industrial
Emissions Directive (IED), which would be reflected in the PPC Permit for the
facility.
4.3.24 During operation the temperature in the combustion chamber would be
continuously monitored and recorded to demonstrate compliance with the
requirements of the IED. The combustion control system would be an
automated system, including the monitoring of combustion and temperature
conditions of the grate, modification of the waste feed rates, and the control of
primary and secondary air.
Boiler Water Treatment
4.3.25 A demineralisation plant would be provided as part of the facility, this would be
located under the boiler within the building basement. Various chemicals,
including hydrochloric acid and caustic soda would be required for the
demineralisation process and for boiler water dosing to prevent corrosion.
4.3.26 The chemicals for demineralisation would be stored within a bunded area
within the demineralisation plant. Caustic soda would be delivered by bulk
tanker and offloaded into a 5m³ tank in a bund. Hydrochloric acid would also
be delivered by tanker and stored in a 5m³ bunded tank after it is vented
through a scrubber.
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Flue Gas Treatment
4.3.27 Gases generated during the combustion process would be cleaned before
being released into the atmosphere. The ERC would be served by a flue gas
treatment system and associated reagent storage silos. The treatment plant
comprises a dry absorption system that includes activated carbon injection,
dry lime scrubbing, and fabric filters. This would be designed to ensure that
the plant operates within the emission limits set out in the IED.
4.3.28 Vehicles would be required to access the FGT plant in order to deliver Air
Pollution Control (APC) reagents and export APC residues. The silos
containing the APC reagents and residues would be housed in the southern
end of the main building adjacent to the FGT plant. Vehicles would access the
silo storage area via the roadway that runs to the east of the main building.
Vehicles would drive in a clockwise direction around the northern elevation
and would access silo storage area via a door on the eastern elevation. APC
reagents and residues would be transferred by sealed pumps into and out of
the storage silos within the building. Vehicles would then exit via a door on the
western elevation of the building and proceed to the exit via the weighbridge.
NOx Reduction
4.3.29 NOx3 levels would be managed through careful control of combustion air and
selective non-catalytic reduction. This involves the injection of ammonium
hydroxide solution into the combustion chamber of the boiler. The ammonium
hydroxide reacts with both nitrogen oxide (NO) and nitrogen dioxide (NO2) to
form nitrogen and water.
Gas Scrubbing
4.3.30 Acid gases produced during the combustion process would be removed by a
dry scrubbing system, using hydrated lime as a reagent. Neutralisation of the
acid gases would take place as they react with the lime. The residual material
would be recovered at the outlet of the flue gas scrubbing system.
3 NOx is the generic term which refers to NO and NO2 gases formed during the combustion process.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 68
4.3.31 Activated carbon would also be injected into the flue gas duct to minimise the
flue gas emissions of dioxins, mercury and other heavy metals.
Fabric Filtering
4.3.32 After flowing through the gas scrubber, the gases would be drawn through a
fabric bag filter to remove particulates, including lime and activated carbon
particles. The fabric filter would be divided into at least four separate
compartments allowing for maintenance as described below. The treated flue
gas passes through an induced draught fan into the stack for release to the
atmosphere.
4.3.33 Regular bag filter cleaning would be performed on-line by pulsing compressed
air through the filter bags. The residues are known as APC residues and
would be collected in fully enclosed hoppers beneath the filters.
4.3.34 Bag failure, albeit it an infrequent occurrence, would be identified by a sudden
increase in particulate concentration at particulate meters installed
immediately downstream of the bag filter. The compartment containing the
failed bag would be isolated and then replaced. The plant would be capable of
operating at full capacity with one compartment off-line whilst maintenance
was being undertaken. Spare bags would be held on site and installed
immediately after a failure occurs.
Stack
4.3.35 Following cleaning, the combustion gases would be released into the
atmosphere via the stack. Emission from the stack would be monitored
continuously by an automatic computerised system and reported in
accordance with the SEPA’s requirements for the operation of the facility. The
proposed stack would be integrated within the structure of the main building. It
would be 75m high from ground level. Details of the stack height and air
quality modelling are provided in the Air Quality Assessment contained within
Appendix 12-1.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 69
By-Product Handling and Disposal
4.3.36 Two types of solid by-products would be produced from the operation of the
EfW facility, bottom ash and APC residues, each of which would have
separate handling and disposal arrangements as described below.
Bottom Ash
4.3.37 Bottom ash is the inert burnt-out residue from the combustion process and
approximately 6 tonnes per hour of bottom ash would be produced at full load.
The volume of bottom ash generated equates to approximately 25% of the
overall volume of the waste managed at the site. Bottom ash typically
comprises a mixture of glass, brick, rubble, sand, grit and metal as well as ash
from combusted waste.
4.3.38 Bottom ash would be quenched as it leaves the combustion chamber to both
cool the ash and also reduce potential for emissions of ash (dust) into the air.
Any water not vaporised in the quenching process would be collected and
recycled for continued use in the quenching process. The bottom ash would
be fed onto a conveyor that would transport it to the bottom ash hall within the
eastern elevation of the building. The bottom ash would then be collected from
the floor of the bottom ash hall using a front end loading shovel and
transferred to a container for collection and transfer off-site.
4.3.39 The ash material would be processed off-site at a dedicated ash processing
facility where it would be processed into a recycled aggregate which would act
as a direct replacement for virgin aggregate.
Air Pollution Control (APC) Residues
4.3.40 APC residues comprise fine particles of ash and residue from the flue gas
treatment process, which are collected in the bag filters. It is estimated that
the operations would generate approximately 0.5 tonnes of APC residues per
hour which equates to approximately 2.8% of the overall volume of the waste
managed at the site. APC residues would be stored in a silo within the flue
gas treatment facility.
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4.3.41 Due to the alkaline nature of the APC residues, they are classified as
hazardous waste (in much the same way as cement). The APC residues
would be transported off-site to a Permitted Hazardous disposal facility or,
alternatively, the residues may be taken to an appropriate treatment facility
where, for example, they could be re-used in the stabilisation of acid wastes or
in cement manufacture.
Raw Materials Handling and Storage
4.3.42 Apart from treating non-hazardous waste, the plant would use various raw
materials during processing. Primarily, these would include hydrated lime,
ammonium hydroxide solution, activated carbon and gas oil. Table 4.2
indicates the processes in which they would be used, the table also provides
estimates of the rates of use. The materials would be stored within
appropriately designed silos either within or adjacent to the facility.
Table 4.2: Proposed Raw Material Usage and Storage
Raw material (if required) Process Typical Rate of Use
Hydrated Lime CA(OH)2 FGT – acid gas scrubbing Approx 1,933 tonnes / annum
Ammonium Hydroxide NH4OH FGT – NOx reduction Approx 635 tonnes / annum
Activated Carbon FGT – dioxins / heavy metal Approx 66 tonnes / annum
Low Sulphur Gas Oil System firing Approx 180 tonnes /annum
4.3.43 In addition, various other materials would be used for the operation and
maintenance of the plant including:
Hydraulic oils and silicone based oils;
Electrical switchgear;
Gas emptying and filling equipment;
Refrigerant gases for air conditioning plant;
Glycol / anti-freeze for cooling;
Oxyacetylene, TIG, MIG welding gases; and
CO2 / fire-fighting foam agents.
4.3.44 In order to minimise the risks of contamination to process and surface water,
all liquid chemicals stored on site would be kept in bunded controlled areas
with a volume of 110% of stored capacity.
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4.3.45 In addition to the raw materials described above, the facility would require
materials necessary to maintain the boiler water demineralisation plant, these
include:
Hydrochloric acid (35% solution);
Caustic soda (30% solution); and
Boiler water dosing chemicals.
4.3.46 These materials would be used both in the demineralisation process and for
boiler water dosing to prevent boiler tube corrosion and would be stored in an
appropriately bunded area within the demineralisation plant, in the main
building.
Employment
4.3.47 The plant would provide permanent employment for up to 39 people, working
in shifts to maintain 24-hour / 7-day per week cover. The majority of
employees would be skilled operatives (electricians / fitters / crane operatives)
or technical engineers (control and plant).
4.3.48 It is anticipated that the proposal scheme would be operated by a total daily
staffing level of the order of 30 staff, broken down into a number of shifts.
Peak day time staffing levels on site are predicted to occur during the early
afternoon shift change period (13:00-14:00) when up to 22 staff could be
present on site. The EfW facility could be expected to operate a three shift
system (5 staff per shift) to support 24 hour operation of the plant, with the MT
facility operating a two shift system (1 staff), reflecting the 05:00 – 23:00
operating hours of this element of the Proposed Development. Up to five office
/ management staff could be expected to work a more traditional 08:00-17:00
weekday pattern.
Hours of Operation
4.3.49 It is proposed that the proposed ERC element of the Proposed Development
would operate on a 24 hour, 7 days a week basis. However, the plant would,
be expected to shut down for occasional short term periods to allow the
carrying out of essential programmed maintenance work – albeit that waste
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 72
deliveries would likely continue to the site during these times, with waste
stored within the on-site bunker / baled waste storage facility.
4.3.50 Waste input & ash export vehicle movements to / from the site could take
place on a 7 day per week basis, with deliveries of municipal waste to the site
extending to 363 days per year (i.e. not including Christmas Day or New
Year’s Day). However, in practice, commercial & industrial waste,
consumables and process exports / recycling would likely be transported to /
from the site on a Monday – Saturday basis, representing a 300 delivery days
per year.
4.3.51 It is anticipated that the mechanical treatment facility would operate between
05:00 and 23:00.
4.3.52 Typically the majority of waste input movements could be expected to take
place during weekday daytime hours 08:00 – 20:00.
Vehicle Numbers
4.3.53 On the basis of the predicted tonnage figures for the Millerhill RERC (set out
previously in this ES Chapter), it is anticipated that the proposed development
would generate in total 128 daily HGV two-way movements (i.e. 64 in plus 64
out). This includes all HGV movements associated with the delivery of waste,
consumables and the removal of residues and recyclables from the site.
4.3.54 A detailed breakdown of the anticipated vehicle numbers associated with the
proposed development, including staff vehicle demand is provided within the
TA) which is provided within Appendix 6-1.
4.4 Energy Recovery
4.4.1 One of the major benefits of the ERC would be the ability to recover energy
from the combustion of the SRF by way of electricity and heat production. For
the avoidance of doubt, the development proposal includes for electricity
generation and export to the grid, but the connection to the local electricity
distribution network is not included within the formal application itself. This
would be delivered through a separate consenting process as described
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 73
subsequently. However, this ES does consider the potential environmental
effects of implementing a grid connection.
4.4.2 Similarly the planning application includes for the generation of heat. As with
electricity connectivity above, the distribution of heat to potential users is not
included within the development proposals. A detailed HPR has been
prepared in support of the planning application (see Part 6 of the PAD) and in
accordance with the guidelines set out within Annex B of the SEPA’s Thermal
Treatment of Waste Guidelines. The HPR provides details of the heat
recovery process, how the heat may be supplied and used by customers, an
estimate of the amount of heat that may be generated and a summary of
discussions held to-date with potential heat users. However, until such time as
the Proposed Development attains both the necessary planning consent and
permit, heat users are unable to make a firm commitment.
4.4.3 The energy generation process is founded upon hot gases from the
combustion chamber passing to a boiler which converts the energy from the
gases into steam. The boiler would be located above the grate and the plant
would generate approximately 76 tonnes of steam per hour.
4.4.4 The ERC would include a steam turbine that would have a generation capacity
of up to 13.45MW of electricity 11.09MW of which would be available for
exported to the local supply grid (the grid connection is discussed
subsequently) with the remainder (2.36MW) used in the operation of the
facility. The turbine would be able to generate an estimated 103,590 megawatt
hours per year (MWh/yr) of electricity (based upon 90% availability i.e.
operating for 7,900 hours in a year). Approximately 87,012 MWh/yr would be
exported to the local grid and the balance would be used to provide power
within the facility itself.
4.4.5 The ERC would also have the capability to export heat to local heat users. To
facilitate this, the turbine would be equipped with steam extraction points to
allow low pressure steam to be supplied directly to consumers, or to be
condensed in heat exchangers in order to provide hot water.
4.4.6 The facility would be able to generate up to 20MW of heat in the form of steam
which would be available for export to a heat network. This would provide an
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 74
estimated 158,000 MWh/yr of heat (based upon 90% availability i.e. operating
for 7,900 hours in a year) for export to a district heating network.
Renewable Energy Generation
4.4.7 It is important to note that a proportion of the energy (both electricity and heat)
created from the combustion of municipal and commercial and industrial
waste is classed as renewable. This is manifest in a number of key legislative
and policy documents including the EU Renewable Energy Directive ‘on the
promotion of the use of energy from renewable sources’ (ref: 2009/28/EC).
This defines energy from renewable sources as meaning: “… energy from
renewable non-fossil sources, namely wind, solar, aerothermal, geothermal,
hydrothermal and ocean energy, hydropower, biomass [our emphasis],
landfill gas, sewage treatment plant gas and biogases.” Furthermore, this
directive defines ‘Biomass’ as meaning “… the biodegradable fraction of
products, waste and residues from biological origin from agriculture (including
vegetal and animal substances), forestry and related industries including
fisheries and aquaculture, as well as the biodegradable fraction of
industrial and municipal waste [our emphasis].”
4.4.8 At a national level, the use of waste to generate renewable energy is
recognised in Scotland’s ZWP4 which sets out an overarching mission and a
strategic objective to: “Recover and utilise the electricity and / or heat from
resources which cannot be reused or recycled for greater environmental or
economic benefit, in line with Scotland’s renewable energy goals.”
4.4.9 With regard to the fraction of waste that represents a renewable energy
source, the Renewable Heat Incentive (RHI)5 states: “Energy from waste
combustion (the biomass proportion of municipal waste) rather than being
sent to landfill the waste we produce can be reused, recycled or burned to
produce heat. More than half of the rubbish households throw away is organic,
renewable matter, such as food or paper products. Although it is usually better
from an environmental perspective to reuse, recycle or produce biogas from
these materials, this is not always possible and combustion can offer a better
4 Scotland’s Zero Waste Plan, published June 2010, by The Scottish Government
5http://www.decc.gov.uk/assets/decc/What%20we%20do/UK%20energy%20supply/Energy%20mix/Renewable%20energ
y/policy/renewableheat/1387-renewable-heat-incentive.pdf (page 35)
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 75
option than disposal to landfill, which generates harmful greenhouse gas
emissions. Due to its renewable biomass proportion, currently around half the
heat produced by burning municipal waste is renewable heat.”
4.4.10 The RHI goes on to state: “Participants who burn MSW will receive the
biomass tariff, adjusted pro-rata for the solid biomass content of their waste.
Unless participants prove a higher percentage of biomass content, the pro-
rata content will be deemed at 50 per cent.” This indicates that 50% is
considered to be the minimum proportion of the waste which is considered
biomass, and therefore the minimum proportion that is a renewable energy
source (i.e. at least 50% of the electricity and the heat generated from the
combustion of municipal and commercial and industrial waste is classed as
renewable).
4.4.11 In reality, the 50% figure would be exceeded, but the actual figure would
depend upon the precise composition of the waste to be treated. For the
purposes of this scheme, based upon predicted waste compositional analysis,
a conservative figure of 55% renewable energy has been adopted.
4.4.12 On the basis that it is estimated that circa 55% of this would be renewable, up
to 7.4MW (56,974MWh/yr) of renewable electricity and 11MW
(56,974MWh/yr) or renewable heat would be generated by the facility
Recovery Operations
4.4.13 Whilst the ERC would recover energy from waste, waste combustion facilities
(i.e. incinerators) are only classed as ‘recovery’ operations (as opposed to
‘disposal’ operations) if they meet a specified energy efficiency as set out in
the revised Waste Framework Directive (ref: 2008/98/EC), enacted in
Scotland through: The Waste Management Licensing (Scotland) Regulations
2011. The Directive includes specific definitions of ‘disposal operations’ and
‘recovery operations’, whereby:
Disposal: “… means any of the operations listed in Part II of Schedule 4,
and any other operation relating to waste which is not recovery even
where it has as a secondary consequence the reclamation of
substances or energy, and any reference to waste being disposed of is
a reference to its being submitted to any such operations;”
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Recovery: “…means any of the operations listed in Part III of Schedule
4, and any other operation the principal result of which is waste serving
a useful purpose by replacing other materials which would otherwise
have been used to fulfil a particular function, or waste being prepared to
fulfil that function, in a plant or in the wider economy, and any reference
to waste being recovered is a reference to its being submitted to any
such operations”
4.4.14 Part III of Schedule 4 of the Directive includes R1, which is defined as: “use
principally as a fuel or other means to generate energy.” A footnote to this
definition states that: “This includes incineration facilities dedicated to the
processing of municipal waste only where their energy efficiency is equal to or
greater than … (ii) 0.65 for other installations” [that is other than those under
part (i) being permitted before 1st January 2009], and defines energy efficiency
using a formula, set out in Annex II of the Waste Framework Directive (WFD),
which takes into account the differing benefits of electricity generation and
heat generation.
4.4.15 Applying this formula gives an energy efficiency factor of 0.70 for the
proposed ERC when only exporting electricity (as opposed to heat, or heat
and electricity in combination). Export of heat would significantly increase the
energy efficiency factor (it would be 0.99 with the export of 20MW of heat and
circa 6.75MW of electricity). This confirms that the operation of the plant would
be defined as a recovery operation.
4.4.16 As alluded to above, Annex II of the WFD restricts the scope of the formula to:
“facilities dedicated to the processing of Municipal Solid Waste” so it does not
effectively apply to plants that are dedicated to incineration or co-incineration
of hazardous waste, hospital waste, sewage sludge or C&I waste. Whilst it is
anticipated that the Millerhill RERC development would receive some C&I
waste, the main purpose of the facility would be for the processing of mixed
municipal solid waste for energy recovery, thus the R1 calculation is relevant.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 77
Summary
4.4.17 In summary the Proposed Development:
would generate electricity, more than half of which would be classed as
renewable;
would be designed with the potential to generate heat for export and use by
local heat users;
would be defined as a ‘recovery’ operation in the revised EU Waste
Framework Directive; and
has the opportunity to provide heat off-take to a number of sources locally.
4.5 Operational Environmental Management
4.5.1 The potential effects of waste management developments can be the subject
of public concern (i.e. nuisance caused by litter and odour), or through the
attraction of vermin or other pests. However, a modern, well run facility, such
as the Millerhill RERC, should not give rise to such issues.
4.5.2 The site would be operated under a Planning and Pollution Control Permit
(PPC Permit), issued and monitored by the SEPA. The Permit would identify
the potential for effects upon public amenity and ensure that management
measures are adopted to minimise these effects and that the Millerhill RERC
does not give rise to unacceptable environmental harm.
4.5.3 The potential impacts of the Millerhill RERC development and associated
mitigation are described in detail within Chapters 6.0 to 17.0 of this ES.
Notwithstanding, the identified additional mitigation measures identified within
these Chapters, this section considers the standard measures that would be
employed to manage and monitor the following potential public amenity issues
at the site:
Vermin and Pests;
Dust and Odour;
Fire; and
Litter.
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Vermin and Pests
4.5.4 All waste would be delivered to the enclosed Reception Hall and deposited
within the appropriate storage areas (described in Sub-section 4.3 above).
Regular inspections of the site would ensure litter within and adjacent to the
site that could attract vermin would be collected and disposed of. In addition,
the Reception Hall would be cleaned daily to ensure that material that could
attract rodents or other pests does not accumulate.
4.5.5 A vermin control programme would be put in place and inspections of the site
by pest control specialists would be undertaken if any rodent or other pest
issues were identified.
Dust and Odour
4.5.6 Whilst odour sources do occur at EfW facilities, odour complaints and escape
of odours at EfW facilities beyond the site boundary are unlikely on the basis
that all operations occur within an enclosed building. Odours would be
prevented from escaping the tipping hall and waste bunker, which is where
most odour issues are likely to arise, as the air within the building is retained
under negative pressure. This is achieved through the extraction of air from
the tipping hall by forced draught fans which feed the combustion process.
4.5.7 The handling operators would be trained to operate a FIFO (first in first out)
system, so that waste is not routinely kept in the waste bunker for longer than
two to three days. In addition, anaerobic conditions within the refuse bunkers,
which could cause odour, would be prevented by regular mixing of the waste
by the crane operators. An activated carbon filter unit would also be installed
to prevent odour issues during any shutdown period. A separate odour filter
would also be installed in the MT facility, which would operate during a
shutdown period, to ensure that odour is not released during the baling of
waste.
4.5.8 No odours would be emitted from the stack as all odorous compounds would
be destroyed due to the high temperatures achieved (850oC) within the
furnace. Deliveries of biogenic waste, which could give rise to odour, would be
within enclosed or sheeted delivery vehicles. All delivery vehicles entering the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 79
site would be inspected by the gatehouse operator to ensure that they are
appropriately enclosed. Any drivers failing to comply with site regulations
would be warned and breaches reported in the Environmental Management
Plan (EMP) for the site (required as part of the PPC Permit). If repeated
offences occur then drivers would be banned from accessing the site.
4.5.9 Odour surveys would be undertaken if any complaint from neighbours in
relation to odours is received. If necessary, operating procedures would be
amended to deal with any issues identified at the site.
4.5.10 Dust emissions from the site are unlikely to occur as all process operations
are undertaken within enclosed buildings. Dust arising from vehicle movement
is unlikely as all trafficked areas would be hard surfaced. During prolonged
periods of dry weather the site roads would be washed, if the potential for
fugitive dust impacts resulting from traffic movements are identified by the
facility’s general manager.
4.5.11 Bottom ash storage, handling and loading would occur within an enclosed
building. The doors of the bottom ash processing facility would remain closed
other than for access to vehicles collecting material for transport off-site. Air
vented from the bottom ash processing building would be filtered before being
released to the atmosphere by means of a bag filter system (or any other
system with at least same performance levels, such as air cyclones, jet
system or multi-venturi), again further mitigating the potential for dust release
from the facility.
Fire
4.5.12 Whist extremely unlikely, it is possible that waste loads being received at the
site may comprise elements of smouldering waste. The site management plan
would have procedures in place to deal with such events and records of any
smouldering load incidents would be made within the EMP and monthly facility
service reports. A dedicated area would be provided within the facility that
would be equipped to receive and extinguish smouldering loads delivered to
the facility.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 80
4.5.13 Once deposited in the waste bunker the waste would be inspected by the
crane operator and as described above the waste would be mixed regularly to
avoid anaerobic conditions developing within the waste mass. Inspections and
regular mixing of the waste would help identify and prevent hot spots forming
within the waste mass which could cause a fire.
4.5.14 Fire prevention and suppression systems would operate at the facility. This
may include the use of a specific water deluge system within the waste bunker
and a fire water sprinkler system.
Litter
4.5.15 FCC would maintain the site in a clean and tidy condition and measures would
be defined within the EMP to prevent the release of litter from the facility
buildings and from the site boundary.
4.5.16 All vehicles carrying waste to the site would be required to be adequately
covered, thus avoiding problems associated with litter escaping onto the
public highway, or other areas outside the boundary of the site. Drivers would
only be allowed to un-sheet vehicles upon entering the waste hall. As
described above any drivers failing to comply with site regulations would be
warned and breaches reported in the site EMP. If repeated offences occur
then drivers would be banned from accessing the site.
4.5.17 All unloading of waste would be undertaken within the enclosed waste
reception hall, which, as described above would be controlled under negative
air pressure. This would assist in preventing any litter from escaping the
building.
4.5.18 The boundary of the operational areas would be secured by a 2.4m high
fence. This would help prevent litter from being blown beyond the site
boundary. The internal and external boundaries of the site would be inspected
daily and any litter would be collected and disposed of.
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Conclusions
4.5.19 The site would be operated under a PPC Permit, which would ensure that any
potential effects upon public amenity are minimised. Management measures
adopted at the facility would help to prevent unacceptable environmental
effects in respect of rodents and other pests, odour, dust, fires and litter.
4.6 Proposed Contingency Plans
4.6.1 Extensive operating procedures and contingency plans would be put in place
to ensure the safe and efficient running of the Millerhill RERC. These would
cover situations such as plant failure, receipt of unacceptable waste and traffic
problems.
4.6.2 Procedures would be put in place in the event that waste cannot be delivered
to the facility for processing. For example, the plant would require essential
annual planned maintenance over a period of 2-3 weeks. Waste which cannot
be processed at the plant during this period would be baled within the MT
plant and transferred to the bale storage building until the facility is
operational. In the event of unexpected shut-down, similar procedures would
apply.
4.7 Waste Inputs
Waste Types, Sources and Quantities
4.7.1 The proposed ERC has been developed for the thermal treatment of circa
190,000tpa of residual non-hazardous waste arising within Edinburgh and
Midlothian. As set out in Chapter 3.0 of this ES (and Section 4.0 of the
Planning Statement) there is a demonstrable need for such treatment capacity
within the joint authority area.
4.7.2 The proposed ERC would cater primarily for residual MSW delivered under
contract by Zero Waste: Edinburgh and Midlothian, but capacity has also been
allowed for the treatment of residual non-hazardous waste received from
either commercial and industrial sources or municipal sources from
neighbouring local authority areas.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 82
4.7.3 Regardless of what the precise residual MSW / C&I waste split transpires to
be, the aforementioned need assessment demonstrates that there is far more
residual waste requiring treatment within the SES Region than could be
accommodated at the plant.
Understanding Waste Throughput
4.7.4 The ERC has been designed with the capacity to thermally treat circa
190,000tpa of residual waste. However, it is important to understand thermal
treatment plants, such as the ERC, are actually sized on thermal capacity, not
mass throughput, and that once a plant has been constructed its thermal
capacity is fixed for life. The relationship between mass throughput and
thermal size is dictated by the Calorific Value (CV) of the Waste. The CV
depends upon the mix of materials that is in the waste and when this is
applied to residual waste this is also related to the materials removed from the
waste by recycling. The higher the CV of the waste, the lower the tonnage
throughput of any given thermal treatment plant and vice versa (this
relationship is independent of the thermal treatment technology selected).
4.7.5 Plant availability is the number of hours per year the plant is running and
processing waste; this affects annual tonnage throughputs. Over the life of the
ERC there will be years of high availability and years of low availability.
Typically a well-run and reliable plant would average circa 90% availability.
There are 8,760 hours available in a year, for a plant averaging circa 90%
availability over a 25 year life this means that on average it would operate for
7,900 hours in a year. However, some years may have more hours and some
less. For example: a plant processing 25 tonnes per hour for 8,000 hours has
an annual throughput of 200,000 tonnes, but if the same plant only operates
for 7,500 hours (maybe due to increased maintenance needs that year) then
the throughput would reduce to 187,500 tonnes.
4.7.6 In light of the above, it should be understood that the plant throughput in any
year is a combination of three factors:
Thermal capacity;
Waste CV; and
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 83
Plant availability.
4.7.7 Given that once a plant has been constructed its thermal capacity is fixed, it is
the other two variables that determine the waste throughput profile over the
life of the plant, albeit the likely change in throughput would be very modest
even if the variables shift.
4.7.8 This is a common issue faced in planning applications for thermal treatment
plants, like the ERC, where the applicant must use the best available
information to fix a throughput figure which accurately reflects current waste
data and is supported by a need argument. It is inappropriate to assess the
effects of the scheme based upon theoretical outcomes (not reflecting the best
available data) which could modestly either reduce or increase the actual
throughput capacity.
4.7.9 As stated throughout, the overall capacity of the Proposed Development is
nominally 195,000tpa, which after removing recyclable material and rejects (at
just over 5,000tpa) gives a required thermal treatment (ERC) capacity of just
under 190,000tpa. The ERC has been designed, in terms of the thermal
capacity of its boiler, to thermally treat 190,000tpa of waste subject to the
following variables:
7,900 operating hours per year (circa 90% of the year); and
A waste net CV of 7.51 MJ/kg.
4.7.10 This is considered to comprise a realistic maximum number of operational
hours per year and towards the minimum CV for the input waste material.
Accordingly, 190,000tpa is the realistic maximum tonnage throughput that the
ERC could deliver. In reality, it is judged that the waste CV will be slightly
higher than 7.51 MJ/kg and thus the operational throughput slightly lower. For
example if the CV were actually 8.37 MJ/kg, then, based on the same 7,900
operating hours, the actual ERC capacity would be reduced to 170,000tpa.
4.7.11 The Proposed Development assessed within this planning application,
therefore represents the highest realistic throughput. Accordingly it is
considered to represent a robust, scenario in terms of vehicle movements etc.
and in terms of demonstrating the need for the facility.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 84
4.7.12 However, for the reasons identified above, whilst the Millerhill RERC facility
capacity is designed to have circa 190,000tpa capacity, the volume of waste
treated at the facility could, dependent upon the aforementioned variables, be
slightly different. For this reason, an absolute tonnage throughput restriction
should not be placed on the facility and it is suggested, as is commonly the
case, that if a tonnage restriction is placed on the permission, it provides for
the planning authority to control and agree minor variations in throughput
depending upon the prevailing circumstances.
4.8 Energy (Heat and Power) Connectivity
4.8.1 As outlined above, the ERC would recover energy from the combustion of SRF
by way of heat and electricity production. A separate HPR has been prepared
in support of the application (see Part 6 of the PAD). This sets out the currently
defined proposals for heat and power export, together with the steps required
to maximise benefits in this regard.
Heat Connectivity
4.8.2 The HPR has identifies 4 potential district heating zones within close proximity
to the Application Site. The location of the identified heat off-take opportunities
and potential routeing of a heat pipe network is illustrated on Figure 16.1. The
heat pipe network does not form part of the planning application for the
Millerhill RERC and would be authorised by either a separate planning
application or through permitted development rights. However, on the basis
that export of heat is an integral part of the scheme, it is considered
appropriate that the potential environmental impacts associated with the
delivery of the heat pipe network are assessed within the ES (refer to Chapter
16.0).
Electricity Connectivity
4.8.3 Similar to the heat pipe network, the grid connection works required to export
electricity from the ERC do not form part of the planning application and would
be authorised either under a separate formal consenting process, or under
permitted development rights, depending on the nature of the connection.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 85
However, on the basis that export of electricity is an integral part of the
scheme, it is considered appropriate that the potential environmental impacts
associated with the connection to the local electricity grid are assessed within
the ES.
4.8.4 The applicant has undertaken a Grid Connection Feasibility Study and has
consulted with the local District Network Operator (DNO) (Scottish Power
Networks) to identify potential grid connection options. The DNO has confirmed
that a connection is feasible.
4.8.5 The most likely connection would be to the 33 / 11kV Niddrie sub-station
located off the A6106 (The Wisp) to the Rear of the Jack Kane Sports Centre in
Niddrie. This would be an underground cabling connection below the existing
highway network (see Figure 16.2).
4.8.6 An assessment of the potential environmental impacts of these connection
options is presented in Chapter 16.0 of this ES.
4.9 Construction Methods
4.9.1 The following section provides a summary of the key elements of the
construction. It is not intended to be prescriptive and the exact construction
methods, phasing and programme would be determined by the appointed
contractor. However, the following description enables the key environmental
effects of the development to be assessed.
Programme
4.9.2 The timing of the construction period would be dependent on the grant of
planning permission for the proposed development and subsequent contract
negotiations. The current programme of works is based on the assumption of
a construction start date in mid-2015.
4.9.3 The construction period is anticipated to take approximately 28 months, this
includes internal fit-out and commissioning of mechanical and electrical plant.
The programmed date for the opening of the plant is early 2018.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 86
4.9.4 The core ground works including site clearance, earthworks, foundations,
drainage are likely to occur within the first five months. The erection of building
frames and the main structural works would be staggered throughout the
construction period. The first major structure to be erected would be the boiler
hall and FGT building, this would begin immediately following the main ground
works. The final building structure to be completed would be the air cooled
condensers. These structures would be erected between months 17 and 22,
towards the end of the construction period. Following completion of the
structural building works, external hardstandings including roads and car
parks would be completed along with lighting, signage and landscaping. All of
the construction works would be managed within the site.
Construction Hours
4.9.5 Construction operations would generally be limited to 07:00 – 19:00hrs
Monday to Friday and 07:00 – 12:00hrs Saturday. It is possible that some
construction activities would be undertaken outside these hours e.g. during
the internal fit out of buildings, delivery of abnormal loads. HGV movements
would not be permitted outside the hours outlined above without prior
agreement from the Waste Planning Authority (WPA) and operations would
not exceed any noise limits imposed as part of the permission.
Site Access
4.9.6 Site access would be from the new access off Whitehill Road. This access has
proved suitable for the construction of the Alauna AD plant to the north.
Main Construction Activities
4.9.7 The key construction phases of the project are described below. The
construction activities are set out in the likely construction sequence.
However, it is expected that a number of the operations would overlap and as
described above the construction of various elements of the main building
would be staged throughout the construction period.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 87
Site Preparation
4.9.8 The perimeter of the site would be secured for the duration of the construction
works by either timber hoardings or Heras (or similar) fencing.
4.9.9 A one way traffic system would be set up on site with a separate entrance and
exit providing access to/from the internal site access road. The site entrance
and exit would be gated and 24 hour manned security would operate
throughout the construction period.
4.9.10 Vegetation clearance on the site would involve the removal of a number of
immature trees and areas of scrubby grassland. Vegetation clearance would
be undertaken outside the bird breeding period (April – September) and would
take into account any other ecological constraints identified at the site.
Earthworks, Foundations and Piling
4.9.11 The construction would involve the excavation of materials at the site. The
excavations would include creation of the void for the waste bunker, turbine
condenser room and bottom ash bunker. Other excavated material would be
generated from the piling and foundation works, development of external hard
standing areas and utilities and drainage runs.
4.9.12 As described previously the landscaping scheme / noise mitigation measures
include the creation of an earth bund. The creation of these bunds, along with
the use of the arisings in road construction and development of building
platforms, would utilise the excavated material on site.
4.9.13 Provisional site investigations indicate that the excavated material would be
suitable for reuse as engineering fill or for landscaping operations.
Building Foundations
4.9.14 Foundations for the frame of the main building are likely to be founded using a
piled solution. Piling methods would be determined by the piling contractor but
could be hammer driven or rotary auger. Noise impacts from the hammer
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 88
driven option has been assessed in Chapter 11.0 as this is likely to result in
the most significant noise impacts.
4.9.15 Foundations for the ancillary buildings including the weighbridge, ACC, water
pump house and substation are likely to be strip or pad footings.
4.9.16 Building slabs would be cast in-situ and concrete would either be delivered
directly to the site via concrete mix lorry or concrete would be made from an
on-site concrete batching plant with aggregates being supplied to site by HGV.
Erection and Cladding of Building Frames
4.9.17 The buildings are likely to be of steel frame construction with the external
envelope formed from a combination of masonry blocks, cold rolled sheeting
rails, metal cladding and polycarbonate cladding. The roofs of the buildings
would be constructed of composite cladding panel.
4.9.18 Steel work would be delivered to the site by HGV. The construction is likely to
be undertaken using a series of mobile truck mounted cranes and a fixed
tower crane. Typically a tower crane with a 55 metre boom and a span of 65
meters to the hook would be used in such a construction. The height of the
tower crane would typically be 40m. The greatest lifting capacity is likely to be
provided by a large crawler (500 tonne capacity) for boiler erection.
Installation of Plant and Equipment
4.9.19 The installation of the main plant and equipment would be undertaken
following the completion of the boiler hall and FGT facility. The installation
would begin approximately 12 months after the start of construction and would
take approximately 12 months.
4.9.20 Commissioning of the plant would take a period of 7 months and would
commence following installation of the main plant. The initial commissioning
referred to as ‘cold testing’ would involve a series of tests prior to the burning
of any waste at the site. The cold testing would ensure that all systems are in
full working order prior to the thermal treatment of waste. Waste would then
begin to be imported to the site to allow ‘hot testing’ of the plant to commence.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 89
Hot testing, optimisation of the plant and performance testing would take a
period of 4 months after which the plant would be fully operational.
External Civil Engineering and Infrastructure (Roads, Car Parking Areas,
Drainage and Utilities)
4.9.21 Much of the external civil engineering works are likely to be undertaken
towards the end of the main construction works in parallel with the installation
of plant and the commissioning period. The works would comprise the laying
of access roads, the car park, external hard standing areas to the buildings
and earthworks associated with the final landscape scheme. The laying and
installation of drainage and utilities would be phased with much of the work
being undertaken in the early phases of the project. Connections and finishing
of service runs are likely to be undertaken towards the end of the construction
phase. It is likely that the external grid connection works i.e. the construction
of the cable route, cabling and any ancillary works e.g. reinforcement of
substations would be undertaken by the DNO. This work would be undertaken
in parallel with the plant installation and commissioning operations.
Site Compound and Operative Facilities
4.9.22 The site compound would be located in the northern area of the site close to
the site entrance. Parking would be provided within the northwest corner of
the site. The main storage and pre-assembly area would be within the north
east corner of the site, the area would be used for the temporary storage and
laydown of materials and plant. Further material storage and laydown areas
would be provided along the southern boundary of the site.
4.9.23 The proposed car parking would be located within two areas of the site and
would cover an area of approximately 5,500m2 in total. The car parking area
would be formed by laying stone either directly on the current ground surface,
to provide a suitable parking surface. In order to minimise the requirement for
operative car parking, buses would be provided and a car sharing scheme
would form part of the Construction Travel Management Plan (CTMP). In
addition, a new rail station has also just been constructed within the SNCD
immediately to the west of the site which could also be used by operatives.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 90
4.9.24 Appropriate bunding and environmental protection measures would be
implemented within the fuel and material storage areas situated within the
construction site. The protection measures would be defined in the
Construction Environmental Management Plan (CEMP) described in further
detail below and would be in line with the SEPA’s Pollution Prevention
Guidelines.
4.9.25 A wheel wash facility would be located at the site exit. It would be self-
contained with an integral pump house and internal settlement collection tank
and would comprise high-pressure water hoses and a power washer hand
lance.
Plant
4.9.26 The following items would be the principal elements used during the
construction period:
Tracked excavators (excavation and loading);
Articulated dump trucks;
Wheeled backhoe loaders;
HVG wagons;
Piling rigs;
Mobile cranes and telescopic handlers;
Tower cranes;
Rollers and vibratory compactors;
Generators and water pumps;
Concrete batching plant and pump; and
Cement mixer trucks.
Construction Environmental Management Plan (CEMP)
4.9.27 A CEMP would be developed for the construction period, the purpose of which
would be to manage and report environmental effects of the project during
construction. The CEMP would set out how environmental issues would be
managed in accordance with relevant legislation, regulations and best practice
guidance. It would be the responsibility of the main contractor to develop and
enforce the CEMP.
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4.9.28 The objectives of the CEMP would be to:
Highlight environmental impacts resulting from the development and
identify sensitive receptors within the development site to the
construction team;
Reduce and manage environmental impacts through appropriate
construction methods;
Reduce and manage environmental impacts through the implementation
of environmental best practice during the construction period;
Undertake on-going monitoring and assessment during construction to
ensure environmental objectives are achieved;
Provide emergency procedures to protect against environmental
damage;
Provide an environmental management structure for the construction
stage;
Recommend mechanisms to reduce risks of environmental damage
occurring; and
Consult and liaise with the SEPA, SNH, Local Authority Officers and
other stakeholders throughout the works if necessary.
4.9.29 A CEMP for a project of this nature would typically cover the following key
elements:
Drainage, water quality and hydrology;
Dust, emissions and odours;
Noise and vibration;
Health and safety / site management;
Site waste management;
Construction traffic management;
Wildlife and natural features;
Cultural heritage;
Contaminated material; and
Pollution control and emergency / contingency procedures.
4.9.30 Prior to the commencement of construction an environmental walkover
ecological survey would be undertaken to establish any changes in the
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environmental baseline since the surveys undertaken as part of the EIA and
update any of the defined construction procedures as necessary.
4.9.31 Detailed construction method statements would be developed for the key
construction phases e.g. site preparation and development of site compound,
site excavation and foundations and piling activities. The method statements
would outline the key construction processes, identify potential environmental
and health and safety risks and define appropriate mitigation measures.
4.9.32 The main contractor would have regard to the following guidelines in the
preparation of the CEMP and during the operation of the site:
Pollution Prevention Guidelines 1: General Guide to the Prevention of
Pollution (PPG1), SEPA;
Pollution Prevention Guidelines 2: Above Ground Oil Storage Tanks
(PPG2), SPEA;
Pollution Prevention Guidelines 3: Use and Design of Oil Separators in
Surface Water Drainage Systems (PPG3), SPEA;
Pollution Prevention Guidelines 4: Disposal of Sewage where no Mains
Drainage is Available (PPG4), SPEA;
Pollution Prevention Guidelines 5: Works and Maintenance in or near
water (PPG5), SEPA;
Pollution Prevention Guidelines 6: Working at Construction and
Demolition Sites (PPG6), SEPA;
Pollution Prevention Guidelines 7: Safe Storage – The Safe Operation of
Refuelling Facilities (PPG7), SEPA;
Pollution Prevention Guidelines 8: Storage and Disposal of Used Oils
(PPG8), SEPA;
Pollution Prevention Guidelines 13: Vehicle Washing and Cleaning
(PPG13), SEPA;
Pollution Prevention Guidelines 21: Pollution Incident Response
Planning (PPG21), SEPA
Pollution Prevention Guidelines 22: Incident Response – Dealing with
Spills (PPG22), SEPA;
CIRIA. Culvert design and operation guide (C689) (2010);
CIRIA. Control of water pollution from linear construction projects.
Technical guidance (C648) (2006);
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CIRIA. Environmental Good Practice on Site (fourth edition) (C741)
(2015);
CAA – Civil Aviation Publication CAP738 – Safeguarding of
Aerodromes;
AOA – Advice note AN/01 – Safeguarding of Aerodromes – Overview;
AOA – Advice note AN/02 – Safeguarding of Aerodromes – Lighting;
AOA – Advice note AN/03 – Safeguarding of Aerodromes – Birds
(Landscaping);
AOA – Advice note AN/04 – Safeguarding of Aerodrome – Cranes; and
AOA – Advice Note AN/06 – Safeguarding of Aerodromes – SUDS
(potential Bird Hazard from Sustainable Urban Drainage Schemes).
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5.0 PLANNING POLICY CONTEXT
5.1 Introduction
5.1.1 This section briefly identifies the planning policy context for the Millerhill RERC
development. The full planning policy assessment is not included in the ES
but provided by way of a separate PS included as Part 3 of the PAD. Only the
relevant policy context is summarised below.
5.2 Policy Context
The Development Plan
5.2.1 In the case of the Proposed Development, the relevant statutory Development
Plan comprises:
The Strategic Development Plan for Edinburgh and South East Scotland
(SESplan) (2013); and
The Midlothian Local Plan (1998).
Material Considerations
5.2.2 Many of the policies contained within statutory Development Plan were
adopted some time ago. As a consequence, whilst they carry statutory weight,
many have been superseded or are supplemented, in part, by elements of
subsequent national policy, guidance and other new evidence. This
information is contained within a number of documents which are considered
to be material planning considerations in the determination of this planning
application. The key documents are judged to comprise the following:
European (EU) Waste, Energy and Climate Change Policy and Legislation:
Revised Waste Framework Directive (2008/98/EC), December 2008;
Renewable Energy Directive (2009/28/EC), June 2009;
Industrial Emissions Directive (2010/75/EU), January 2011;
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Waste, Energy and Climate Change Policy and Legislation:
UK Government Policy, as relevant within Scotland:
Energy White Paper ‘Meeting the Energy Challenge’, May 2007;
The Renewable Energy Strategy, July 2009;
The Low Carbon Transition Plan, July 2009;
The Renewable Heat Incentive, March 2011;
The Renewable Energy Roadmap Update, July 2011 (including
updates);
The Carbon Plan: Delivering our Low Carbon Future, December 2011;
Planning our Electric Future: A White Paper for Secure, Affordable and
Low-Carbon Electricity, July 2011;
Scottish Government Policy:
Zero Waste Plan, June 2010;
Policy Statement: Zero Waste Regulations, October 2011;
Waste (Scotland) Regulations 2012, May 2012;
SEPA Thermal Treatment of Waste Guidelines, May 2014;
SEPA Guidance Note 6 Land Use Planning System, February 2013;
Planning Advice Note 63: Waste Management Planning, February 2002;
Specific Advice Document / Sheet ‘Energy from Waste’, February 2011;
The Climate Change (Scotland) Act 2009, August 2009;
The Climate Change Delivery Plan: Meeting Scotland’s Statutory
Climate Change Targets, June 2009;
2020 Routemap for Renewable Energy on Scotland, July 2009
(including 2013 update);
The Renewables Action Plan, June 2009 (including updates);
Electricity Generation Policy Statement, June 2013;
Scottish National Planning Policy:
National Planning Framework 3, June 2014;
Scottish Planning Policy, June 2014;
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Emerging Development Plan Documents:
Emerging Second Strategic Development Plan for Edinburgh and South
East Scotland - the latest e-bulletin update regarding the preparation of
the Plan indicates that: “The team are finalising the Main Issues Report
(MIR) and supporting documents. All statutory documents will be
considered for approval and subsequent ratification at the SESplan Joint
Committee meeting on the 18th May 2015.” It goes on to state that: “The
MIR and all supporting documents will be available on the SESplan
website form the 11 May 2015. The official consultation via the SESplan
consultation portal will run for 8 weeks from 21 July 2015 until 15
September 2015.”
Emerging Midlothian Local Development Plan - from an informal
discussion with Officers in the Council’s planning policy team, they have
confirmed that a consultation exercise will take place between 14th May
and 26th June 2015.
5.2.3 A further material planning consideration is the overriding and demonstrable
‘need’ for the development which is set out in Chapter 4.0 of Planning
Statement (Contained within Part 3 of the Planning Application Document)
and summarised in Chapter 3.0 of this ES.
5.2.4 In combination, the statutory Development Plan and the identified material
considerations contain policies and guidance which seek to:
Control the use of land;
Protect the environment;
Give locational guidance for new development;
Facilitate sustainable development including sustainable waste
management; and
Encourage renewable energy development.
5.2.5 As such, they provide a framework against which development proposals
should be considered. In addition, in many instances, they provide the
planning basis for the scope of this EIA. Accordingly, the EIA findings have
been used to inform the assessment of the Proposed Development against
the identified planning context as set out in the PS.
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6.0 TRAFFIC AND TRANSPORTATION
6.1 Introduction
6.1.1 This Chapter of the ES has been prepared to consider the traffic and transport
related environmental effects of the construction and operation of the
proposed Millerhill RERC development.
6.1.2 Detailed traffic and transport operational analysis work, including the
identification of development trip generation, a review of network safety
records and an audit of general site accessibility has been considered in a
supporting formal Transport Assessment (TA) document. The TA report has
been submitted separately as part of the Planning Application and has been
prepared in accordance with 2012 Transport Scotland (TS) document
“Transport Assessment Guidance” for the preparation of Transport
Assessment reports. The TA also makes reference to environmental
assessment criteria set out in Institution for Environmental Management &
Assessment (IEMA) document “Guidelines for the Environmental Assessment
of Road Traffic”, which represents the industry standard guidance that
underlies the traffic and transport analysis set out within this ES chapter.
6.1.3 The TA report also includes a Travel Plan Framework (Appendix TA6 to the
TA). This Travel Plan would act as an inherent mitigation measure in support
of the Millerhill RERC development to manage development traffic related
operational and environmental effects. The Travel Plan also identifies a range
of measures to maximise sustainable staff and visitor travel to the Millerhill
RERC development and the control and management of large goods vehicle
routing over the immediate local highway network to the proposal site.
Potential Impacts
6.1.4 Traffic and transport related environmental impacts for new road based
employment developments are typically associated with changes in traffic
demand, both in terms of the total number of development vehicles and the
type of vehicles generated (i.e. the proportion of larger HGV service vehicles).
Key impact types to be considered in traffic related environmental assessment
are as follows:
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Changes in development traffic demand impacting on prevailing
highway safety conditions, accident risk and network congestion and
delay on key links in the immediate vicinity of the proposal site and
further a-field;
Changes in development traffic demand impacting on other local road
network users and the immediate community, resulting in a reduced
amenity (e.g. community severance, pedestrian delay / intimidation,
etc.);
Changes in development traffic demand resulting in noise and vibration
effects at surrounding / frontage properties to key access road corridors;
and,
Changes in development traffic demand and congestion resulting in
local air quality effects at key local network links and junctions.
6.1.5 Traffic and transport related environmental impacts also vary over the different
stages of the development lifetime. Typically a full assessment of transport
environmental impact considers the following:
Construction Traffic Impact – i.e. the extent of vehicle movements that
would take place to / from the main application site during the
construction phase. It should be noted that any environmental impacts
associated with construction related traffic demand are generally only
temporary in nature (occurring for the extent of the project build period
only) and are rarely constant over the full construction period. Typically
construction traffic impact can vary greatly in scale depending on the
main activities taking place on site on any particular day.
Operational Traffic Impact – i.e. the day to day transport impact of the
operation of the proposal site – associated with typical staff, visitor and
operational HGV demand.
Assessment Scope and Consultation
6.1.6 The scope and nature of the assessment considered with the TA and this ES
chapter reflect the extent of the highways and transport issues identified as
being of interest to Midlothian Council (Local Highway Authority) and officers
of Transport Scotland (Strategic Highway Network) – see Appendix TA1 to the
formal Transport Assessment report. Scoping consultation with officers
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identified that the assessment of key highways and transport issues should be
concentrated on understanding future predicted development HGV and car
traffic demand levels over the immediate highway network and a comparison
to those traffic levels previously identified as being acceptable in relation to
similar recent waste management proposals at the site.
Relevant Planning History
6.1.7 The Millerhill RERC proposal site forms part of the Edinburgh and Midlothian
Zero Waste Contract ‘reference site’ and therefore already benefits from
Planning Permission in Principle (PPiP) for an integrated waste management
facility, including Mechanical Biological Treatment (MBT) and Energy from
Waste (EfW) processes - known as the Zero Waste Facility (ZWF). The site is
also identified for waste management land use within the strategic plan for the
Edinburgh and South East Scotland region.
6.1.8 The extant ZWF PPiP consent is considered to represent a material planning
consideration when reviewing highways and transport issues associated with
the Millerhill RERC proposals, as it establishes the principle of waste
management activities at the proposal site and a ‘fall-back’ threshold of
acceptable development related traffic demand. Formal highways and
transport submissions prepared to support the consented 230,000tpa ZWF
scheme (Feb 2011 Transport Assessment Report by Colin Buchanan &
Partners Ltd and parallel Traffic & Transport Chapter to the Environmental
Statement) identified the ZWF development traffic demand to be circa 400
vehicle movements per day (in + out), including of the order of 350 HGV
movements.
6.1.9 The supporting TA & ES reports for the ZWF scheme ultimately concluded
that such development traffic levels would result in only insignificant or
negligible impact on the operation of the surrounding road network and related
environmental conditions, as set out in paragraphs 13.12.3 and 13.12.4 of the
ZWF ES:
“The traffic assessments concluded that there would be short term
increases in traffic levels during the construction of the Proposed
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Development. In accordance with the IEMA significance criteria, these
increases are judged to be insignificant.
The traffic generated during the operational phase of the development
would be minimal and would have a negligible effect on the traffic flows
associated with the strategic and local road network.”
6.1.10 These conclusions were reviewed and accepted by statutory highway
consultees, who raised no objections to the ZWF scheme on highways and
transport capacity or traffic related environmental grounds.
6.1.11 The above traffic estimates for the ZWF development and the related
assessment conclusions are therefore considered highly relevant to the
assessment of the impact of the Millerhill RERC proposals, as they effectively
establish a traffic generation ‘fall-back’ position for the Millerhill RERC
proposal site. In simple terms, the ZWF traffic estimates represent a threshold
level of traffic demand associated with waste management development at the
proposal site that has been tested and demonstrated as having no material
impact both in terms of network operational capacity issues and traffic related
environmental effects. Scoping discussions with representatives of the
relevant highway authorities have validated this position, with officers
confirming that future development traffic volumes below this previously
identified threshold level would be acceptable - as they would ultimately
represent a reduced level of traffic impact when compared to the current
consent, which itself has already been demonstrated as resulting in only
negligible traffic and transport related operational and environmental effects.
6.2 Assessment Modelling
6.2.1 In accordance with best practice, the assessment of traffic and transport
impacts has been undertaken in line with advice set out in the following
documents:
Guidelines for the Environmental Assessment of Road Traffic produced
by the Institute of Environmental Assessment (March 1993) (now
Institute of Environmental Management & Assessment (IEMA).
The Design Manual for Roads & Bridges, produced by the Department
for Transport (DfT);
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Transport Assessment Guidance produced by Transport Scotland
(2012).
6.2.2 This guidance identifies that traffic and transport impact assessment can
generally be categorised as follows:
Operational Issues – i.e. does the network offer sufficient capacity to
accommodate development traffic movements and what improvements
might be required to ensure suitable future year operating conditions?
Environmental Issues – i.e. what are the environmental effects of
additional development related traffic movements and what mitigation
measures might be required in order to manage impacts to ensure that
they fall below appropriate thresholds?
6.2.3 This ES Chapter concentrates on the potential environmental effects of
transport movements, in terms of the impact of additional development related
traffic movements on local amenity and sensitive users / receptors, and the
extent of effects on key environmental criteria such as noise, air quality and
vibration.
6.2.4 IEMA guidelines have been used as the core reference document to inform
the environmental appraisal of development road traffic effects. This is the
same approach as adopted for the assessment of the consented ZWF
scheme - which as noted above, forms a key reference text for the
environmental analysis of the proposal site and identifies existing thresholds
for acceptable site related traffic demand.
6.2.5 The IEMA guidelines suggest the following general rules when considering the
initial ‘screening’ of traffic and transport related environmental impact and the
identification of when more detailed analysis of specific environmental effects
might be required:
“Rule 1: Include highway links where traffic flows will increase by more
than 30% (or the number of heavy goods vehicles will increase by more
than 30%).
Rule 2: Include any other specifically sensitive areas where traffic flows
have increased by 10% or more”
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6.2.6 IEMA guidance notes that traffic forecasting is not an exact science and that it
is generally accepted that accuracies of greater than 10% are not achievable.
Day to day variation of traffic on a route corridor is frequently at least some +
or – 10% of data recorded on a single survey date. The IEMA guidelines
therefore suggest that, at a basic level, projected changes in total traffic of
less than 10% would create no discernible environmental impact.
6.2.7 With respect to Rule 1 (30% threshold), IEMA guidance notes that the most
discernible environmental impacts of road traffic are considered to be noise /
vibration, severance and pedestrian delay & intimidation. In terms of these
potential impacts, IEMA guidance states the following:
In general, people are unable to perceive a change in noise nuisance for
changes in noise levels of less than 3dB(A), such changes require a
“doubling or halving in the level of traffic”.
At low flows, increases in traffic of around 30% can double the delay
experienced by pedestrians attempting to cross a road.
Severance (community disruption) and intimidation are much more
sensitive to traffic flow and DfT suggest 30%, 60% and 90% changes in
traffic levels should be considered as ‘sight’, ‘moderate’ and ‘substantial’
impacts respectively.
6.2.8 Other environmental impacts (e.g. pollution, ecology, etc.) are considered to
be less sensitive to traffic flow changes. IEMA guidelines therefore
recommended that as a starting point a 30% change in traffic would represent
a reasonable threshold for identifying a potential need to undertake a more
detailed assessment of environmental conditions.
6.2.9 Where there are major changes in the composition of the traffic flow, the IEMA
guidance suggests that a lower percentage change threshold might be
appropriate and that the assessor should use their professional judgement as
to whether additional detailed assessment is required.
6.2.10 Guidance with respect to Rule 2 (10% threshold) IEMA guidance identifies
that the assessor should consider the inclusion of any other locations or
network links where a 10% change in traffic demand is predicted in specific
environmentally ‘sensitive’ areas. The IEMA guidelines suggest a ‘sensitive’
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receptor could include accident blackspot locations, conservation areas,
hospitals, links with high pedestrian flows, etc.
6.2.11 IEMA guidance notes that it would not normally be appropriate to consider
links where total traffic flows have changed by less than 10%, unless there are
significant changes in the composition of traffic, e.g. an usually large increase
in the number of heavy goods vehicles. Ultimately the assessor is charged
with utilising professional judgement to determine whether further assessment
is necessary in such cases. This will also include the need to reflect the
‘cumulative’ effects of a combination of new development schemes against
background conditions.
6.2.12 In the case of the immediate study network to the Millerhill RERC site
(typically characterised by routes with only strictly limited levels of frontage
residential development or other potentially sensitive land uses) it is not
anticipated that the Rule 2 threshold would typically apply.
6.2.13 For clarity this ES Chapter has been prepared on the basis of the suggested
IEMA approach that a projected change in total traffic or HGV traffic levels of
less than the relevant IEMA screening thresholds (30% and 10%) on each
study link would not create a discernible traffic related environmental impact
and in such cases no further detailed assessment would be required.
Significance Criteria
6.2.14 The significance level attributed to traffic and transport related effects is based
on the magnitude of change expected to take place as a result of development
traffic levels, and the sensitivity of the affected receptor / receiving
environment to any changes.
6.2.15 The approach to the assessment of the significance of effects has been based
on the following definitions, which have been adapted from relevant guidance
notes and correspond to the significance criteria utilised in the reference ZWF
assessment.
Major / Substantial impact: where the proposed development could be
expected to have a substantive impact (either positive or negative),
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resulting in a loss of resource and / or the quality and integrity of a resource
or location via a major impact on key characteristics, features or elements.
Moderate impact: where the proposed development could be expected to
have a noticeable impact (either positive or negative), resulting in a loss of
resource, but not adversely affecting the integrity (partial impact on key
characteristics, features or elements).
Slight impact: where the proposed development could be expected to
result in a small, barely noticeable impact (either positive or negative),
resulting in some measurable changes in attributes or one or more key
characteristics, features or elements
Negligible: where no discernible impact is expected as a result of the
proposed development.
6.2.16 Impacts classified as Major and / or Moderate are considered as being
potentially ‘significant’ in EIA terms. Typically changes in baseline traffic
demand of less than 30% as a result of development are not anticipated to
result in readily discernible traffic related environmental effects (i.e. they are
‘negligible’ in scale) and therefore, as noted above, a 30% change forms the
basis for the IEMA ‘screening threshold’ for the identification of potential more
significant effects.
6.3 Baseline Highway Network Conditions
Wider Network Connections
6.3.1 Wider network connections to the Millerhill RERC proposal site are provided
by Whitehill Road, which runs to the north of the site. This route is of circa
7.0m width at the currently under construction connection point to the Zero
Waste Parc but narrows to 5.5m in places and on the approach to the junction
at Redcroft Cottage. The route currently accommodates HGV traffic
associated with the Network Rail marshalling yard, which is accessed further
to the east along Whitehill Road, to the eastern side of the existing rail bridge.
6.3.2 Whilst Whitehill Road has historically served HGV traffic, the planning
application in support of the ZWF scheme proposed a range of local highway
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improvements for the Whitehill Road corridor to support increased HGV
operation including:
Widening of Whitehill Road to 7.3m between the priority junction at
Redcroft Cottage and the junction of Whitehill Road / unnamed road to
The Wisp.
Widening of Whitehill Road to a minimum of 6.5m between the junction
of Whitehill Road / unnamed road to The Wisp and the access to the
Millerhill development area.
Alterations to the minor arm of the priority junction at Redcroft Cottage.
6.3.3 It is understood that these improvements are programmed to be delivered by
the Partner Councils prior to the opening of the Millerhill RERC.
6.3.4 Whitehill Road provides onward connections to the wider highway network via
the junction connection at Redcroft Cottage, which links to the looped
commercial estate road of Whitehill Road / Newcraighall Road, which in turn
eventually terminates to the north east at a roundabout with the A6095
Newcraighall Road (approximately 1200m travel distance from the Zero Waste
Parc access road connection to Whitehill Road). The A6095 Newcraighall
Road provides access to the Strategic Road Network via the nearby grade-
separated junction with the A1 Musselburgh Bypass and local connections to
Musselburgh to the east and Niddrie, Craigmillar and Cameron Toll to the
west.
Local Network Background Traffic Flows
6.3.5 2014 background traffic flow information for the immediate local highway
network to the Millerhill RERC proposal site was presented in support of the
ZWF planning application. Review of this background data demonstrates that
traffic flows on the immediate access road to the Zero Waste Parc (Whitehill
Road) are typically low, with total traffic demand at the Redcroft Cottage
junction (the connection to the main looped section of route) being of the order
of just 5,000 vehicles per day. Traffic flows on the main local distributor route
of the A6095 are at much busier levels, with daily flows at the key Whitehill
Road connections to Newcraighall Road at Fort Kinnaird being in excess of
25,000 vehicle movements per day.
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Road Safety
6.3.6 An appraisal of the operational safety of the immediate local network to the
Millerhill RERC proposal site has been carried out through reference to
Personal Injury Accident (PIA) data for the most recently available standard
five year search period (January 2009 – December 2013 (inclusive)), with the
extent of the search area including the full length of Whitehill Road and
connections to the A1.
6.3.7 Review of the historical accident information for this five year period identifies
that only 12 accident incidents have been recorded within the search area,
with all of these accident events being of a slight severity classification. Only
three of the recorded accidents are noted to have taken place on the
immediate Whitehill Road / Newcraighall Road section of route that is
anticipated would accommodate all predicted development HGV movements.
None of these incidents involved HGV movements or pedestrian / cycle users.
6.3.8 The remaining recorded accident incidents within the study area took place at
the A6095 Fort Kinnaird Eastern Roundabout (2 accidents), A6095 / A1
western slip road junction (3 accidents), A6095 / A1 eastern slip road junction
(3 accidents). Given the significant traffic volumes experienced at these
junctions and the fact that the accident incidents recorded at the connections
to the A1 slip roads all took place either prior to or during recent local highway
improvement works, it is not considered that this review of accident issues
indicates any material highway safety / design concerns that would require
specific improvements to support the proposed Millerhill RERC development
over and above the committed package of local works. Indeed, it is worth
noting that highway safety issues were not previously raised as an issue of
concern by local highway stakeholders with regard to the consented ZWF
project, which was predicted to generate higher levels of operational HGV
levels when compared to the current Millerhill RERC scheme.
Sustainable Transport Connections and Site Accessibility
6.3.9 It is envisaged that the majority of regular staff / visitor movements to / from
the proposed Millerhill RERC development would likely access the site using
the private car. The site is located in an area which is generally quite remote
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from large local centres of population and therefore provides only relatively
limited access by cycling and public transport. Given the generally low levels
of staff numbers anticipated to be based at the site, however, it is not
expected that the proposals would give rise to a significant demand for staff /
visitor private vehicle travel that could not be easily accommodated by the
local highway network.
Local Committed Development
6.3.10 For the purposes of the assessment of the network operational and traffic
related environmental effects of the Millerhill RERC development, it is
assumed that the following consented developments will have been
completed and are operational.
The AD Facility being constructed to the immediate north of the
Application Site.
The Borders Railway to the immediate north and west of the RERC site.
The Millerhill Development Area site access road and bridge over the
Borders Railway.
The consented Rail Rolling Stock Maintenance Depot to the north &
east of the RERC site.
The SNCD to the south and west of the RERC site (NB – this represents
a long term project which could take of the order of 20 years to
complete)
6.3.11 Further details of the highways and transport implications of these schemes is
summarised below.
6.3.12 Following approval of the ZWF scheme, Alauna Renewable Energy has
progressed a 30,000tpa capacity AD Facility at the Zero Waste Parc on the
site to the immediate north of the RERC proposal site, with this AD Facility
designed to serve the food waste portion of the Edinburgh & Midlothian Zero
Waste contract. Robust estimates of traffic demand associated with maximum
30,000tpa operation of the AD Facility have been calculated by Axis via a ‘first
principles’ trip generation exercise, based on experience of the operation of
similar AD facilities at other locations across the UK. This suggests daily traffic
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estimates at circa 66 vehicle movements per day (in + out), including 46 HGV
movements.
6.3.13 It should be noted that this AD Facility is entirely separate from the Millerhill
RERC proposal (the RERC scheme seeks to expand on the principles of the
MBT and EfW elements of the ZWF scheme originally approved as part of the
January 2012 ZWF PPiP), however, cognisance of the traffic generation
implications of the consented AD Facility is important in understanding future
combined traffic levels predicted to be generated to the proposed waste
management facilities at Zero Waste Parc and any comparison to previously
consented ZWF traffic levels.
6.3.14 As part of the enabling works for the ZWF, planning consent (Ref:
12/00060/DPD) has also been granted for the formation of a new access road,
new bridge structure over the proposed ‘Borders Railway’ rail route and
junction connection to Whitehill Road. The access road is currently under
construction and will be fully delivered by Autumn 2015 to support the
commencement of operations at the consented AD Facility and will therefore
be available to serve future operations over the remainder of the Zero Waste
Parc, including the Millerhill RERC development. The road itself is not
predicted to generate any specific traffic movements or result in any diversion
/ re-assignment of existing traffic, but is to be delivered simply to support
future development at the Zero Waste Parc.
6.3.15 The adjacent rail freight yard site to the north east of the Millerhill RERC
proposal site, enjoys planning consent for the development of a rail depot for
the maintenance and cleaning of new trains associated with the electrification
of the Edinburgh rail network. The proposals have yet to be constructed. The
Transport Statement prepared to support this depot facility identified that
traffic flows for the proposed development would generally be related to staff
movements, with 80% of staff working an overnight (19:00-07:00) shift. The
majority of movements associated with the scheme can therefore be expected
to take place outside of the core weekday day-time periods and traditional AM
& PM network peak hours. In total the submitted TS report identified that the
consented Rolling Stock Depot development could generate of the order of
172 additional movements per day (in + out).
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 109
6.3.16 The SNCD is predicted to generate additional levels of traffic of up to 500
vehicle movements per hour at junctions on the A6095 through Fort Kinnaird
and onward towards the A1. In practice, such levels of traffic will take many
years to build up as a consequence of the phased nature of the Shawfair
development and its long-term development timetable, with traffic
programmed to be accommodated by a package of off-site highway
improvements. The short term network impacts of the initial phases of the
Shawfair scheme, (for example during the construction of the Millerhill RERC
and the it’s initial operating years), are anticipated to be negligible.
6.4 Assessment of RERC Operational Traffic Issues
Predicted RERC Operational Traffic Generation
6.4.1 Anticipated demand estimates for vehicle trip movements to / from the
proposed Millerhill RERC under maximum operation have been calculated
using a ‘first principles’ approach, based upon main plant operating
assumptions such as anticipated site waste input capacity, site operating /
delivery hours and anticipated vehicle input / export payloads. Core
information and operating assumptions have been provided by the site
operator, FCC Environment and the Edinburgh & Midlothian Zero Waste
Team based on relevant operational experience.
6.4.2 The Millerhill RERC proposals envisage delivery to the site of up to
195,000tpa waste / SRF inputs (including for circa 5,500tpa of rejects and
recyclables which will be subsequently extracted from the waste supply) and
additional process consumables such as lime, activated carbon, ammonia and
oil. The site would be road served in terms of both waste / consumables inputs
and the export of process (ash / pollution control) residues (estimated at circa
51,858tpa).
Table 6.1: Input and Export Materials
Input materials
Municipal Waste Contract Delivery 135,000tpa
Bulk Third Party SRF / Residual Waste Delivery 60,000tpa
Total Consumables (lime / ammonia / oil / carbon) 2,874tpa
Export materials
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 110
Recyclables from treated waste inputs 2,740tpa
Rejects from treated waste inputs 2,789tpa
Ash output 46,553tpa
Air Pollution Control Residues 5,305tpa
6.4.3 On the basis that no ‘backloading’ would be undertaken at the Millerhill RERC
development (i.e. HGV vehicles would operate full in one direction only, i.e.
arriving full and leaving empty, or vice versa), the maximum operation of the
RERC could be anticipated to generate of the order of 128 HGV movements
on an average day (64 arrivals / 64 departures), as illustrated in Table 6.2
below.
Table 6.2: Input and Export Material Arrivals and Departures
Arrivals Departures
Waste Inputs / Consumables: 53 53
Recyclables / Process Exports 11 11
6.4.4 Typically waste management plants do not experience substantive levels of
operational HGV demand during the traditional weekday AM & PM ‘rush hour’
periods – reflecting standard waste collection patterns operated by waste
authorities and commercial clients. Waste delivery demand would be spread
across the core weekday day-time delivery window (08:00-20:00).
6.4.5 In order to provide an indication of the likely HGV demand profile associated
with the Millerhill RERC development, reference has been taken to the waste
trip generation profile information submitted in support of the previous ZWF
consent, which was based on operational information supplied at that time by
the local waste collection authorities and operational experience of the export
of process waste materials. Application of the predicted average Millerhill
RERC total daily HGV demand to the trip profile information demonstrates that
site related HGV demand could be expected to be of the order of 18 vehicles
(9 in / 9 out) over the AM peak hour (08:00-09:00) & PM peak period (16:00-
18:00) traditional busy network periods. Such traffic demand is not considered
to represent a level that would typically be expected to result in a material
impact on local network operation.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 111
Table 6.3: Predicted Millerhill RERC Operational HGV Traffic Demand
WCA Arr
WCA Dep
SRF Arr
SRF Dep
Export Arr
Export Dep
Total Arr
Total Dep
07:00-08:00 0 0 0 0 0 0 0 0
08:00-09:00 8 8 1 1 0 0 9 9
09:00-10:00 4 4 1 1 1 1 6 6
10:00-12:00 1 1 2 2 3 3 6 6
12:00-14:00 12 12 2 2 3 3 16 16
14:00-16:00 6 6 2 2 3 3 10 10
16:00-18:00 7 7 1 1 1 1 9 9
18:00-19:00 0 0 1 1 0 0 1 1
19:00-20:00 7 7 1 1 0 0 7 7
07:00-19:00 37 37 9 9 11 11 57 57
08:00-20:00 44 44 10 10 11 11 64 64
24hrs 44 44 10 10 11 11 64 64
HGVs - (Values rounded for presentation)
6.4.6 The proposed Millerhill RERC development is anticipated to require input from
up to 30 staff members over a typical weekday 24 hour period. Given the 24 /
7 nature of the Proposed Development. However, it is anticipated that the site
would be operated on a shift system, with a maximum of 22 staff members
being on site at any one time (during shift change periods). In addition, the site
will also generate some technical visitor trips as well as occasional organised
group educational visits. It is predicted that the Millerhil RERC could ultimately
result in staff / visitor car trip demand of the order of 60 vehicles (27in + 33out)
across the core weekday day-time period 07:00-19:00. Typically trip demand
during traditional AM & PM network peak periods is not anticipated to be
significant (less than 13 car trip movements over 2 hours) with maximum staff
/ visitor demand anticipated to take place for early afternoon period of 12:00-
14:00, when of the order of 25 vehicle trips are predicted (13in + 12out) –
associated with the early afternoon main shift changes.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 112
Table 6.4: Predicted Millerhill RERC Staff & Visitor Traffic Demand
Time Arrivals Departures
07:00-08:00 6 -
08:00-09:00 2 -
09:00-10:00 2 2
10:00-12:00 4 4
12:00-14:00 13 12
14:00-16:00 4 5
16:00-18:00 2 10
18:00-19:00 - -
19:00-20:00 - -
07:00-19:00 33 33
08:00-20:00 27 33
24hr 50 50
All vehicles (Values rounded for presentation)
6.4.7 Summation of the staff / visitor car trip demand levels to the predicted
operational HGV traffic levels suggests a total daily Millerhill RERC vehicular
demand to the Millerhill site of 214 vehicle movements (in + out).
Table 6.5: HGV Deliveries and Staff / Visitor Movements
Arrivals Departures
HGV Deliveries (Imports / Exports) 64 64
Staff / Visitor Movements 50 50
6.4.8 Maximum weekday vehicular demand to / from the proposal site is proposed
to take place for the hour of 12:00-14:00 - when a total of 56 / 58 vehicle
movements (in + out) could be expected to be generated by the Millerhill
RERC on an average operational day. Such demand levels represent
significantly less than 1 development vehicle movement per minute.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 113
Table 6.6: Predicted Total Millerhill RERC Operational Traffic Demand
Time (Hour Start) Staff / Visitor
Demand HGV
Demand
Total
Vehicles
07:00-08:00 6 0 6
08:00-09:00 2 18 20
09:00-10:00 4 11 15
10:00-12:00 8 12 20
12:00-14:00 25 32 57
14:00-16:00 9 20 29
16:00-18:00 12 19 31
18:00-19:00 0 1 1
19:00-20:00 0 15 15
07:00-19:00 66 114 180
08:00-20:00 60 128 188
24hr 100 128 228
Vehicle trips: in + out (Values rounded for presentation)
Millerhill RERC Operational Traffic Impact Assessment: Comparison to
the Extant PPiP Development Consent
6.4.9 As set out in Chapter 1.0, the proposal site already benefits from planning
consent for integrated waste management development (the ZWF project),
which was anticipated to generate of the order of 400 vehicle movements per
day (in + out), including 352 HGV movements. The formal TA & ES
assessments prepared to support the ZWF scheme established that such
levels of traffic would only give rise to negligible network operational or traffic
and transport related environmental effects. It therefore follows that
development traffic levels below these established thresholds would represent
a further reduced level of traffic impact.
6.4.10 A comparison of the difference in total traffic generation levels between the
delivery of the extant ZWF consent and the predicted combined total traffic
demand associated with the Millerhill RERC proposals and the adjacent
under-construction AD Facility (effectively the replacement facilities to the
consented ZWF project) demonstrates that that the current proposals would
give rise to a reduced level of daily traffic volume. Over the course of a typical
day, for example, the combined Millerhill RERC & AD projects would result in
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 114
some 106 less vehicle movements (in + out) than the consented ZWF scheme
(see Table 6.4 below).
Table 6.7: Comparison of Predicted Total Daily Millerhill RERC & AD
Traffic to Consented ZWF PPiP Demand Levels
Trip Demand Arrivals Departures Total
Current Proposals
AD Scheme 33 33 66
RERC 114 114 228
Total Traffic 147 147 294
Consented Facility
ZWF Scheme 200 200 400
Net Change -53 -53 -106
All vehicles (Values rounded for presentation)
6.4.11 A similar comparison exercise for HGV traffic levels demonstrates that
anticipated combined daily HGV traffic levels for the Millerhill RERC proposals
and consented AD scheme would be significantly lower than those associated
with the permitted ZWF development. Over the course of an average day, it is
anticipated that the delivery of the Millerhill RERC scheme in combination with
the consented AD Facility would result in of the order of 178 fewer HGV
movements over the local network when compared to the currently permitted
ZWF scheme.
Table 6.8: Comparison of Predicted Total Millerhill RERC & AD HGV
Demand to Consented ZWF HGV Estimates
Trip Demand Arrivals Departures Total
Current Proposals
AD Scheme 23 23 46
RERC 64 64 108
Total Traffic 87 87 174
Consented Facility
ZWF Scheme 176 176 352
Net Change -89 -89 -178
HGVs (Values rounded for presentation)
6.4.12 It is therefore clear that the combined operation of the Millerhill RERC and the
currently under-construction AD Facility would result in substantially less
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 115
development related traffic demand (both in terms of overall vehicle numbers
and, importantly, HGV trips), when compared to the consented ZWF scheme.
Given that ZWF predicted traffic levels have already been demonstrated as
being expected to result in only a negligible level of traffic and transport
related impact, there can be a high degree of confidence that the day-to-day
operation of the Millerhill RERC scheme would also not give rise to material
traffic related operational or environmental effects. Indeed delivery of the
current proposals would result in an overall ‘net benefit’ in traffic and transport
impact terms when compared against the current reference planning position.
6.4.13 Given the above analysis it is therefore concluded that the traffic and transport
related environmental effects of the day to day operation of the Millerhill
RERC development would be negligible.
RERC Operational Traffic Management & Mitigation
6.4.14 Whilst operation of the Millerhill RERC development is anticipated to result in
only negligible traffic and transport related effects, it is still proposed that a
number of traffic related management / mitigation measures are adopted. For
example, it is proposed that operational (HGV) traffic movements to / from the
site would be encouraged to observe appropriate local route corridors. This
routing strategy would seek to restrict operational HGV traffic to those roads
suitable to accommodate regular large service vehicle movements and would
ensure that no operational vehicle trips take place on immediate local rural
routes to the west of Whitehill Road through Shawfair. Such inappropriate
local rural routes are already signed as being unsuitable for HGV access.
6.4.15 In practice it is anticipated that the majority of Millerhill RERC related HGV
delivery traffic would seek to access the site via the A6095 Newcraighall Road
and onward strategic road network connections to / from the A1. Some local
RCV collection traffic may, however, use Newcraighall Road further to the
east to serve Musselburgh or Niddrie Mains Road to the west to give access
to Niddrie, Craigmillar & Duddingston.
6.4.16 Local route enforcement of waste delivery / export vehicles serving the
Millerhill RERC would be delivered via the following measures:
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 116
All delivery drivers to be provided with suitable route plan mapping
before beginning a delivery run to the Millerhill RERC site;
Suitable signing strategy on immediate links and key junctions;
A clear disciplinary procedure for drivers to discourage the use of
inappropriate local routes.
6.4.17 Such arrangements would be controlled and managed as part of the Site
Travel Plan. A copy of an Interim Travel Plan document is included as
Appendix TA6 to the formal Transport Assessment report.
6.5 Assessment of Development Construction Traffic Issues
Predicted Millerhill RERC Construction Traffic Demand
6.5.1 Development construction would be phased in order to minimise development
construction traffic demand on the local highway network. This will ensure
that, even during peak construction periods, construction HGV traffic demand
will not exceed those levels associated with the ultimate operation of the
Millerhill RERC site post opening of the facility.
6.5.2 Maximum construction related HGV demand is anticipated to take place
during the initial earthworks / delivery of building structural supplied phase of
construction, with a secondary peak in demand occurring during final ‘hot
testing’ / commissioning of the Millerhill RERC immediately prior to formal
opening.
6.5.3 Construction staffing levels are anticipated to be at their highest levels during
the core building fit out & installation period, involving a high number of
technical staff required for the delivery of specialist equipment. Fit out and
process installation could be expected to take place over an approximate 13
month period, with staffing levels of over 100 workers undertaking E&I tasks
for over 9 months of that period, in parallel to other building structural and
building service workers.
6.5.4 Ultimately maximum combined construction staff traffic demand is anticipated
to take place at the peak of the fit out & installation phase (288 staff based on
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 117
site in Month 17). Such staffing levels could be expected to generate circa 145
– 190 staff vehicle movements per day based on typical construction staff
vehicle occupancy rates of 1.5 – 2 staff per vehicle. Such staff travel demand
would be accommodated by the proposed on-site parking arrangements and
supporting travel management initiatives. Construction HGV demand during
such peak construction staff periods are likely to be at generally lower levels
(circa 25 HGV deliveries per day (50 movements (in + out)).
Assessment of Millerhill RERC Construction Traffic Impact
6.5.5 The peak construction traffic levels identified for the Millerhill RERC scheme
are noted to be slightly higher than the preliminary estimates previously
considered in relation to the delivery of the consented ZWF project. Given this
potential for a higher level of short term trip movements, an appraisal of the
effects of the predicted Millerhill RERC peak construction traffic volumes has
been undertaken via reference to IEMA Rule 1 (30% increase in traffic) and
Rule 2 (10% increase in traffic) thresholds.
6.5.6 Table 6.6 over the page sets out anticipated ‘worst case’ peak construction
traffic volumes (Month 17: 288 staff and 24 HGV arrivals) on key local routes
to the proposal site when compared to 2016 baseline traffic estimates. These
2016 baseline estimates have been calculated by:
Growthing of the 2014 background network traffic estimates set out in
the ZWF traffic submissions, to a 2016 assessment year using
estimates for the Midlothian area as taken from STEP (3.8%).
The addition of the predicted additional operational traffic movements
associated with the adjacent Rail Rolling Stock Depot (172 movements
per day, in+out), assigned to the highway network on a similar basis to
the general routing proportions set out in para 6.5.7 below.
The addition of traffic flows associated with the operation of the adjacent
AD Facility (20 staff movements, 46 HGV movements per day (in + out))
- due to begin operations in late 2015. HGV deliveries have been
assigned 80% east / 20% west along A6095 Newcraighall Road, with
staff traffic movements on the basis of the routing proportions set out in
para 6.5.7.
NB - No additional traffic flows have been included in the 2016 baseline estimates in relation to the adjacent Shawfair development area, as it has been assumed that this scheme would only
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 118
be at a very preliminary stage of development for the 2016 assessment year and therefore any local network traffic effects to the Millerhill RERC site would be of a strictly limited nature.
6.5.7 Millerhill RERC construction traffic estimates have been calculated on the
robust staff vehicle occupancy rate 1.5 staff per car and via reference to the
following construction traffic route assignment proportions:
Construction Staff Traffic (ZWF construction staff local route assignment):
30% west on A6095 to Niddrie and West Edinburgh
10% east on A6095 and then north via the A1
60% east on A6095 and then south via the A1 to A720 Edinburgh
Bypass.
Construction HGV Traffic:
100% via A6095 east to the A1.
Table 6.9: Assessment of Peak Millerhill RERC Construction Traffic Impact over
the Immediate Highway Network to the Zero Waste Parc
Junction
2016
24hr AADT
2016 AADT +
Rail Depot
2016 AADT
+ AD Facility
BASELINE
RERC Constructi
on
%’tage Change
vs Baseline
A6095 Newcraighall Rd / The Wisp
42240
(1745)
42291
(1745)
42306
(1754)
115
(0)
0.27%
(-)
Fort Kinnaird Main Western R’bout
27814
(590)
27865
(590)
27880
(599)
115
(0)
0.41%
(-)
Fort Kinnaird Main Eastern R’bout
29070
(650)
29191
(652)
29253
(698)
317
(48)
1.08% (6.88%)
Whitehill Road / Redcroft Cottage Jnt
5144
(104)
5316
(106)
5382
(152)
432
(48)
8.03%
(31.6%)
A1 Interchange Western Jnt
32940
(2337)
33061
(2339)
33123
(2385)
317
(48)
0.96%
(2.01%)
All Traffic (HGVs)
6.5.8 This assessment of construction traffic effects demonstrates that anticipated
‘worst case’ peak Millerhill RERC construction traffic volumes on key local
routes to the proposal site would not result in an increase in 24hr baseline
total traffic volumes in excess of critical 10% thresholds, with impact on the
main A6095 Newcraighall Road being predicted to be circa 1% or less.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 119
6.5.9 A similar conclusion can also be drawn for predicted changes in local HGV
volumes, with all local links bar the immediate site access road of Whitehill
Road demonstrating changes in HGV demand of less than 7% of baseline
levels. As identified in sub-section 6.2 above, IEMA guidelines state that, at a
basic level, changes in traffic of less than 10% create no discernible impact.
6.5.10 Given that predicted construction traffic volumes over the network would
typically be less than appropriate assessment thresholds and that HGV
volumes on Whitehall Road would be less than predicted operational HGV
levels associated with average day-to-day operation of the Millerhill RERC site
– levels which have already been established as only likely to give rise to a
negligible traffic effects (see sub-section 6.4 above) - it can only be concluded
that Millerhill RERC construction traffic volumes would not give rise to any
material network operational or traffic related environmental impacts.
6.5.11 Based on the above review, it is ultimately concluded that the traffic related
environmental effects of construction of the Millerhill RERC development
would be negligible.
Millerhill RERC Construction Traffic Management & Mitigation
6.5.12 FCC Environment recognise that the delivery of the Millerhill RERC
development would represent a major construction project in the local area
and that it is therefore important that that any disturbance to the local
community be minimised during the construction period. To this end it is
proposed that a Construction Traffic Management Plan (CTMP) would be
prepared, to ensure that the best available techniques necessary to manage /
mitigate adverse effects would be adopted. It is anticipated that the CTMP
would encompass issues such as construction operating hours & vehicle
delivery hours, on-site construction vehicle parking & manoeuvring, staff travel
management initiatives, off-site construction vehicle routing, management of
abnormal load access, local signage strategy and construction noise & dust
management.
6.5.13 The CTMP would seek to ensure that all construction HGV related traffic on
the local network is routed to / from the site via Whitehill Road and
Newcraighall Road to the east to connect to the A1 and onward links to the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 120
A720 Edinburgh City Bypass. This proposed haulage route is considered
suitable to accommodate construction HGV movements and is consistent with
the routing strategy currently used by HGV traffic travelling to / from the
adjacent Network Rail facility, the consented AD Facility and ultimately
proposed to serve the operation of the Millerhill RERC. The use of such a
haulage route would minimise impact on key local residential areas such as
Niddrie, Craigmillar, Danderhall & Duddingston.
6.5.14 Construction traffic routing would be supported by a suitable temporary
construction traffic / HGV signage strategy to / from the A1 which would be
implemented in parallel to driver education and enforcement practices. The
CTMP would further manage local conditions on the immediate haulage route
through the implementation of supporting dust suppression and road / vehicle
cleansing arrangements.
6.6 Additional Mitigation Measures
6.6.1 Given the review of anticipated future operational highway conditions and
reference to appropriate guideline standards, it is concluded that the Millerhill
RERC development would not result in a material impact on operational or
environmental conditions over the local highway network. There is therefore
no requirement for additional off-site highway improvement / mitigation works
over and above those already programmed to be delivered by the Partner
Councils in relation to the Zero Waste Parc.
6.6.2 As noted above, a number of operational measures are proposed to assist in
managing development traffic demand and restricting the time periods and
haulage routes associated with key operational HGV movements. Ultimately it
is anticipated that such management measures would be secured and
controlled by planning condition / legal agreement in line with good practice.
Should such controls be implemented and enforced appropriately, it is not
anticipated that the proposal scheme would operate with any material residual
traffic related environmental effects.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 121
6.7 Impact Summary
6.7.1 The assessment of the transport related environmental effects of the Millerhill
RERC development has established that the proposal scheme would not give
rise to unacceptable network operational or traffic related environmental
effects. The proposed development is to be located on a site that has been
identified as being suitable for waste management use within the strategic
plan for the Edinburgh and South East Scotland region and already benefits
from an existing consent for an integrated waste management facility.
Millerhill RERC Operational Traffic Effects
6.7.2 The traffic levels associated with the extant waste management consent
(ZWF) have established an acceptable threshold for traffic volumes
associated with development at the proposal site, below which traffic demand
has been demonstrated via formal environmental assessment as not likely to
give rise to discernible network operational or traffic related environmental
concerns.
6.7.3 The combined operation of the Millerhill RERC and the currently under-
construction AD Facility would result in substantially less development related
traffic demand (both in terms of overall vehicle numbers and, importantly,
HGV trips), when compared to the consented ZWF scheme. There can
therefore be a high degree of confidence that the day-to-day operation of the
Millerhill RERC development would also not give rise to material traffic related
operational or environmental effects. Indeed delivery of the current Millerhill
RERC proposals would result in an overall ‘net benefit’ in traffic and transport
effects when compared against the current reference planning position. Given
the above analysis it is concluded that the traffic related environmental effects
of the day to day operation of the Millerhill RERC development would be
negligible.
Millerhill RERC Construction Traffic Effects
6.7.4 Construction of the Millerhill RERC would not generate a material level of
HGV demand. None of the construction phases are anticipated to generate
HGV levels in excess of those associated with the day to day operation of the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 122
Millerhill RERC or indeed, those HGV thresholds already established as being
acceptable with respect to previously consented development.
6.7.5 Maximum construction periods could result in the requirement for up to 288
staff to be based at the site, to be accommodated by appropriate on site
parking areas and supporting travel management initiatives. Such peak staff
demand levels would not be experienced across the full extent of the
construction programme, being typically related to the building fit out /
installation phases. Indeed, construction staffing levels of over 200 workers
are only anticipated to occur for approximately a quarter of the construction
programme. Furthermore, during intensive staff demand periods, HGV
construction traffic would be at typically low levels (circa 20-30 HGV arrivals
per day).
6.7.6 Such combined peak daily construction traffic demand including for maximum
predicted staffing levels has been demonstrated as falling well within industry
standard screening thresholds for the assessment of operational and traffic
related environmental effects. It can therefore only be concluded that the
traffic and transport related environmental effects of construction of the
Millerhill RERC development would be negligible.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 123
7.0 LANDSCAPE AND VISUAL EFFECTS
7.1 Introduction
7.1.1 This Landscape and Visual Impact Assessment (LVIA) has been prepared in
relation to the Proposed Development. The assessment was undertaken by a
Chartered Member of the Landscape Institute (CMLI). The LVIA follows best
practice guidance set out in Guidelines for Landscape and Visual Impact
Assessment (3rd edition 2013, Landscape Institute and Institute of
Environmental Management and Assessment).
7.1.2 Landscape and visual effects are separate, although closely related and
interlinked issues. As such, the assessments of the effects of the Proposed
Development upon the landscape and upon visual amenity have been carried
out separately and are described under separate headings below.
7.1.3 The assessment of landscape effects considers the potential effects of a
development on the landscape as an environmental resource. Landscape
effects are caused by physical changes to the landscape, which may result in
changes to the distinctive character of that landscape and how it is perceived.
7.1.4 A visual assessment is concerned with the potential effects that may occur
resulting from a development, upon the population likely to be affected. It
assesses the change in visual amenity undergone by specific receptors that
would arise from any change in the nature of views experienced.
7.1.5 The LVIA aims to establish the following:
A clear understanding of the Application Site and its context, in respect
of the physical and perceived landscape and in respect of views and
visual amenity;
An understanding of the Proposed Development in terms of how this
would relate to the existing landscape and views;
An identification of the likely significant effects of the Proposed
Development upon the landscape and upon views, throughout the life-
cycle of the development;
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 124
Potential for mitigation to reduce/eliminate any potential adverse effect
on the landscape or views arising as a result of the Proposed
Development; and
A conclusion as to the residual likely significant effects of the Proposed
Development.
7.1.6 The process follows a standard approach, namely:
The establishment of the baseline conditions, against which the effects
of the Proposed Development will be assessed;
The determination of the nature of the receptor likely to be affected, i.e.
its sensitivity;
The prediction of the nature of the effect likely to occur, i.e. the
magnitude of change; and
An assessment of whether a likely significant effect would occur upon
any receptor, by considering the predicted magnitude of change
together with the sensitivity of the receptor, taking into account any
proposed mitigation measures
7.1.7 Further details on the specific methodologies of assessment and
determination of significance are included in Appendix 7-1. The LVIA has
been informed by both desk and field-based studies.
7.1.8 It should be noted that the landscape (including the context in which views are
experienced) is dynamic, i.e. it is affected by social, economic, technological
and climatic changes, all of which can influence patterns of land use, land
cover and land management. As such, the baseline context for the LVIA is not
static.
7.1.9 Cumulative effects are addressed in Chapter 15.0 of the ES. The landscape
and visual effects of the proposed grid connection are set out in Chapter 16.0
of the ES. The assessment of effects upon the setting of cultural heritage
assets is set out in Chapter 13.0 of the ES.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 125
Previous Assessment
7.1.10 As discussed in Chapter 1.0 of the ES, the Application Site benefits from PPiP
(granted in 2012) for the Zero Waste Facility, comprising:
An Energy from Waste (EfW) facility;
An Anaerobic Digestion (AD) facility; and
A Mechanical and Biological Treatment (MBT) facility.
7.1.11 A LVIA was carried out for the Zero Waste Facility at the Application Site. In
order to address AMSC associated with the Zero Waste Facility, a further
LVIA was prepared in respect of the AD Facility, located immediately north of
the Proposed Development site. Planning permission for the AD Facility was
granted in June 2013, and construction was on-going at the time of writing.
7.1.12 The Proposed Development would be implemented instead of the consented
EfW and MBT facilities. Given the greater height of some of the proposed
elements, landscape and visual effects are likely to be different to those
assessed for the Zero Waste Facility and hence the current LVIA is required.
As stated in Chapter 1.0, it is for these reasons that a detailed planning
application will be submitted to MLC, rather than an application for AMSC.
Description of the Proposed Development
7.1.13 A detailed description of the Proposed Development is set out Chapter 4.0 of
the ES. Key aspects of the development that are of relevance to this LVIA
include:
EfW facility with maximum roof height (boiler house) 41.6m;
Exhaust stack of height 75m;
Associated ancillary infrastructure;
Lighting; and
Landscape proposals.
7.1.14 Table 7.1 summarises the key differences in height between the Proposed
Development and the consented Zero Waste Facility and also, for
completeness, includes details of the AD Facility (currently under
construction).
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Table 7.1: Comparison of Developments
Zero Waste EfW / MBT facility (consented)
AD Facility (under construction)
Proposed Development
Stack Height 65m 20m 75m
Roof Height (tallest building 20m 17.3m 41.6m
Legislative and Policy Context
7.1.15 Full details of the planning and policy background for the proposal, including
an appraisal of effects on relevant landscape-related policies, as set out in the
adopted statutory Development Plan, are included in the PS which forms Part
3 of the PAD. Key legislation and policies relevant to the LVIA are
summarised below.
European Landscape Convention
7.1.16 The UK Government is a signatory of the European Landscape Convention
(ELC), which became binding in March 2007. The ELC is aimed at the
protection, management and planning of all landscapes and raising
awareness of the value of a living landscape. It relates chiefly to public bodies
and to the policies, plans and programmes produced by these.
7.1.17 Article 6C of the ELC sets the following requirement:
“Identification and assessment
1. With the active participation of the interested parties, as stipulated in
Article 5.c, and with a view to improving knowledge of its landscapes,
each Party undertakes:
(a) To identify its own landscapes throughout its territory;
(b) To analyse their characteristics and the forces and pressures
transforming them;
(c) To take note of changes; and
(d) To assess the landscapes thus identified, taking into account the
particular values assigned to them by the interested parties and
the population concerned.
2. These identification and assessment procedures shall be guided by the
exchanges of experience and methodology, organised between the
Parties at European level pursuant to Article 8.”
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7.1.18 Article 8 of the ELC requires that:
“The Parties undertake to co-operate in order to enhance the effectiveness of
measures taken under other articles of this Convention, and in particular:
a. To render each other technical and scientific assistance in landscape
matters through the pooling and exchange of experience, and the
results of research projects;
b. To promote the exchange of landscape specialists in particular for
training and information purposes;
c. To exchange information on all matters covered by the provisions of the
Convention.”
7.1.19 The LVIA is a development specific process which accords with Article 6C.
The LVIA is informed by extant Landscape Character Assessment (LCA)
studies (described in sub-section 7.3 below), which more directly relate to the
provisions of Article 6C.
Planning Policy
National
7.1.20 National planning policy applicable across the whole of Scotland is set out in
SPP (2014). Policies of direct relevance to this LVIA include:
“The planning system should: Facilitate positive change, while
maintaining and enhancing distinctive landscape character…”
(Paragraph 194)
“The siting and design of development should take account of local
landscape character. Development management decisions should take
account of potential effects on landscapes and the natural and water
environment, including cumulative effects. Developers should also seek
to minimise adverse impacts through careful planning and design,
considering the services that the natural environment is providing and
maximising the potential for enhancement.” (Paragraph 202)
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Strategic Development Plan
7.1.21 The adopted Strategic Development Plan (2013) sets out strategic policies for
south-east Scotland. Whilst there are a range of policies set out in the
document, none of them have direct relevance to this LVIA.
Midlothian Local Plan
7.1.22 The adopted Midlothian Local Plan (2008) includes policies that are of direct
relevance to this LVIA, as follows:
Policy RP5: Woodland, Trees and Hedges, states: “Development will not
be permitted where it could lead directly or indirectly to the loss of, or
damage to, woodland, groups of trees, individual trees (including areas
covered by a Tree Preservation Order, areas defined as ancient and
semi-natural woodland, or areas forming part of any designated
landscape) and hedges which have particular amenity, nature
conservation, biodiversity, recreation, landscape character, shelter or
other importance…Where an exception to this policy is agreed, any
trees lost will be replaced with equivalent.”
Policy RP7: Landscape Character, states: “Development will not be
permitted where it may adversely affect the quality of the local
landscape. Where development is acceptable, it will respect the local
landscape character and contribute towards its maintenance and
enhancement. New development will incorporate proposals to:
o Maintain the local diversity and distinctiveness of landscape
character including natural and built heritage features of landscape
value such as woodland, hedges, ponds, stone walls and historical
sites; and
o Enhance landscape characteristics where they have been
weakened and need improvement and create new landscapes
where there are few existing features.”
Policy IMP1 New Development’ states: “Planning conditions will be
applied and, where appropriate, legal agreements sought to ensure that,
where new development gives rise to a need, appropriate provision is
made for: (D) landscaping, including its management for the longer
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term, and the retention of open spaces and amenity spaces.”
7.1.23 Additionally, Policy DP2 Development Guidelines sets out detailed guidance in
respect of landscape proposals.
7.2 Methodology
7.2.1 This Section outlines the methodology used for the LVIA. It provides details of
the professional guidance that has been considered when undertaking the
LVIA. The full methodology can be found in Appendix 7-1.
Current Guidance
7.2.2 This LVIA has been based on the published best practice guidelines set out in
Guidelines for Landscape and Visual Impact Assessment (3rd edition 2013,
Landscape Institute and IEMA).
7.2.3 Reference has also been made to the following additional guidance
documents when carrying out the LVIA:
Swanwick C (2002) Landscape Character Assessment - Guidelines for
England and Scotland Countryside Agency / Scottish Natural Heritage;
The Countryside Agency / SNH (2004) Topic Paper 6: Techniques and
Criteria for Judging Capacity and Sensitivity; and
Landscape Institute (2011) Photography and photomontage in
landscape and visual impact assessment. Landscape Institute Advice
Note 01/11.
The Study Area
7.2.4 It is considered that, based upon previous experience of similar
developments, if any significant landscape and visual effects are to be
experienced, they would arise at relatively closer distances to the Proposed
Development, most likely within approximately 2.5km. Whilst elements of the
Proposed Development would potentially be visible at longer-range, it is
considered highly unlikely that this would give rise to significant effects upon
either the landscape or upon views. An additional 2.5km radius has been
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included to act as a buffer which captures potential longer-range effects from
sensitive receptors, giving an overall study area of approximately 5km radius.
Significance of Effect
7.2.5 The purpose of EIA is to determine the likely significant effects of a
development proposal. Not all landscape and visual effects arising as a result
of a particular proposal will be significant. Furthermore, where likely significant
effects are predicted, this does not automatically mean that such effects are
unacceptable. The acceptability of landscape and visual effects is a matter to
be weighed in the planning balance alongside other factors. What is important
is that the likely effects of any proposal are transparently assessed and
described in order that the relevant determining authority can bring a balanced
and well-informed judgement to bear as part of the decision-making process.
Refer to Appendix 7-1 for further details.
Consultation
7.2.6 As part of the iterative design process, FCC (including the project architect
and project landscape architect) attended a series of Architecture and Design
Scotland (A&DS) Design Forum Workshops. As a result of this process, there
has been an increase in the area of the Application Site that would be open for
permanent public access. This has been achieved through alteration of the
secure boundary treatment (a requirement of the waste management licence)
such that it is located closer to the operational area. A public access through
the site has also been introduced.
7.2.7 Provisional viewpoint locations for inclusion in the LVIA were forwarded to
MLC, SNH, East Lothian Council and ECC for comment. Further locations
were suggested by consultees. Following the consultation process, final
viewpoint locations were agreed with MLC’s Landscape Officer (refer to
Appendix 7-2 for details of the viewpoint selection process).
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7.3 Baseline
Baseline Data Collection
7.3.1 Baseline data for the LVIA has been gathered using both desk and field based
surveys. These have included review of extant landscape character
assessment studies (see below) and site visits to gain an understanding of the
landscape and visual context of the Application Site.
Baseline Conditions
Development under Construction
7.3.2 As mentioned in Chapters 1.0 and 2.0, a series of developments are currently
under construction in the vicinity of the Application Site. These principally
comprise:
AD Facility (as discussed earlier in this Chapter):
o Maximum roof height 17.3m; and
o Exhaust stack of height 20m.
Borders Railway:
o A new railway line to the west of the Application Site (and
associated over bridges); and
o A new station.
SNCD:
o Residential neighbourhoods;
o Town centre;
o Industrial estate;
o Business park / biomedical hub; and
o Structural landscaping, including public parks.
7.3.3 As construction work is underway, the presence of these three developments
in their completed state forms part of the baseline for the LVIA. This approach
has been agreed, for the ES as a whole, with MLC (refer to Chapter 2.0 for
further details).
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The Application Site and its Surroundings
7.3.4 The Application Site is located within the former Millerhill Marshalling Yards,
between an operational Marshalling Yard to the east and land associated with
the former Monktonhall Colliery to the west. Woodland cover has developed
across much of the Application Site via natural regeneration over the period
since the active use of the Application Site as part of the railway network
ceased, approximately 20 – 25 years ago. A strip of this woodland located
towards the western boundary of the Application Site has been removed to
accommodate construction access to the adjacent AD Facility (immediately to
the north) and to accommodate construction compounds for the new Borders
Railway (to the west).
7.3.5 The Application Site is set within the Edinburgh urban fringe, where a mix of
different land uses is present, including agriculture, industry, residential and
major transport corridors. Much of the undeveloped area lies within the Green
Belt, although the Application Site lies outside this planning designation.
Significant change is underway in the surrounding area, with the AD Facility
immediately to the north, and the SNCD and Borders Railway to the west,
which are under construction at the time of writing and are included in the
baseline for this assessment. Additionally, other nearby areas of land are
allocated for development in the new Local Plan. Refer to Figure 2.3 for
indicative locations of development sites.
7.3.6 Established settlements are present in the vicinity of the Application Site at
Newcraighall (circa 970m to the north), Old Craighall (circa 960m to the east),
Easter Millerhill (circa 960m to the south), Newton Village (circa 950m to the
south-west) and Harelaw (circa 670m to the south). Farm properties at
Shawfair (circa 350m to the west) and Whitehill Mains (circa 470m to the
north) are located closer to the Application Site.
7.3.7 Larger residential communities are located at Danderhall (circa 1.5km to the
south-west), Niddrie (circa 1.6km to the north-west), Brunstane (circa 1.3km to
the north) and Musselburgh (circa 1.2km to the north-east). Dalkeith is
located circa 2.7km to the south. The centre of Edinburgh is circa 6.75km to
the west.
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7.3.8 The A1 dual carriageway runs east-west approximately 575m north of the
Application Site. National Cycle Route 1 is located north of the A1, linking
Edinburgh with Musselburgh. The A720 Edinburgh bypass runs north-south
(joining the A1) approximately 1.2km east of the Application Site. A large retail
development is located south of the A1 at Fort Kinnaird, approximately 1km
north-west of the Application Site.
7.3.9 The landform of the area surrounding the Application Site is undulating and
subject to local variations, including changes associated with former mining
activity, but elevation generally decreases to the north, towards the Firth of
Forth. As such, views are often available along the coast and across the Firth
to Fife, with a range of urban and industrial development visible in a broad
panorama. Views are also available westwards towards Edinburgh, with the
distinctive hills within the city being prominent features (particularly Arthur’s
Seat). The Pentland Hills are also obvious features to the south-west.
Landscape Designations
7.3.10 There are no statutorily protected landscape designations (National Parks and
/ or National Scenic Areas) located within the study area for the LVIA. The
nearest such designation is the Upper Tweeddale National Scenic Area,
located approximately 30km to the south.
7.3.11 Additionally, the Application Site is not covered by the non-statutory Areas of
Great Landscape Value (AGLV) designation currently maintained by
Midlothian Council. Refer to Figure 7.1a-b for AGLV boundaries. The closest
AGLV is the North Esk Valley, approximately 1.75km to the south, towards
Dalkeith.
7.3.12 As part of the background to the emergent local plan, MLC undertook a review
of AGLV boundaries (Midlothian AGLV Review Final Evaluation Report Carol
Anderson Associates 2013), with a view to replacing the AGLVs with a similar
Special Landscape Area (SLA) designation. Following the review process, no
proposed SLA boundary would be located any closer to the Application Site
than any of the current AGLV boundaries. The closest boundary of the North
Esk Valley AGLV is not proposed to be changed following the review.
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Landscape Character Assessment and Related Studies
Lothians LCA
7.3.13 At a regional level, the Application Site is located within a sliver of urban land
surrounded to east and west by the Musselburgh/ Prestonpans Fringe
landscape character area (The Lothians landscape character assessment,
Ash Consulting 1998). The dominant urban/ industrial character of this area is
identified in the regional character assessment as a negative attribute of the
landscape.
7.3.14 Regional landscape character areas located within the 5km study area for this
LVIA include (refer to Figure 7.1a for location):
13: North Esk;
15: Mayfield/ Tranent Ridge; and
25: Musselburgh/ Prestonpans Fringe Coastal Margins
7.3.15 Urban areas are excluded from the Lothians LCA.
Edinburgh Green Belt LCA
7.3.16 At a more local level, the Edinburgh Green Belt Landscape Character
Assessment (Land Use Consultants 2008) identifies that the Application Site
is located within an urban area that is excluded from the study. The area
occupied by the adjacent SNCD is also largely excluded from the study for the
same reason. The Application Site borders landscape character areas 46:
Danderhall Settled Farmland and 95: Old Craighall.
7.3.17 There are a large number of Green Belt Character Areas located within the
Study Area, as illustrated on Figure 7.1b. Green Belt Character Areas within
approximately 2.5km of the Proposed Development are considered within this
LVIA, these being:
45: Brunstane Farmland;
46: Danderhall Settled Farmland;
47: Craigmillar Farmland;
49: Drum Estate Landscape;
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55: Edmonstone Policies;
87: Dalkeith Palace;
93: Musselburgh Golf Course;
94: Newhailes;
95: Old Craighall.
7.3.18 Two Green Belt Character Areas, 44: Burdiehouse Farmland and 91:
Wallyford Farmland have been excluded from the LVIA as only a very small
proportion of either area falls within 2.5km of the Proposed Development.
Future Landscape Change
7.3.19 As mentioned earlier in this Section, there is considerable development
pressure in the area, which is evidenced by a number of allocations for
housing, mixed-use and employment development and a series of
developments that were under construction in the vicinity of the Application
Site at the time of writing (AD Facility, Borders Railway and SNCD). These
three developments under construction are included as part of the baseline for
the LVIA, and it should be noted that their presence results in considerable
landscape and visual change, regardless of the presence of the Proposed
Development. The underlying context for the LVIA is that the landscape
surrounding the Application Site is far from static and is experiencing dynamic
change.
Visual Baseline
ZTVs
7.3.20 Zone of Theoretical Visibility (ZTV) mapping has been utilised to determine
the overall extent of theoretical visibility of the project. The ZTVs are displayed
on Figure 7.2, which also shows the locations of agreed Viewpoints (see
below).
7.3.21 The ZTVs enable an understanding of the visual context of the Proposed
Development and allow the identification of the areas of the surrounding
landscape from which people may experience views of it.
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7.3.22 The ZTVs are based upon the Ordnance Survey Terrain 50 bare earth digital
terrain model (DTM) which takes no account of other elements in the
landscape such as vegetation, buildings or built up areas. As such, they
represent a maximum and worst-case scenario of potential visibility.
7.3.23 A clear limitation of this technique is that actual zones of visibility are not
determined by topography alone. Other elements in the landscape act as
screens, such as buildings, or filters, such as hedgerows and woodlands.
Screening and filtering of views by these elements can often be very
significant.
7.3.24 In addition, a simple ZTV takes no account of the scale of the visible
components of the Proposed Development within the view, or whether the
entirety of the development would be visible or just a small part; it simply
illustrates that a part of the facility would be visible.
7.3.25 In order to provide a more detailed understanding of the extent of visibility of
the Proposed Development, Figure 7.2 combines four separate ZTVs, namely:
The theoretical visibility of the consented Zero Waste facility buildings
(maximum roof height 20m);
The theoretical visibility of the proposed buildings (maximum roof height
41.6m);
The theoretical visibility of the consented Zero Waste facility exhaust
stack (height 65m); and
The theoretical visibility of the proposed exhaust stack (height 75m).
Viewpoints
7.3.26 Following the consultation process outlined in sub-section 7.2 above, sixteen
viewpoints have been included in the LVIA. Refer to Appendix 7-2 for details
of the process by which these viewpoints were selected.
7.3.27 Viewpoints fall into three categories, as set out in the GLVIA:
Representative viewpoints (which represent the experience of different
types of receptors in the vicinity);
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Specific viewpoints (a particular view, for example a well-known beauty
spot);
Illustrative viewpoints (which illustrate a particular effect/issue, which
may include limited/lack of visibility).
7.3.28 It should be noted that the viewpoint itself is not the receptor; rather the
receptor is the person that would be experiencing the view from the viewpoint.
7.3.29 The viewpoints are set out in the Table below (refer to Figure 7.2 for viewpoint
locations).
Table 7.2: Viewpoint Locations
Viewpoint British National Grid Co-ordinates
Viewpoint Type
1: Battle Memorial, Salter’s Road
336300, 671283 Specific viewpoint from battle memorial. Also, broadly representative of views from the adjacent stretch of the A1.
2: Old Craighall 333373, 670415 Representative of views from residential properties within a small village.
3: Danderhall Medical Centre
331069, 669410 Representative of views from the village.
4: Danderhall 330410, 670001 Representative of views from the village.
5: The Wisp 330517, 670584 Representative of views from minor road linking Danderhall and Niddrie
6: Minor road east of Cauldcoats
331473, 671104 Representative of views from minor road west of Application Site
7: A1 (Queen Margaret’s University)
332726, 671353 Representative of views from the A1 north-east of the Application Site.
8: B6415, A1 underpass 333547, 670799 Representative of views from the A1 to the east of the Application Site. Note the viewpoint is at a lower elevation than the carriageway of the A1.
9: Falside Hill 338110, 671263 Specific viewpoint from lay-by on minor road in an elevated location.
10: A720 (footpath) 333215, 669108 Representative of views from the A720 east of the Application Site and from the adjacent footpath.
11: Craigmillar Castle 328810, 670870 Specific viewpoint from publicly accessible castle
12: Queen’s Drive 328132, 672840
Specific viewpoint from lay-by on minor road affording views eastwards across Mid and East Lothian. Also, more generally representative of views from Arthur’s Seat/ Holyrood Park.
13: Fort Kinnaird 331344, 671742 Representative of views from out of town retail park.
14: Newcraighall 332237, 671909 Representative of views from residential area.
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Viewpoint British National Grid Co-ordinates
Viewpoint Type
15: Borders Railway overbridge
332002, 670044 Representative viewpoint from within the SNCD.
16: A68 (A6106 overbridge)
337344, 667192 Specific viewpoint from hillside south-east of the Application Site.
PPiP Future Baseline Scenario
7.3.30 The PPIP future baseline scenario (refer to Chapter 2.0 for full details) reflects
the fact that a major development located at the Application Site has been
granted planning consent. The assessment of effects in this Scenario seeks
to set out in brief any additional landscape and visual effects that would derive
from the Proposed Development, over and above those deriving from the
consented PPiP development which it would effectively replace. (The principal
differences between the consented PPiP Development and the Proposed
Development, in so far as they relate to the assessment of landscape and
visual effects, were set out in Table 7.1 earlier in this Chapter.)
7.4 Assessment of Effects
Incorporated Mitigation
7.4.1 A detailed description of the Proposed Development is set out in Chapter 4.0
and is summarised in sub-section 7.1 above. A series of measures have been
incorporated into the design of the Proposed Development and into
construction and operational procedures, which are intended to provide
mitigation against potentially adverse landscape and visual effects and other
environmental effects. These measures include:
Form of buildings: The buildings have been designed using the principal
that the process equipment should be enclosed in a volumetrically
efficient manner so as to minimise the overall building height and
volume.
Colour of buildings: The built form has been designed with a dark ‘plinth’
below a paler upper structure. This has the effects of ‘grounding’ the
building and reducing the apparent overall scale.
Cladding materials: Whilst the building plinth would be clad in a
composite sheet material, the upper part of the structure would be clad
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in a translucent polycarbonate material. The polycarbonate would reflect
the tones of the sky and would assist in assimilating the structure and
providing the building with a dynamic, ever-changing element. After
dark, the material would allow a low level glow of process lighting to
permeate into the landscape introducing a further dynamic aspect.
Landscape design: Whilst a comprehensive landscape design has been
developed, in most views considered as part of the LVIA, this will have
little mitigating effect. The landscape scheme would however be very
effective in the immediate vicinity in providing an attractive and
functional setting for the development.
Lighting design: The lighting design would incorporate the following
mitigation measures:
o The use of low level lights as far as possible to reduce the visibility
of site lighting;
o The use of carefully sited directional lighting incorporating light
shields to avoid unwanted light spill and possible glare effects;
o Digital programmable switches including timers and / or movement
sensors;
o Avoidance of any unnecessary or unplanned lighting of building
façades;
o Concentrated of lighting in locations essential to night operations;
and
o Low level lighting bollards with low energy fittings utilised around
the offices, visitor centre and pedestrian routes;
o Possible use of a surface finish to the road with very low
reflectivity; and
o Possible use of kerbs with inbuilt reflectors to assist night time
navigation of the roads (reducing the overhead illumination
requirement).
7.4.2 As such, the landscape and visual effects of the Proposed Development (as
assessed below) relate to a project that has benefited from considerable
mitigation through design.
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Construction Phase
Assessment of Effects against Existing Baseline
7.4.3 An overview of the key elements of the construction process for the Proposed
Development is set out in Chapter 4.0 of this ES. It is anticipated that
construction would last for a period of approximately 28 months. Initial works
would include site clearance, foundations and drainage, and these would be
likely to take place early, within the first 5 months. Erection of building frames,
plant and equipment, and then cladding would follow. Landscaping and other
external works would generally be amongst the last tasks to be completed.
7.4.4 Construction activity is already evident, both within the boundary of the
Application Site, and in the surrounding area, associated with the Borders
Railway, AD Facility and SNCD. The baseline for the LVIA assumes that this
construction activity is complete. The construction of Proposed Development
would introduce visible construction activity from approximately mid-2015 until
spring 2018. There would be adverse effects of short-term duration deriving
from this construction activity.
7.4.5 The construction process would be managed in accordance with a project-
specific CEMP which would set out how construction would comply with any
specific environmental limitations imposed by the planning consent, as well as
relevant legislation, regulations and best practice guidance. The CEMP would
include detailed method statements for specific tasks where necessary, as
described in Chapter 4.0 of the ES. The CEMP would include details of
measures required to protect any retained tree/ woodland cover from harm
during construction, with outline measures set out in the Tree Survey (refer to
Part 7 of the PAD).
7.4.6 A temporary compound would be required during the construction process to
accommodate contractor’s personnel, welfare facilities, storage of plant and
materials etc. A temporary parking area would also be required. Both would
be located within the Application Site boundary. Some vegetation clearance
would be required to accommodate these temporary facilities, which would be
additional to that required to accommodate the operational facility. As such,
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there would be some limited specific construction phase effects resulting from
this aspect of the works.
7.4.7 The construction of the Proposed Development would require the use of
cranes, which by their nature would be visible for some distance. Both fixed
tower cranes and mobile cranes would be used. Typically, a tower crane with
a 55m boom and a span of 65m to the hook would be used. The height of the
tower crane would typically be 40m (see Chapter 4 for further details). The
cranes would be tall structures and hence potentially visible over a wide area.
It is anticipated that cranes would be present on site for approximately
fourteen months (between months 10 and 23), i.e. for approximately one-half
of the construction phase. Whilst short term and adverse visual effects would
result from the presence of cranes, these would be temporary in nature and
would not be significant.
7.4.8 Lighting during construction would be required during the winter months to
ensure the health, safety and welfare of those on-site during poor light
conditions and in particular at the beginning and end of the working day. This
may require both fixed lighting columns and mobile task lighting. In some
instances lighting may be required for work on elevated structures, including
crane mounted lighting. Lighting would be at the minimum levels necessary as
far as practicable. The CEMP would include measures to monitor and control
lighting levels and light spillage throughout the construction process.
7.4.9 Construction operations would generally be limited to 07:00 – 19:00hrs
Monday to Friday and 07:00 – 12:00hrs Saturday and as such, the main
construction lighting would be limited to this period. Low level lighting of
security compounds may be required throughout the night, but the effects of
this would be very limited in their extent. Night-time effects would not be
significant.
Assessment of Effects against PPiP Future Baseline Scenario
7.4.10 The construction period for the PPiP development was proposed to occur
between 2013 / 2014 and 2015 / 2016 for a period of approximately 24
months. The details regarding construction in the PPiP ES are limited, and as
such, it seems reasonable to assume construction would involve similar
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activities to those required for the Proposed Development. The PPiP LVIA
simply states that temporary construction phase effects would be equal to or
no greater than the residual operational effects of the PPiP development, with
no further consideration of construction phase effects.
7.4.11 The difference between the construction phase for the Proposed
Development, as compared with that for the PPiP development, would be the
increased duration of construction activity and the increased height of the
structure, which is likely to result in taller cranes and a more widespread
visibility of activities. As such, the adverse effects of the Proposed
Development would be incrementally greater due to this. It is not considered
that other aspects of the construction process would result in any effect that is
appreciably different from that would could be anticipated from the PPiP
development.
Landscape Effects: Operational
Assessment of Effects against Existing Baseline
Effects on Landscape Fabric
7.4.12 The landscape fabric of the Application Site chiefly comprises young
deciduous woodland that has regenerated on the compacted substrates of a
former marshalling yard. The predominant tree species is birch. The woodland
is generally of poor quality and vigour due to poor growing conditions, and has
in places been disturbed due to adjacent construction activity and on-site
ground investigation works. There are also areas within the Application Site
where no tree cover has developed; these areas are composed of grassland
or bare earth. A temporary construction access track for the adjacent AD
Facility runs north-south through the western part of the Application Site.
7.4.13 A Tree Survey of the Application Site has been undertaken and is included as
part of the planning application documentation (refer to Part 7 of the PAD).
This confirms that the tree cover is of low quality and value.
7.4.14 The vegetation cover within the Application Site has a low to medium
susceptibility to change. Both the young woodland and the grassland could be
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recreated with little difficulty in a relatively short period of time. Value is
low/medium; the woodland is not mature and is of low quality (as identified as
part of the Tree Survey), and there is no public access. Overall, sensitivity is
low / medium.
7.4.15 The Proposed Development would result in the loss of most of the woodland
cover within the Application Site, although where possible, pockets of existing
woodland would be retained. Additionally, areas of grassland, bare earth and
hard surfacing would also be lost to accommodate the Proposed
Development. Again, it is considered beneficial to retain some of these areas
where possible, as they provide habitat niches and would contribute to the
diversity of external areas.
7.4.16 The Proposed Development would introduce new built structures and
associated external hard surfacing (roads, footways and parking). The
proposed indicative landscape scheme is illustrated on Figure 7.4 and would
include areas of new native woodland, specimen tree planting and areas of
species-rich grassland. New waterbodies with associated planting would also
be provided.
7.4.17 Changes to the landscape fabric would occur within the Application Site.
There would be a loss of tree cover, but there would be replanting of new,
more sustainable woodland (planted into better substrate), and also a greater
diversity of vegetation types would be created. Overall, the Application Site
would change from a vacant site with young poor quality woodland, to an
operational industrial facility with only a proportion of the site covered in
vegetation. Change would be long-term (for the life of the Proposed
Development). The magnitude of change would be medium.
7.4.18 A moderate level of effect upon the landscape fabric of the Application Site
would occur as a result of the Proposed Development. The existing fabric
comprises young woodland that has regenerated on poor substrates within a
vacant industrial site. The re-introduction of industrial development at the
Application Site would result in the loss of much of the existing vegetation
cover to accommodate the Proposed Development. New and more diverse
vegetation cover would be introduced and both this, and retained existing
vegetation would be actively managed by the Applicant to promote
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biodiversity. The reduced amount of vegetation cover within the site would be
adverse, but the greater diversity of vegetation and the enhanced
management of the landscape fabric would be beneficial.
Assessment of Effects against PPiP Future Baseline Scenario
7.4.19 The PPiP LVIA did not make any specific conclusion as to the significance of
effects upon the landscape fabric. Two layout options were considered in the
PPiP LVIA; a landscape scheme was not produced for either option.
7.4.20 In the absence of any details regarding landscape proposals for the PPiP
scheme, it is not possible to assess the effects of the Proposed Development
against these. It seems reasonable to assume that the PPiP landscape works
would be similar in type to those outlined for the Proposed Development, i.e.
loss of the majority of existing woodland, introduction of replacement
woodland and other vegetation types, and management of this. As such, it
also seems reasonable to state that there would be little/ no additional effects
upon the landscape fabric resulting from the Proposed Development, i.e.
effects would at worst be negligible.
Effects on Landscape Character
7.4.21 The effects of the Proposed Development upon each of the Lothians LCAs
located within the 5km study area, and upon each of the Edinburgh Green Belt
landscape character areas located within approximately 2.5km of the
Application Site are assessed in detail in Appendix 7-3.
7.4.22 To summarise this, none of the character areas assessed in the LVIA would
experience significant effects upon their character. The Proposed
Development would be introduced into an urban fringe landscape where the
presence of built development, including electricity pylons and road corridors
is already strong, and will be even more so with the addition of the new
Borders railway, AD Facility and SNCD (all of which form part of the LVIA
baseline).
7.4.23 In this context, the presence of the Proposed Development would be visually
apparent due to the size and scale of the structures proposed and would be
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larger than any other single existing feature. However, the influence of the
development upon the wider character would nonetheless be limited, due to
the very strong influence of built features in the baseline landscape, as
identified above.
7.4.24 There would be an incremental increase in the influence of built development
in some locations closer to the Application Site (Lothians character area 25:
Musselburgh / Prestonpans Margins; Green Belt character areas 46:
Danderhall Settled Farmland and 95: Old Craighall). Effects would be minor to
moderate adverse and not significant.
7.4.25 Elsewhere, change would be limited to changes in the visual context of the
landscape, with underlying characteristics wholly or largely unaffected, given
the widespread existing visibility of other urban / industrial and infrastructure
development. Effects, whilst adverse, would be minor at worst.
Assessment of Effects against PPiP Future Baseline Scenario
7.4.26 The PPiP LVIA identified localised significant effects upon landscape
character, which it considered would occur in the Green Belt character area
46: Danderhall Settled Farmland, with all other character areas experiencing
effects that would not be significant. SEI submitted in relation to the PPiP LVIA
did not address effects on landscape character.
7.4.27 It should be noted that the PPiP LVIA did not reflect the presence of the
Borders Railway and the SNCD as part of the baseline receiving landscape,
and therefore did not recognise the changes in character that will inevitably
result from the presence of these two developments (and which indeed are
already being felt). The AD Facility which also forms part of the baseline for
the current LVIA, was a component element of the PPiP development. As
such, the baseline for the PPiP LVIA and the current LVIA are not the same
and it is understandable that differences between the two assessments have
resulted.
7.4.28 Whilst the Proposed Development would be more visible than the PPiP
development due to the greater height and bulk of the buildings, its influence
upon the surrounding landscape would be no greater from most character
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areas, and would be less from the Danderhall Settled Farmland, where the
presence of the SNCD will exert a strong influence.
Visual Effects: Operational
Assessment of Effects against Existing Baseline
Viewpoints
7.4.29 The visual effects of the Proposed Development from each of the sixteen
viewpoints included in the LVIA are assessed in detail in Appendix 7-4, and
are summarised below. The view from each viewpoint looking towards the
Application Site is displayed on Figures 7.3a to 7.3m. (NB. It must be
recognised that the Figures reflect the view available at the date of
photography, and hence do not show the full assessment baseline which
includes a fully built AD Facility, Borders railway and SNCD).
7.4.30 Photomontages from selected viewpoints are displayed on the same set of
Figures. The photomontages superimpose a computer-generated model of the
Proposed Development onto the photograph of the existing view. It should be
noted that the photomontages are merely a tool in the assessment process,
representing a static image of how the Proposed Development would appear
the particular weather and light conditions and at the particular time of day
when photography was taken.
7.4.31 Of the sixteen viewpoints, significant visual effects would be experienced from
a single viewpoint, namely Viewpoint 2: Old Craighall. At this viewpoint, the
Proposed Development would be introduced into a view where similar
features are not presently visible. Partial screening would be provided by the
intervening railway embankment, but the taller elements of the Proposed
Development would nevertheless form conspicuous new skyline features.
There would be an obvious contrast with the distinctive skyline landforms of
Arthur’s Seat and the Pentland Hills, and with other features in the view.
7.4.32 At each of the other sixteen viewpoints, visual effects would not be significant.
The viewpoints are located at a range of distances from the Application Site
and reflect views toward the Application Site from different directions. The
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views available are defined by the presence of built development, including
large-scale urban areas, industrial / commercial buildings (such as Fort
Kinnaird), and major trunk roads and other transport routes, often with
prominent embankments (particularly the A1 embankment). Whilst not visible
in the viewpoint photography, or shown on the photomontages, the presence
of the SNCD (which forms part of the assessment baseline) in particular
means that visual influence of built development is already extensive, and this
restricts the visibility of the Proposed Development from some nearby
locations. In this context, the Proposed Development, whilst generally visible
over a wide area, would have only a limited influence upon the views
available, which would be characterised by the presence of built development
and road traffic. It is again stressed that the presence of the AD Facility,
Borders Railway and SNCD form part of the assessment baseline. Therefore,
in reality, in the baseline scenario that is being assessed, many views would in
reality be blocked or heavily influenced by built development.
Pattern of Visual Effects
7.4.33 The Proposed Development would theoretically be visible from much of the
surrounding area by virtue of its height (refer to Figure 7.2 for the ZTV). The
nature of existing views is that they are strongly influenced by the presence of
built development (despite the rural character conveyed in some viewpoint
figures), and the Proposed Development would always be experienced in this
context.
7.4.34 From the north, the Proposed Development would in general be clearly visible
to traffic along the A1, which is elevated on an embankment (see Viewpoint
8). Views would be screened by vegetation from some short stretches of the
road. Typically, the Proposed Development would be conspicuous as a new
large structure visible at short-range, but change would be in the context of a
view where highway traffic and infrastructure is very prominent and with other
built development, such as the AD Facility and Queen Margaret’s University,
often also prominent. It should also be noted that some of the land east and
north-east of the Application Site (south of the A1) is allocated in the emerging
East Lothian Local Development Plan for mixed-use development and, as
such, the context of the views available from the road is likely to change
further.
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7.4.35 Further north, beyond the A1, the wooded road embankment would screen the
lower elevations of the Proposed Development from view. The tallest
proposed structures, including the exhaust stack, would in general be visible
above this existing feature, alongside the existing very tall lighting columns at
the Millerhill Marshalling Yards. Views would be in the context of other built
development (primarily urban/ suburban) located north of the A1, and the
obvious visual separation provided by the A1 embankment would result in the
Proposed Development appearing as a background feature with little influence
of note upon the type of views available (see Viewpoint 14).
7.4.36 From National Cycle Route 1, the Proposed Development would be partially
screened by the A1 embankment and associated tree cover, and by further
woodland to the south of the road. Again, the tallest elements of the Proposed
Development would be visible above this, but would be background features
visually subordinate to the far more prominent Queen Margaret’s University
buildings and the A1. In this context, visual effects would not be significant.
7.4.37 From the east, the Proposed Development would be visible from properties at
Old Craighall (see Viewpoint 2) and from the nearby A1 (see Viewpoint 8) and
A720. The taller elements of the Proposed Development would break the
skyline and offer a clear contrast with the background landforms of Arthur’s
Seat and the Pentland Hills. From more sensitive static receptors, such as
people in residential properties, this would intrude upon the view and may give
rise to significant effects.
7.4.38 At a longer range, views of the Proposed Development would be available
from along the A1 corridor (see Viewpoint 1) and from more exposed,
elevated locations further east, such as Falside Hill (see Viewpoint 9). In these
cases, the Proposed Development would be visible in the middle ground of a
view where a wide range of development types are already visible. In this
context, the Proposed Development would be a minor addition.
7.4.39 In respect of views from the south-east, the Proposed Development would be
visible from the A720 (see Viewpoint 10), in the context of the busy traffic and
prominent highway infrastructure, and perpendicular to the direction of travel.
Longer views would be available from the hillsides further south-east, such as
stretches of the A68 (see Viewpoint 16). Again, the Proposed Development
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would be a minor addition to a view where built development is already readily
apparent in the middle and longer ranges.
7.4.40 From Dalkeith Country Park, views would typically be screened by the dense
woodland cover present. From some locations, the taller elements of the
Proposed Development would occasionally be discernible, for example from
the footbridge over the A68 located towards the north-eastern edge of the
Park. Such views would be in the context of the existing development visible.
7.4.41 From the south, all views of the Proposed Development would be in the
context of the SNCD. The built form of development at Shawfair would
obscure short-range views of the Proposed Development, although occasional
clearer views are likely to remain possible from more elevated locations, or
where there are vistas formed through gaps between buildings (see Viewpoint
15). In general, views from this area would inevitably be dominated by urban
built development regardless of the presence of the Proposed Development.
7.4.42 Further to the south, built development at Shawfair will occupy the intervening
ground between the Proposed Development and people living in properties at
Danderhall, Newton Village, Easter Millerhill and Wester Millerhill. The tallest
elements of the Proposed Development would be visible from some properties
(see Viewpoints 3 and 4), but their influence upon the view would be limited by
the existing context of dense built development at Shawfair.
7.4.43 From the west, the Proposed Development would typically be clearly visible at
short-range (see Viewpoints 5 and 6). The landform in this area tends to slope
downhill towards the Firth of Forth (i.e. northwards), which naturally focuses
views toward the developed coast, with Fort Kinnaird particularly conspicuous.
Additionally, the presence of the SNCD immediately south-west of the
Proposed Development would result in built development having a strong
influence upon landward views. In this context, the Proposed Development
would have only a limited influence upon the nature of views available,
whether from the scattered residential properties in the area, from the public
road network, or from footpaths.
7.4.44 From a series of elevated vantage points further west, including Arthur’s Seat
and Queen’s Drive (see Viewpoint 12), the high-rise flats at Niddrie, and
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Craigmillar Castle (see Viewpoint 11), the Proposed Development would be
visible in the context of long views eastwards across Mid and East Lothian.
Existing built development is widely visible within Edinburgh, along the coast
and at the urban fringe, with buildings representing a wide range of styles and
periods and at a variety of scales. The further presence of the Proposed
Development would constitute only a minor addition and would not give rise to
any significant visual effects.
Views from SNCD
7.4.45 The SNCD Masterplan indicates that residential development would be built
close to the western boundary of the Application Site. This would comprise a
series of two-storey properties. For the purposes of the LVIA, it has been
assumed that these would have direct views into the Application Site from rear
windows.
7.4.46 Clear views of the Proposed Development would be available from second
storey rear windows. The baled waste building would partially screen views of
vehicle movements and other ground level activities, although these would be
apparent to either side of the building. The main building would be clearly
visible above the baled waste building. Visual effects would be significant and
adverse, as the Proposed Development would be a prominent new feature
added into the view at close range.
7.4.47 It should be noted that the LVIA has assumed that no screening features
would be present within the boundaries of the SNCD. In reality, garden
vegetation, and / or boundary features are likely to feature and would reduce
visibility.
7.4.48 From locations further west and south-west within the SNCD, it is likely that
the juxtaposition of buildings and other structures would restrict clear views of
the Proposed Development, and often would wholly screen views. Clear views
may be available from the windows of some individual properties or other
buildings, or from roads / paths, depending upon the specific orientation of
these once built, but such views would always be in the context of the
extensive surrounding development and the Proposed Development would be
a background feature set within the newly urbanised context of the foreground
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view. As such, more general visual effects from Shawfair would not be
significant.
Plume Visibility
7.4.49 The combustion process produces an emissions plume, composed primarily
of water vapour, which is emitted via the exhaust stack. The degree to which
this plume is visible is determined by the flowrate of the exhaust gases in
combination with their temperature and humidity relative to that of the
surrounding air environment.
7.4.50 When visible, emission plumes vary greatly in their visual characteristics in
response to weather conditions. Plumes often have characteristics in common
with the surrounding air environment, (i.e. on a cloudy day they would often
blend in with the background as they comprise primarily of water vapour).
7.4.51 Plume visibility has been modelled as part of air quality assessment for this
Environmental Statement. The modelling was based on weather data
recorded over the five year period 2009 – 2013.
7.4.52 The modelling indicates that a visible plume would be apparent for
approximately 70% of daylight hours. When visible the average plume length
is predicted to be short, with plume length being less than 20m for around
50% of daylight hours. The plume would be longer than the average distance
from the exhaust stack to the site boundary for less than 5% of daylight hours.
7.4.53 The presence of the emissions plume would have potential to accentuate
visibility of the development and its stack in the wider landscape.
7.4.54 Atmospheric conditions that lead to plume formation (low temperature &
humidity) occur more frequently in winter, and consequently both plume length
and visibility greatly decrease in the summer months.
7.4.55 Cloud cover is a significant factor in determining the extent to which visible
plumes are discernible. In clear or blue sky conditions a plume will contrast
strongly with its background. However, in skies with more than one or two
oktas of cloud this contrast become progressively less marked. The periods
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when cloud cover is likely to be at its greatest are across the autumn, winter
and early spring seasons which coincide with when the plumes are most likely
to occur.
7.4.56 As such, whilst the modelling indicates that plumes will be present for the
majority of daylight hours, in general it is considered that plumes would not be
prominent. There would be occasional transient adverse visual effects (for
example where long plumes form in clear skies during a temperature
inversion) but is concluded overall that the emissions plume would not lead to
significant adverse visual effects.
Night-time Effects
7.4.57 The lighting proposed as part of the Proposed Development is described in
Chapter 3.0, including an overview of mitigation measures that would be
implemented to reduce the adverse effects of lighting.
7.4.58 The area surrounding the Application Site is one where external lighting is an
established night-time presence. Street lighting is prevalent within urban areas
and around road junctions, including within the SNCD (part of the baseline for
the assessment). The lighting at the Millerhill Marshalling Yards is
conspicuous, set on tall columns. The high volumes of traffic on the A1 and
A720 are also a source of light. Internal lighting within buildings, especially
taller buildings, such as those at Queen Margaret’s University, is also
apparent.
7.4.59 The upper elevations of the Proposed Development would principally
comprise translucent polycarbonate material, which during the day would
appear generally white in colour, with changes in tone in response to ambient
light and the changing sky. At night the translucent nature of the material
would be such that internal lighting would be partially visible through the
cladding and the building would seem to ‘glow’ when viewed from the
surrounding area. This ‘glow’ would be a light source of low intensity, filtered
through the polycarbonate building façade. In the context of the area
surrounding the Application Site, which is already well-lit (including lighting
from the SNCD) and where there is a significant degree of ‘sky glow’ from the
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adjoining urban areas, the very limited light generated by the ‘glowing’ building
would not be intrusive.
7.4.60 Some areas of the Proposed Development would be lit at ground level. This is
necessary to ensure safe working in operational areas, and for the health and
safety of people walking to and from proposed buildings to car parking areas.
Additionally, lighting columns would be provided along the publicly accessible
link path around the northern and western boundaries. Such lighting would be
the minimum intensity required and would deploy modern full cut-off
luminaires to minimise light spill. All of the lighting at the site would occur in
the context of established urban lighting in the surrounding area.
7.4.61 Given the widespread sources of existing light and the incorporation into the
lighting design of measures intended to minimise light pollution and the
generation of obtrusive light, it is considered that the night-time effects of the
Proposed Development would be small scale and would not be significant.
Assessment of Effects against PPiP Future Baseline Scenario
7.4.62 The PPiP LVIA identified significant visual effects from locations closer to the
PPiP Site, including Danderhall, Millerhill, Newton Village and Old Craighall.
At all these settlements effects were identified as generally not significant, but
locally significant. Additional significant effects were identified from short
stretches of the A1 and National Cycle Route 1 to the north-east of the PPiP
Site.
7.4.63 SEI submitted in relation to the PPiP LVIA includes consideration of visual
effects from five additional viewpoint locations. Three of these viewpoints are
located in the area west of the Application Site, including one at Harelaw
within the boundaries of the SNCD; the PPiP SEI concludes that visual effects
from these locations would not be significant, but makes no reference to the
future presence of Shawfair within the view.
7.4.64 The PPiP SEI does identify significant visual effects from two viewpoints
located to reflect potential views available to future residents at Shawfair,
namely 9 Former Monktonhall Colliery Site and 10 Monktonhall Bing, and
goes on to identify that these effects are likely to reduce over time due to new
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planting both within the PPiP site and within Shawfair. Neither viewpoint is
publicly accessible at present, but both lie within the boundary of the Shawfair
development, close to the eastern boundary with the wider Millerhill
Marshalling Yards. Viewpoint 10 lies due west of the Application Site, close to,
if not directly on the line of the new Borders Railway, which is not recognised
in the PPiP SEI.
7.4.65 The respective ZTVs of the Proposed Development and the PPiP are
displayed on Figure 7.2. The buildings associated with the Proposed
Development would be theoretically visible over a wider area than the PPiP
buildings, due to their greater height. The proposed exhaust stack would be
10m higher than the consented PPiP stack; however, the areas of increased
stack visibility (refer again to Figure 7.2) would be limited. The majority of the
extent of additional theoretical visibility would be concentrated in the urban
areas north and west of the Application Site, from within which significant
screening of views would be provided by other buildings and structures, and
therefore actual additional visibility of the Proposed Development would be
limited
7.4.66 The Proposed Development would generally be more visible than the PPiP
development, due to the greater height of the buildings. However, due to the
subsequent changes to the visual context of the surrounding area, visual
effects would be less. In particular, visual effects from the south and west (i.e.
Danderhall, Millerhill and Newton Village) would not be significant due to the
presence of extensive built development at Shawfair and the transformative
influence of this development upon views. Visual effects from properties at Old
Craighall would remain significant, although it is noted that land between this
settlement and the Application Site is allocated for mixed-use development in
the East Lothian Local Plan and could therefore undergo a similarly profound
change in outlook. Properties within the SNCD located close to or adjacent to
the boundary of the Application Site (PPiP SEI Viewpoints 9 and 10) would
also remain significantly affected
7.4.67 In relation to visual effects for users of the A1, the visual effects of the
Proposed Development would not be significant for the reasons stated earlier
in this Section and set out in more detail in Appendix 7-4. From NCR 1, the
Proposed Development would be a background feature, partially screened by
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intervening earthworks and vegetation and less prominent than closer existing
features; again effects would not be significant. It is considered that a similar
statement should apply in relation to the PPiP and that the conclusions of the
PPiP LVIA in relation to these two receptors exaggerate the visual effects that
would occur. The visual effects of the Proposed Development would be
incrementally more adverse than those of the PPiP, but would not be
significant, due to the receiving context.
Effects on Landscape Designations
7.4.68 The presence of the Proposed Development would not affect the integrity of
the North Esk Valley AGLV. The Development would be located in a different
landscape context, separated from the designation by the corridor of the
A720, and there would be few clear views due to the dense and extensive
woodland cover north of Dalkeith. Neither the character of the landscape
within the AGLV, nor the views available, would be significantly affected. It is
concluded that the presence of the Proposed Development would not
materially affect the designation.
Decommissioning Effects
7.4.69 Landscape and visual effects experienced during the decommissioning stage
would, by and large, represent a reversal of those that would occur during
construction. Buildings and other structures, and the majority of above ground
infrastructure, would be removed from the Application Site and tall cranes
would be utilised as part of this process. There would be some adverse
effects, and for some nearby residents these would be likely to be significant.
Effects would however be temporary and of relatively short duration. It is
anticipated that mitigation measures in relation to specific potential effects
would be developed prior to decommissioning taking place.
7.4.70 It should also be noted that the decommissioning stage would represent the
progressive removal of the effects associated with the operation of the
Proposed Development, (i.e. the adverse effects upon landscape character
and upon views would cease following removal).
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7.5 Additional Mitigation
7.5.1 No additional measures are proposed to mitigate against potential adverse
landscape and visual effects.
7.6 Residual Effects
Residual Effects against Existing Baseline
7.6.1 In the absence of additional mitigation measures, the residual effects of the
Proposed Development would be as set out in Section 7.4 above.
Residual Effects against PPiP Future Baseline Scenario
7.6.2 In the absence of additional mitigation measures, the residual effects of the
Proposed Development would be as set out in Section 7.4 above.
7.7 Conclusions
7.7.1 The Proposed Development would be located within a former industrial site,
set within a wider urban fringe landscape. The existing influence of transport
infrastructure and built development, including electricity pylons and road
corridors, is marked. The agreed EIA baseline includes a number of further
developments (the new Borders railway, AD Facility and SNCD) which are
currently under construction in the immediate vicinity of the Application Site.
The LVIA has been undertaken on the basis that these three developments
have been built and are established features in the landscape. The Shawfair
development in particular will have a profound influence upon the surrounding
area. As such, despite its height, the potential for the Proposed Development
to change the landscape of its surroundings would be less than might be
anticipated. A similar but differently configured development (larger footprint,
but lower building height) at the same site benefits from planning consent. In
this context, the influence of the Proposed Development upon character would
be limited due to the already strong existing influence of built features. There
would be no significant effects upon landscape character.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 157
7.7.2 The assessment identified that Significant visual effects would be experienced
from one of the sixteen selected viewpoints, at the western edge of Old
Craighall. This viewpoint would be representative of views from short range to
the west, where there are approximately 30 residential properties and where
the taller elements of the Proposed Development would form a conspicuous
new skyline feature, contrasting with distinctive background landforms and
with other features in the view. The ES for the consented PPiP development
also found that there would be significant effects from this location. Whilst
effects would be significant, views from the majority of the residential
properties would be oblique or obscured by other properties. It must also be
noted that the parcels of land situated between Old Craighall and the
marshalling yard have been allocated for mixed use development in the
emerging East Lothian Local Development Plan. As such whilst it cannot be
guaranteed that development will come forward, there is a strong likelihood
that the view illustrated on Figure 7.3b will change significantly in the short to
medium term, with much of the foreground likely to take on an urbanised
character and with the Proposed Development becoming partially screened
and a such less conspicuous component of the view as a result.
7.7.3 When contrasted with the landscape and visual effects identified for the
consented PPiP development, the significant effects of the Proposed
Development would be less extensive, due to the on-going changes in the
surrounding area and the spread of built development, including the AD
Facility, Borders Railway and SNCD. The presence of these developments
changes the context of the receiving landscape and greatly increases the
influence of buildings and other structures upon it. Hence whilst the Proposed
Development would be a larger structure than the PPiP development, it would
have a lesser effect upon its surroundings.
7.8 References
ASH Consulting Group (1998). The Lothians landscape character assessment.
Scottish Natural Heritage Review No. 91. Scottish Natural Heritage;
Carol Anderson Associates (2013). Midlothian AGLV Review Final Evaluation
Report;
European Landscape Convention (2000) opened for signature 20 Oct 2000;
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 158
Land Use Consultants in association with Carol Anderson (2008). Edinburgh Green
Belt Landscape Character Assessment Final Report. Midlothian Council, City of
Edinburgh Council, East Lothian Council, West Lothian Council, Scottish Borders
Council, and Scottish Natural Heritage;
Landscape Institute (2011) Photography and photomontage in landscape and visual
impact assessment. Landscape Institute Advice Note 01/11;
Landscape Institute and Institute of Environmental Management and Assessment
(3rd edition 2013). Guidelines for Landscape and Visual Impact Assessment.
Routledge, Abingdon;
Midlothian Local Plan (2008). Midlothian Council;
Scottish Planning Policy (2014). The Scottish Government;
Shawfair Developments Limited (2002). South East Wedge ‘our vision’ The
Masterplan;
Shawfair Developments Limited (2006). South East Wedge ‘our vision’ The Design
Guide;
Strategic Development Plan (2013). SESPlan; The Strategic Development Planning
Authority for Edinburgh and South East Scotland;
Swanwick C (2002). Landscape Character Assessment - Guidelines for England
and Scotland. Countryside Agency/Scottish Natural Heritage;
The Countryside Agency / Scottish Natural Heritage (2004). Topic Paper 6:
Techniques and Criteria for Judging Capacity and Sensitivity.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 159
8.0 ECOLOGY AND NATURE CONSERVATION
8.1 Introduction
8.1.1 This Chapter considers the potential impacts of the Proposed Development on
flora and fauna. The assessment was undertaken in accordance with the
Chartered Institute of Ecology and Environmental Management (CIEEM)
Guidelines for ecological impact assessment in the UK.
8.1.2 The structure of the assessment follows standard practice; scope and
methodology of the study are first described, including evaluation and
assessment methods. This is followed by a description of the ecological
context of the site and its habitats and fauna, including the occurrence of
legally protected species. The nature conservation interest of the site and its
surroundings is then evaluated; any significant impacts upon interest features
are assessed, including indirect impacts on interest features in the wider
vicinity of the Proposed Development.
8.1.3 Full account is taken of the results of the Air Quality Assessment (Chapter
12.0) in assessing potential ecological impacts in a wider context, including
effects on European and nationally designated conservation sites within a
15km buffer, and ancient woodland sites within 2km. Other environmental
studies reported in this EIA have also been consulted in order to assess
impacts on ecological receptors, including Noise (Chapter 11.0) and Surface
Water and Flood Risk (Chapter 10.0).
8.1.4 Where possible mitigation design measures have been identified to avoid,
reduce or compensate for any potentially significant ecological impacts on
identified interest features on the site and features in the surrounding
landscape. Ecological impacts of the construction and operation phases of the
development are outlined, with an assessment of impact significance based
on the conservation status of identified interest features. Further proposed
mitigation and ecological enhancement measures are outlined, with a
summary of residual impacts following the implementation of these measures.
8.1.5 Cumulative ecological effects are assessed in Chapter 15.0; ecological effects
of the proposed grid connection are assessed in Chapter 16.0 of this ES.
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Description of the Proposed Development
8.1.6 A detailed description of the Proposed Development is set out in Chapter 4.0.
Key aspects of the development of relevance to the ecological assessment
include:
Construction methods and their requirement for land-take;
Stack height and its influence on air quality at ecological receptors;
Lighting design and measures to reduce light spillage; and
Landscape design and its potential to provide ecological mitigation and
enhancement.
Legislative and Policy Context
8.1.7 Full details of the planning and policy background for the proposal, including
an appraisal of effects on relevant nature conservation policies, as set out in
the adopted statutory Development Plan, are included in the PS (Part 3 of the
PAD). Key legislation and policies relevant to the ecological assessment are
summarised below.
European Legislation
8.1.8 The Habitats Directive (92/43/EEC) provides for the establishment of
protected sites (Special Areas of Conservation (SAC)) as part of the Natura
2000 network, to protect habitats and species of Community interest listed on
Annex I and Annex II respectively of the Directive. It also provides for strict
protection of species of Community interest listed in Annex IV(a) of the
Directive – European Protected Species (EPS).
8.1.9 Article 12 of the Habitats Directive sets out the system of strict protection
which Member States are required to adopt for animal species listed on Annex
IV(a). Article 12(1)(b) prohibits: “deliberate disturbance of these species,
particularly during the period of breeding, rearing, hibernation and migration”;
Article 12(1)(d) prohibits: “deterioration or destruction of breeding sites or
resting places.”
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8.1.10 The Birds Directive (2009/147/EC) provides a scheme of protection for all wild
birds naturally occurring in the European Union. Article 4(1) of the Directive
provides for the protection of habitats of birds requiring special conservation
measures (listed in Annex I). Article 4(2) provides for the protection of habitats
of regularly occurring migratory species, with particular reference to the
protection of wetlands. This is undertaken through establishment of Special
Protection Areas (SPA), which also form part of the Natura 2000 network.
8.1.11 Article 4(4) of the Birds Directive states that within the SPA network, Member
States should: “take appropriate steps to avoid (significant) pollution or
deterioration of habitats or any disturbances affecting the birds.” Outside the
protected areas network, they should: “also strive to avoid pollution or
deterioration of habitats.”
8.1.12 Article 2 of the Birds Directive states: “Member States shall take the requisite
measures to maintain the population of the species referred to in Article 1 (i.e.
all wild birds within their natural range) at a level which corresponds in
particular to ecological, scientific and cultural requirements, while taking
account of economic and recreational requirements, or to adapt the population
of these species to that level.”
8.1.13 The 1971 Ramsar Convention on Wetlands provides for the protection of
wetlands of international importance. These are frequently, but not
exclusively, sites which qualify under the selection criteria because of their
ornithological interest.
Implementation of European Legislation in Scotland
8.1.14 The Habitats Directive is implemented in Scotland by the Conservation
(Natural Habitats, &c.) Regulations 1994 (as amended). Regulation 39
implements the system of strict protection applied to EPS.
8.1.15 Procedures for designation of SPAs and duties in relation to wild bird habitat
were incorporated into Scottish law by the Conservation (Natural Habitats,
&c.) Amendment (Scotland) Regulations 2011 and 2012 respectively.
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8.1.16 Section 38 of the Nature Conservation (Scotland) Act provides for notification
of Ramsar sites. There is no specific legal framework in Scotland for Ramsar
site protection, but they are typically also designated as European protected
sites.
Scottish Legislation
8.1.17 The Wildlife and Countryside Act 1981, as amended by the Nature
Conservation (Scotland) Act 2004 provide the main national nature
conservation legislation for designation of nationally important sites and
protection of species.
8.1.18 Sites of Special Scientific Interest (SSSI) are nationally important conservation
sites, designated and protected under Part 2, Chapter 1 of the Nature
Conservation (Scotland) Act.
8.1.19 Section 1 of the amended Wildlife and Countryside Act provides for protection
against deliberate or reckless killing or injury of wild birds, their nests and
eggs. Birds listed in Schedule 1 receive additional protection from disturbance
while breeding; Schedule 1A species may not be intentionally or recklessly
harassed at all times, while the nests of Schedule A1 species are protected
from intentional or reckless damage, destruction or interference at all times.
8.1.20 Section 9 of the amended Wildlife and Countryside Act provides for protection
of certain animal species which are listed on Schedule 5. The degree of
protection under Schedule 5 varies; the commoner reptile species in Scotland
(adder, slow worm and common lizard) are protected against deliberate or
reckless killing or injuring, but no protection is given to their habitat.
8.1.21 Section 1 of The Nature Conservation (Scotland) Act 2004 addresses the duty
of public bodies to further the conservation of biodiversity (the ‘biodiversity
duty’), implemented in Section 2 through the Scottish Biodiversity Strategy.
Section 2(4) requires the publication of a list of species of principal importance
for the conservation of biodiversity in Scotland (the Scottish Biodiversity List).
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Policy Context
8.1.22 National planning policy applicable across the whole of Scotland is set out in
SPP (the Scottish Government 2014). Policies of direct relevance to this
ecological assessment include:
[194] “The planning system should:
...conserve and enhance protected sites and species, taking account of the
need to maintain healthy ecosystems and work with the natural processes
which provide important services to communities….protect and enhance
ancient semi-natural woodland as an important and irreplaceable resource,
together with other native or long-established woods, hedgerows and
individual trees with high nature conservation or landscape value…seek
benefits for biodiversity from new development where possible, including the
restoration of degraded habitats and the avoidance of further fragmentation or
isolation of habitats…”
[195] “Planning authorities, and all public bodies, have a duty under the
Nature Conservation (Scotland) Act 2004 to further the conservation of
biodiversity. This duty must be reflected in development plans and
development management decisions.”
[203] “Planning permission should be refused where the nature or scale of
proposed development would have an unacceptable impact on the natural
environment. Direct or indirect effects on statutorily protected sites will be an
important consideration, but designation does not impose an automatic
prohibition on development.”
[204] “Planning authorities should apply the precautionary principle where the
impacts of a proposed development on nationally or internationally significant
landscape or natural heritage resources are uncertain but there is sound
evidence indicating that significant irreversible damage could occur. The
precautionary principle should not be used to impede development without
justification. If there is any likelihood that significant irreversible damage could
occur, modifications to the proposal to eliminate the risk of such damage
should be considered. If there is uncertainty, the potential for research,
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surveys or assessments to remove or reduce uncertainty should be
considered.”
[214] “The presence (or potential presence) of a legally protected species is
an important consideration in decisions on planning applications. If there is
evidence to suggest that a protected species is present on site or may be
affected by a proposed development, steps must be taken to establish their
presence. The level of protection afforded by legislation must be factored into
the planning and design of the development and any impacts must be fully
considered prior to the determination of the application.”
8.1.23 The Midlothian Local Plan (adopted 2008) includes local policies that are of
direct relevance to this ecological impact assessment, including:
[RP10 Internationally Important Nature Conservation Sites] “Development will
not be permitted where it could adversely affect, either directly or indirectly,
the integrity of a nature conservation site of international importance (Natura
2000 areas), or any other site which is proposed or designated as of
international importance during the lifetime of the Plan, unless it can be
demonstrated that there are imperative reasons of overriding public interest
and:
A. The proposed development would have no significant effect on the
habitats or species being safeguarded; or
B. There are no alternative solutions.”
[RP11 Nationally Important Nature Conservation Sites] “Development will not
be permitted where it could adversely affect, either directly or indirectly, the
integrity of a nature conservation site of national importance, or any other site
which is proposed or designated as of national importance during the lifetime
of the Plan, unless it can be demonstrated that:
A. The objectives of designation and the overall integrity of the area will not
be compromised; or
B. Any significant adverse effects on the qualities for which the area has
been designated are clearly outweighed by social or economic benefits
of national importance.”
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[RP12 Regionally and Locally Important Nature Conservation Sites]
“Development will not be permitted where it could adversely affect, either
directly or indirectly, the nature conservation interest of any sites, or wildlife
corridors, of regional or local conservation importance unless the applicant
can show that:
A. The development has been sited and designed to minimise damage to
the value of the site and includes measures that will appropriately
compensate for any damage which cannot be avoided; or
B. The public interest to be gained from the proposed development can be
demonstrated to clearly outweigh the nature conservation interest of the
site.”
[RP13 Species Protection] “Development that would affect a species protected
by law will require an appropriate level of environmental and biodiversity
assessment. Where development is permitted, proposals will require:
A. Measures for mitigation; and
B. Measures for enhancement or sustainable habitat replacement, where
appropriate.”
[RP14 Habitat protection outwith Formally Designated Areas] “In the
assessment of planning applications for development that would affect sites
which contain habitat of some significance (although insufficient to justify a
formal natural heritage designation), effects on the habitat, including the
expected results of mitigation measures, will be taken into account.”
[RP15 Biodiversity Action Plan] “Development proposals shall be expected to
demonstrate compatibility with the aims and objectives of the Midlothian Local
Biodiversity Action Plan and related plans, by identifying appropriate
measures to protect, enhance and promote existing habitats and/or the
creation of new habitats, and provide for the effective management of these
habitats.”
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8.2 Methodology
Scope of Investigation
8.2.1 The rationale for the scope of ecological survey and assessment works is set
out in the informal Scoping Report submitted to MLC in January 2014. The
scope of the ecological assessment takes into account the availability of
recent survey data commissioned by Zero Waste: Edinburgh and Midlothian in
2013 to inform the Millerhill RERC development, as well as surveys
commissioned the same year to inform the adjacent AD Facility development.
A suite of ecological surveys had also been undertaken in 2009 of the site and
wider surrounding area to inform the application for PPiP. Based on this data,
an ecological impact assessment was carried out for Zero Waste: Edinburgh
and Midlothian and presented as Chapter 9 of the associated Environmental
Statement.
8.2.2 The 2009 ecological assessment to inform the application for PPiP was
supported by the following surveys:
Phase 1 Habitat and Invasive Plants Survey (David Dodds Ecology,
March – April 2009);
Lower Plants Survey (David Dodds Ecology, March – April 2009);
Breeding Bird Survey (April – June 2009);
Bat Roost Survey (Nov – March 2008-09) and activity survey (June –
Sept 2009);
Reptile Survey (April – September 2009); and
Badger Survey (June 2009).
8.2.3 Although these surveys are all now too old to provide valid data to inform the
current application, they provide useful contextual information, covering a
wider area than the current Application Site, highlight potential issues, and
allow an assessment of change in relation to more recent survey data.
8.2.4 AMEC were subsequently commissioned in 2013 by Zero Waste: Edinburgh
and Midlothian to update the ecological surveys undertaken in 2009. These
further surveys included a vegetation survey (updating the previous Phase 1
Survey), an Invasive Species Search, Bat Survey, Breeding Bird Survey and
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Badger Survey. The Bat Surveys followed Bat Conservation Trust (BCT)
guidelines for bat activity surveys appropriate to the habitat quality present,
while the breeding bird survey similarly followed standard methodology used
to support ecological impact assessments.
8.2.5 The informal Scoping Report identified the need for an updated habitat survey,
carried out at an optimum season, in order to provide a more detailed
description of woodland habitats and allow for a better evaluation of the site’s
habitat quality; this was undertaken by Argus Ecology in Summer 2014, and
incorporated a further check on use of the site by protected species. In order
to ensure contextual data were up-to-date and to ensure compliance with data
supply copyright restrictions, a data search was commissioned from The
Wildlife Information Centre for Lothian and the Borders (TWIC) for a 2km
buffer around the Application Site. An online data search was also carried out
of the Scottish Natural Heritage (SNH) website, including downloads of digital
boundary data for statutory designated sites and ancient woodlands (see
Figure 8.1).
8.2.6 As well as surveys commissioned to inform the earlier PPiP and the Millerhill
RERC development, ecological surveys carried out to inform the adjacent AD
Facility development were also consulted. These were carried out by Barton
Wilmore and BSG Ecology in 2012, with a wider geographic scope
encompassing the Application Site. They included an updated Phase 1
Habitat Survey, an Emergence Survey of a possible bat roost identified in the
2009 surveys, and an inspection of possible barn owl roost sites.
8.2.7 Following a review of existing data by Argus Ecology, MLC and TWIC (as
agents of the local planning authority) were consulted to confirm that further
reptile surveys were not necessary to inform the Millerhill RERC application.
Desktop Study
8.2.8 The wider ecological context of the development site has been updated from
information provided in the Environmental Statement for the PPiP application.
Digital boundary datasets for European Conservation Sites (Natura 2000
sites, i.e. SAC and SPA), SSSIs and Ancient Woodland Inventory data have
been downloaded from SNH Natural Spaces website
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(https://gateway.snh.gov.uk/natural-spaces/, accessed 08/12/2013). The
location and distance from the Application Site boundary have been
determined by measurement using QGIS 2.6.
8.2.9 Data on protected and priority species, and non-statutory designated
conservation sites were obtained from TWIC for a 2km buffer from the
Application Site boundary.
Phase 1 Habitat Survey
8.2.10 Surveys were carried out on the 9th June and 4th July 2014, of habitats within
the planning application boundary, and adjacent vegetated habitats to the
south. The survey area excluded areas within the footprint of the Proposed
Development which were being used as a haul road to the AD Facility
construction site to the north, or were being actively disturbed as part of the
Borders Rail construction works to the west.
8.2.11 An extended Phase 1 Habitat Survey was carried out to verify habitats on site.
Survey methods followed extended Phase 1 methodology (JNCC, 1993; IEA,
1995). Detailed notes were made on vegetation throughout the accessible
parts of the site in order to provide a full update of previous survey data.
These are presented in a series of ‘target notes’ in accordance with Phase 1
standards supplemented by an abundance-weighted species list subdivided
by habitat compartment in the report. Where possible, the relevant National
Vegetation Classification (NVC) communities (Rodwell, 1991 et seq) were
identified. All species were identified in the field where possible, including
bryophytes and terricolous (ground-living) lichens. Where necessary, selected
bryophyte and lichen samples were collected for expert verification.
8.2.12 As the site had changed significantly since the most recent available OS base
plans and aerial photography, most notably in terms of significant felling of
parts of the woodland, habitat boundaries were mapped in the field as
necessary using a Topcon GMS-2Pro differential GNSS receiver. This can
provide sub-metre accuracy, although this was degraded slightly in places due
to the proximity of the tree canopy.
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8.2.13 In accordance with Extended Phase 1 methodology, faunal habitat quality was
assessed as part of the habitat survey, with particular reference to assessing
the suitability for the site to support protected species. This included in
particular an assessment of whether the site contained features suitable for
bat or barn owl roosts. Signs of use of the site by badger and other protected
mammal species were searched for, and any birds noted in the course of the
habitat survey were recorded.
Other Relevant Survey Data
8.2.14 The results of the Tree Survey (AJT Consultants, 2015) provide further
evidence of habitat quality, including in particular a description of an area of
scrub to the west of the site which was not accessible in Summer 2014,
information on tree health and longevity, and further confirmation of
conclusions relating to suitability of trees to support bat roosts.
Assessment Criteria
8.2.15 In order to assess the impacts of the development on flora and fauna, it is first
necessary to identify the nature and geographical extent of likely impacts and
identify the component ecological interest features of the receiving
environment. The valuation of ecological features utilises current guidance
produced by the CIEEM (2006). This process assesses the geographical
scale of importance of habitats and species that may be impacted by the
development proposals. It also identifies legal issues, including habitats and
species with legal protection, or with a specific requirement for control (e.g.
invasive alien species).
8.2.16 The evaluation first considers species and habitats subject to legal protection,
before considering other ecological features. These include locally designated
sites, species and habitats listed on the Scottish Biodiversity List. The Scottish
Biodiversity List (SBL) is a list of animals, plants and habitats that Scottish
Ministers consider to be of principal importance for biodiversity conservation in
Scotland. The SBL was published in 2005 to satisfy the requirement under
Section 2(4) of the Nature Conservation (Scotland) Act 2004. The SBL has
been updated to take account of changes to the UK BAP priorities list. Finally,
the assessment takes account of local priority habitats and species listed in
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the Midlothian Biodiversity Action Plan (MBAP), and other features of local
importance for nature conservation.
8.2.17 The impact assessment methodology also follows current CIEEM guidelines
(2006), as recommended in a handbook on environmental impact assessment
(SNH, 2013). CIEEM guidance is based on:
The identification of valued ecological resources described above;
The characterisation of potential impacts as a consequence of the
development;
An assessment of the likelihood of occurrence, duration, extent,
magnitude, frequency and reversibility; and
An assessment of impact significance.
8.2.18 The findings of the Air Quality Assessment (Chapter 12.0) provide data to
assess the likelihood of effects on off-site nature conservation designations
and inform the requirements for any detailed appraisal of effects on such
features. This includes impacts on European and nationally designated
conservation sites within 15km of the development, and other sites including
ancient woodlands within 2km of the site. The results of the AQA also inform
the determination of likely significant effect on any European Sites in
accordance with the Habitats Regulations.
8.2.19 The results of the noise assessment (Chapter 11.0) have been considered in
terms of near-site ecological impacts in the vicinity of the development, using
the extent of the 55dB(A)eq noise contour to determine the magnitude of
potential impacts on birds, based on territory mapping within the 2013
Breeding Bird Survey.
8.2.20 In the CIEEM guidelines a significant impact in ecological terms is defined as
an impact on the integrity of a defined site or ecosystem and/or the
conservation status of habitats or species within a given geographical area.
The guidelines do not favour a matrix approach to the assessment of
significance, because these can downplay impacts on features of local
importance, and the ecological meaning of the resulting terms is often poorly
defined. Instead, significance is defined at the geographic scale at which it
occurs.
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Limitations
8.2.21 All surveys carried out by were carried out within acceptable seasonal and
weather parameters, and conformed to current guidelines with respect to
duration and frequency. There were some restrictions in access for the Phase
1 Habitat Survey due to site investigation works, while an area in the west of
the site was inaccessible at the time of survey for safety reasons due to
Borders Rail construction work.
8.2.22 The assessment relies partly on the survey work carried out by SLR
Consulting on behalf of Zero Waste: Edinburgh and Midlothian in 2013 and
reported in the documents listed in Paragraph 8.2.4.
8.3 Baseline
Ecological Context
European Designated Sites
8.3.1 Table 8.1 illustrated the European designated conservation sites located
within 15km of the Application Site.
Table 8.1: European Conservation Sites within 15km
Site Status European Site Qualifying Features Location of
Nearest Point
Distance and Direction from Site Boundary
Firth of Forth
SPA,
Ramsar
Waterfowl assemblage (>20,000 waterfowl); non-breeding species: curlew, dunlin, goldeneye, great crested grebe, knot, lapwing, mallard, pink-footed goose, red-breasted merganser, ringed plover, Slavonian grebe, turnstone, wigeon, common scoter, golden plover, long-tailed duck, redshank, shelduck, bar-tailed godwit, cormorant, eider, grey plover, oystercatcher, red-throated diver, scaup, velvet scoter; passage species: Sandwich tern.
333050, 673030
2.35km, NE
Imperial Dock Lock
SPA
Breeding species: common tern 327013, 677300
8.32km, NW
Forth Islands
SPA Breeding: seabird assemblage; gannet, kittiwake, lesser black-backed gull, roseate tern, Sandwich tern, guillemot, razorbill, fulmar, common tern, Arctic tern, cormorant, herring gull, puffin, shag
320713, 680517
14.83km, NW
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8.3.2 SPA sites are classified under Article 4 of the EU Birds Directive
(2009/147/EC), to protect rare and vulnerable birds and regularly occurring
migratory species.
8.3.3 In addition to being classified as a SPA Firth of Forth is also listed as a
Ramsar site and SSSI. These designations are largely contiguous, and cover
a large area of 6,313.72ha. Ramsar sites are wetlands of international
importance, listed under the Ramsar Convention.
8.3.4 The following nationally designated nature conservation sites are located
within a 15km buffer of the Application Site boundary. The list below includes
sites designated for biological but not earth science (geological) interest.
Table 8.2: Nationally Designated Conservation Sites within 15km
Site Status Interest Features Location of Nearest Point
Distance and direction from site boundary
Dalkeith Oakwoods
SSSI Oak woodland, wood pasture and parkland, lichen assemblages and beetles
333466,668920 1.96km SE
Duddingston Loch
SSSI Transition open fen, eutrophic loch
328340, 672200 4.14km NW
Arthur’s Seat Volcano
SSSI Acid grassland, calcareous grassland, vascular plants
328100, 672590 4.44km NW
Hadfast Valley SSSI Breeding bird assemblage, scrub 338610, 668810 6.57km SE
Bilston Burn SSSI Upland mixed ash woodland 328680, 664935 6.62km SW
Roslin Glen SSSI Upland mixed ash woodland 328580, 664130 7.35km SW
Wester Craiglockhart Hill
SSSI Lowland acid grassland, lowland calcareous grassland
322900, 670260 9.22km W
Crichton Glen SSSI Upland oak woodland, valley fen, lowland neutral grassland
337860, 661730 10.35km SE
Black Burn SSSI Lowland acid grassland, fen meadow
323675, 658550 14.70km SW
8.3.5 SSSIs are nationally important sites, designated under Section 28 of the 1981
Wildlife & Countryside Act, or Section 3 of the 2004 Nature Conservation
(Scotland) Act.
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Non-statutory Designated Sites
8.3.6 TWIC provided details of the following locally designated non-statutory
conservation sites within 2km of the Application Site boundary.
Table 8.3: Non-statutory Designated Conservation Sites within 2km
Site Status Interest features Location of nearest point
Distance and
direction from site boundary
Edmonstone UWS LBS
Open parkland and mature woodland. Common pipistrelle roost.
330376, 670045 1.87km WSW
Dalkeith Estate LBS Open parkland and woodland 332845, 668742 1.87km SSE
Disused Railway Network
UWS Areas of mature woodland and scrub that provide habitat for a variety of species and function as a wildlife corridor.
332935, 671760 1.1km NE
Brunstane Burn UWS Riparian corridor with stream, woodland and grassland.
332552, 672649 1.79km NNE
8.3.7 Urban Wildlife Sites (UWS) (City of Edinburgh only), and Local Biodiversity
Sites (LBS) are non-statutory sites of local level importance, and protected
under local authority planning policies.
Ancient Woodland and Other Woodland Sites
8.3.8 Table 8.4 below illustrates Ancient Woodland sites which are located within a
2km buffer of the Application Site boundary.
Table 8.4: Ancient woodlands within 2km
Site* Interest Features Location of Nearest Point
Distance and Direction from Site Boundary
Newhailes Ancient woodland 332600,672283 1.52km NE
Eastfield Wood Ancient woodland 333851, 670393 1.46km ESE
Wood East of Newton Ancient woodland 333788, 669706 1.63km SE
Howland’s Park Ancient woodland 333080, 668893 1.79km SSE
Wood East of Newton Church Ancient woodland 333653, 669180 1.86km SE
* Ancient woodland names not given in SNH database, taken from nearest points of woodland groups on OS 1:25000 map.
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8.3.9 Whether or not they have a statutory or non-statutory conservation
designation, ancient woodlands are significant in nature conservation terms as
they represent ‘critical natural capital’, which cannot be readily re-created.
They are frequently protected under local planning policies. They can also be
regarded as sensitive receptors with respect to changes in air quality.
8.3.10 The Forestry Commission Scotland (FCS) website mapping tool
(www.maps.forestry.gov.uk) shows the results of the Native Woodland Survey
of Scotland. The map indicates that the Application Site is located within a
17.5ha area of lowland mixed deciduous woodland (ID 950154828) described
as: ‘young native woodland’, with the dominant structure being immature. The
site is not ancient woodland.
Protected and Priority Species
8.3.11 The following protected species records were received from TWIC. These
include:
EPS listed under Schedule 2 of the Habitats Regulations 1994 (CHS-2)
and Annex 4 of the EU Habitats Directive (HD-4);
Animals protected in Scotland under Schedule 5 of the Wildlife &
Countryside Act 1981 (W5) as amended; and
Birds with special protection under Schedule 1 of the Wildlife &
Countryside Act 1981 as amended (W1) and Protection of Badgers Act
1992 (BA).
8.3.12 All records illustrated in Table 8.5 over the page are within a 2km radius, but
none relate to the Application Site or its immediate environs.
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Table 8.5: Protected Species Records
Species Status Grid reference / details Distance and direction from site boundary
Bat Chiroptera CHS-2, HD-4, W5 & SBL
Inveresk Lodge NT 34 71
Edmonstone Terrace NT 309 697
Newhailes Estate NT 326 725
1.65km E
1.55km SW
1.68km NNE
Otter Lutra lutra CHS-2, HD-4, W5 & SBL
River Esk NT 338 717
Water of Leith NT 315 691
1.76km NE
1.57km SW
Badger Meles meles BA SBL SO1 Newhailes Estate NT 326 725 1.70km NNE
Common crossbill Loxia curvirostra
W1 Newhailes Estate NT 327 724 1.64km NNE
Fieldfare Turdus pilaris W1 Musselburgh NT 335 721
Newhailes Estate NT 325 727
1.73km NE
1.84km NNE
Redwing Turdus iliacus W1 Newhailes Estate
NT 326 725
NT 325 727
NT 329 727
NT 330 724
NT 327 724
1.7km NNE
1.88km NNE
1.95km NE
1.69km NE
1.59km NE
8.3.13 TWIC also supplied data on priority species records within a 2km buffer
around the Application Site. A number of priority species including SBL
species, UK Biodiversity Action Plan (UK BAP) (PS) and local BAP species
have been recorded within the search area including City of Edinburgh (C),
East Lothian (E) and Midlothian (M) local BAP priority species. Only one
record relates to the site: woodcock Scolopax rusticola, with a grid reference
given as NT 3226 7071 (332660, 670710). This is a SBL species, listed
because a decline of 25% or more in abundance or range has occurred in
Scotland over a recent 25 year period. Other species that have been recorded
in the wider 2km search area include:
Skylark Alauda arvensis (SBL, E, C);
Grey partridge Perdix perdix (SBL, PS, E, C);
Swift Apus apus (SBL, E, C);
Yellowhammer Emberiza citronella (PS, C);
Linnet Carduelis cannabina (SBL, E, C);
Brown hare Lepus europaeus (SBL, PS, E, C);
European hedgehog Erinaceus europaeus (PS);
Grayling Hipparchia semele (PS); and
Pyramidal orchid Anacamptis pyramidalis (E, very local distribution).
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Local Ecological Context
8.3.14 The site is located on a former area of the Millerhill rail marshalling yard which
was abandoned and became colonised with birch woodland, established on
made ground including colliery spoil and ballast. The currently active area of
rail sidings is located to the east of the Application Site. A new access road for
the AD plant and site is in the process of construction between the site and rail
sidings.
8.3.15 An AD Facility is located to the immediate north of the Application Site, and at
the time of writing is in the process of being constructed. The newly
constructed Borders Railway runs in cutting to the north and west of the site.
The remaining area of former rail sidings to the south of the site support birch
woodland, interspersed with areas of open ballast.
8.3.16 To the west of the site, former arable fields and a reclaimed waste tip are
being developed as the new settlement of Shawfair, a large residential
complex with commercial and retail space and a new rail station. The local
ecological context is therefore one of significant recent and on-going
urbanisation and attendant habitat change, particularly to the west and north
of the Application Site.
8.3.17 OS maps and aerial photography show no surface watercourses in the vicinity
of the Application Site. A small drain flows east from the adjacent rail sidings
towards the River Esk, which discharges into the Firth of Forth circa 3.4km
north-west of the Application Site boundary.
Habitats and Vegetation
8.3.18 Habitats within the site are described more fully in Extended Phase 1 Habitat
Survey (Appendix 8-1). This provides a detailed description of species
composition and is described in a series of target notes in accordance with
Phase 1 methodology. The table below is adapted from the habitat survey,
with additional cross-referencing to European Nature Information System
(EUNIS) habitats in accordance with current SNH practice (Strachan, 2015):
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 177
Table 8.6: Habitats Present on Site
EUNIS category (level 3/4) Phase 1 category Area (ha)
G1.91 Birch woodland not on marshy terrain
A1.1.1 Broadleaved semi-natural woodland
2.3
F3.13 Atlantic poor-soil thickets A2.1 Dense scrub 0.08
E5.1 Anthropogenic herb stands C.3.1 Tall ruderal 0.1
G5.8 Recently felled areas A.4 Recently felled woodland
(retaining vegetation)
1.09
G5.8 Recently felled areas A.4 Recently felled woodland
(with bare ground)
0.33
E5.22 Thermophile woodland fringes – mesophile fringes
B2.1 Unimproved neutral grassland
0.04
(various – road / construction area, bare ground, small areas of woodland and scrub not accessible for survey)
1.49
Birch Woodland
8.3.19 The largest area of habitat within the site comprised secondary silver birch
(Betula pendula) woodland, covering 2.3ha. Although well-established, this is
of relatively recent origin, with trees mostly less than 12-14m high,
interspersed with areas of younger birch trees. The Tree Survey assessed the
majority of tree groups as having a low value, with limitations to growth
imposed by the nature of the substrate, and some wind-throw. The age of the
trees was assessed as being up to 20 – 25 years.
8.3.20 The field layer vegetation was atypical compared to semi-natural birch
woodland communities, reflecting the mixed nature of the artificial substrate,
and including flora typical of both base-rich and acidic soils. Abundant field
layer species included rosebay willowherb (Chamerion angustifolium), wild
strawberry (Fragaria vesca), Yorkshire fog (Holcus lanatus) and perforate St.
John’s-wort (Hypericum perforatum). The bryophyte layer was luxuriant in
places; both the 2009 lower plant survey and 2014 habitat survey found that
this was composed of common species such as Pseudoscleropodium purum.
Lichens were also locally frequent, including Peltigera and Cladonia species.
8.3.21 Many semi-natural birchwoods in eastern Scotland are examples of the W11
oak (Quercus sp.) – downy birch (Betula pubescens) – wood sorrel (Oxalis
acetosella) NVC community. This is a community of relatively base-poor soils;
reference to the description and floristic tables in British Plant Communities
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 178
(Rodwell, 1991) indicates a poor correspondence with this community on the
Application Site, with few characteristic species present, with the exception of
some of the mosses such as Pseudoscleropodium and Rhytidiadelphus
triquetrus. This is likely to be a consequence both of the recent age of the
woodland, and the substrate on which it has established.
8.3.22 Woodland to the south of the Application Site was similar in structure and
species composition, additionally including partially-vegetated clearings in
areas where a greater depth of coarse track ballast remained at the surface.
Other Habitats
8.3.23 Large areas of the woodland had been felled by Summer 2014, creating
clearings and broad access corridors which were bare or sparsely vegetated,
in places retaining remnants of the original woodland field layer vegetation. A
large pile of stumps and brash had been placed in the largest, northern
clearing.
8.3.24 Other habitats included a very small area of neutral grassland with Yorkshire
fog and wild strawberry in the south of the site, close to two small areas of
dense scrub with goat willow (Salix caprea) and broom (Cytisus scoparius). A
small patch of tall ruderal (disturbed-ground) vegetation occupies an area in
the north of the site.
Fauna
Bats
8.3.25 The 2013 Bat Surveys found relatively low levels of activity within the site and
the wider survey area, which took in the whole of the vegetated former rail
sidings, including land well to the south of the Application Site. Soprano
pipistrelle (Pipistrellus pygmaeus) were most frequently recorded, with smaller
numbers of common pipistrelle (Pipistrellus pipistrellus); static detector
surveys also recorded very low levels (1-2 passes) of Nyctalus sp. (in
Midlothian, almost certainly noctule, Nyctalus noctula), and brown long-eared
bat (Plecotus auritus).
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 179
8.3.26 A bat roost had previously been located in 2008 in a brick retaining wall
located approximately 300m south of the site boundary. This was investigated
in 2009 and 2012 (in the AD Facility surveys) with emergence surveys, and
was used as a static monitoring location in the 2013 surveys. No further use of
this structure by bats has been confirmed.
8.3.27 Within the Application Site, as none of the trees are fully mature, they are
lacking in crevice and cavity habitats which would make them potentially
suitable as bat roosts. There are no other structures within the proposed
development boundary which would be capable of supporting a bat roost.
8.3.28 Current site conditions differ from earlier surveys in terms of bat foraging
habitat quality. Woodland clearance within the site will have temporarily
improved bat foraging habitat quality by increasing the amount of edge habitat
and sheltered rides, but in the absence of a high bat population in the wider
area are unlikely to result in a significant increase in bat activity, as surveys
inferred the nearest roosts were likely to be some distance from the site.
Badger
8.3.29 TWIC hold records of badger over 1.7km from the site and the 2013 surveys
by AMEC noted that the site provided suitable habitat for badger, with the
woodland areas providing a suitable location for setts.
8.3.30 The 2014 extended Phase 1 Habitat survey checked areas of rabbit holes,
which were frequent near the eastern boundary of the woodland where
adjacent rail tracks had been constructed on different levels, now forming a
‘terraced’ appearance within the woodland. No signs of use by badger were
found, which supported and confirmed the findings of earlier surveys.
Furthermore, badger habitat quality is not particularly high across the
Application Site, largely because of the immature soils likely to support a
limited earthworm population. Even over better-vegetated parts of the
woodland ground flora, soils appear to consist of a relatively thin layer of
surface humus over colliery spoil or railway ballast.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 180
Riparian Mammals
8.3.31 As noted above, TWIC hold records of otter (Lutra lutra) in the wider area on
the River Esk and Water of Leith. There are no suitable habitats on site to
support riparian mammals such as otter or water vole.
Reptiles
8.3.32 A dedicated reptile survey in 2009 found no evidence of reptiles within the
Application Site or wider survey area, but in the 2013 surveys there was an
incidental record of common lizard (Zootoca vivipara) at the northern
boundary, adjacent to land which has now been cleared and is in the process
of being developed as the AD Facility.
8.3.33 Although recent disturbance associated with the AD Facility construction and
tree felling on the Application Site is likely to have displaced lizards, the piles
of tree stumps and brash noted above as present in Summer 2014 are located
only around 50m south of the location of the previous record location, and
provide a suitable hibernation site. Open areas with patches of bare ground
close to areas of denser cover also provide suitable summer basking habitat.
Breeding Birds
8.3.34 The results of breeding bird surveys reported by AMEC in 2013 provide an
assessment of the number of breeding territories within the Application Site.
These comprise common passerines of woodland habitats, with 7 willow
warbler (Phylloscopus trochilus) territories, 3 robin (Erithacus rubecula), 2
chaffinch (Fringilla coelebs), 1 blackcap (Sylvia atricapilla) and 1 wren
(Troglodytes troglodytes).
8.3.35 Birds noted in the course of the 2014 Habitat Survey were consistent with the
results of the 2013 bird survey, although the area of suitable breeding habitat
had declined through woodland clearance. Species such as willow warbler
which were found in relatively high densities in the 2013 survey were
prominent, together with wren, robin, chaffinch, chiffchaff (Phylloscopus
collybita), blackcap and greater spotted woodpecker (Dendrocopos major).
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Ecological Interest Features
Designated sites
8.3.36 Tables 8.1 and 8.2 list the statutory designated sites within a 15km buffer;
Table 8.3 lists non-statutory sites within a 2km buffer of the Application Site.
European designated sites such as SPAs can be considered interest features
of international importance; SSSIs can be considered as being of national
importance. Local non-statutory sites and ancient woodlands can be
considered to be of local interest.
8.3.37 There are no statutory or locally designated conservation sites within or
adjacent to the Application Site. The nearest statutory designated site is
Dalkeith Oakwood SSSI, located 1.96km to the south-east of the site
boundary. Firth of Forth SPA, Ramsar site and SSSI is located 2.35km to the
NE, and is hydrologically connected via the River Esk.
Protected Species
8.3.38 In order to assess the level of value of protected species as ecological interest
features, it is important to consider the following aspects separately:
Their scale of importance on site, including the extent to which the site
contributes to the maintenance of their conservation status in the wider
area; and
Their level of legal protection, in order to later assess whether the
proposed development may contravene this protection.
8.3.39 For example, it may be possible that the site could be of negligible value for a
EPS, and any impacts would not be significant in EIA terms. However,
because of strict legislative protection, there may nevertheless be a risk of
committing an offence which would require the implementation of avoidance
measures; if avoidance is not possible, a SNH disturbance licence would be
required.
8.3.40 As noted above, four species of bat have been recorded foraging within the
Application Site and / or the wider area of wooded rail sidings, although only
two species (soprano and common pipistrelle) were frequently recorded. The
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absence of a nearby roost site, and relatively low levels of activity detected
indicate that the site is of no more than local value for bats.
8.3.41 All bat species are EPS, listed on Annex IV of the Habitats Directive and
Schedule 2 of the Habitats Regulations 1994 (as amended).
8.3.42 No bird species listed on Annex I of the Birds Directive or having special
protection under Schedule 1 of the Wildlife and Countryside Act 1981 have
been recorded within the Application Site. The 2012 AD Facility survey
recorded a barn owl roost (a Schedule 1 species) to the north of that site,
under a bridge. Habitat quality for barn owl was assessed as low in the 2013
breeding bird surveys, and no further evidence was found. The assessment
baseline conditions of increased urbanisation of farmland to the west of the
site (associated with the Shawfair and Borders Railway developments) are
likely to further reduce habitat quality for barn owl in the wider vicinity of the
Application Site; barn owl require rough grassland habitats with a good small
mammal population, coupled with suitable roost sites in structures such as
farm outbuildings. Although use of the site on occasion cannot be ruled out,
for the above reasons it can be considered as being of at most negligible
interest for barn owl.
8.3.43 Evidence of other breeding birds was found on site, with woodland, scrub and
tall herb habitats providing reasonable cover. The total of fourteen territories
recorded in 2013 all comprised common species, although one species has a
declining population (see below). The breeding bird assemblage can be
regarded as a feature of local interest.
8.3.44 The population size of common lizard in the site and surroundings appears to
be low, with only one record from all surveys, including a dedicated reptile
survey in 2009, before any construction works and disturbance of habitats
took place. However, as common lizard are very difficult to accurately assess,
a precautionary approach would suggest that there could be a population of
local conservation interest utilising the site. Woodland clearance and creation
of a pile of stumps and brash may have recently improved common lizard
hibernation habitat; although there is no evidence of habitat utilisation, a
precautionary approach should be taken which assumes likelihood of
occupancy. Common lizard have partial protection under the Wildlife and
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Countryside Act 1981 (as amended) against intentional or reckless killing or
injuring.
Priority Habitats and Species
8.3.45 Section 1 of the Nature Conservation (Scotland) Act 2004 places an obligation
on public bodies to conserve biological diversity in accordance with the 1992
UN Convention on Biological Diversity. A list has been published of habitats
and species considered to be of principal importance for the conservation of
biological diversity in Scotland (the SBL).
8.3.46 SBL habitats and species are classified into four Categories for Action:
Conservation action needed;
Avoid negative impacts;
Watching brief only; and
Communicating with the public (iconic habitats and species of cultural
significance).
8.3.47 The identification of priority habitats is facilitated by reference to descriptions
published by Biodiversity Scotland. The woodland areas can be considered to
fall within the category of lowland mixed deciduous woodland UK BAP / SBL
priority habitat. As noted earlier, it is atypical of woodland communities due to
its origin on an artificial substrate, while the Tree Survey emphasises the poor
tree condition resulting from difficult soil conditions; it does not closely match
the descriptions of the priority habitat either. However, this does not
necessarily endow it with a lower conservation value and its inclusion within
the Forestry Commission Native Woodland Survey of Scotland (Forestry
Commission, 2014) further supports its classification as lowland mixed
deciduous woodland. They identify the site as being located within a 17.5ha
area of lowland mixed deciduous woodland, although felling to accommodate
the AD plant, access road and bridge, and works within the site have reduced
this to around 8ha located to the south of the site.
8.3.48 The importance of the woodland on site also has to be seen in the context of
the wider Regional / County context. Midlothian is noted as having a total of
671ha of lowland mixed deciduous woodland, so the woodland in which the
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site is located accounted for 2.6% of this resource prior to the AD Facility and
road construction and partial felling on site. The remaining 2.3ha of woodland
on site is equivalent to 0.34% of the County-wide resource. It can therefore be
regarded as a feature of local importance as part of the wider woodland area
established on the former sidings.
8.3.49 The four bat species recorded within the Application Site are also priority
species; they have been evaluated above as EPS.
8.3.50 No other priority species have been recorded on site, although the breeding
bird survey recorded a number of species within the wider survey area, which
could conceivably utilise the Application Site for foraging on occasion.
Local BAP Priority Habitats
8.3.51 The site falls within the definition of Brownfield Land local priority habitat in the
Local Biodiversity Action Plan (LBAP) for Midlothian. This highlights coal spoil
heaps, shale bings and derelict mill sites as particular features of the
Midlothian area; the site’s vegetation shares some characteristics of colliery
spoil heaps and shale bings, and could be considered to be of local
conservation interest.
Other Ecological Interest Features
8.3.52 Willow warbler is on the British Trust for Ornithology (BTO) Amber List of Birds
of Conservation Concern (BOCC), due to a moderate decline in breeding
population (>25 - <50%) over both longer-term (40 year) and shorter-term (25
year) periods. This is the only species of higher conservation value recorded
breeding within the Application Site is willow warbler. Although it remains a
common and widespread migratory species, because of the favourable habitat
conditions (birch woodland with varied structure) leading to a relatively high
breeding density (7 pairs in 2013), can be considered a feature of local
conservation interest as part of the breeding bird assemblage.
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Invasive Species
8.3.53 No plant or animal species listed on Schedule 9 of the Wildlife & Countryside
Act 1981 (as amended) were recorded within the site during any of the
surveys.
Summary of Ecological Interest Features
8.3.54 The table below summarises the ecological interest features identified above
with an indication of their geographical scale of importance. These are the
features which will be considered as sensitive receptors for the purposes of
the EcIA.
Table 8.7: Summary of Ecological Interest Features
Feature Legal and National Policy Status
Scale of Importance
Firth of Forth SPA and Ramsar Site
Imperial Dock Lock SPA
Forth Islands SPA
Article 4 Birds Directive; Habitats Regulations 1994 (as amended in Scotland); Scottish Planning Policy (2014), paras. 194, 195, 196, 203-04, 207-08, 211.
Features of international importance within 15km of site to be considered in terms of air quality or other indirect impacts.
Firth of Forth SSSI
Dalkeith Woodlands SSSI
Arthur’s Seat Volcano SSSI
Duddingston Loch SSSI
Hadfast Valley SSSI
Bilston Burn SSSI
Wester Craiglockhart Hill SSSI
Crichton Glen SSSI
Black Burn SSSI
Section 3-11 Nature Conservation (Scotland) Act 2004; Scottish Planning Policy (2014), paras. 194, 196, 203-04 & 212.
Feature of national importance within 15km of the site to be considered in terms of air quality or other indirect impacts.
Edmonstone UWS / LBS
Dalkeith Estate LBS
Disused Railway Network UWS
Brunstone Burn LWS
Scottish Planning Policy (2014), paras. 196-97.
Feature of local importance within 2km of the site to be considered in terms of any potential indirect impacts.
Newhailes ancient woodland
Eastfield Wood ancient woodland
Wood east of Newton ancient woodland
Howland’s Park ancient woodland
Wood East of Newton Church ancient woodland
Scottish Planning Policy (2014), paras. 194, 201, 216 & 218
Feature of at least local importance within 2km of the site to be considered in terms of air quality impacts.
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Feature Legal and National Policy Status
Scale of Importance
Lowland mixed deciduous woodland (G1.91 birch woodland) priority habitat
Scottish Planning Policy (2014), para. 195.
Feature of local importance within site.
Bats Annex Iva Habitats Directive; Schedule 2 1994 Habitats Regulations (as amended in Scotland); Scottish Planning Policy (2014), paras. 194, 195 & 214.
Feature of local importance on site;
EPS to be considered in terms of legislative compliance.
Breeding bird assemblage 1981 Wildlife & Countryside Act (as amended in Scotland); Schedule 6, 2004 Nature Conservation (Scotland) Act; Scottish Planning Policy (2014), para. 194, 214.
Feature of local importance on site;
Legal protection against deliberate or reckless killing or injury, to be considered in terms of legislative compliance.
Common lizard Schedule 5 1981 Wildlife & Countryside Act (as amended in Scotland); Scottish Planning Policy (2014), para. 194, 214
Feature of up to local importance on site;
Legal protection against deliberate or reckless killing or injury, to be considered in terms of legislative compliance.
Brownfield site Scottish Planning Policy (2014), paras. 195, 197, 217 & 218. Midlothian BAP.
Secondary woodland, scrub and grassland habitat; local importance.
PPiP Future Baseline Scenario
8.3.55 The PPIP future baseline scenario (refer to Chapter 2.0 for full details) reflects
the fact that a major development located at the Application Site has been
granted planning consent. The assessment of effects in this scenario seeks to
set out in brief any additional ecological effects that would derive from the
Proposed Development, over and above those deriving from the consented
PPiP development which it would effectively replace.
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8.4 Assessment of Effects
Incorporated Mitigation
8.4.1 A number of mitigation measures have been incorporated into the scheme
design, construction and operational procedures in order to avoid, reduce or
compensate for potential adverse ecological impacts. These include:
Measures incorporated into the combustion and energy generation
processes to avoid or reduce emissions, which are outlined in the
scheme description contained within Chapter 4.0 and the AQA in
Chapter 12.0;
Measures are incorporated into construction methods and operational
procedures in accordance with the SEPA guidelines in order to reduce
the risk of any potential impacts on the water environment, as described
in Chapter 10.0;
Measures incorporated into the site design to reduce the extent of light
and noise pollution, as described in Chapters 3.0 and 11.0; and
Measures incorporated into the site’s landscape design to replace
woodland habitat loss and maintain or enhance the biodiversity interest
of the site, as illustrated in the Indicative Landscape Masterplan (Figure
7.4).
Construction Phase Impacts – Existing Baseline
Direct Impacts on Habitats and Species
8.4.2 Construction works will result in loss of the habitats listed in Table 8.7 above,
although efforts will be made to retain the eastern fringe of birch woodland
during construction, as shown in Figure 7.4 (Indicative Landscape
Masterplan). Based on current construction plans all areas required for offices
/ staff facilities, parking, storage and pre-assembly can be accommodated
within the Application Site boundary, and there will be no requirement for
additional habitat loss outside of this area.
8.4.3 The loss of 2.3ha of lowland mixed deciduous woodland habitat represents a
reduction of 13.1% in the original woodland resource present on the wider
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Millerhill sidings site, and could be seen as a moderate magnitude impact in a
local context.
8.4.4 Bat foraging habitat will be degraded over the site due to the loss of sheltered
woodland edge and glade habitats and their associated insect prey species.
No roost sites will be affected, and since the site now lies on the northern
edge of the wooded rail sidings, with the AD Facility to the north, habitat
connectivity will not be adversely affected. The loss of foraging habitat is a low
magnitude impact due to the relatively low bat activity levels recorded in
surveys.
8.4.5 Habitat loss will result in the displacement and loss of nesting habitat for up to
14 territories in total of five woodland breeding bird species, including seven
territories of an Amber List species, willow warbler. There will also be a loss of
potential foraging habitat for species breeding in adjacent habitats, and loss of
foraging habitat for birds outside the breeding season. If further vegetation
clearance works are carried out during the breeding season, there is a risk of
loss of nests and eggs and killing or injuring young birds.
8.4.6 Construction activity on site, with associated noise, vibration and movement of
plant is likely to result in displacement of common lizard from the site and its
surroundings. There is also a risk of killing or injuring lizards during the
removal of piles of tree stumps and brash, particularly if this is carried out
during the hibernation season.
Indirect impacts on habitats and species
8.4.7 Potential adverse indirect ecological impacts during construction include:
Disturbance of wildlife in adjacent habitats due to noise, lighting,
vibration and human activity; and
Pollution of adjacent land as a consequence of leakage of hydrocarbons
from plant or stored fuels, and deposition of waste materials from
construction operations.
8.4.8 The risk of significant indirect ecological impacts is lessened by the lack of
sensitive ecological receptors in close proximity to the Application Site. The
recently constructed AD Facility to the north, Borders Rail line and Shawfair
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urban development to the west, and active rail sidings to the east are not
sensitive to disturbance impacts. The birch woodland to the immediate south
of the site does support breeding birds and foraging bats, and is a likely to
support a small population of common lizard, and can be considered a
sensitive receptor to near-site effects.
8.4.9 The magnitude of disturbance impacts would vary according to the time of
day, season of operations and species group concerned. They would tend to
be greater in spring for birds during the breeding season, and in spring and
autumn for bats when activity periods coincide with working hours. Human
activity involved with construction at height, sudden construction noise, and
high intensity lighting are likely to be the most disturbing activities. Movement
of vehicles and plant is generally less disturbing, with some habituation of
birds likely. All of these disturbance effects are likely to be of short duration,
with the likelihood of recovery following completion of the activity.
8.4.10 With respect to lighting impacts, the proposed working hours of 07:00 –
19:00hrs Monday to Friday and 07:00 – 12:00hrs Saturday will have limited
effects on the bat flight activity period, with any overlap limited to small periods
of the spring and autumn. As noted in Chapter 4.0, low-level lighting of
security compounds may be necessary outside these periods, but this is likely
to result in a low level of light spillage and consequently limited disruption to
nocturnal wildlife.
8.4.11 The Surface Water and Flood Risk Chapter (see Chapter 10.0) assesses the
risk of water pollution of downstream habitats during construction as short
duration and minor adverse in significance. Any risks would be minimised by
measures outlined in Chapter 10.0 and summarised in the Incorporated
Mitigation section above, and implemented through a CEMP produced in
accordance with the SEPA guidelines.
8.4.12 The AQA does not predict any adverse impacts on sensitive ecological
receptors as a consequence of the construction phase of the Proposed
Development. With implementation of incorporated mitigation measures, local
scale impacts such as dust deposition to adjacent vegetation would be
minimal and very unlikely to have a measurable ecological effect.
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Impacts on Ecological Interest Features
8.4.13 Table 8.8 lists the potential construction phase impacts on ecological interest
features identified in the preceding section.
Table 8.8: Construction Phase Impacts on Interest Features
Interest Feature Potential Impact and Magnitude / Extent
Risk of Occurrence, Duration and Reversibility
Lowland mixed deciduous woodland
Loss of up to 2.3ha, moderate magnitude in local context
Certain to occur. Can be partially reversed by tree and shrub planting in landscape scheme.
Bats Loss of foraging habitat for low numbers of bats, mainly soprano pipistrelle
Certain to occur during the construction phase. Can be partially mitigated by tree and shrub planting in the landscape scheme.
Breeding bird assemblage Displacement of breeding birds on site (14 territories) and disturbance of birds adjacent to site.
Certain to occur, risk of wider impacts depends on nature and timing of operations, medium term (>2-3 years), partly reversible with mitigation.
Common lizard Displacement of probably small population and potential killing / injury of common lizard.
Possible occurrence during site clearance of piles of brash. Can be avoided through method statement.
Brownfield habitat Loss of 5.43ha of habitats within the brownfield site including birch woodland, scrub, tall herbs, grassland and vegetated clearing.
Certain to occur during the construction phase. Can be partially mitigated through compensatory planting and landscape scheme.
Construction Phase – Assessment Against PPiP Future Baseline
8.4.14 The PPiP scheme proposed two options, one of which (option ‘A’, drawing no.
25640-G012-K) would require the greater part of the birch woodland to be
cleared in order to accommodate the development.
8.4.15 The PPiP scheme does not set out construction methods in detail, but it is
reasonable to assume that they would require the use of additional areas to
accommodate site compounds, storage or pre-assembly areas.
8.4.16 It is reasonable to assume that the PPiP scheme would carry out similar
precautions to limit the risk of indirect impacts on the water environment in
accordance with legislative requirements and the SEPA guidance, as well as
measures to limit construction noise and light spillage.
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8.4.17 The PPiP development is therefore likely to result in a significantly greater
impact of lowland mixed deciduous woodland priority habitat and brownfield
land local BAP priority habitat, together with all associated fauna including the
breeding bird assemblage. With reference to the 2013 breeding bird survey,
this would involve loss of a further 25 territories from the area to the south of
the current Application Site, including six willow warbler territories. In addition,
the area supports one yellowhammer territory and a song thrush territory; both
are SBL species, albeit not in the highest risk categories (song thrush: ‘avoid
negative action’ category; yellowhammer: ‘watching brief category).
Operational Phase – Existing Baseline
Summary of Potential Ecological Impacts
8.4.18 The operational phase of the Proposed Development would not result in any
additional direct impacts in terms of land-take and consequent habitat loss.
The habitats created in the landscaping scheme and the development of
ponds will start to offset habitat losses during the construction phase, leading
to positive impacts through habitat enhancement for amphibians and other
wildlife.
8.4.19 Potential indirect adverse impacts during the operational phase may arise due
to the ecological effects of lighting, noise, human disturbance and emissions
to air and water. These are considered in further detail below.
Potential Ecological Impacts of Lighting
8.4.20 Light spillage from the site into adjoining wooded habitats to the south and
landscaped areas within the site could potentially disrupt bat foraging
behaviour, and affect nocturnal flying insect behaviour. Published levels with
observed ecological effects range from 1 lux to over 4 lux, depending on
spectral quality. Effects are species-specific, with the pipistrelle species which
have been most frequently recorded on site being less sensitive. Lighting
impacts also have to be assessed in comparison with the current baseline,
which includes tall lighting towers over the Millerhill Marshalling Yards.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 192
8.4.21 Chapter 4.0 describes a number of incorporated mitigation measures to
address external light spillage. Light sources will include the translucent
building façade, low-level lighting in operational areas and along paths, and
lighting columns along the public path which will be constructed around the
northern and western boundaries of the site. These will be unlikely to prevent
utilisation of wooded habitats adjacent to the site, or newly-created wetland
and woodland habitats within the site by common and soprano pipistrelle bats.
Potential Ecological Impacts of Noise
8.4.22 There are no regulatory standards applied to noise impacts for the protection
of ecological receptors. Based on studies carried out by the University of
Hull’s Institute of Estuarine and Coastal Studies, a noise level of 55dB(A) can
be considered as a threshold at which disturbance of sensitive species of
waders may occur. Passerines (perching birds) are generally thought to be
less sensitive, although behavioural effects and in some species a reduction in
breeding success can occur. This is probably a consequence of the masking
effect of certain frequencies (e.g. from road traffic noise). The ‘A’ weighting
used to adjust sound pressure levels to the frequency range of human hearing
can be applied to birds, and is slightly precautionary.
8.4.23 The Noise Assessment predicts day-time and night-time noise levels to be
well below the 55dB(A)eq level at the site boundary (see Appendix 11-6,
Noise Mapping), and noise from the Proposed Development will not therefore
have a discernible ecological effect on adjoining habitats.
Potential Disturbance Impacts
8.4.24 There will be some increase in human disturbance as a consequence of the
Proposed Development, with vehicle movements and activity generated by the
operation of the RERC. There will also be public access to some of the
landscaped areas of the site, including grassland, ponds and some of the
woodland habitats, as illustrated by Figure 7.4.
8.4.25 Disturbance levels may be sufficient to prevent utilisation of the new
landscape by some sensitive species, possibly including reptiles such as
common lizard. However, this has to be seen in the context of the concurrent
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 193
urbanisation of the wider environment, with a consequent shift to species
which are adapted to more urban habitats.
8.4.26 As a working facility, the proposed development is unlikely to generate
significant additional human disturbance on habitats outside of the site.
Potential Ecological Impacts of Emissions to Air
8.4.27 In ecological terms, the emissions of greatest potential concern are oxides of
nitrogen, sulphur dioxide and ammonia, because of their fertilising or
acidifying effect on ecosystems. Nitrogen dioxide and ammonia have a
fertilising effect and all three can have an acidifying effect when deposited to
soils and vegetation (the alkaline gas ammonia as a source of hydrogen ions).
Sensitivity varies between habitats and particular components of habitats and
is reflected in a series of Critical loads (CL) for deposition of nitrogen and
acidity. Because of their potential to affect sensitive ecological receptors
remote from the site, including European designated sites, it is important to
give careful consideration to these potential adverse ecological impacts.
8.4.28 The AQA modelled the cumulative air quality impacts of the Proposed
Development (with 75m stack) and the adjacent AD Facility for sensitive
ecological receptors within 15km of the site. The AD Facility was not included
in the ammonia modelling as it does not produce significant emissions.
8.4.29 In accordance with the SEPA guidance, significance thresholds for ecological
effects are set for a process contribution (PC) of 1% of the long-term (annual)
critical level or critical load, and 10% of the short-term (24-hour) critical level. If
the predicted environmental concentration (PEC) resulting from the
background levels and PC is <70% of the relevant critical level or load, then
the process contribution can be screened out as insignificant. Where the PC
exceeds 1% and the PEC 70%, assessment of potential ecological effects has
been carried out.
8.4.30 For oxides of nitrogen, none of the predicted PCs exceeded the short-term
threshold. A number of sites exceeded the 1% long-term threshold, including
five of the modelled receptor locations at Firth of Forth SPA / Ramsar / SSSI,
together with Newhailes and Eastfield Wood ancient woodlands. The
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maximum PC (at Newhailes) was 1.5%. However, in every case the PEC is
<70% of the critical level for protection of ecosystems of 30µg/m3, and can be
screened out as insignificant.
8.4.31 For sulphur dioxide, all the process contributions were less than the 1% long-
term threshold of the critical level for protection of ecosystems of 20µg/m3; the
PC was also less than the lower critical level for sites with sensitive lichen
communities of 10µg/m3 applied to Dalkeith Oakwood SSSI. Modelled
background concentrations are also all well below critical levels.
8.4.32 For ammonia, all the process contributions were less than the 1% long-term
threshold of the critical level for protection of ecosystems of 3µg/m3; the PC
was also less than the lower critical level for sites with sensitive lichen
communities of 1µg/m3 applied to Dalkeith Oakwood SSSI. In the case of
ammonia, modelled background concentrations exceed Critical levels at
Dalkeith Oakwood, but as the Proposed Development is only predicted to
make a 0.31% process contribution to this level it cannot be considered to
have an ecological effect.
8.4.33 The process contribution to nitrogen deposition was predicted to exceed the
1% of critical load threshold at three of the modelled locations at Firth of Forth
SPA / Ramsar site / SSSI (E5-E7), and Newhailes ancient woodland, with a
maximum PC of 1.20%. Table 47 of the AQA provides full details.
8.4.34 The Firth of Forth sites are all at Levenhall Links near Musselburgh, and only
exceed the 1% threshold if the lower critical load (LCL) for sand dune habitat
of 8kg N/ha/yr is applied. In fact the habitats within the SPA in the vicinity of
these points are intertidal mud, a coastal ash lagoon and a wetland area, all of
which have significantly higher critical loads. Furthermore, reference to the
SSSI citation indicates that qualifying sand dune habitats in the Firth of Forth
are calcareous dunes. The recommended critical load for environmental
assessment purposes for calcareous dunes (from the Air Pollution Information
Service (APIS) website) is 10kg N/ha/yr; the maximum modelled PC of
0.959kg N/ha/yr does not exceed the 1% threshold of what would in any case
be a very precautionary critical load.
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8.4.35 With respect to Newhailes ancient woodland, the correct critical load for
environmental assessment purposes is 10kg N/ha/yr, with the 1% threshold
just exceeded by the modelled PC of 0.1058kg N/ha/yr. Modelled background
levels (from APIS) are 24.22kg N/ha/yr, and therefore exceed the 70%
threshold and cannot be screened out as insignificant. However, the PC is
less than 0.44% of background levels, representing a small incremental
contribution to critical load exceedance. While not understating the potential
detrimental effects of critical load exceedance, such a small magnitude effect
is very unlikely to have a measureable ecological effect.
Potential Ecological Impacts of Emissions to Water
8.4.36 Mitigation measures have been incorporated into the scheme design and
operational procedures which would prevent release of untreated wastewaters
to watercourses, and attenuate surface water drainage from hard surfaces.
Potential ecological impacts on the water environment would therefore be
avoided.
Summary of Operational Phase Impacts
8.4.37 Table 8.9 over the page summarises potential operational phase impacts on
ecological interest features identified in the previous section, with an
assessment of magnitude, risk of occurrence, duration and reversibility.
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Table 8.9: Summary of Operational Phase Impacts
Interest feature Potential impact and magnitude/extent
Risk of occurrence, duration and reversibility
Firth of Forth SPA / Ramsar site / SSSI
Habitat changes as a consequence of (a) increased oxides of nitrogen levels and (b) increased nitrogen deposition.
(a) No risk of occurrence as air quality standard not exceeded; (b) No risk of occurrence as process contribution <1% of critical load for relevant habitat.
Newhailes ancient woodland
Habitat changes due to increased nitrogen deposition
Negligible risk of measurable effect as process contribution <1% of background deposition.
Bats Reduction in potential use of bat habitat within and around the site due to lighting
Low risk of occurrence with incorporated mitigation measures.
Breeding bird assemblage Reduction in potential use of bird habitat within and around the site due to noise and human disturbance
Low risk of discernible effects as bird community likely to change in wider vicinity of site; no risk of noise impacts outside site.
Common lizard No colonisation of new habitats within the site due to human disturbance
Moderate risk of occurrence without mitigation to improve habitat quality.
Operational Phase Impacts – Assessment Against PPiP Scheme
8.4.38 It is likely that the operational phase impacts of the PPiP scheme would be
essentially similar to those of the Proposed Development in terms of potential
ecological effects of lighting, noise, human disturbance, air quality and water
quality. These are not specified in the ecological assessment carried out to
inform the PPiP, but it is reasonable to assume they would not be significantly
different.
Impact Significance
Impacts on European Conservation Sites
8.4.39 No likely significant effects are predicted on any of the three European
designated sites within a 15km buffer of the Application Site. When habitat-
specific critical loads for nitrogen deposition are taken into account, air quality
impacts on the Firth of Forth SPA and Ramsar site are not significant.
Incorporated mitigation measures will ensure that any risks to the water
environment are avoided or reduced in accordance with the SEPA pollution
prevention guidance.
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Impacts on Ecological Interest Features
8.4.40 Table 8.10 summarises the significance of the impacts outlined in Tables 8.8
and 8.9 above. This combines the scale of importance of the interest feature
with the magnitude of predicted impact, to arrive at an assessment of impact
significance. This utilises the site integrity or conservation status approach
favoured in current guidelines, and arrives at a conclusion based on the
criteria set out in Table 8.1. Note that features of negligible interest, and
features with no impacts predicted are excluded from the assessment.
Table 8.10: Impact Significance
Interest feature Scale of
importance Impacts
Impact significance / effect on site integrity or conservation status
Firth of Forth SPA / Ramsar / SSSI
International Small magnitude increase in oxides of nitrogen & nitrogen deposition likely
No likely significant effect: not significant
Newhailes ancient woodland
Local Small magnitude increase in oxides of nitrogen & nitrogen deposition likely
No measurable effect likely – not significant
Lowland mixed deciduous woodland priority habitat
Local
Certain loss of feature on site, moderate magnitude impact on remaining woodland cover; partial recovery in area following re-establishment
Effect on site integrity certain – significant at local scale of importance.
Bats Local
Certain small loss of foraging habitat for relatively low numbers of bats, mainly soprano pipistrelle; possible ongoing local reduction in local habitat quality due to lighting
No impact predicted on conservation status of bat species in the local area, therefore not significant in ecological terms
Impact Significance – PPiP Scheme
8.4.41 The ecological assessment for the PPiP (Chapter 9 of the Zero Waste ES)
reached broadly similar conclusions on impact significance despite some
differences in assessment methodology. Impacts on woodland habitats and
breeding birds were assessed as slight / moderate adverse significance,
based on a matrix approach which valued the features as having ‘low’ value
and the impact magnitude as ‘moderate’. Given the greater scale of impact on
these features (e.g. loss of 39 breeding bird territories), the impacts of the
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PPiP scheme could be regarded as having a higher ecological significance
than the Proposed Development.
8.4.42 Key differences in PPiP ecological impact assessment include the
identification of barn owl as an interest feature subject to slight / moderate
significance impacts in the PPiP scheme, and the identification of possible
impacts on common lizard in the present scheme. The identification of barn
owl as a sensitive receptor in the PPiP scheme is a consequence of the wider
area affected by the scheme, and differing baseline conditions; barn owl have
not been recorded on or near the Application Site, while the more urbanised
nature of the current baseline is likely to displace barn owl further from the
site. Common lizard were not recorded prior to the PPiP, so impacts on
reptiles did not form part of that assessment. Had they been, it is possible that
they would have been identified as a significant ecological impact at least at
the local scale, particularly given the greater extent of habitat loss and
disturbance associated with the PPiP scheme.
Compliance with Protected Species Legislation
8.4.43 It is also necessary to consider the predicted impacts to determine whether
there is any possibility of breaching protected species legislation. Key
questions to consider include:
Would the development comply with EPS legislation, as implemented by
the Conservation (Natural Habitats, &c.) Regulations 1994 (as
amended)?
Would the development comply with European and UK protected
species legislation, including any Schedule 1, Schedule 5 or Schedule 8
Wildlife and Countryside Act 1981 species (as amended) recorded on
site?
Are there any other protected species which may need to be
considered, other than those already recorded?
8.4.44 There are no confirmed bat roosts on site, and the assessment has
demonstrated that habitats present have a negligible risk of supporting a bat
roost. Development of the site would not involve any licensable activities. The
assessment has concluded that the loss of foraging habitat as a consequence
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of the development would not affect the conservation status of bats in the local
area; it would not constitute ‘disturbance’ in the sense of Article 12(1)(b) of the
Habitats Directive.
8.4.45 No other EPS are known to occur or likely to occur on site, and there is
therefore no risk of non-compliance with EPS Legislation.
8.4.46 All species of wild bird are under protected against deliberate or reckless
destruction of nests and eggs, or killing and injuring adults and young. It will
be necessary to avoid activities such as scrub clearance and tree felling
during the bird breeding season (April – July for most species) to ensure
legislative compliance with respect to breeding / nesting birds.
8.4.47 Common lizard have partial protection under Schedule 5 of the Wildlife &
Countryside Act 1981 (as amended) against killing and injuring. It will be
necessary to formulate a method statement in the CEMP to implement
measures during site clearance operations which ensure legislative
compliance with respect to common lizards. This may involve ecological
supervision of brash-pile clearance, particularly if this is undertaken during the
winter hibernation season (October – March).
8.4.48 No impacts are expected on any other protected species.
8.5 Mitigation and Enhancement Measures
Need for Additional Mitigation
8.5.1 The incorporated mitigation measures previously described adequately
address the need to avoid, reduce and compensate for many of the potentially
significant adverse impacts on ecological interest features. The landscape
design includes some woodland planting along the eastern boundary of the
site, which will provide partial compensation for habitat loss and impacts on
the breeding bird assemblage. New habitats will not provide direct
compensation, but will contribute to the overall biodiversity of the site and
address policy needs to achieve no net loss of biodiversity interest.
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8.5.2 Within the framework of the landscape design, additional ecological mitigation
can best be achieved by formulating a long-term management plan targeted at
key species and habitats. These include not necessarily those displaced from
the site by construction works, but priority species and other key species
which have a reasonable expectation of establishment given appropriate
management. As part of the site is open to the public, it would be appropriate
for some of these to be species of cultural significance in the SBL.
8.5.3 Although it would be difficult to recreate the specific features of the woodland
which will be lost from the site, particularly the soil conditions which have led
to its distinctive post-industrial flora, it should be possible to achieve better
growth rates and future condition of the woodland. In doing so it will minimise
the gap between felling and the new woodland achieving some of the
ecological functions fulfilled by the present habitat, such as providing a
sheltered feeding site for bats, and sufficient cover and structural diversity to
support foraging and nesting birds. It is anticipated that the new planting will
start to fulfil some of these functions within 5 years of planting, when a closed
canopy is achieved and it is able to provide suitable conditions to support a
range of breeding birds.
8.5.4 Features should be incorporated into the site design which provide suitable
habitat for common lizard. It is not certain that common lizard will recolonize
the site, although parts of the active rail sidings and woodland to the south
could potentially support any displaced individuals which would have access
to the restored landscape as it became suitable. Features such as
hibernacula and areas of longer grass adjacent to open basking areas would
be beneficial and will be incorporated into the landscape management plan.
The location of some of these features in areas which are not readily
accessible to the public will help ensure there are no residual impacts caused
by greater levels of disturbance.
Mitigation of Impacts on Protected Species
8.5.5 In order to comply with protected species legislation, measures described
above relating to the avoidance of impacts on breeding birds and common
lizard should be implemented during the construction phase of the
development.
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Ecological Enhancement Measures
8.5.6 For the purposes of the ecological assessment, features such as new ponds
and grassland incorporated into the landscape design are best characterised
as enhancement rather than mitigation, since they introduce new habitats
which were not present on site before the development.
8.5.7 Target species and habitat condition standards for new habitats will also be
formulated in the Landscape and Ecological Management Plan (LEMP), with
the aim of maximising biodiversity benefits. These will include the
establishment of aquatic vegetation, the avoidance of introducing invasive
alien species, and the establishment of a diverse grass sward composed of
species native to the south-east Scotland region.
8.5.8 Target fauna will include those native species with a reasonable chance of
colonising, including birds of aquatic and marginal habitats such as moorhen,
and freshwater invertebrates, which are not currently represented on site. The
establishment of aquatic habitats with clean water and good invertebrate
populations will also improve habitat quality for foraging bats. Habitat and
species targets will be selected with reference to the Midlothian LBAP and
SBL.
8.6 Residual Impacts
8.6.1 The development will result in a residual impact of local ecological significance
(minor significance) on lowland mixed deciduous woodland priority habitat and
brownfield land local priority habitat.
8.6.2 Following establishment of new trees and shrubs from around 5 years after
planting, together with new wetland habitats, the residual impacts on the
breeding bird assemblage will differ from the current baseline in terms of
numbers of breeding pairs and species composition. However, these
differences are unlikely to be significant in ecological terms.
8.6.3 No other residual impacts are anticipated; with appropriate management of
the planned landscape design, it is a reasonable expectation that there will be
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 202
no significant loss of biodiversity interest in terms of numbers of species
present on site.
8.7 Conclusions
8.7.1 The effects of the Proposed Development on flora and fauna have been
considered in accordance with current guidance for ecological impact
assessment.
8.7.2 The assessment predicts adverse impacts of local significance on lowland
broadleaved woodland priority habitat; brownfield land local priority habitat;
the breeding bird assemblage on site; and common lizard.
8.7.3 No effects are predicted on the conservation status of bats in the local area as
a consequence of the Proposed Development; although there will be a
reduction in habitat quality by loss of woodland edge habitat, this has not been
assessed as ecologically significant. No other effects are predicted on EPS.
8.7.4 These effects occur against a baseline of increasing urbanisation, which
would be likely to change the species composition of the site and surrounding
area in the absence of any development in the site.
8.7.5 Consideration of wider scale effects on sensitive ecological receptors within
15km of the Proposed Development has shown that there will be no significant
ecological effects. In particular, no likely significant effects are predicted on
European conservation sites.
8.7.6 Measures will be required to be incorporated in the CEMP to protect common
lizard and breeding birds in accordance with species protection legislation and
policy.
8.7.7 The establishment of new habitats within the site provides the opportunity to
realise benefits for biodiversity within the site, in accordance with national
planning policy.
8.7.8 When compared to the future baseline represented by the PPiP scheme, the
Proposed Development will reduce the magnitude of impact on features such
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 203
as lowland broadleaved woodland habitat and its component breeding bird
assemblage.
8.8 References
IEEM (2006). Guidelines for ecological impact assessment in the United
Kingdom. Approved version, 26 June 2006.
Midlothian Biodiversity Action Plan (2006) (accessed 2nd December
2014).
http://www.midlothian.gov.uk/info/200134/biodiversity/409/biodiversity_inf
ormation/2
Natural Scotland Scottish Government Forestry Commission Scotland
(2014), Native woodland survey of Scotland: Local Authority and regional
native woodland areas by priority woodland type. Summary Leaflet.
Scottish Natural Heritage (2013). A handbook on environmental impact
assessment. 4th edition.
Strachan, I.M. (2015). Manual of terrestrial EUNIS habitats in Scotland.
Scottish Natural Heritage Commissioned Report No. 766.
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9.0 GEOLOGY AND GROUND CONDITIONS
9.1 Introduction
9.1.1 This Chapter provides an assessment of the potential environmental effects
and impacts of the Proposed Development in relation to geology,
hydrogeology and ground conditions (including contamination and
geotechnical stability).
9.1.2 Soils, geology and hydrogeology (i.e. groundwater) play an important role in
determining the environmental character of an area. Development schemes
can have both direct and indirect effects on geology and groundwater.
Existing soil conditions (particularly land contamination), can impose
constraints on development and pipelines can form pathways for the migration
of groundwater, both in the short-term, during construction, and in the long-
term. Ground conditions can also introduce physical constraints on the
construction of structures (e.g. historic mining, foundations, hard standing,
services and excavations).
9.1.3 This section of the ES report will set out how these issues will be assessed in
a systematic manner.
Planning Policy and Guidance
9.1.4 Planning policy and legislation relevant to the consideration of geology and
hydrogeology in the context of the development is as follows:
SPP1 – Development of Contaminated Land (PAN33) and Planning and
Environmental Protection (PAN51);
Environmental Protection Act, 1990 (Part IIA) – Statutory Guidance:
Edition 2
The Groundwater (Scotland) Regulations, 2009;
Contaminated Land (Scotland) Regulations 2005;
Water Environment and Services (Scotland) Act, 2003;
Flood and Water Management Act, 2010;
The Environment Act, 1995;
Town and Country Planning Act (Scotland), 1997; and
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 205
Scottish Private Water Supply Regulations 2006.
Previous Planning Application at the Site
9.1.5 The EIA undertaken for a previous PPiP application for a similar but facility to
the proposed Millerhill RERC development, assessed the geological and
hydrogeological impacts of the proposed development. The facilities proposed
within the previous PPiP included an option which was larger than the
currently proposed Millerhill RERC development. This previous ES concluded
that most potential impacts during the construction, operational and
decommissioning phases of the development were assessed as being of
negligible or minor significance. This was with the exception of the potential
for mineral instability to impact site operatives during construction and
decommissioning (assessed as being of moderate/major significance) and for
contamination to impact human health assessed as being of moderate
significance due to construction workers being considered as high sensitivity.
With the proposed mitigation measures and monitoring identified in the ES in
place, the potential impacts of the previously proposed development were
assessed as being negligible and not significant.
9.1.6 The PPiP required that the development shall not begin until a scheme to deal
with any contamination of the site and/or previous mineral workings has been
submitted to, and approved by, the planning authority. The PPiP also required
that proposals should be provided to deal with any contamination and/or
previous mineral workings and include:
A. The nature, extent and types of contamination and/or previous mineral
workings on the site;
B. Measures to treat or remove contamination and/or previous mineral
workings to ensure that the site is fit for the uses hereby approved, and
that there is no risk to the wider environment from contamination and/or
previous mineral workings originating within the site;
C. Measures to deal with contamination and/or previous mineral workings
encountered during construction work; and
D. The condition of the site on completion of the specified decontamination
measures.
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9.1.7 The PPiP also required that before any of part of the development is brought
into use, the measures to decontaminate and stabilise the site if required shall
be fully implemented as approved by the planning authority.
9.2 Methodology
9.2.1 The assessment methodology will involve assessing the existing baseline
conditions and assessing the risks to various receptors in order to rank the
significance during all aspects of the project lifetime (e.g. current conditions,
during construction, operation and during decommissioning phases). The
required mitigation measures will then be presented and the revised level of
potential impact will then be assessed.
9.2.2 The sensitive receptors identified as part of this assessment will be
considered in terms of their importance and their sensitivity to change within
the context of the site. The criteria used to define this are presented in Table
9.1 below.
Table 9.1: Evaluation of Sensitive Receptors
Importance
National Nationally designated sites (e.g. Geological SSSI). A nationally important feature that is rare in the region.
Regional A feature that falls short of national designation guidelines but provides a resource that is rare or relied upon at a regional level (e.g. a RIGS).
Local A regularly occurring feature that provides a resource that is relied upon at a local level.
Sensitivity to Change
High Long-term integrity of the receptor may be compromised at a national or regional level
Medium Integrity of the receptor may be compromised at a local level
Low Integrity of the receptor is not at risk
9.2.3 Significance criteria used in this assessment are based on changes (resulting
from the development) to the impact of contamination on the environment in
terms of statutory standards (primarily statutory guidance Contaminated Land
(Scotland) Regulations 2005 under Part IIA of the Environmental Protection
Act 1990).
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9.2.4 Significance of impact is based on the change in level of risk from
contamination. The classification of risk is explained in Table 9.2. This follows
DEFRA’s Guidelines for Environmental Risk Assessment and Management
(2000).
Table 9.2: Classification of Risks from Contamination
Probability High Medium Low Negligible
Level of
Severity Consequence of Risk Likely
Reasonably Foreseeable
Unlikely Not
Credible
Sev
ere
Acute risks to human health
Catastrophic damage to buildings/property (e.g. by explosion).
Direct pollution of sensitive water receptors or serious pollution of other controlled water (watercourses or groundwater) bodies.
Very High
High High/
Medium Low
Mo
dera
te
Harm to human health from long-term exposure.
Slight pollution of sensitive controlled waters (surface waters or aquifers) or pollution of other water bodies.
Significant effects on sensitive ecosystems or species.
High Medium Medium/
Low Low
Mild
No significant harm to human health in either short or long term.
No pollution of sensitive controlled waters, no more than slight pollution of non-sensitive waters.
Significant damage to buildings or structures.
Requirement for protective equipment during site works to mitigate health effects.
Medium/ Low
Low Low Low
Neg
lig
ible
Damage to non-sensitive ecosystems or species.
Minor damage to buildings or structures
No harm or pollution of water.
Low Near Zero Near Zero
Near Zero
9.2.5 The risks from all pathways to relevant receptors from contaminant sources
are assessed. Where potential linkages between sources of contamination
and sensitive receptors are identified, predicted effects documented. The
prediction of these effects considers the importance and sensitivity of the
receptor and the assessment also assess whether the predicted effect is
beneficial or adverse, direct or indirect and permanent or temporary.
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9.2.6 The predicted effects have been evaluated in terms of their likely significance,
which will then inform any proposed mitigation measures. The criteria used to
determine the significance of predicted effects are provided in Table 9.3
(below). Where the significance of a predicted effect would be influenced by
further intrusive data and quantitative risk assessment, a worst case scenario
was assumed in order to provide a robust assessment.
Table 9.3: Impact Significance
Significance Criteria
Major Adverse The effect would adversely affect the integrity of the receptor, and would be difficult to reverse and/or alleviate.
Moderate Adverse The effect would not permanently affect the integrity of the receptor but may result in noticeable damage that would require mitigation.
Slight Adverse No permanent or noticeable damage but requiring mitigation as a preventative measure.
No Significant Effect
No significant adverse or beneficial effects would result.
Beneficial The effect would benefit the quality of the receptor but not such that its importance would be improved.
Major Beneficial The effect would improve the integrity of the receptor such that its overall importance would improve.
Geotechnical Assessment
9.2.7 An assessment will be made of issues associated with ground conditions
present at the site including natural hazards, land instability due to the
presence of low strength and compressible strata and the presence of deep
Made Ground. The risks from shallow mine workings and mine entries
together with former railway structures (e.g. basements) and presence of
shafts has also been assessed. The risk from past mine workings is currently
considered to be a significant risk that requires mitigation.
9.2.8 Areas of uncertainty are indicated and site investigations recommended that
to reduce any uncertainty prior to commencement of construction. Where
piling is proposed for foundations, a preliminary piling risk assessment will be
carried out in accordance with the SEPAs requirements.
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Stages of Assessment
9.2.9 The ground-based environmental conditions will change over time given the
different processes that will be carried out at each stage. An evaluation has
been made of each of the following stages:
Current (Baseline) conditions;
Effects of the construction process;
Effects during the operational phase; and
Effects during decommissioning.
Baseline Conditions
9.2.10 The potential effects of the presence of contamination at the Application Site
are identified and evaluated using the contaminant-pathway-receptor risk
assessment approach and from this, potential contaminant linkages will be
identified. The potential for the creation of pathways between contaminant
sources and receptors, as well as consideration of the significance of the
predicted effect, will be considered. As detailed in Chapter 2.0, the baseline
assessment shall assume that the Shawfair development (located adjacent to
the west of the Application Site and comprising residential housing) has been
constructed and completed. Additional developments which are assumed to
have been completed will an AD Facility located to the north and the
completion of the borders railway and site access road.
Mitigation
9.2.11 Mitigation measures, including any further investigation considered necessary
prior to construction, is described in the assessment. This includes any
measures required to mitigate harmful effects on human health, the
environment or built structures that may arise from the proposed development.
If options exist to mitigate the potential risks then these will be compared and
assessed in a rational and economical manner as set out in CLR11 (EA,
2004) for contamination and CIRIA Report SP32 (1984) regarding the
mitigation of risk from abandoned mine workings. Potential mitigation
measures may include:
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Remedial Options Appraisal – An appraisal of remedial options for all
plausible contaminant linkages would be assessed and discussed in an
appropriate manner with different technically feasible options being
ranked in terms of practicality, effectiveness, durability, sustainability,
environmental benefits, timescale, cost etc.;
Remediation Strategy – this would be prepared based on the findings of
the Options Appraisal for the highest ranked solution. Any
Environmental Permits required for the remediation will also be
indicated;
Consolidation of shallow mine workings (particularly in the northern part
of the site) prior to construction;
Grouting and capping of shafts present on the site; and
Proposals for the mitigation of other geotechnical risks.
9.3 Baseline
9.3.1 As part of the ES process, a Phase 1 desk-based assessment of the
Application Site has been carried out which incorporates the results from the
previous activities listed below. Based on previous site investigations at the
site for the proposed development and the current understanding of the
ground and groundwater conditions at the site, no new intrusive investigation
works will be required in order to provide sufficient information for the ES. The
assessment for this ES chapter is based on assessment of the following
information sources summarised in Table 9.4 (below). This ES chapter only
summarises the relatively extensive number of reports regarding the site.
These reports should be referred to if any additional details are required.
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Table 9.4: Sources of Geological and Ground Conditions Information
Data Source Information Obtained
British Geological Survey Hydrogeological Map (at 1:625,000 scale): Scotland
British Geological Survey Groundwater Vulnerability Map (at 1:625,000 scale): Scotland
British Geological Survey (BGS) Map (at 1:50,000 scale): Edinburgh, Bedrock and Superficial Deposits
Superficial and solid geology. Hydrogeology
Ordnance Survey Historic Maps. Previous site use, possible contaminant sources, existing foundations, former excavations and infilled ground etc.
SEPA website (www.sepa.org.uk) with regard to Water Framework Directive water quality.
Existing background conditions, aquifer designations, Groundwater Source Protection Zones, groundwater and aquifer information
Environmental Data Base Search (EnviroCheck / GroundSure report & web-based searches) including Scottish Natural Heritage (SNH), Sitelink, online designated site database
Contamination sources (historic colliery, landfilling etc) and receptors (including adjacent lake, surface waters), heritage sites.
Historic aerial photography Information on geology, hydrogeology, contamination sources, potential buried obstructions etc.
Coal Authority Coal Mining Report Historic mining, shafts, mining risk
BGS Borehole Logs Superficial and solid geology.
White Young Green Environmental Ltd (2005) Preliminary Geotechnical Interpretative Report: Millerhill Depot.
Details of ground conditions on the development and adjacent areas with particular reference to the stability of the site from shallow coal workings and the presence of shafts/mine entries.
WSP Environment and Energy (WSPE) (2009a) Millerhill Waste Facility
Site: Geo‐environmental Review for The City of Edinburgh Council and Midlothian Council
Desk study information and preliminary risk assessments.
WSP Environment and Energy (WSPE) (2009b) Millerhill Waste Facility Site: Geotechnical and Mineral Stability Assessment for the City of Edinburgh Council and Midlothian Council
Geo-environmental conditions for the development area.
WSP (2009c) Proposed Millerhill Waste Facility Site. Geotechnical and A more in depth study on ground conditions for the development area with
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Mineral Stability Assessment. WSP Report No 12141325/003 particular reference to the stability of the site from shallow coal workings and the presence of shafts/mine entries.
WSP (2009d) Proposed Millerhill Waste Facility Site – Geo-Environmental Investigation Report WSP Report No 12141325/004
Geo-environmental investigation including desk study, and intrusive investigation concentrating on geo-environmental aspects.
Van Elle Limited (2011) Factual report – Mineral Stability Ground Investigation
Factual ground investigation report comprising cable percussive boreholes, trial pits, plate bearing tests and rotary probeholes.
WSP(2012) Proposed Access Road and Bridge, Millerhill Waste Facility Site – Ground Investigation Report
Ground investigation report including cable percussive boreholes, trails pits including a mine shaft excavation area. Laboratory and in-situ testing.
Unknown author (2014) Ground Investigation Report – Proposed Millerhill Residual Site Access Road. Job Number G135550
Factual ground investigation report round, comprising cable percussive boreholes, trial pits, plate bearing tests, rotary probing (for 3 possibly abandoned mine entries) and laboratory testing (laboratory testing referenced as being reported within a WSP report)
Midlothian Council to provide information on private water supplies Potential water supply receptors.
Topographical Survey Ground levels
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9.3.2 A site walkover was also undertaken in order to inspect areas of potential
interest from the plans and other pertinent information, identifying key features
that are visible and assess the site specific conditions.
Site History
9.3.3 In the earliest historical mapping in 1895, the site was agricultural with a single
railway line running from north to south. In the 1952 mapping, a large colliery
(Monktonhall) was located to the west, with associated coal marshalling yards,
spoil heap and mine water treatment lagoons. The Millerhill sidings to the east
were extensive by this stage. Monktonhall Colliery initially closed 1989, but
was briefly reopened in 1993, before it finally closed in 1997. The use of the
marshalling yard commenced in 1963 and ceased in 1983, with the exception
of two railway lines which serviced the colliery. The railway lines were
removed following closure of the colliery.
Previous Investigations
9.3.4 The reports of four previous site investigations on the site are listed in Table
9.4 (above). The report from 2005 presents the results of a desk-based geo-
environmental assessment, including an assessment of the site history.
9.3.5 The geo-environmental review report of 2009 has not been made available for
review but is understood to be superseded by later reports.
9.3.6 The geo-environmental investigation report from 2009 presents a revised
Phase 1 desk-based study, which leads into a preliminary conceptual site
model and intrusive site investigations of ground investigation. The report
notes that the assessment of potential coal mining in the previous report of
2005 did not assess the entire current site, and only assessed approximately
the eastern 20% of the site.
9.3.7 The revised desk-based study shows that the site is underlain by Glacial Till
with thicknesses varying between 10 and 20m, increasing in thickness to the
north. The bedrock geology underlying the site is the Coal Measures, with
applied geological mapping showing the site is potentially subject to shallow
mining. Assessment of Coal Authority reports and mine abandonment surveys
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revealed that the site is potentially underlain by worked coal seams at depth of
between 24m and 73m, with deeper seams also possibly worked. Up to 6
possible mineshafts are present on site.
9.3.8 The intrusive investigation comprised 30 trial pits to a maximum depth of 3m,
10 boreholes to a maximum depth of 10m included soil, groundwater and
geotechnical analysis, installation of 10 monitoring wells and 4 rounds of
ground gas monitoring, soil and groundwater environmental laboratory
analysis, and geotechnical laboratory analysis. Potential risks to human health
from contaminants in soils were only found in relation to asbestos.
9.3.9 The maximum methane concentration was 2.3% and the maximum carbon
dioxide concentration was 10.3%. Ground gas conditions were classified as
Characteristic Situation 2.
9.3.10 No significant risks to controlled waters were encountered and buried concrete
ground conditions were found to be AC-1 with DS-1, locally DS-4.
9.3.11 It was assessed that potential risks from the presence of asbestos could be
mitigated via clean cover systems, use of appropriate PPE by site personnel
during construction and implementation of appropriate construction methods
during earthworks. It was recommended to have the identified soils buried
beneath soils with lower concentrations as part of the planned cut and fill
exercise. Geotechnical recommendations included the use of deep strip or
pad foundations onto the underlying Glacial Till deposits. Re-engineering of
Made Ground would leave areas of the site suitable for landscaping and
roads.
9.3.12 The Geotechnical and Mineral Stability Assessment report of 2009 provides
an additional assessment of existing geotechnical data and details an
extensive intrusive investigation to further assess coal mining related ground
stability. The intrusive investigations comprised the drilling of 30 rotary open
hole boreholes and 2 rotary cored boreholes to investigate shallow mine
workings and 900 rotary probe holes to investigate the position of reported
mine entries. The shallow mine working investigations found that 3 coal
seams were present, with 2 potentially workable seams. One seam was
encountered at between 35.8 and 37.2mbgl comprising a 1.2 to 2.0m thick
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seam. The deeper third seam was encountered a further 12m to 16m below
the second seam, and comprised between 0.9 and 2.0m thick seam. Ground
stability risks were assessed as minimal due to the age of the workings, depth
to the seams and a lack of voids being encountered. The shaft investigation
proved the presence of 3 shafts on site out of a possible 9 that were identified
as potentially being located on the site. The three encountered shafts were
between 2m and 3m wide and between 31m and greater than 70m deep. No
caps were encountered. The report recommends that three of the suspected
mine entries require further investigation.
9.3.13 A factual report (written by Van Elle Limited) was issued in 2011 and included
11 days of trial pitting and trenching in to locate one possible mine entry;
progression of thirteen rotary probeholes and 4 rotary cored boreholes to
investigate former mine workings in three coal seams and provide information
on rock integrity at rockhead.
9.3.14 The first coal seam was encountered at depths of between 18.4m bgl and
20.3m bgl, and varied in thickness between 0.6m and 1.25m. The second coal
seam was encountered at depths of between 23.5m bgl and 27.3m bgl and
varied in thickness between 0.22m and 0.9m. The third seam was
encountered at depths of between 32.0m bgl and 28.1m bgl and varied in
thickness between 0.8m and 1.6m. Evidence of former mine workings in the
south of the site were encountered at depths below ground level of between
23.8m and 24.9m, 36.7m and 37.1m, 36.1m and 37.4m, 36.1m and 37.0m,
35.7m and 37.0m, 32.0m and 33.4m, 35.7m and 37.0m. In eight probeholes,
there was no evidence of mine workings recorded. The investigation
undertaken to prove a mine entry did not find any evidence of an entry.
9.3.15 Ground gas concentrations did not find methane above the limit of detection.
Carbon dioxide concentrations were not recorded.
9.3.16 The WSP interpretative report based on the Van Elle factual report issued in
2011 was issued in 2012 providing interpretation of the investigation in relation
to a proposed bridge structure and roads. The report recommends some
localised grouting of workings in relation to the proposed bridge and additional
investigation in relation to two unidentified mine entries.
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9.3.17 A factual report by an unknown author (although the field work was
undertaken by Van Elle Limited) reported in 2014 comprised the drilling of
numerous rotary Probeholes in an attempt to located Shafts 012, 013 and 065
along a proposed access road. Soft ground was encountered during drilling for
Shaft 013 (indicating this was a likely location of this shaft), but evidence of
Shafts 012 and 065 was not encountered. Further information relating to the
depth and details of evidence for Shaft 013 is not provided in the report. The
reports makes references to an interpretative report issued by WSP, but this
has not been made available.
9.3.18 Documents provided by CNIM in relation to the design and construction of the
proposed facility indicate that additional site investigation was undertaken in
relation to shallow mine workings and shafts in July 2014. The original report
has not been made available for review. The CNIM document summarises
findings the investigation which encountered evidence of shallow mine
workings at 23.5m bgl. Investigations to locate additional mine shafts were
unsuccessful and further investigatory works are recommended during the
pre-engineering construction phase of the proposed facility.
Geology / Proven Ground Conditions
9.3.19 Made Ground deposits were encountered in all exploratory holes and were
shown to be predominantly of granular in nature comprising variable amounts
of brick, ash, colliery spoil (including sandstone, coal and mudstone), red
burnt shale (blaes) and some slag and wood. In places the top 100mm
comprised and limestone hardcore gravel or topsoil. Possible reworked clay
was encountered in some locations. Made Ground was proven to vary in
thickness between 0.5m a maximum thickness of 2.9m bgl. When considering
the possible reworked clay, Made Ground deposits extended to depths of
between 4.7m and 6.3m bgl.
9.3.20 Drift deposits are shown to comprise firm to stiff sandy gravelly clay with
occasional cobbles and boulders. The top surface of the Glacial Till varied
from 36.9m AOD to 44.96mm AOD. These deposits were proven to extend to
rockhead (where encountered) at depths of between approximately 10 and
15mbgl in the south of the site and between approximately 15m and 20m bgl
in the central and northern parts of the site.
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9.3.21 The bedrock Middle Coal Measures deposits were proven to a depth of
40mbgl by rotary coring and to a conjectured depth of 52m based on all
investigatory information. Rockhead was encountered at between 11.8m and
21.3m bgl (32.75m and 21.65m AOD). The deposits were found to comprise
mudstone, siltstone, sandstone and two proven seams of coal.
Coal Mining
9.3.22 The geology indicates that there is the potential for shallow mining at the site.
Geological maps indicate the possible presence of the following shallow
seams:
Splint Coal (1.35m thick);
Rough Coal (0.15m to 1.2m thick); and
Beefie Coal (1.125m thick).
9.3.23 Assessment of depths to the seams indicates that the Rough Coal may be
present at 40m to 60m bgl, placing the Splint Coal at approximately 30m to
50mbgl. The geological maps indicate the Clayknowes seam (0.75m thick) is
present above the Splint Coal, although it is shown to be absent at the site.
9.3.24 The Coal Authority report and mine abandonment surveys generally confirm
the findings of the geological assessment. The Coal Authority and mine
abandonment reports indicate that the site is underlain by two worked seams
at depths of 24m and 73m and a further fourteen seams at depths of up to
950m. The last recorded mine workings ceased in 1996.
9.3.25 Within the site, or within 20m of the site boundary, there are a total of ten mine
entries. The Coal Authority does not hold any further information of the nature
of the mine entries or any treatment of mine entries.
9.3.26 Further information was obtained from mine abandonment plans for the site.
This has shown that the Splint Coal and Rough Coal seams have been
worked in the southern part of the site, with the seams located 41m and 72m
bgl respectively. Mine abandonment plans would also indicate the Four Foot
Coal has been worked, although this seam is not shown on geological maps.
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The seam may have been misinterpreted and it is actually the Clayknowes
Coal. This seam has been shown to have been worked close to outcrop
beneath the majority of the site. The northern third of the site is shown as
having this seam worked at outcrop level.
9.3.27 The Coal Authority report and the mine abandonment plans contain no
information on the diameter, treatment or completion of the shafts, although
notes indicate that shafts extend into the Splint and Rough Coal seams, with
inferred depths of 40m to 72m bgl.
9.3.28 Two probehole intrusive investigations were undertaken to allow an
assessment of shallow coal seams and any associated workings. Probeholes
were drilled between 35m and 50mbgl to encounter the Four Foot and Splint
Coal seams.
9.3.29 Proven ground conditions were:
Rockhead encountered at between 10.6mbgl and 21.3mbgl, with
thickness increasing from north to south;
3 coal seams proven:
o Shallow seam found in approximately 40% of probeholes, and less
than 0.5m thick, but locally up to 1.25m thick;
o Four Foot Coal was found to be outcropping or encountered at
between 18.3m and 41.5m bgl and found to be between 0.22m to
2.0m thick and comprises coal, coal with mudstone or mudstone
with coal traces. Limited evidence of being worked, with only 3
probeholes showing the presence of soft ground or voids; and
o Splint Coal encountered 12m to 16m beneath the Four Foot Coal
at a depth of 31m to 41m bgl dipping to the south and east. The
seam was only encountered in the north of the site. The seam was
found to be 0.8m to 2.0m thick and comprised mudstone with coal
traces or coal with mudstone bands or 1.5m thick coal seam.
Hydrogeology
9.3.30 The bedrock Middle Coal Measures Formation is reported as a ‘Minor Aquifer’
although a more recent classification scheme for aquifers classifies the
bedrock Secondary Aquifer being of Intergranular / Fracture: Moderate
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Productivity. The Glacial Till deposits are classified as Not a Significant
Aquifer / Unproductive Strata.
9.3.31 During previous investigations at the site groundwater was not encountered
during progression of exploratory holes. In subsequent monitoring visits,
groundwater levels were found at depths of between 1.71m bgl and 8.33m
bgl, with monitoring levels also recording groundwater to be absent during
some of the monitoring. This was interpreted as representing discontinuous
groundwater perched within the Made Ground deposits.
Surface Waters
9.3.32 There are no surface waters on the site. The nearest surface watercourse is
the River Esk located 2.5km east. The Carinie and Niddrie burns are
understood to be culverted beneath an adjacent site. The findings of a
previous desk study indicate that no water quality data is available for these
water courses.
9.3.33 There is localised areas of standing water of limited depth at the site after
periods of heavy rainfall indicating that the Made Ground does not drain
rapidly.
Summary of Current Baseline Conditions
9.3.34 Currently the ground and groundwater conditions are considered to have a
low to medium effect on the environment in the surrounding area.
Investigations have generally shown low concentrations of potential
contaminants with only localised elevated concentrations of a limited number
of contaminants and then not at particularly high concentrations. Isolated
occurrences of asbestos have been encountered in shallow soils but given the
current site use and that of the surrounding area this has a negligible effect to
environmental receptors. There is a localised presence of elevated sulphate
concentrations (which is relatively common in many coal mining areas due to
natural background concentrations from the bedrock) and this presents a
negligible effect to environmental receptors.
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9.3.35 Previous investigations at the site indicate the permanent ground gases are
classified as Characteristic Situation 2 based on monitoring from 2009. There
is no impact from radon and minimal impact from volatile organic compounds.
9.3.36 Overall the current baseline conditions prior to development of the site overall
presents a low to negligible impact to environmental receptors.
9.3.37 Investigations have shown that the site has been subject to shallow mine
workings, although mine workings are not ubiquitous across the site and
sixteen worked coal seams are present beneath the site. From intrusive
investigations, two seams are present at relatively shallow depths, being
encountered at depths between rockhead and 41m. Coal seam thicknesses
ranged between 0.5m and 2.0m. Due to the thickness of the seams, the depth
of the seam and the dip of the beds, there is only a significant risk from mined
seams in the northwest of the site.
9.3.38 Nine historic mine shafts are recorded to be present on site. Shaft
investigations have proved the presence of 3 shafts on site out of a possible 9
that were identified as potentially being located on the site. The three
encountered shafts were between 2m and 3m wide and between 31m and
greater than 70m deep. No caps were encountered. Three suspected mine
entries require further investigation because they pose a potential stability risk.
Investigations in July 2014 to locate the additional mine shafts were
unsuccessful and further investigatory works are recommended during the
pre-engineering construction phase of the proposed facility.
PPiP Future Baseline Scenario
9.3.39 No additional baseline risks are envisaged as being encountered in relation to
the proposed Millerhill RERC development than would be encountered for the
previous proposed development which was granted PPiP.
9.4 Assessment of Effects
9.4.1 This section of the assessment reviews the effects of the Proposed
Development upon geology and hydrogeology together with geotechnical
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stability. Particular emphasis will be made on the possibility of contamination
due to soil, groundwater and ground gases and the risk from historic mining.
9.4.2 The following has been carried out in order to establish the baseline
conditions:
Review of all site investigation and geo-environmental information
provided by the Client;
Environmental setting: former and current land-uses and the
hydrogeological setting of the site;
Intrusive investigation data obtained during mineral stability assessment
works;
Potential contaminant sources both on-site and off-site including soil
contamination, groundwater and ground gas conditions;
Potential receptors both on-site and off-site including humans, controlled
waters, structures and ecology;
Contaminant linkages (pathways) between contaminant sources and
receptors will be reviewed and described;
Use of the above information to develop a Conceptual Site Model, which
identifies potential receptors and helps to characterise the physical and
geochemical parameters.
9.4.3 The assessment complies with the relevant principles and requirements of:
BS5930:1999: +A2 2010: “Code of practice for site investigations”, BS10175:
2011 +A1 2013 “Investigation of Potentially Contaminated Sites - Code of
Practice” and the DEFRA / EA Report CLR11 “Model Procedures for the
Management of Land Contamination” together with the SEPA, British
Standards, CIRIA and a range of other guidance.
9.4.4 A Tier 2 assessment on soils, groundwater and ground gas will be undertaken
if deemed necessary. Chemical data from the existing site investigation
results have been used to inform the Tier 2 assessment which was
undertaken in line with the SEPAs guidelines and recommendations.
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Construction Phase
9.4.5 The likely significant effects of the construction phase of the Proposed
Development on the environment prior to mitigation are summarised under the
following sub-headings:
Hazards identified with the proposed development;
Potential sources of contamination;
Potential receptor of contamination;
Identification of pathways;
Geotechnical hazards associated with the Proposed Development; and
Summary of the likely significant effects of the construction phase of the
Proposed Development on the environment prior to any mitigation
measures.
Hazards Identified with the Proposed Development
9.4.6 The hazard identification is based on the assumptions presented below:
The site will be a commercial / industrial development consisting of a
waste treatment facility including ancillary offices and car parking areas;
and
Drinking water will be from mains supply.
Potential Sources of Contamination
9.4.7 The site is located in an area which is currently largely undeveloped, although
there are some remnants of railway sidings including railway tracks, isolated
concrete foundations and some small derelict buildings. Further remnant
railway sidings and a maintenance yard are located to the east. As part of the
baseline assumptions, the land to the west is assumed to have been
redeveloped within the Shawfair new community development. Historical
sources of contaminants associated with lagoons previously used for mine
water treatment will have been remediated as part of the Shawfair
development, and no potential sources are assumed to be associated with
these. The site was part of the Millerhill Marshalling Yard which was
associated with the adjacent Monktonhall colliery. Coal mining and
abandonment records show that the site has nine former shafts on site.
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9.4.8 Intrusive investigations and associated laboratory analysis has been
undertaken for environmental sources. The main sources of potential
contaminants are associated with areas of Made Ground which locally has
elevated concentration of contaminants, specifically locally with asbestos. The
ground gas regime was classified as Characteristic Situation 2 from
monitoring reported in 2009. The main potential sources of contamination are
listed in Table 9.5 below.
9.4.9 Information provided by NCIM indicates that the adjacent maintenance yard is
impacted with petroleum hydrocarbon contaminants which are impacting the
Carinie Burn. It is understood that the adjacent site was considered to be
classed as a ‘contaminated site’ with respect to S57 of the Environment Act
(1995) or the Control of Pollution Act (1974). It is unknown whether the
adjacent site has formerly been determined as ‘contaminated land’, or
impacting environmental receptors under any other Act.
Table 9.5: Potential Sources of Contaminants
Main Potential Sources of Contaminants
On-site: Asbestos (free fibres of amosite and chrysotile) encountered in 10 % of samples analysed
On-site: Soils with elevated calorific value which are potentially combustible (not analysed for).
On-site: Soils with elevated sulphate.
On-site: Contaminants associated with possible historic spillages from railway rolling stock.
On-site: Elevated methane and carbon dioxide (Characteristic Situation 2 based on 2009 monitoring)
Potential Receptors of Contamination
9.4.10 Based upon the data previously discussed in sub-section 9.3, the following
potential receptors to contamination have been identified.
Table 9.6: Identified Potential Receptors
Identified Receptors
A Humans – pre-development completion - including construction staff and adjacent residential and commercial receptors
B Humans – including adjacent residents and people on the site and adjacent sites post construction.
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C Controlled waters – surface waters (culverted burns, lagoons and rivers) and groundwater.
D Local flora and fauna during and post construction.
E Building structure and services.
9.4.11 It should be noted that humans on adjacent sites (specifically Shawfair, the
AD Facility and the existing Network Rail marshalling yards to the east) are
potential receptors but the risk to commercial / industrial workers on site under
Receptors A and B is assessed to be higher than humans off-site. In addition,
risks to residential receptors at Shawfair will occur only during the construction
phase due to the potential release of fugitive dust/vapours. Risks to
construction staff will be greater than off-site residential receptors and on-site
control measures to reduce risks to construction staff will reduce potential
risks to off-site residential receptors to being negligible. Therefore off-site
human receptors are not considered further in detail to reduce the complexity
of the report as the risk to these humans is covered through the assessment
for Receptors A and B.
9.4.12 The preliminary assessment of risks undertaken for the development
considers potential risks to receptors A to E (in Table 9.6 above).
Human Health (A and B);
Property (including buildings, crops, livestock, pets, woodland, service
lines) (E);
Adjoining Land (B, D and E);
Controlled Waters (C);
Ecological Systems (D); and
Building and Structures (E).
9.4.13 The nearest of each of the above receptor categories to the application site
are considered to be:
On-Site:
Site users;
Proposed buildings and associated structures including roadways;
Aquifer of Moderate Productivity; and
Flora and fauna.
Off-Site:
Culverted burn;
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 225
Low grade agricultural land; and
Commercial/industrial developments:
Maintenance yard; and
AD Facility.
Residential, commercial, community and employment development
associated with Shawfair.
9.4.14 Identification of Pathways
9.4.15 There are various routes by which a potential contaminant may reach a
receptor. For example, in areas where contaminated material is exposed,
dermal contact with the material, inhalation or ingestion of dust may occur.
9.4.16 Inhalation or ingestion of dust and water could occur during the construction
and operational phase of the Millerhill RERC development. Pathways from
dermal contact with soil and groundwater may also arise. It is considered that
the risk of short term exposure for ground workers and other construction
workers is low except for the presence of asbestos fibres in Made Ground.
9.4.17 Post-development, the surface of the development area will be occupied with
buildings and hard standing. This will break pathways for human health
receptors post-development for the potential contaminants at this site.
9.4.18 Gas and vapour entry into buildings due to the possibility of advection and
diffusion into buildings is considered to be an unlikely pathway for the
proposed development. From existing site investigation data the ground gas
regime is classified as Characteristic Situation 2. No hydrocarbon
contaminants which may give rise to a significant vapour phase have been
encountered, above generic assessment criteria values.
Pathways to Controlled Waters
9.4.19 Shallow groundwater within Made Ground deposits was generally not
encountered during intrusive investigations. Perched groundwater in
monitoring wells was attributed to discontinuous perched groundwater within
Made Ground.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 226
9.4.20 Where Made Ground is present on site this is likely to have a higher
permeability than the underlying Glacial Till. The vertical leaching of
contaminants from any Made Ground into deep groundwater is not considered
a potential pathway due to the thickness of low permeability Glacial Till.
However, surface runoff to adjacent surface water features and drains may be
a potential pathway. Due to a lack of a hard standing site surface, this will be
uncontrolled prior to and during the groundworks phase when this must be
carefully managed. Post-construction the majority of the site will be covered
through buildings and hard standing so infiltration into the ground will be
negligible. Post construction surface runoff will be controlled through the site’s
proposed drainage system.
Pathways to Buildings / Structures
9.4.21 The ground gas regime is classified as Characteristic Situation 2 based on
monitoring data reported in 2009.
9.4.22 Other potential pathways that are possibly less significant to the site but still
require consideration are:
Chemical attack on foundations and services (especially from elevated
sulphate in Made Ground and burnt shale materials);
Permeation of contaminants through water pipes; and
Potential phytotoxic effects on sensitive landscaping plants.
9.4.23 Previous investigations have noted the presence of historical coal mining, and
outcropping coal seams. Potential combustibility assessment of shallow soils
has not been undertaken as part of previous studies. However, based on an
assessment of the geological/site investigation information and the Coal
Authority’s database of coal seams susceptible to combustion it is assessed
that there is no significant risk from combustibility to the development.
Contamination Linkages
9.4.24 For each contamination source there are potential contaminant linkages with
all potential receptors. However, in the context of this site, not all of the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 227
contaminant linkages are plausible. The likelihood of the various pathways
linking the contaminants to the receptors is presented in Table 9.7 below.
Table 9.7: Matrix of Contaminant Linkages
Source / Contaminated Medium
Pathway
Receptor
A
–
Hu
man
s
p
re-
develo
pm
en
t
co
mp
leti
on
–
inclu
din
g
co
nstr
ucti
on
sta
ff
an
d
ad
jacen
t
resid
en
tial
an
d
co
mm
erc
ial
recep
tors
B
–
Hu
man
s
–
inclu
din
g
ad
jacen
t
resid
en
ts
an
d
peo
ple
w
ork
ing
at
the o
n t
he s
ite a
nd
ad
jacen
t s
itesp
ost
co
nstr
ucti
on
. C
–
Wate
r
Recep
tors
D
–
Flo
ra
an
d
Fau
na
E
–
Bu
ild
ing
an
d
Serv
ices
Soil
/ M
ade G
rou
nd
Ingestion P U - P -
Dermal Contact P U - P P
Inhalation P U - P -
Infrastructure / Drainage U U U U P
Groundwater - - U U U
Surface water U U - U U
Gro
undw
ate
r
Ingestion U U - - U
Dermal Contact P U - - U
Inhalation U U - - U
Groundwater U U U - U
Surface water U U U U U
Gas
(CH4 CO2)
Migration P P - U P
Key of significance of contamination linkages: (S = Significant Pathway P = Possible Pathway U = Unlikely Pathway = Not Applicable). Only significant and possible linkages are taken forwards to the next part of the risk assessment
9.4.25 Piling may be carried out at the site. On some sites piling and other deep
foundations can cause a contaminant pathway to be formed between
contamination and a groundwater receptor (e.g. the piling forms the
completion of a pollutant linkage by creating a pathway between the
contaminant and the receptor). At this site there is a negligible contaminant
source with respect to the effects of piling (e.g. the localised presence of
asbestos will not affect the groundwater receptor, there is likely to be similar
concentrations of sulphate in the bedrock to the Made Ground etc.) and that
due to the significant thickness of relatively low permeability Glacial Till being
present, the piling will not form a pathway for any remnant contamination on
site to reach the groundwater in the bedrock. Therefore the environmental risk
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 228
from piling at this site is negligible and no further assessment or mitigation is
required and it will not be considered further.
Preliminary Contamination Hazard Assessment
9.4.26 The preliminary hazard assessment has been based upon contemporary
published guidance. This is based on a preliminary conceptual site model
which has been established using the desk study information and has formed
the basis for the preliminary hazard assessment. Only the significant and
possible potential pathways (referred to in Table 9.7 above) are considered in
the hazard assessment.
9.4.27 The preliminary hazard assessment is a qualitative assessment of the risks
posed by each viable pollution link identified. The hazard assessment leads to
a recommended subsequent activity which could comprise:
Action Required (AR) in the short term to break existing contaminant-
pathway-receptor (CPR) link;
Site Investigation Required (SIR) with objectives for impact estimation;
or
No Action Required (NAR) at this stage.
9.4.28 The hazard assessment for the Application Site is provided in Table 9.8 (over
the page) and is based upon current site conditions with no mitigation
measures being implemented.
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Table 9.8: Preliminary Hazard Assessment
Hazard Identification Hazard Assessment
Link Contaminant Pathway Receptor Probability Consequence Impact Hazard Assessment
1 Contaminated soil / groundwater
Ingestion (via soil dust) and inhalation (via soil
dust and vapours), ingestion through dirty hands, dermal contact
with soil/water.
A- Humans using the site during construction and adjacent residential
and commercial receptors
Medium/ Reasonably Foreseeable
Medium Medium SIR -. Site hygiene, PPE and monitoring of air in accordance with requirements of CAR may be sufficient. Adjacent residential and commercial receptors must be considered
in terms of control of fugitive releases to air.
Additional analysis for suspected asbestos containing materials may be required.
2 Contaminated soil /groundwater
Ingestion (via soil dust) and inhalation (via soil
dust and vapours), ingestion through dirty hands, dermal contact
with soil/water.
B- Humans using the site after development
completion.
Low/Unlikely Mild Low NAR
3 Contaminated soil / groundwater
Via service pipes C- Surface Waters.
E- Building structures
Low/Unlikely Mild Low NAR
4 Contaminated soil / groundwater
Lateral migration C – Groundwater / Surface water features
Low/Unlikely Mild Low NAR
5 Gas – methane & carbon dioxide
Inhalation, explosion A & B- Humans using the site during
construction and after development
completion, E - buildings.
Low/Unlikely Severe High/ Medium
SIR – Ground gas conditions classified as Characteristic Situation 2. Appropriate
ground gas protection measures should be installed within building foundations.
During construction phase, atmospheric monitoring in excavations should be
undertaken.
6 Contaminated soil/groundwat
Ingestion, inhalation, dermal/direct contact
D- Ecology (Flora/Fauna)
Low/Unlikely Negligible Near Zero
NAR
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 230
er
7 Contaminated soil/groundwater
Direct contact. E- Building structures. Medium/ Reasonably Foreseeable
Medium Medium SIR – Concrete specific chemical analysis for designer’s risk assessment.
Analysis has been undertaken in previous reports
8 High calorific value soils
Direct Contact/combustion E- Building structures Medium/ Reasonably Foreseeable
Medium Medium SIR – Analysis of soils should be undertaken to assess potentially
combustible soils
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9.4.29 It must be reiterated that the impacts presented within the hazard assessment
does not take any mitigation measures into account.
Geotechnical Hazards Associated with the Development
9.4.30 In addition to the potential contamination hazards, there are also potential
geotechnical hazards associated with the stability of the ground (including
load bearing capacity, slope stability and effects of ground (mining) cavities. A
summary of the geotechnical considerations are provided in Table 9.9 below.
Table 9.9: Summary of Geotechnical Hazards
Potential Risk Assessment
Highly compressible ground
Made Ground deposits are likely to be highly variable.
Combustion Possibility that some of the Made Ground could locally be combustible due to a high calorific value because coal has been stored at the site.
Collapsible soils Very low.
Swelling clay Low – Glacial Till
Running sand Negligible.
Ground dissolution No
Landslip Low.
Obstructions
Localised relic foundations/basements/obstructions may be present at the site. The extent of any buried structures is assessed as being limited because none have been encountered in the investigations and trial trenching carried out at the site.
Mining and quarrying
No quarrying at the site.
Shallow mining has been shown to have occurred on site with at least 2 worked seams within 50 m of ground level, potential risk in northwest of the site.
Nine shafts present on site, with no records of any backfilling or treatment, three of these have not been located by the investigations carried out so far.
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Summary of the likely Significant Effects of the Construction Phase of
the Development prior to Mitigation Measures
9.4.31 If no mitigation measures are implemented as part of the Proposed
Development there would be the following unacceptable environmental risks:
High Risk
o With the presence of coal mining related shafts remaining unlocated
and treated there is the risk of ground instability due to collapse of
non-engineered backfill.
o Loose and poorly compacted Made Ground materials may result in
differential settlement. This could affect structures associated with
the Proposed Development together with roads and services.
Medium/High Risk
o Previous investigations have identified some elevated ground gas
concentrations in shallow deposits on the site. Ground gasses
including methane and carbon dioxide have the potential to result in
an explosion or asphyxiating atmosphere respectively and result a
potential impact to buildings, infrastructure and human health.
o In the northwest of the site there is an area where shallow mining
potentially causes a risk of high settlements from collapse of
workings induced by the new and higher imposed loads from the
development in this area of the site.
o Asbestos fibres (amosite and chrysotile) have been detected in
shallow soils. If appropriate measures are not taken to minimise
exposure during construction, risks to construction works health will
be present.
Medium
o Soils which are potentially highly combustible may locally be
present, due to the historic use of the site for coal mining and the
storage of coal at the surface. Laboratory analysis of soils is
recommended so that risk can be quantified because earthworks
which disturb the ground and introduce oxygen could trigger
combustion. Note that this is relatively unlikely and the affected
area should this happen would be relatively small but it needs
quantifying and appropriate mitigation measures implemented if
required.
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Assessment of Effects Against Existing Baseline
Operational Phase
9.4.32 As previously indicated a number of the above likely significant effects
identified during the construction of the Proposed Development would also
have the potential to give rise to adverse impacts and likely significant effects
on the environment during the operational phase if no mitigation measures are
put in place. The likely environmental effects are associated with:
Effects of contaminants (e.g. sulphate) on construction materials;
Potential effect of high calorific value soils;
Leakage from facility plant or associated structures;
Leakage or runoff from storage areas;
Spillage/leakage of stored fuels, materials and chemicals; and
The discharge of effluent.
9.4.33 The effects of contaminants (e.g. sulphate) on construction materials and from
the potential effect of high calorific value soils will be mitigated through
appropriate design and construction methods so there is no effect during
operation.
Decommissioning
9.4.34 In general during decommissioning there will be no significant geo-
environmental risks that are not mitigated through standard demolition and
decommissioning practice. The one area where there could be an elevated
risk is if there is to be excavation into ground which has asbestos. The
location of the asbestos in the ground will be known following the construction
so this risk can be managed through standard health and safety measures in
relation to encountering asbestos in the ground.
9.4.35 Therefore the decommissioning scenario is neutral in terms of impact and
risks and are assessed as being of negligible significance.
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Assessment against PPiP Future Baseline Scenario
9.4.36 No additional impact or risks will be associated with the proposed Millerhill
RERC development compared to the PPiP development. The baseline
scenario will not change significantly and therefore the baseline scenario is
neutral in terms of impact and risks.
9.5 Additional Mitigation
9.5.1 The incorporated mitigation measures within the current design are
considered to be suitable for the proposed development during the
construction, operational and decommissioning phase. However, the following
additional mitigation measures will be required.
Construction Phase Mitigation
9.5.2 A number of mitigation measures have been incorporated into the scheme
design, construction and operational procedures in order to avoid, reduce or
compensate for potential environmental impacts. These include:
Pre-Construction Mitigation - Site Investigation
9.5.3 Prior to commencing the construction works further site investigation would be
carried out in order that the geo-environmental and geotechnical risks can be
assessed in more detail. Identified data gaps (notably soil combustibility,
possibly additional asbestos identification and quantification plus further mine
shaft investigation) can be investigated and assessed and appropriate
geotechnical design carried out. Investigations would be carried out in
accordance with current UK guidance and best practises, such as
BS10175:2011+A1:2013, BS5930:1999+A2 2010, CIRIA and CLEA guidance
etc.
9.5.4 Geotechnical investigations would be required especially in relation to three
shafts identified in the vicinity of proposed structures which have not currently
been located. Upon location and investigation, appropriate treatment
methodologies can be designed and appropriate agreements made with the
Coal Authority.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 235
9.5.5 During the investigation, additional data should be obtained from shallow soils
including laboratory analysis of shallow soils for combustibility and asbestos
identification and quantification. Additional parameters for geotechnical design
of foundations, floor slabs and roadways may also be required by the
Designer and this information should be obtained during any intrusive works,
as required.
9.5.6 The report on the conditions and risk associated with the site would be
forwarded to MLC for approval. If the investigations indicate that any remedial
measures are considered necessary to reduce environmental risk to
acceptable levels these would have to be agreed with the Council.
Pre-Construction Mitigation – Geotechnical Design
9.5.7 All of the geotechnical impacts indicated in Table 9.9 can be mitigated by
appropriate site investigation, design and through the standard construction
methods. The proposed mitigation measures described above would
effectively ameliorate the potential impacts of the Proposed Development in
connection with:
Contamination within Made Ground (notably asbestos fibres and
possibly high calorific soils);
Ground gases;
Geotechnical instability associated with historical coal mining; and
Pollution of surface water from day to day construction activities.
9.5.8 The desk study assessment and intrusive investigations have shown that
there are mine shafts present on site. There are no records of any backfilling
or treatment of these shafts. Site investigation for shallow mine workings has
shown that three shallow coal seams have been proven beneath the site.
9.5.9 From the proposed location of the structures associated with the development,
it is understood that additional site investigation and treatment of shafts is
planned to take place prior to commencement of construction phase of works.
Following the investigation and assessment treatment of the shafts may be
required.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 236
9.5.10 Whilst there are three shallow coal seams at the site, potential historic
workings are only considered provide an adverse risk to the development in
an area in the northwest of the site.
9.5.11 Following the investigation and assessment it is likely that treatment of the
mine shafts will be required. Generally no structures should be built over
shafts, or within an area of two cap diameters (to be determined) centred on
the shafts even after they have undergone standard shaft capping and
treatment treated unless additional mitigation measures are incorporated into
the design. Location / shaft specific treatment measures will have to be
agreed with the Coal Authority before buildings are constructed over any
treated shafts.
9.5.12 In the northwest area of the site where there is a shallow coal seam. Some
localised consolidation treatment of the workings may be required beneath
structures sensitive to differential settlement in order to mitigate the potential
risk of settlement on the structure.
9.5.13 If potentially combustible materials are identified and delineated as part of the
pre-construction site investigation these will need to either be removed from
site or excavated and placed at a depth of more than 1.5m below final ground
level. If retained on site these soils will have to be re-compacted so the air
voids content is less than 5% as this has been shown to prevent combustion.
9.5.14 It is anticipated that there will be relatively high foundation loads. Based on
the thickness of Made Ground it is consider piled foundations or for more
moderate loads use vibro (stone) columns will be appropriate but this will be
determined by the detailed geotechnical design. An 8m deep basement
(waste bunker) is proposed for the northern part of the main building adjacent
to the tipping hall. Standard geotechnical risks associated with deep
basements will be mitigated through appropriate design and construction
methods.
9.5.15 Relatively high floor loadings are anticipated which may need to be supported
on vibro (stone) columns or it may be possible to excavate and re-engineer
the Made Ground and to have conventional load bearing floors. This will be
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 237
mitigated through implementation of standard appropriate design and
construction methods.
9.5.16 The pH and sulphate content of the soils require checking with respect to its
potential attack on concrete and take appropriate action in terms of specifying
a suitable mix in line with Building Research Establishment Special Digest 1
Concrete in Aggressive Ground (2005). From existing data, soils are generally
classed as AC-1 with DS-1, locally DS-4.
9.5.17 Current understanding of the ground gas regime shows Characteristic
Situation 2 conditions to prevail. BS8485:2007 indicates that for an industrial
building one level of gas protection is required. Given the nature of the
proposed development, 1.5 levels of protection can be provided by a floor slab
solution comprising a reinforced concrete ground bearing slab with limited
service penetrations that are cast into the slab. Such a floor slab solution will
be used for the proposed development and no further mitigation works will be
required with regard to ground gases in the main area of the development.
However within office areas it is understood from CNIM documentation that 2
levels of protection is be installed within office areas, via the installation of
propriety gas resistant membrane installed to reasonable levels of
workmanship under CQA with integrity testing and independent validation.
Therefore the standard design will mitigate the risks from carbon dioxide in the
ground.
Construction Phase Mitigation of Environmental Risks
9.5.18 A Construction Environmental Management Plan (CEMP) would be developed
for the facility construction works in accordance with good practice.
Appropriate environmental method statements would be developed and
mitigation works implemented where necessary. The works would follow
appropriate legislation and guidance including the SEPAs Pollution Prevention
Guidelines and also include measures to ensure effective site management,
including procedures for dealing with accidental oil and fuel spillages during
the use of plant, equipment and machinery would be included as part of the
CEMP for the site.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 238
9.5.19 The CEMP would include appendices that would provide remediation
implementation and validation plans for areas of higher geo-environmental risk
(if appropriate) together with environmental monitoring plans. The monitoring
plans would be implemented to demonstrate that the development is not
having a significant impact on the surrounding environment. With the potential
for asbestos to be present the CEMP will include mitigation measures in
accordance with the Control of Asbestos Regulations (2012) (CAR) and the
HSE’s ACoP for asbestos (2013).
9.5.20 The impacts to groundworkers installing foundations, below ground
infrastructure and groundworks in/through potentially contaminated Made
Ground is anticipated to be relatively low, with the exception of risks from
inhalation of asbestos fibres, but this would be assessed following the site
investigations. An appropriate action plan will be agreed with the Council and
the HSE in accordance with CAR. The action plan will include the preparation
of the Risk Assessment and Plan of Work in accordance with CAR and other
statutory requirements including:
Site mobilisation;
Excavation methodology;
Handling, movement and storage on site of excavation arisings;
Any processing of excavation arisings containing ACMs;
Movement and placement of arisings to final destination;
Placing of cover system over soils with and ACMs remaining on
site;
Off-site disposal of ACMs;
Licences;
PPE & RPE;
Dust and fibre monitoring.
9.5.21 Potential mitigation measures that would be required include:
Further site investigation and risk assessment;
Removal or treatment of asbestos hotspots;
Using construction plant which limits direct contact and dust inhalation;
Monitoring of air during earthworks in accordance with CAR;
Appropriate PPE / RPE appropriate to the CAR; and
A good level of personal hygiene.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 239
9.5.22 Appropriate measures would be implemented to reduce the generation of dust
from earthworks by implementing standard earthworks practices (e.g.
damping down exposed materials during dry conditions, reducing vehicle
speeds, minimising drop heights of vehicles being loaded with soils etc.).
9.5.23 It is possible that there would be a risk to personnel entering trenches from
build-up of ground gases (carbon dioxide). Historical ground gas monitoring
has shown limited elevated occurrences of ground gases. However, some
localised although short-lived, occurrences have been encountered. This
would be mitigated by implementing standard procedures in relation to
confined spaces.
9.5.24 The proposed development will result in the re-compaction of Made Ground
materials and the installation of hard standing. These measures will reduce
the possibility for the release of asbestos fibres and potential inhalation by
humans both on and off site, thus reducing the risk to potential exposure to
asbestos.
9.5.25 All excavations would be carried out in accordance with current UK best
practice so as to prevent the spread or mobilisation of any contaminated
excavated material and cause surface water pollution.
9.5.26 In addition to the above works, the groundworks may create a significant
quantity of spoil including from the excavation of the waste bunker. These
excavated soils which would be reused or disposed of as follows:
Re-use on site for to create a suitable development platform or for
landscaping purposes;
Re-use of excavated Glacial Till as clean capping soils;
Direct transfer of clean natural soils to third party development site for
re-use;
Transfer to soil treatment centres where the soils are treated before
being re-used on other sites;
Direct transfer of soils to quarry restoration sites or similar; and/or
Disposal of soils at landfills which are licensed appropriately for the type
of soils being disposed.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 240
9.5.27 The re-use of soils on site would be carried out in accordance with the SEPAs
guidance on land remediation and waste management. Based on the current
understanding of the proposed development, the re-use of soils on site would
be possible under these guidelines.
9.5.28 If unexpected contaminated material is encountered in the ground during
construction. If this occurred during construction the nature and extent of the
contamination would be assessed and appropriate mitigation implemented.
The following procedures should be adhered to:
1. All site works at the position of the suspected contamination will cease.
2. A suitably trained geo-environmental specialist should assess the
visual and olfactory observations of the condition of the ground and the
extent of contamination and the Client and the Local Authority should
be informed of the discovery. Should the contamination be likely to
affect controlled waters the EA shall also be informed.
3. The suspected contaminated material will be investigated and tested
appropriately in accordance assessed risks. The investigation works
will be carried out in the presence of a suitably qualified geo-
environmental engineer. The investigation works shall commence to
recover samples for testing and, using visual and olfactory
observations of the condition of the ground, delineate the area over
which contaminated materials are present.
4. The unexpected contaminated material will either be left in situ or be
stockpiled whilst testing is carried out and suitable assessments
completed to determine whether the material can be re-used on site or
requires to be disposed as appropriate.
5. Where the material is left in situ awaiting results it will be reburied or
covered with plastic sheeting.
6. Where the potentially contaminated material is to be temporarily
stockpiled it will be placed either on a prepared surface of Glacial Till,
or on 2000 gauge Visqueen sheeting (or other impermeable surface)
and covered to prevent dust and odour emissions.
7. Any areas where unexpected visual or olfactory ground contamination
is will be surveyed, a photographic record kept and testing results
incorporated into the Verification Report.
8. A photographic recorded will be made of relevant observations.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 241
9. The testing suite will be determined by the independent geo-
environmental specialist on the basis of visual and olfactory
observations.
10. Test results will be compared against current assessment criteria
suitable for the future use of the area of the site affected.
11. The results of the investigation and testing of any suspect unexpected
contamination will be used to determine the relevant actions. After
consultation with the Local Authority and if necessary the EA, materials
should either be:
Re-used in areas where test results indicate that it meets
compliance targets so it can be reused without treatment; or
Treatment of material on site to meet compliance targets so it can
be reused; or
Removal from site to a treatment centre or to a suitably licensed
landfill or permitted treatment facility.
12. Verification Report will be produced for the work.
Operation Phase Mitigation of Environmental Risk
9.5.29 The following mitigation measures are proposed to be implemented in order to
prevent environmental impacts from occurring during the operation of the
facility in respect of creation of pathways to groundwater and surface water
and effects on construction methods.
Waste materials brought in to the facility should be stored to ensure they
have minimal opportunity to develop leachates due to rainfall, and
placed on hardstanding;
Fuels/chemicals should be stored in appropriate tanks/bunded areas;
Hardstanding should be designed in an appropriate way that any runoff
should be directed to an oil/water separator and any other treatment
facility which may be required;
Discharge of effluent during the operation will be mitigated through
appropriate design appropriate operation;
Areas of vehicle parking should be designed so that run-off is directed to
an oil/water separator; and
The site will operate through an Permit which will include an
Environmental Management System (EMS). By implementation of this
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 242
EMS there will be a reduction of environmental impacts to humans, the
ground, groundwater and surface waters.
9.6 Residual Effects and Conclusions
9.6.1 In terms of geology, hydrology, hydrogeology, contamination and ground
stability, most environmental effects have the potential to occur during the
construction phase, when major excavations and ground disturbance would
take place. However, these effects will be mitigated through further site
investigation, standard design and implementation of standard construction
site practices. Only a number of the effects could carry through to the
operational phase of the development. During the operational phase the site
will operate through a Permit which will include an EMS. By implementation of
this EMS there will be a reduction of environmental impacts to humans, the
ground, groundwater and surface waters mitigating these relatively low risks.
Construction Phase
9.6.2 Following mitigation, the potential for adverse residual effects arising from the
construction of the Proposed Development in terms of geology, hydrogeology
and ground conditions are assessed as being very low or negligible.
9.6.3 Conversely, following implementation of the remediation measures described
in the preceding sub-section, there would be a material improvement in the
local geological, hydrological and hydrogeological environment when
compared to the existing baseline position. This would give rise to significant
beneficial effects.
Operational Phase
9.6.4 No additional impact or risks will be associated with the operation of the
proposed Millerhill RERC development compared to the baseline scenario.
Therefore the operational scenario is neutral in terms of impact and risks.
With the implementation of the proposed mitigation measures during the
construction of the Millerhill RERC development, the potential residual
environmental effects due to ground conditions during the operational phase
are assessed as being of negligible significance.
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Operational Phase Future Baseline
9.6.5 No additional impact or risks will be associated with the proposed Millerhill
RERC development compared to those identified in the PPiP development.
Thus, the development would have a neutral impact when compared with the
future baseline position
9.7 Conclusions
9.7.1 This chapter has assessed the potential effects of the Proposed Development
upon the geology and water local to the Application Site and the required
design and mitigation works required to ensure suitable geotechnical
performance for foundations and earthworks during construction and
throughout its operational lifetime. The risk from historic mining has also been
assessed and additional investigation and assessment is required in order that
appropriate design and construction can be implemented to mitigate these
risks. A comparison has also been made between the Proposed Development
and the previous proposals for developing the site which has a PPiP.
9.7.2 The facility is located in an area which has been used as a colliery and railway
sidings and retains a number of structures associated with the sidings. This
study has identified a number of contamination sources on and off the
Application Site. The main sources are:
Off-site Made Ground containing petroleum hydrocarbon which may be
adversely affecting surface water quality. There is no evidence this
contamination has migrated onto the subject site;
On-site Made Ground containing potentially elevated calorific value
which could lead to combustion of the ground;
Asbestos fibres locally identified in Made Ground;
Elevated methane and carbon dioxide (characterised as Characteristic
Situation 2); and
Locally elevated sulphate concentrations.
9.7.3 Notwithstanding the above, previous site investigations carried out at the
Application Site indicate that is contains relatively low concentrations of
contaminants, with the exception of localised identified amosite and chrysotile
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asbestos fibres. Localised slightly elevated concentrations of leachable
contaminants have been identified, although these have been assessed as
having a low risk to water receptors.
9.7.4 Current understanding of the ground gas regime shows Characteristic
Situation 2 conditions to prevail. or the proposed industrial building one level
of gas protection is required which will be provided by a floor slab solution
comprising a reinforced concrete ground bearing slab with limited service
penetrations that are cast into the slab. Two levels of protection should be
installed within office buildings. No further mitigation works will be required
with regard to ground gases.
9.7.5 Due to the nature of the facility the main geo-environmental risks would occur
during the construction process. These risks would be managed through the
following mitigation measures:
Further site investigation;
Risk assessment;
Remediation where required;
The geo-environmental design of the facility;
Production and implementation of a CEMP which would include:
a) Consideration of adjacent residential and commercial / industrial
human receptors;
b) Generic measures to ensure effective environmental site
management;
c) Procedures for working in ground contaminated with asbestos in
accordance with CAR and the HSE ACoP.
d) Procedures for working near surface waters in accordance with
the SEPA guidance;
e) Excavations carried out in accordance with current UK best
practice; environmental monitoring plan to demonstrate that the
facility is not having a significant impact on the surrounding
environment;
f) Mitigating risks to groundworkers during installation of
infrastructure; and
g) Re-use of soils carried out in accordance with appropriate the
SEPAs Guidelines.
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9.7.6 During the operation of the facility there are a number of on-going risks that
could potentially develop into higher risks. These include:
Effects of contaminants on construction materials;
Leakage from the facility plant or associated structures; and
Leakage or run off from storage areas.
9.7.7 The first item will be mitigated through design and the last two through
standard industry mitigation measures and adherence to the site’s Permit.
9.7.8 As a result of the proposed mitigation measures there will be no significant
residual adverse effects due to geology and ground conditions on any
receptors during the operation of the facility. Overall, after completion of the
facility it is assessed that there would be a beneficial geo-environmental effect
due to the removal or remediation of any contaminant hotspots and the
construction of buildings and hard standing will effectively cap the site from
breaking pathways between potential contaminant sources and receptors.
9.7.9 The mining related risks are the presence of the unidentified mine shafts with
unknown treatment status and shallow mining below the north western part of
the site. Further assessment of the requirement for treatment of these will be
made following an additional phase of site investigations. Once located and
treated appropriately these shafts and the shallow mining will pose a
negligible long term risk to the development.
9.7.10 Geotechnical impacts have also been assessed. All of the geotechnical
impacts can be mitigated thorough the standard process of appropriate site
investigation, design and through the normal construction methods to leave a
negligible residual impact to the development.
9.7.11 In terms of the Proposed Development in comparison to the PPiP
development, the impacts are considered to be neutral.
9.7.12 On the basis of the assessment presented in this chapter there is considered
that there are no significant residual environmental effects associated with
geology, hydrogeology and ground conditions.
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9.7.13 It is considered that the desk based and intrusive investigation reports listed in
Table 9.4 provides sufficient information to enable the determination of this
planning application. However, it is acknowledged that the planning
permission (should it be granted) is likely to include conditions requiring
further intrusive investigations prior to the commencement of construction.
The results of the investigation would be used to update the current
conceptual site model and risk assessment and ensure a more detailed
assessment of potential risks can be made and any required mitigation
measures can be designed and implemented.
9.8 References
9.8.1 This Chapter of the ES generally complies with the relevant principles and
requirements of a wide range of guidance including:
Part IIA of the Environment Protection Act, 1990;
Contaminated Land (Scotland) Regulations 2005;
BS5930:1999 + A2 2010: Code of practice for site investigations;
BS10175: 2011 + A1 2013: Investigation of Potentially
Contaminated Sites - Code of Practice;
DEFRA/Environment Agency (2004) Report CLR11 Model
Procedures for the Management of Land Contamination;
SEPA (2010) “An Introduction to Land Contamination and
Development Management”;
SEPA (2010) “Environmental Standards for Discharges to Surface
Waters.” WAT-SG-53 V3.1, August 2010;
Environment Agency (2001) Piling and Penetrative Ground
Improvement Methods on Land Affected by Contamination:
Guidance on Pollution Prevention” (Ref: NC/99/73);
Health & Safety Executive (2013) Approved Code of Practice:
Managing & working with asbestos. Control of Asbestos
Regulations 2012.
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10.0 SURFACE WATERS AND FLOOD RISK
10.1 Introduction
10.1.1 This chapter of the ES has been prepared to consider the potential impacts of
the proposals, in terms of the effects upon surface waters and flood risk.
10.1.2 It addresses the development in the context of contemporary planning
guidance on flood risk issues, and establishes the extent to which flood risk
assessment is necessary.
10.1.3 An appraisal is also presented of on-site activities, during the construction,
operational and decommissioning phases of the development, and the
potential effects these may have upon the local water environment, in terms of
contamination of surface waters by suspended solids or other pollutants.
Planning Policy and Guidance
10.1.4 There is a range of planning legislation and guidance relating to development,
flood risk and pollution of water resources, and the following documents are
considered to be those most pertinent to the proposed development. The
assessment presented in this chapter has been prepared cognisant of the
content of these documents:
Scottish Planning Policy (June 2014);
Technical Flood Risk Guidance for Stakeholders (SEPA February 2014);
and
Water Framework Directive (2000/60/EC), implemented in Scotland
through the Water Services Act 2003.
10.2 Methodology
10.2.1 The assessment has primarily involved a desk-based study using information
gleaned from the following sources:
Ordnance Survey mapping;
Scottish Environment Protection Agency (SEPA) - Flood Maps;
A site-specific topographical survey;
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Millerhill Zero Waste Facilities PPiP Application – Environmental
Statement (March 2011) – Appendix 10-1 Flood Risk Assessment; and
Millerhill Zero Waste Facilities PPiP Application – Environmental
Statement (March 2011) – Chapter 10 Geology, Hydrogeology,
Hydrology and Water Resources.
10.2.2 An analysis has also been undertaken of the surface water runoff generated
by the proposed development using the ‘Micro Drainage’ simulation program;
the output from which has been used to design the preliminary surface water
drainage scheme submitted as part of the planning application (see Appendix
10-1).
10.2.3 Given the work previously undertaken to prepare the PPiP application for the
Millerhill Zero Waste Facilities and, ultimately, the acceptability of the
supporting Environmental Statement, it has not been considered necessary to
re-consult technical stakeholders in advance of preparing this chapter.
Significance Criteria
10.2.4 The significance of impacts attributable to the proposed development is
derived from a combination of the magnitude of the potential impact and the
sensitivity of the receptor (either beneficial or adverse). The criteria used to
determine magnitude are set out below in Table 10.1.
Table 10.1: Impact Magnitude
Impact Magnitude Description
Negligible
Undetectable change in hydrological conditions, including water quality.
Low
Detectable but minor change to hydrological conditions or slight deterioration in water quality unlikely to affect most sensitive receptor.
Medium
Detectable change to hydrological conditions or deterioration in water quality likely to affect most sensitive receptor on a temporary basis.
High
Substantial change to hydrological conditions or deterioration in water quality likely to affect most sensitive receptor on a permanent basis.
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10.2.5 The criteria used to establish the sensitivity of potential receptors has been
based upon the degree of environmental response to a specific impact or the
conservation status of the receptor itself, as set out below in Table 10.2.
Table 10.2: Sensitivity
Sensitivity Description
Negligible Receptor insensitive to impact. Receiving environment/habitat has low conservation value.
Low Receptor responds minimally to impact. Receiving environment/habitat has only local value/status.
Medium Receptor exhibits material response to impact. Receiving environment/habitat has a regional value/status.
High Receptor exhibits substantial response to impact. Receiving environment/habitat has a national or international status (i.e. SSSI, SAC etc).
10.2.6 The impact magnitude and receptor sensitivity established from Tables 10.1
and 10.2 respectively have then been combined in the matrix presented below
in Table 10.3 to categorise overall impact significance.
Table 10.3: Impact Significance
Magnitude
Sensitivity
Negligible Low Medium High
Negligible Negligible Negligible Negligible Negligible
Low Negligible Minor Minor Minor/Moderate
Medium Negligible Minor/Moderate Moderate Moderate/Major
High Negligible Moderate Major Major
10.2.7 The assessment of predicted impacts is based upon the significance before
any mitigatory measures are introduced. In accordance with the EIA
Regulations, any impacts predicted to be moderate or major are considered to
be significant.
Limitations
10.2.8 No specific limitations were encountered in the preparation of this assessment
chapter.
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10.3 Baseline
Baseline Conditions
10.3.1 Reference to SEPA’s indicative flood map identifies the site as being of ‘low
risk’ from both fluvial and pluvial sources, i.e. having a flooding risk less than
0.5% annual probability in any given year (also referred to as 1 in 200).
10.3.2 In accordance with SEPA’s technical flood risk guidance, only sites with a
medium to high risk of flooding (i.e. >0.5% annual probability) need to be
subjected to detailed flood risk assessment, although it is important to
understand how a developed site will respond to statistically infrequent storm
events, to ensure that downstream properties are not adversely affected.
10.3.3 The proposed development lies within the hydrological catchment of the
Cairnie Burn which, in turn, is fed by a number of watercourses and drains to
the west of the site. Cairnie Burn flows in a north-easterly direction via a series
of open channel and culverted sections, before its confluence with the River
Esk at Monktonhall, approximately 2km from the site. Ultimately, the River Esk
discharges to the Firth of Forth at Musselburgh approximately 2.5km from the
site.
10.3.4 Cairnie Burn has yet to be classified under the Water Framework Directive
(WFD). However, the River Esk has been classified as moderate under the
WFD, by virtue of the morphological alterations that have resulted from urban
development and pollution from various sources (sewage disposal, aggregate
and coal mining and farming activities).
10.3.5 As described elsewhere in the ES, the proposal site can presently be
described as brownfield in nature, largely comprised of regenerating
woodland. Accordingly, surface water runoff is limited to overland flow,
influenced by the prevailing ground conditions and specific rainfall events.
10.3.6 In hydrological terms, there are no designated sites on or near the proposed
development.
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PPiP Future Baseline Scenario
10.3.7 As described earlier in this ES, the proposal site already benefits from PPiP
for a comprehensive waste management scheme, which would see the site
largely covered by impermeable roofs and hardstandings.
10.3.8 With this in mind, it is appropriate to consider the development now being
proposed (i.e. the Millerhill RERC) in the context of the scheme already
approved, assuming that the PPiP development and associated infrastructure
and environmental mitigation works have been implemented.
10.3.9 In this scenario, the future baseline condition envisages that the surface water
runoff from the proposal site is regulated to the ‘greenfield’ rate set out in the
site-specific runoff assessment, prepared by Midlothian Council’s Consulting
Engineers, Fairhurst, i.e. 3.6l/s/Ha or 19.8l/s for the developed site area of
5.5Ha (see Appendix 10-1).
10.3.10 In addition, it is also assumed that the dedicated foul and surface water
drainage systems, proposed as part of the aforementioned PPiP development,
both on-site and off-site, have been implemented in full.
10.4 Assessment of Effects
Existing Baseline
Potential Effects – Flood Risk
Construction Phase
10.4.1 During the construction phase of the project there would be a gradual increase
in impermeable areas until the development is complete. Without regulation,
the consequential increase in surface water runoff would result in overloading
of the off-site receiving drainage infrastructure and a modest increase in flood
risk to property ‘downstream’ from the site. This potential impact is assessed
as having a low magnitude and medium sensitivity, combining as minor
significance.
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Operational Phase
10.4.2 During the operational phase of the development, without regulation, the
increase in surface water runoff from the developed site would substantially
exceed that from the existing ‘greenfield’ conditions. The consequences of this
increase would be overloading of the receiving drainage infrastructure and an
increased risk of flooding to properties downstream. This potential impact is
assessed as having a medium magnitude and medium sensitivity, combining
as moderate significance.
Decommissioning
10.4.3 During the decommissioning phase of the project there would be a gradual
decrease in impermeable areas until the development is completely removed
and pre-existing conditions are restored. Without retaining the proposed flow
attenuation facilities and associated drainage system intact, the potential
increase in surface water runoff could result in overloading of the receiving
drainage infrastructure and a consequential increase in flood risk to property
‘downstream’ from the site. This potential impact is assessed as having a low
magnitude and medium sensitivity, combining as minor significance.
Potential Effects – Surface Waters
Construction Phase
10.4.4 During construction, the potential effects upon surface water quality which
should be considered include:
The mobilisation of site soils (via storm runoff), into the off-site surface
water regime; and
Plant operations including cleansing, refuelling etc.
10.4.5 Suspended solids exist in all surface water runoff, to some extent or another.
However, during the earthworks phase of a construction project this situation
can be exacerbated beyond acceptable levels, without appropriate measures
being implemented.
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10.4.6 The site investigation works undertaken (and reported upon in Chapter 9)
confirm that there are some ‘hotspots’ of contamination within the proposed
development site. The presence of these contaminant sources increases the
potential for adverse impact upon the quality of surface water flows.
10.4.7 In light of the above, it is considered that the potential impact during
construction upon surface waters from suspended solids and contamination is
of medium magnitude with low sensitivity, resulting in minor / moderate
significance.
10.4.8 Like all construction projects, there is a risk of spillage from plant and
equipment used during the construction phase. However, in the absence of
any direct physical connectivity to the wider water environment, via surface
flow paths, the potential impacts are considered to be of low magnitude and
low sensitivity, resulting in minor significance.
Operational Phase
10.4.9 The potential effects upon surface waters which should be considered during
the operational life of the development are:
Oils, fuels and/or suspended solid contamination, emanating from
vehicles using the roads, car parks and hardstandings; and
Inundation of parts of the site where waste materials are stored.
10.4.10 The prospect of surface water contamination arising from oils, fuels and/or
suspended solids is most unlikely to occur, as a result of the drainage features
that would be installed at the site. In particular, the development would be
drained by surface water channels and trapped gullies providing a primary
phase of interception / separation. In addition, the site’s internal roadways and
hardstandings would discharge to the below-ground system via the SEPA
approved oil / petrol interceptors. Accordingly, the potential impact has been
assessed as negligible magnitude and negligible sensitivity, resulting in
negligible significance.
10.4.11 It should also be noted that the proposed facilities would operate under the
controls imposed by a PPC permit, issued and regulated by the SEPA. One
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important aspect of this permit would be to ensure that there would be no
pollution / contamination of surface waters on or surrounding the site.
10.4.12 The proposed development lies in an area identified as having a low flooding
risk and has limited physical connections to the wider land drainage network.
In addition, the proposed drainage system has been designed with the
capacity to accommodate statistically infrequent storm events and there is no
recorded history of on-site surface water inundation / flooding. Accordingly,
the risk of those areas used for the storage of waste being inundated is very
low and, consequently, the potential impact is assessed as negligible
magnitude with negligible sensitivity and, as such, negligible significance.
Mitigation
10.4.13 As stated earlier in this chapter, assessment work undertaken in support of
the previously approved PPiP application and the construction of related off-
site surface water drainage infrastructure, has resulted in a strategy for
bringing forward the proposal site in a sustainable manner, from a flood risk
perspective.
10.4.14 The surface water drainage scheme serving the proposed development (as
illustrated in Figure 10.1) has been designed to ensure that post-development
flows from the site are regulated to a maximum rate of 19.5l/s, via a series of
attenuation ponds/lagoons. The Micro Drainage model outputs that
demonstrate this are presented in Appendix 10-2.
10.4.15 Provided these attenuation facilities and associated controlled outfall are
constructed at an early stage, and run-off from the site is directed into the
system as the development progresses, there should be no increase in
surface water flows to the off-site drainage network.
10.4.16 These storage facilities would also capture silt and suspended solids present
in run-off, during the construction phase of the project, pending the
construction of finished surfacing and associated drainage features.
10.4.17 In terms of the construction phase, best practice techniques, in line with the
measures outlined in the CIRIA document: ‘Control of Water Pollution from
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Construction Sites’ would be employed to minimise the risk of any potential
impacts upon surface water resources.
PPiP Future Baseline Scenario
10.4.18 When assessed against the Future Baseline conditions, which assume that
the proposal site has been developed for the approved alternative waste
management facilities, it is evident that there would be very little difference
between:
The scale of the facilities;
The construction practises that would be employed; and
The drainage infrastructure that would be installed to serve each
development scenario.
10.4.19 In light of the above, it is considered that the development now proposed is
neutral in terms of flood risk and surface water impacts.
10.5 Residual Effects and Conclusions
Residual Effects - Existing Baseline
Flood Risk
10.5.1 Following the introduction/application of the mitigation measures described
above, those potential impacts originally assessed as being of moderate or
greater significance have been reconsidered, as follows.
10.5.2 During the operational life of the development, the implementation of the
proposed surface water drainage system (as illustrated in Figure 10.1) will
serve to ensure that post-development runoff is regulated to existing
‘greenfield’ (pre-agreed) flow rates. Accordingly, the risk of downstream
infrastructure being overloaded and, consequentially, third-party properties
being inundated is negated.
10.5.3 The residual effect of this potential impact is reduced to low magnitude
(beneficial), as off-site flows cannot exceed those attributable to the pre-
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developed state, irrespective of the statistical infrequency of the storm event,
with a medium sensitivity receptor, resulting in a minor beneficial effect.
Surface Waters
10.5.4 Adopting best practice techniques, as outlined in the CIRIA document “Control
of Water Pollution from Construction Sites”, throughout the construction phase
of the development, would serve to ensure that the risk of surface water
resources becoming polluted or contaminated would be minimised.
Accordingly, the residual effect attributable to this potential impact is
considered to be low magnitude with a low sensitivity receptor, resulting in
minor significance.
Comparison with PPiP Future Baseline Scenario
10.5.5 As identified earlier in this chapter, the residual effects attributable to the
proposed development are unlikely to be different to those considered for the
PPiP application. Accordingly, the position from a flood risk and surface
waters perspective can be regarded as neutral.
10.6 Conclusions
10.6.1 The site lies in an area of low flood risk and will discharge surface water into
off-site infrastructure designed to receive regulated flows from the
development, approved as part of the wider, previously approved, PPiP
proposals.
10.6.2 The infrastructure serving the proposed development has been designed
using criteria, pre-agreed as part of the PPiP development, to ensure that the
resulting flows do not exceed those envisaged during the design of the off-site
infrastructure.
10.6.3 Given that runoff from the site will be restricted to a pre-agreed peak flow rate
that cannot be exceeded, irrespective of the statistical infrequency of storm
events, it has been concluded that the residual effect upon downstream
properties is minor beneficial.
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10.6.4 The development would not affect the quality of surface waters in the
surrounding area, by virtue of the drainage systems that would be installed to
serve the site, and the specific practises employed to maintain these systems,
in line with the site’s pre-requisite PPC permit. As such, the residual effects
upon surface waters are not considered to be significant.
10.6.5 When assessed against the residual effects attributable to the PPiP
application, the proposed development is considered to be neutral, from a
flood risk and surface waters standpoint.
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11.0 NOISE AND VIBRATION
11.1 Introduction
11.1.1 This chapter of the ES assesses the impact of the Proposed Development
with regard to noise and vibration. It describes the methods used to assess
the impacts, the baseline conditions currently existing at the Application Site
and the potentially affected noise sensitive receptors. The potential direct and
indirect impacts arising from the Proposed Development and an example of
the mitigation measures required.
11.1.2 The assessment includes the consideration of:
Information on representative existing baseline sound climate;
Information on the noise impact upon existing or potential future
residential dwellings from site noise and vibration sources;
Information and predictions on noise from construction and
decommissioning works;
The vibration impact on existing or potential future residential dwellings;
and
Noise mitigation measures, which would be necessary to comply with
current noise standards, guidance and proposed noise conditions.
11.1.3 The aforementioned potential noise impacts are considered in the context of
the existing ambient noise at the site, which is generally influenced by road
traffic movements and intermittent aircraft noise.
11.1.4 Appendix 11-1 provides details of technical terms within the chapter, for ease
of reference. There is also a chart showing typical everyday noise levels to
assist in understanding the subjective level of noise in terms of decibels.
Previous Assessment
11.1.5 As presented in Chapter 2.0 of the ES, the Application Site benefits from PPiP
which was granted in 2012 for the ZWF and comprised:
An EfW Facility;
An AD Facility; and
A MBT Facility.
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11.1.6 A Noise Impact Assessment (NIA) was undertaken as part of the EIA
undertaken in support of the application for the ZWF. A further NIA was
prepared in respect of the AD Facility, located immediately to the north of the
Application Site. Planning permission for the AD Facility was granted in June
2013, and construction was on-going at the time of writing.
11.1.7 The Millerhill RERC would be implemented instead of the consented EfW and
MBT facilities. Given that the plant content and layout of the Proposed
Development are likely to be different to those assessed for the PPiP a further
NIA is required.
11.1.8 As mentioned in Chapters 1.0 and 2.0, as construction is underway for three
developments including the AD Facility, Borders Railway and SNCD, these
developments have been taken into account within the noise assessment
presented within this Chapter. Further discussion on this matter is provided in
sub-section 11.4
11.1.9 The elements of the proposed development to be considered and assessed in
terms of noise include the following (see Figure 4.2):
Energy Recovery Centre:
Tipping Hall;
Waste Bunker and Hoppers;
Bottom Ash Treatment Building;
Boiler Hall;
Mechanical Pre-treatment Building;
Flue Gas Treatment Building;
Turbo Generator Hall;
Baled Waste Storage Hall;
Air Cooled Condenser;
Staff and Visitor Facilities;
Step-Up Transformer;
District Heating Building;
Water, Fuel, Oil and Ammonia Tanks;
Weighbridge and Gatehouse.
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11.1.10 It is intended that the Proposed Development would operate 24 hours per day
and 7 days per week. The hours proposed for import / export of materials
would relate to daytime periods from 08:00 hours up to 20:00 hours Monday to
Friday. The doors into the buildings would generally be kept closed except to
allow access for vehicles.
11.1.11 Access to the site is to be via an entrance on the northern boundary, which
will lead to the gatehouse and weighbridge.
11.1.12 The objectives of the survey and assessment were to provide information and
advice in respect of the following:
Identify plant equipment and its location;
Identify the nearest existing or potential future noise and vibration
sensitive receptors or sites;
Determine likely source noise and vibration levels;
Provide information on existing background sound levels at the nearest
sensitive receptors;
Provide predictions of resultant noise and vibration levels at the nearest
sensitive receptors; and
Provide an example of amelioration measures to reduce noise for the
proposed development by applying BAT.
11.1.13 Information used in this assessment has been obtained from the following
sources:
Ordnance Survey maps of the local area;
General layout of the proposed development;
Road traffic assessment provided by Axis;
British Standards BS4142:2014, BS7445:2003, BS8233:2014, BS6472-
12008, BS7385:1993: Part 2;
WHO: Guidelines for Community Noise (April 1999);
WHO: Night Noise Guidelines for Europe (2009);
Planning Advice Note (PAN) 1/2011: Planning and Noise (March 2011);
Design Manual for Roads and Bridges, Volume 11, Environmental
Assessment (2011);
Empirical vibration measurements recorded at other waste
management, energy from waste and construction sites;
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The SEPA Guidance on the control of noise at PPC installations; and
ISO 9613-2:1996 Acoustics: Attenuation of Sound During Propagation
Outdoors.
11.2 Legislation, Policy and Guidance
11.2.1 The following section outlines the key planning policy and guidance that
relates to the assessment of residential amenity and protection of residents
from general environmental and industrial noise and vibration sources.
Planning Advice Note 1/2011Planning and Noise: 2011
11.2.2 Within the introduction of Planning Advice Note 56, Planning and Noise
(1999), it states: “This Planning Advice Note (PAN) provides advice on the
role of the planning system in helping to prevent and limit the adverse effects
of noise. Information and advice on noise impact assessment methods is
provided in the associated Technical Advice Note Assessment of Noise.
Appendix 3 of the Technical Advice Note provides Excel Workbooks which
have been included to assist in the technical evaluation of noise assessment
as part of the planning process.”
11.2.3 Within the Introduction of PAN 1/2011 it states:
“It supersedes Circular 10/1999 Planning and Noise and PAN 56
Planning and Noise. Information and advice on noise impact
assessment (NIA) methods is provided in the associated Technical
Advice Note. It includes details of the legislation, technical standards
and codes of practice for specific noise issues.
The PAN promotes the principles of good acoustic design and a
sensitive approach to the location of new development. It promotes the
appropriate location of new potentially noisy development, and a
pragmatic approach to the location of new development within the
vicinity of existing noise generating uses, to ensure that quality of life is
not unreasonably affected and that new development continues to
support sustainable economic growth. Environmental Health Officers
and/or professional acousticians should be involved at an early stage in
development proposals which are likely to have significant adverse
noise impacts or be affected by existing noisy developments.”
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11.2.4 In respect of development planning, the following issues may be relevant
when considering noise issues during the preparation of a development plan:
Avoidance of significant adverse noise impacts from new developments;
Applying noise impact criteria reasonably;
Use of mitigation measures to manage noise impacts;
Protection of Quiet Areas; and
Avoidance of development significantly adversely affecting Noise
Management Areas.
11.2.5 Under the heading: Noise Impact Assessment (Paragraph 19) the guidance
states: “The preparation and consideration of planning applications that raise
significant noise issues can be greatly assisted by a Noise Impact
Assessment (NIA). Planning authorities can require a NIA either as part of an
Environmental Impact Assessment or separately. The need for noise impact
assessments is best identified during pre-application discussions. The
purpose of a NIA is to demonstrate whether any significant adverse noise
impacts are likely to occur and if so, identify what effective measures could
reduce, control and mitigate the noise impact. Before a NIA is commissioned,
planning authorities and applicants are advised to:
Agree any potential representative limits of noise and /or the relevant
NIA methodology in the context of the proposed development, its
location and the surrounding area, and
Establish criteria for assessing any significant adverse noise impact or
predict and describe ambient noise levels (including noise from transport
sources) that the proposed development is likely to generate and/or is
likely to be subjected to.
For further information on NIA methodologies see the Technical Advice Note.”
11.2.6 The guidance also provides examples of measures that could be considered
as part of a mitigation strategy (where required) which should be proportionate
and reasonable. Examples given include consideration of reduction of noise at
source, layout, operational time, work sequencing, baffle mounds, acoustic
fencing, alternatives to vehicle reversing alarms, off road transport routes and
road surface treatments, setting noise limits and suitable glazing for existing
development.
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BS4142:2014 Methods for Rating and Assessing Industrial and
Commercial Sound
11.2.7 BS4142:2014: Methods for Rating and Assessing Industrial and Commercial
Sound, is based on the measurement of background sound using LA90
noise
measurements, compared to source noise levels measured in LAeq
units. The
differential between the two measurements; once any corrections have been
applied for source noise tonality, distinct impulses and intermittency etc. (i.e.
the ‘rating’ level); determines the impact magnitude.
a) Typically, the greater this difference, the greater the magnitude of the
impact.
b) A difference of around +10 dB or more is likely to be an indication of
a significant adverse impact, depending on the context.
c) A difference of around +5 dB is likely to be an indication of an
adverse impact, depending on the context.
d) The lower the rating level is relative to the measured background
sound level, the less likely it is that the specific sound source will have
an adverse impact or a significant adverse impact. Where the rating
level does not exceed the background sound level, this is an
indication of the specific sound source having a low impact,
depending on the context.
11.2.8 In terms of establishing the rating level, corrections for the noise character has
to be taken into consideration. These include the following factors:
Tonality: For sound ranging from not tonal to prominently tonal the
Joint Nordic Method gives a correction of between 0 dB and +6 dB for
tonality. Subjectively, this can be converted to a penalty of 2 dB for a
tone which is just perceptible at the noise receptor, 4 dB where it is
clearly perceptible and 6 dB where it is highly perceptible.
Impulsivity: A correction of up to +9 dB can be applied for sound that
is highly impulsive, considering both the rapidity of the change in
sound level and the overall change in sound level. Subjectively, this
can be converted to a penalty of 3 dB for impulsivity which is just
perceptible at the noise receptor, 6 dB where it is clearly perceptible
and 9 dB where it is highly perceptible.
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Other sound characteristics: Where the specific sound features
characteristics that are neither tonal nor impulsive, though otherwise
are readily distinctive against the residual acoustic environment, a
penalty of 3 dB can be applied.
(NOTE: Where tonal and impulsive characteristics are present in the
specific sound within the same reference period then these two
corrections can both be taken into account. If one feature is dominant
then it might be appropriate to apply a single correction. Where both
features are likely to affect perception and response, the corrections
ought normally to be added in a linear fashion.)
Intermittency: When the specific sound has identifiable on/off
conditions, the specific sound level ought to be representative of the
time period of length equal to the reference time interval which
contains the greatest total amount of on time. This can necessitate
measuring the specific sound over a number of shorter sampling
periods that are in combination less than the reference time interval in
total, and then calculating the specific sound level for the reference
time interval allowing for time when the specific sound is not present. If
the intermittency is readily distinctive against the residual acoustic
environment, a penalty of 3dB can be applied.
11.2.9 The assessment of noise from the fixed and mobile plant at the nearest
receptors is considered and our expert opinion is provided below.
Tonality
11.2.10 In terms of tonality the proposed development would include appropriate noise
mitigation measures to ensure that any tonal noise sources (i.e. fans, pumps,
tonal reverse alarms etc.) would be either enclosed within buildings or
acoustically treated by design. It is our experience in dealing with this type of
development that the detailed design mitigation strategy will enable the Site to
operate under normal operating conditions where tonal noise in unlikely to be
significant at Site and imperceptible at receptor locations. The proposed Local
Authority noise condition for the Site includes an NR25 limit on noise levels
within bedrooms during night-time, which provides some additional control
over frequency content. Tonal noise penalties are therefore unlikely to be
applicable and no penalty is deemed to be required.
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Impulsivity
11.2.11 In terms of impulsivity (i.e. noise from pressure relief valves, offloading of
waste) these noise sources would also be controlled by the use of quick acting
access doors into buildings to contain noise from offloading operations,
silencers on any intermittent pressure relief valves etc., it is our experience
that impulsive noise is not a character shown to be significant with this type of
site due to design mitigation strategies. Offloading activities within the Tipping
Hall would not occur during night-time periods and doors into building would
be closed. Impulse noise penalty is therefore not deemed to be relevant or
appropriate in this case.
Intermittency
11.2.12 In terms of intermittency the only significant typical intermittent activity on site
is likely to be the noise from daytime vehicle movements on and off Site. The
question is whether these intermittent noise sources would be distinctive at
noise sensitive receptors (NSRs) and whilst the noise associated with these
activities is not expected to be significant, to be robust we have allowed for a
+3dB penalty to the calculated noise contribution in accordance with BS4142:
2014.
11.2.13 In conclusion, we would add +3dB to the calculated noise contribution for
intermittency during the daytime period with the proposed mitigation
measures. During night-time there would be no HGV movements and
therefore no penalties are deemed to be appropriate for the calculated noise
contribution.
BS8233:2014 Guidance on Sound Insulation and Noise Reduction For
Buildings
11.2.14 The British Standard BS8233 provides additional guidance on noise levels
within buildings. These are based on the WHO recommendations and the
criteria given in BS8233 for unoccupied spaces within residential properties.
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11.2.15 The guidance provided in Section 7.7 of BS8233 provides recommended
internal ambient noise levels for resting, dining and sleeping within residential
dwellings. Table 11.1 below provides detail of the levels given in the standard.
Table 11.1: BS8233: 2014 Indoor Ambient Noise Levels For Dwellings
Activity Location 07:00 to 23:00 23:00 to 07:00
Resting Living Room 35 dB LAeq,16hours -
Dining Dining Room / Area 40 dB LAeq,16hours -
Sleeping (daytime resting) Bedroom 35 dB LAeq,16hours 30 dB LAeq,8hours
11.2.16 The attenuation from an open window, referred to in BS8233: 2014 and other
guidance is -10dB(A) to -15dB(A). Therefore, to achieve a ‘good’ design
according to the standard, the level outside a living room window would
be within the range 40-45dB(A) Leq and for a ‘reasonable’ standard a
level of between 50-55dB(A) Leq. For night-time periods a `good’ design
within the bedroom would be an external level of between 40dB and 45dB.
World Health Organisation (WHO) Guidelines for Community Noise: April
1999
11.2.17 This document provides further updated information on noise and its effects
on the community. Within the document for noise ‘In Dwellings’ it states that:
“The effects of noise in dwellings, typically, are sleep disturbance, annoyance
and speech interference. For bedrooms the critical effect is sleep disturbance.
Indoor guideline values for bedrooms are 30dB LAeq for continuous noise and
45dB LAmax for single sound events. Lower noise levels may be disturbing
depending upon the nature of the noise source.”
11.2.18 The WHO document also states: “At night-time, outside sound levels about 1
metre from facades of living spaces should not exceed 45dB LAeq, so that
people may sleep with bedroom windows open. This value was obtained by
assuming that the noise reduction from outside to inside with the window open
is 15dB. To enable casual conversation indoors during daytime, the sound
level of interfering noise should not exceed 35dB LAeq. To protect the majority
of people from being seriously annoyed during the daytime, the outdoor sound
level from steady, continuous noise should not exceed 55dB LAeq on
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balconies, terraces and in outdoor living areas. To protect the majority of
people from being moderately annoyed during the daytime, the outdoor sound
level should not exceed 50dB LAeq. Where it is practical and feasible, the lower
outdoor sound level should be considered the maximum desirable sound level
for new development.”
11.2.19 In 2009, the WHO published: Night Noise Guidelines for Europe, which it
describes as an extension to the WHO Guidelines for Community Noise
(1999). It concludes that: “Considering the scientific evidence on the
thresholds of night noise exposure indicated by Lnight,outside as defined in the
Environmental Noise Directive (2002/48/EC), an Lnight,outside of 40dB should be
the target of the night noise guideline (NNG) to protect the public, including
the most vulnerable groups such as children, the chronically ill and the elderly.
Lnight,outside value of 55dB is recommended as an interim target for those
countries where the NNG cannot be achieved in the short term for various
reasons, and where policy-makers choose to adopt a stepwise approach.”
Guidance on Construction Noise
BS 5228: 2009 Code of Practice for Noise and Vibration Control on
Construction and Open Sites
11.2.20 BS5228 refers to: “the need for the protection against noise and vibration of
persons living and working in the vicinity of, and those working on,
construction and open sites. It recommends procedures for noise and
vibration control in respect of construction operations and aims to assist
architects, contractors and site operatives, designers, developers, engineers,
local authority environmental health officers and planners.”
11.2.21 Part 1 deals with noise in terms of background legislation and gives
recommendations for basic methods of noise control relating to construction
and open sites where significant noise levels may be generated. The guidance
is aimed at giving advice on achieving ‘best practice’ in controlling noise and
vibration from construction and open sites. There is an example of noise limits
given in Annex E, which sets out cut-off limits between 65dB(A) and 75dB(A)
or 5dB(A) above the ambient noise, whichever is the greater. Part 2 of BS
5228 deals specifically with vibration control and provide the legislative
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background to the control of vibration and recommendations for controlling
vibration at source and management controls (e.g. liaison with communities,
supervision, preparation and choice of plant etc.)
Guidance on Ground Vibration
11.2.22 Most of the available data relating to the effects of ground vibration on
buildings have been obtained during tests using explosives. From these
studies, two regimes of building damage have evolved, those of structural
damage involving major failures of whole or parts of buildings and
architectural damage involving cracking plaster or other brittle materials.
11.2.23 Architectural, sometimes called cosmetic, damage is thought to be more
annoying than dangerous and would start to occur at lower levels of vibration
than structural damage. Recent International and BS define and categorise
building damage under three main headings:
a) Cosmetic - the formation of hairline cracks on drywall surfaces or the
growth of existing cracks in plaster or drywall surfaces. In addition, the
formation of hairline cracks in mortar joints of brick / concrete block
construction.
b) Minor - the formation of large cracks or loosening and falling of plaster
or drywall surfaces, or cracks through bricks/concrete blocks.
c) Major - damage to structural elements of the building, cracks in support
columns, loosening of joints, splaying of masonry cracks, etc.
11.2.24 An investigation into the effects of induced vibration undertaken by the British
Standards Institution has culminated in BS7385:1993; Part 2 which gives
guide values to prevent cosmetic damage to property of 15 to 20mms-1
between 4Hz and 15Hz, whilst above 40 Hz the guide value is 50mms-1. The
BSI suggests reducing these figures by a factor of 50% for continuous
vibration, for example from rail traffic, thus the values become 7.5-10mms-1 at
4-15Hz, and 25.0mms-1 at 40Hz and above.
11.2.25 With regard to the threshold of cosmetic damage, for continuous vibration
such as road or rail traffic, levels below 5.0mms-1 are unlikely to be significant.
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For a given level of vibration the risk of damage decreases as the frequency of
that vibration increases.
11.2.26 BS5228-2:2009 Annex B gives guidance on the effects of vibration levels,
which is summarised below in Table 11.2.
Table 11.2: Guidance on Effects of Vibration Levels
Vibration Level
mm.s-1
Effect
0.14 Vibration might be just perceptible in the most sensitive situations for most vibration frequencies associated with construction. At lower frequencies, people are less sensitive to vibration.
0.3 Vibration might be just perceptible in residential environments.
1.0 It is likely that vibration of this level in residential environments will cause complaint, but can be tolerated if prior warning and explanation has been given to residents.
10 Vibration is likely to be tolerable for any more than a very brief exposure to this level.
11.2.27 In terms of response limits of buildings BS5228-2:2009 (Annex B, Table B.2)
refers to BS7385-1 and BS7385-2 and sets out guide values for transient
vibration for cosmetic damage, which gives a low frequency limit of 15mm/sec
(4Hz) increasing to 20mm/sec at 15Hz for residential or light commercial
buildings. For reinforced or framed structures the limit is 50mm/sec at 4Hz and
above.
Vibration Nuisance
11.2.28 The fact that the human body is very sensitive to vibration can result in
subjective concern being expressed at energy levels well below the threshold
of damage.
11.2.29 Guidance on the human response to vibration in buildings may be found in
British Standard BS 6472-1:2008. Weighting curves related to human
response to vibration of buildings are presented within this document.
Estimates are given on the probability of adverse comment, which might be
expected, from human beings experiencing vibration in buildings. This is
based on a vibration dose value (VDV), assessed from frequency weighted
vibration measurements and based on a 16-hour day and 8 hour night period.
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11.2.30 For the purposes of assessing the potential to cause nuisance the guidance in
BS6472-1:2008 has been used.
11.3 Assessment Methodology
11.3.1 To establish the impact of the Proposed Development in relation to noise on
existing residential areas it is necessary to consider the relevant noise
guidance, standards and policy for an industrial development. The following
section examines the guidance and establishes the methodology to be
adopted for assessing noise and vibration impacts.
11.3.2 The Technical Advice Note ‘Assessment of Noise’ associated with PAN1/2011
gives guidance on what issues relating to Noise Impact Assessments. At
paragraph 2.6 it states: “Issues which may be relevant when considering noise
in relation to a development proposal include:
Type of development and likelihood of significant noise impact;
Sensitivity of location (e.g. existing land uses, Noise Management
Areas, Quiet Areas);
Existing noise level and predicted change in noise level;
Character (tonal, impulsivity etc.), duration, the number of occurrences
and time of day of noise that is likely to be generated; and
Absolute level and possible dose-response relationships e.g. health
effects, if robust data available.”
“When noise impact assessments are being prepared, the recommended
approach is to consider both the likely level of noise exposure at the time of
the application and any increase that may reasonably be expected in the
foreseeable future using the most appropriate parameters. The extent to
which it is possible to mitigate the adverse effects of noise should also be
considered.” (Paragraph 2.7)
Noise and Vibration Assessment Criteria
Construction Noise
11.3.3 For construction noise BS5228 is the appropriate standard. This is an
approved code of practice under the Control of Pollution Act and consequently
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there is a legal requirement for construction noise to be controlled according
to the recommendations given in this standard. The standard places emphasis
upon ensuring that best practical means are adopted to control noise on site.
During the decommissioning phase, similar plant would be utilised and
therefore the same standard would apply.
Road Traffic Noise
11.3.4 Access to the site is via the northern boundary and Whitehill Road, which
utilises the existing access road then connects to the local road network.
Please refer to the Transport Assessment that supports the planning
application for more information.
11.3.5 In order to assess the likelihood of any impact upon existing residential
properties from traffic noise generated by the Proposed Development, noise
calculations have been undertaken using BS5228-1:2009 methodology for on-
site movements and ‘Calculation of Road Traffic Noise’ (CRTN) methodology
for movements on the local road network. The movements on site are too low
for CRTN methodology calculations to be valid.
11.3.6 For existing residents, who may be affected by road traffic noise from the
Proposed Development through increased traffic along the local road network,
the limits referred to in the Design Manual for Roads and Bridges (DMRB)
would be relevant. This is based on an assessment against an 18-hour
daytime average.
11.3.7 The DMRB (May 2008) Part 2 GD 01/08 provides information and advice
principally for Trunk Road works. The guidance states: “It may also be
applicable in part to other roads with similar characteristics. Where it is used
for local road schemes, it is for the local highway authority to decide on the
extent to which the documents in the manual are appropriate in any particular
situation.”
11.3.8 Volume 11, Section 3, Part 7 (HD 213/11) of the DMRB (November 2011)
provides advice on noise and vibration. The procedure for assessing noise
impacts advises the use of a LA10 measurement index based on an 18 hour
time period (i.e. 06:00 to 24:00 hours). Further assessment of the impact
would be required where changes of 1dB(A) or more are expected in the
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short-term and changes of 3dB(A) in the long term. Section 3.37 (of the
DMRB) provides an example of the magnitude of impact for different changes
in noise level for the short-term and long-term situation. Tables 3.1 and 3.2
within Part 7 of the DMRB are provided below, represented as Table 11.3 and
11.4 below.
Table 11.3: Magnitude of Impact for Changes in Road Traffic Noise in the
Short Term
Noise Change, LA10,18hour Magnitude of Impact
0 No Change
0.1-0.9 Negligible
1-2.9 Minor
3-4.9 Moderate
5+ Major
Table 11.4: Magnitude of Impact for Changes in Road Traffic Noise in the
Long Term
Noise Change, LA10,18hour Magnitude of Impact
0 No Change
1.0-2.9 Negligible
3.0-4.9 Minor
5-9.9 Moderate
10+ Major
11.3.9 The impact magnitude scale in Tables 11.3 and 11.4 have been used in the
assessment of operational impacts of the Proposed Development as well as
being relevant to the assessment of road traffic noise.
11.3.10 According to the DMRB Volume 11, Section 3, Part 7 (HD 213/11) (November
2011) the two tables represent the situation related to the opening of a new
road and in the short term the smallest impact that is considered perceptible is
a change of 1dB LA10 18hr. In the longer term (typically 15 years after project
opening) a 3dB LA10 18hr change is considered perceptible.
11.3.11 Reference to Paragraph 3.38 of the DMRB states: “Research into the
response to changes in road traffic noise is largely restricted to daytime
periods. Until further research is available only noise impacts in the long term
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is to be considered and Table 3.2 should be used to consider the magnitude
of noise change at night. However, given the caution with predicting night time
noise levels as traffic flows fall (see 3.24) only those sensitive receptors
predicted to be subject to a Lnight,outside exceeding of 55dB should be
considered. The Lnight,outside of 55dB corresponds to the Interim Target
level specified in the WHO Night Noise Guidelines for Europe.”
Fixed and Mobile Plant Noise
11.3.12 The assessment for fixed industrial noise has been undertaken with reference
to BS4142:2014. The standard indicates that if the level difference between
the background noise and the site rating noise is +5dB(A) or greater then
there may be an adverse impact depending on the context. The rating level
includes any deemed noise character penalty based on tonal, impulsive or
intermittent noise characteristics and the perceptibility of these features.
Consultation
11.3.13 Following extensive consultation with MLC’s EHO and appointed noise
consultant (acting on their behalf), the baseline noise monitoring positions and
methodology and assessment method were agreed.
11.3.14 The Local Authority advised that the noise assessment should be designed to
achieve a design criteria similar to that imposed on the AD Facility located to
the immediate north of the Application Site at Millerhill. The condition relates
to the following limits:
(i) Daytime: Fixed and mobile plant (including site vehicles): 0800-2100
hours 40dB LAeq1hr (free field).
(ii) Evening: Fixed plant: 2100-2300 hours 39dB LAeq1hr (free field)
(iii) Night-time: Fixed plant: 2300-0800 hours 39dB LAeq5mins (free field) and
internal level with windows open of NR25.
(iv) All reversing alarms to be of the broadband type (restricted between
0800-2000 hours).
(v) Construction noise (all site operations): 70dB LAeq12hr (1m façade) `best
practicable means’ applied at all times in accordance with BS5228
guidance.
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(vi) Construction (piling): 75dB LAeq1hr (1m façade), 80dB LA01(1hr) `best
practicable means’ applied at all times in accordance with BS5228
guidance.
(vii) Construction (Community Relations): A community liaison
representative will be appointed to: ensure (a) availability of information
and (b) complaints are dealt with expeditiously.
11.3.15 Although the noise limits detailed in the above condition is shown to be lower
in terms of existing baseline sound levels recently measured at the nearest
Shawfair development plot location, it is understood that the Local Authority
wish to keep similar conditions to those imposed on the permitted AD Facility.
The only modification that is proposed is to the reference times to which the
noise limits apply, as the daytime and night-time periods do not concur with
defined reference times as stated in BS4142 (1997 or 2014 versions) and
BS8233:2014 as being 07:00 to 23:00 hours for daytime and 23:00 – 07:00 for
night-time. This would affect items (i) and (iii) above in paragraph 11.3.14.
11.3.16 The calculation method used in this study is based upon ISO9613:2, noise
propagation model, which takes into account source position, screening
effects, distance and direction in relation to the nearest receptor.
11.3.17 The assessment has used empirical field data taken at other sites in the UK
(having similar plant) to calculate the expected resultant noise contribution at
the nearest property boundary locations during daytime and night-time
operations.
11.3.18 The assessment is based on plant noise levels as outlined in Appendix 11-5
and assumes that a reasonable level of noise amelioration measures have
been included in the design, similar to those outlined in sub-section 11.8.
These measures are intended to minimise noise impacts relative to the
nearest receptor so that any noise characteristics associated with the
Proposed Development are controlled.
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Vibration Criteria
11.3.19 For the purposes of assessing cosmetic damage from construction vibration
(i.e. transient vibration), the following limiting criteria has been chosen in
accordance with BS5228-2: 2009:
For residential or light commercial buildings: Limit of 15mm/sec (4Hz)
increasing to 20mm/sec at 15Hz.
For reinforced/framed structures or industrial and heavy commercial
buildings: Limit of 50mm/sec at 4Hz and above.
11.3.20 For the purpose of assessing cosmetic damage at residential properties, the
following limiting criteria would be considered:
A limiting value for continuous vibration of 5.0mms-1; and
A limiting value for intermittent vibration of 10.0mms-1.
11.3.21 For the purpose of assessing vibration nuisance, BS6472:2008 gives the
vibration dose values which might result in various probabilities of adverse
comment within residential buildings, which is detailed below in Table 11.5.
Table 11.5: Vibration Nuisance according to BS 6472: 2008 based on
VDV
Place and time Low probability of adverse
comment
m.s-1.75
Adverse comment
possible
m.s-1.75
Adverse comment
probable
m.s-1.75
Residential 16hr day 0.2 to 0.4 0.4 to 0.8 0.8 to 1.6
Residential 8hr night 0.1 to 0.2 0.2 to 0.4 0.4 to 0.8
11.3.22 For the assessment of vibration the DMRB guidance advises that initial
screening to consider properties where the level of vibration has the potential
to rise above a level of 0.3mm/sec or an existing background level (above
0.3mm/sec) is predicted to increase. Where this occurs this should be classed
as a change in magnitude of the vibration impact.
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Assessment of Significance
11.3.23 Chapter 3 of the Technical Advice Note associated with PAN 1/2011 provides
the procedure suitable for the situation where you have a new noisy
development affecting a noise sensitive building. For ease of reference, the
procedure is detailed below.
“Example 2: New Noisy Development (incl. commercial and recreation)
Affecting a Noise-Sensitive Building – This example illustrates the procedure
for assessing the noise impact on a residential property where an industrial
development is proposed. The assessment is based on the principles
described in BS 4142:1997: Method of rating industrial noise affecting mixed
industrial and residential areas, but does not adhere to the BS 4142: 1997
method of evaluation.” (Paragraph 3.16)
“Stage 1: Initial Process: BS4142:1997 can be described as a context,
comparison based, noise assessment. The assessment is carried out by
comparing specific noise levels from a source, against appropriate indicators
for the situation without the specific noise source operating or influencing the
ambient noise level. Examples of context comparisons might include
comparing Rating Level (L Ar,Tr) (derived from the Specific Noise Level (L Aeq,T)
with an appropriate character correction, as necessary) with the existing
background noise level L A90,T (The LAeq,T of the Residual Noise Level (L
Aeq,T)) Where the Rating Level, as defined in BS 4142: 1997, exceeds the pre-
existing noise levels this is taken as indicative of the likelihood of adverse
complaints arising.” (Paragraph 3.17)
“With BS 4142:1997 the measured background noise level (L A90,T) is
subtracted from the Rating level (L Ar,Tr) under investigation. Paragraph 9 of
BS 4142:1997 advises that as the difference increases, the likelihood of
complaints increases, and that:
A difference of around 10 dB indicates that complaints are likely
A difference of around 5 dB is of marginal significance.” (Paragraph 3.18)
“If the rating level is more than 10 dB below the measured background noise
level this is a positive indication that complaints are unlikely.” (Paragraph 3.19)
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“In deciding if a significant impact occurs in regard to the assessment of
industrial noise, or noise of an industrial nature, using the methodology of BS
4142 (where appropriate); the Scottish Government consider impacts are
normally not significant (in a quantitative sense only) the difference between
the Rating and background noise levels is less than 5 dB(A), and that usually
the threshold of minor significant impacts is when the difference between the
Rating and background noise levels is at least 5 dB(A); and commonly do not
become sufficiently significant to warrant mitigation until the difference
between the Rating and background noise levels is more than 10 dB(A).”
(Paragraph 3.20)
“In assessing the noise impact from an industrial development, the noise
sensitivity of a receptor is described in terms of the level of exceedance of the
rating level, L Ar,Tr above the background noise level, L A90,T, where the
sensitivities are defined as follows:
Rating Level (L Ar,Tr) - Background (L A90,T) <5 dB(A), the sensitivity is
Low;
Rating Level (L Ar,Tr) - Background (L A90,T) = 5 dB(A), but less than 10
dB(A), the sensitivity is Medium;
Rating Level (L Ar,Tr) - Background (L A90,T) = >10 dB(A), the sensitivity is
High” (Paragraph 3.21)” (Paragraph 3.21).
“Stage 2: Quantitative Assessment – In this example, a quantitative
assessment is based on an estimate of the change in noise level, L Aeq,T
before and after the industrial development is operational. Table 3.4 [i.e. Table
9.6 in this chapter] shows the criteria used to define the magnitude of noise
impacts for this example.” (Paragraph 3.22)
Table 11.6: Assigning Magnitudes of Noise Impact
Magnitude Change in noise level,L Aeq,T dB (After - Before) 1
Major = 5
Moderate 3 to 4.9
Minor 1 to 2.9
Negligible 0.1 to 0.9
No change 0
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Note: 1 when evaluating noise levels for magnitude of impact purposes, all levels should be rounded to 1 decimal point i.e. when the 2nd decimal is 5 or more, round up.
“If the local authority or representative carrying out the assessment considers
that the above assignment of magnitudes of noise impacts is not appropriate for
a particular situation an alternative assessment approach needs to be justified.
In addition, should it be decided that the assessment would be more
appropriately undertaken on the basis of internal levels it must be clearly stated
whether or not the assessment is to be made with the windows open or closed
and reference should be made to the use of internal design standards,
corrected for the character of the noise source being assessed.” (Paragraph
3.23)
“For example, the above magnitude of noise impacts could be derived on the
basis of the ambient noise level, when the development is operational,
exceeding a target noise level that is based on WHO precautionary guideline
levels.” (Paragraph 3.24)
“For a continuous noise source, the recommended WHO precautionary
guideline internal noise levels within dwellings is 35 dB L Aeq,16h for day and
evening periods, this is to avoid critical effects of speech intelligibility and
moderate annoyance, and to avoid sleep disturbance for the night time period
30 dB L Aeq,8h is reported as being representative of the noise level at which the
onset of effects occur, with no, single sound events exceeding 45 dB L Amax,
FAST. The effects on sleep become increasingly more marked at levels of 35 dB
L Aeq,8h and greater. However, the WHO levels are in respect of general
environmental noise and not industrial / commercial in isolation. Therefore, the
nature of the noise requires to be taken into account.” (Paragraph 3.25)
“The World Health Organisation publication entitled Night Noise Guidelines
advises that: considering the scientific evidence on the thresholds of night noise
exposure, as indicated by L night, external noise level, as defined in the
Environmental Noise Directive (2002/49/EC), an external L night of 40 dB should
be the target of the night noise guideline (NNG) noise level to protect the public,
including the most vulnerable groups, such as children, the chronically ill and
the elderly. However, the World Health Organisation also recognises that this is
a very onerous and precautionary noise level, and further advises that a target
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 279
L night, external noise level of 55 dB is recommended as an interim target for the
countries where the NNG cannot be achieved in the short term for various
reasons, and where policy-makers choose to adopt a stepwise approach.”
(Paragraph 3.26)
“Stage 3: Qualitative Assessment: The derivation of the magnitude of impact
as described above may not be adequate. This is because the magnitude of
impacts based on changes in noise level alone will be dependent on a number
of factors including the nature of the noise source, in particular, the spectral
content of the noise source and its absolute level. In addition, the period of the
day will be a further factor that needs careful consideration in assigning
magnitudes of noise impacts.” (Paragraph 3.27)
“Stage 4: Level of Significance: The level of significance of the noise impacts
from the industrial development on the residential property is then determined
from Table 3.5 [i.e. Table 11.7 in this chapter].”
Table 11.7: Significance of Effects
Magnitude of Impact (After - Before) L Aeq,T dB
Sensitivity of Receptor based on likelihood of complaint x = (Rating (L Ar,Tr) - Background (L A90,T)) dB
Low (x < 5) Medium (5 = x < 10) High (x =10)
Major (=5) Slight/Moderate Moderate/Large Large/Very Large
Moderate (3 to 4.9) Slight Moderate Moderate/Large
Minor (1 to 2.9) Neutral/Slight Slight Slight/Moderate
Negligible (0.1 to 0.9) Neutral/Slight Neutral/Slight Slight
No change (0) Neutral Neutral Neutral
“The sensitivity of the receptor is based on the likelihood of complaint as
determined by the difference between the Rating level and the background
noise level. The sensitivity of the receptor to noise increases from 'Low' to 'High'
as the probability of complaint increases. The level of significance depends on
the difference in noise levels as determined by the magnitude of the impact and
the sensitivity of the receptor as determined by the probability of complaint.”
(Paragraph 3.28)
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 280
“Stage 5: The Decision Process: Depending on the outcome of the
assessment, the decision making process would take into account the level of
significance of the noise impact on the property according to:
Very Large: These effects represent key factors in the decision-making
process. They are generally, but not exclusively associated with impacts
where mitigation is not practical or would be ineffective.
Large: These effects are likely to be important considerations but where
mitigation may be effectively employed such that resultant adverse
effects are likely to have a Moderate or Slight significance.
Moderate: These effects, if adverse, while important, are not likely to be
key decision making issues.
Slight: These effects may be raised but are unlikely to be of importance
in the decision making process.
Neutral: No effect, not significant, noise need not be considered as a
determining factor in the decision making process.” (Paragraph 3.29)
11.3.24 The impact magnitude scale in Table 11.6 has been used in the assessment
of operational noise and road traffic noise (refer to Tables 11.3 and 11.4). The
impact scale in relation to construction or decommissioning noise is slightly
different as this type of noise is of a temporary nature and therefore the
magnitude of impact is different.
11.3.25 Table 11.8 over the page shows the impact scale used to assess construction
and de-commissioning noise. The construction impact semantic scale is
based on the ABC method of assessment, which sets out threshold values
depending upon the ambient noise at receptors, which have been defined
from the baseline sound survey.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 281
Table 11.8: Impact Magnitude Category: Construction and De-
commissioning Noise
Threshold Value
LAeq dB
Time of Day Change in total noise level above threshold dB(A) [i.e. ambient + construction noise]
Impact Magnitude
65
55
45
Daytime (0700-1900)
Evening (1900-2300) or weekend
Night-time (2300-0700)
0 or lower No significant
impact (negligible)
65
55
45
Daytime (0700-1900)
Evening (1900-2300) or weekend
Night-time (2300-0700)
+0.1 to +3.0 Slight
65
55
45
Daytime (0700-1900)
Evening (1900-2300) or weekend
Night-time (2300-0700)
+3.1 to +9.9 Moderate
65
55
45
Daytime (0700-1900)
Evening (1900-2300) or weekend
Night-time (2300-0700)
+10.0 or more Substantial
Note: Construction or de-commissioning noise is a temporary noise source and whilst peak noise events may exceed +10dB(A) above the threshold during peak noise events, the nature of the impact is unlikely to produce anything greater than a moderate change in noise levels due to its temporary nature. However the application of `best practice’ would be followed in this situation to mitigate effects.
11.3.26 The impact magnitude categories applied to the assessment of ground
vibration are described in Table 11.9 below.
Table 11.9: Impact Significance Category: Ground Vibration
Vibration Level
(mm.s-1
)
Subjective Response
(Residential)
Impact Magnitude Significance Level
0.14 to 0.29 Imperceptible to Barely perceptible Negligible Neutral
0.3 to 0.99 Just perceptible Minor Slight
1.0 to 4.99 Noticeable Moderate Moderate
5 to 14.99 Potential cosmetic damage (continuous vibration)
Major Large
15 or more Potential structural damage (continuous vibration) Potential cosmetic damage
(transient vibration)
Substantial Very Large
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 282
Ground Vibration – Fixed Plant and Mobile Plant
11.3.27 Measurements of ground borne vibration from empirical data obtained from
measurements at a waste, construction and a Biomass site have been
referred to for an indication of ground borne vibration levels from HGVs,
mobile plant and fixed plant. Definitions of all vibration measurement
parameters noted during the survey are presented in Appendix 11-7.
11.3.28 Vibration measurements were made, in the three mutually perpendicular axes,
during the monitoring period. The seismograph monitored the ground borne
vibration in terms of Peak Particle Velocity (PPV). Further detail of the
vibration surveys are provided in Appendix 11-8.
Limitations
11.3.29 Measurement of prevailing background sound levels has involved monitoring
over the quietest likely daytime and night-time periods (i.e. weekend period) to
represent a ‘worst case’ scenario. Monitoring involved the use of both fixed
monitoring positions and also spot roaming ‘round robin’ measurements where
access and security of equipment was an issue. This methodology was
agreed with the Local Authority and the assessment is therefore deemed to be
robust in its assessment of impacts.
11.4 Baseline
11.4.1 As previously stated, the assumed baseline for the EIA includes the AD
Facility to the immediate north, Borders Railway and the SNCD. Further
details regarding this approach can be found in Chapter 2.0 of this ES.
11.4.2 As these developments are not yet operational, their contribution to
background noise levels has, self-evidently, not been included within the
background noise modelling.
11.4.3 In order to provide a robust assessment, it has been assumed that these
developments would not have any effect on the measured existing
background and residual sound levels. Additionally, due to the lack of
available detail in respect of the future development of plots on Shawfair, it
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 283
has been assumed that the residential receptors are built up to the site
boundary, which represents a worst case basis for assessment.
11.4.4 Both of these assumptions enable a worst case assessment to be undertaken
in relation to BS4142:2014, BS8233:2014 and in terms of impact magnitude.
In reality the AD Facility, Borders Railway and the SNCD would contribute to
the background sound climate, thereby reducing the predicted impacts from
the Proposed Development.
Baseline Data Collection
11.4.5 The background sound survey was carried out in accordance with BS4142
(1997 or updated version in October 2014 as appropriate) and advice given in
BS 7445:2003 Description and measurement of environmental noise.
11.4.6 A detailed environmental sound survey was carried out at the site to
determine details of the noise climate at the nearest residential properties to
provide typical background sound data. The site inspection and detailed
baseline survey was carried out on Saturday 24th May through to Monday 26th
May 2014 and Saturday 17th January to Monday 19th January 2015.
11.4.7 Fixed position and spot roaming noise measurements were undertaken at
nearest receptor locations to establish representative background levels
relative to the existing noise climate.
11.4.8 Following consultation with the EHO and their appointed noise consultant at
MLC, the areas surrounding the site were examined and the following suitable
locations for noise monitoring were established:
NMP1 (Harelaw Farm): General ambient noise was associated with
birdsong, distant road traffic noise, occasional aircraft noise, and
occasional distant train noise and dog barking.
NMP2 (Old Craighall): Noise observed at this location related to local
and distant road traffic noise and birdsong.
NMP3 (Whitehall Mains): This location is relatively close to the A1 road
and is therefore dominated by road traffic noise. During late night
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 284
periods low level noise from train engine `tick-over’ was just audible
from the rail sidings.
NMP4 (Newton Cottages): Noise observed at this location relates to
local and distant road traffic movement. During early morning periods on
the Monday goods train movement was also audible.
Position 1: Position 1 is west of the Application Site on existing
farmland and on higher ground. Noise observed at this location during
the evening and night-time periods related to distant road traffic noise
and birdsong. Noise from the railway sidings was just audible on
occasions as a low level `engine’ type noise.
Position 2: Position 2 was located at the closest accessible approach to
the Application Site in a westerly direction. The noise climate at this
location was dominated by distant road traffic noise, with occasional
noise from high level aircraft and birdsong during evening periods and
occasional noise from train engine tick-over’ emanating from the existing
rail sidings to the south east of the Application Site. This position was
only accessible during the 2015 survey due to railway construction
works and available access to this part of the Application Site.
Position 3: Position 3 is south of the Application Site in the field north of
Old Craighall Road and the background sound is formed by distant road
traffic noise, birdsong and occasional train movements.
Position 4: Monitoring at the newly constructed railway line bridge was
only possible during the Sunday evening period in the 2014 survey due
to the influence of local lighting generators on site and the noise climate
was observed to be formed by distant road traffic noise, birdsong and
occasional distant train noise.
Position 5: Position 5 is located towards the end of the access road
leading to the newly constructed railway bridge off Millerhill Road. Noise
levels at this location are formed by distant and local road traffic and
birdsong during the evening and night-time periods.
Position 6: Monitoring at position 6 at the opposite end of the access
road leading to the railway bridge included one measurement during
Sunday evening in the 2014 survey with distant road traffic and birdsong
was audible.
Position 7: This static monitoring position is southwest of the
Application Site on relatively low lying land and is generally dominated
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 285
by distant road traffic noise and birdsong during the evening and distant
road traffic noise during night-time periods. This position was chosen in
the 2014 survey which was one of the nearest accessible positions to
the Application Site boundary (access was limited due to railway
construction works).
Position 8: The spot roaming measurement position was chosen as
being the closest approach to the Application Site during the 2014
sound survey. The noise climate was formed by distant road traffic
noise. During the bank holiday night-time period there was very little
road traffic movement along the A1 road which resulted in unusually
lower background sound levels compared with typical weekend periods.
11.4.9 The sound monitoring positions are indicated on Figure 11.1. The monitoring
positions are representative of residential properties adjacent to the
development.
11.4.10 The fixed monitoring positions provide broadband noise data of the existing
noise climate around the site at the nearest residential properties.
11.4.11 The initial monitoring exercise was carried out over a bank holiday Sunday
morning through to early hours of Bank Holiday Monday morning which was
used to establish the worst case baseline. To establish the typical ambient
noise climate (i.e. representative baseline as required by BS4142: 2104) an
additional survey on a Saturday into Monday morning period was undertaken.
Details of the instrumentation used for the surveys are detailed in Appendix
11-2.
Baseline Conditions
Site Baseline Noise Survey
11.4.12 The results of sound measurements taken at the fixed monitoring positions at
site are presented in Tables 11.10 to 11.14 (over the page) and detailed
measurements in Appendix 11-3.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 286
Table 11.10: Baseline Sound Levels at Monitoring Positions (Saturday Daytime)
Position Time Period (Year) LAeq
dB
LA10
dB
LA90
dB
LAmax
dB
Representative
Daytime (complete survey
period) LA90 dB
P1.West of site (Shawfair zone B)
Daytime (bank holiday 2014)
Daytime (weekend 2015)
46
47
48
45
44
42
55-58
47-79
44
41
P2.Western boundary (zone D)
Daytime (weekend 2015) 48 47 42 52-84 41
P3.South of site
(zone R)
Daytime (bank holiday 2014)
47
48
44
49-66
45
P6. Southwest of site
(access road to bridge)
Daytime (bank holiday 2014)
47
52
45
61-68
45
P7. Southwest of site
(zone A)
Daytime (bank holiday 2014) 50 51 46 51-82 45
NMP1: Harelaw Farm Daytime (bank holiday 2014) 47 49 43 56-63 47
NMP2: Old Craighall Daytime (bank holiday 2014) 59 60 54 76-78 54
NMP3: Whitehall Mains Daytime (bank holiday 2014) 55 57 52 62-65 50
NMP4: Newton Cottages Daytime (bank holiday 2014) 57 58 53 73-79 53
Table 11.11: Baseline Sound Levels at Monitoring Positions (Sunday Daytime)
Position Time Period (Year) LAeq
dB
LA10
dB
LA90
dB
LAmax
dB
Representative
Daytime (complete survey period)
LA90 dB
P1.West of site (Shawfair zone B)
Daytime (bank holiday 2014)
Daytime (weekend 2015)
49
49
50
49
47
45
55-61
49-82
44
41
P2.Western boundary (zone D)
Daytime (weekend 2015) 50
50 46 54-89 41
P3.South of site
(zone R)
Daytime (bank holiday 2014)
Daytime (weekend 2015)
49
47
50
47
46
43
44-69
49-74
45
45
P4.Southwest of site
(Bridge)
Daytime (bank holiday 2014)
Daytime (weekend 2015)
52
46
53
47
50
41
57-72
52-65
50
41
P5.Southwest of site
(zone P)
Daytime (bank holiday 2014)
Daytime (weekend 2015)
48
44
50
46
45
40
56
53-57
45
40
P6. Southwest of site
(access road to bridge)
Daytime (weekend 2015) 51 52 42 54-66 42
P7. Southwest of site
(zone A)
Daytime (bank holiday 2014) 54 53 47 53-86 45
NMP1: Harelaw Farm
Daytime (bank holiday 2014)
Daytime (weekend 2015)
48
46
51
47
44
43
56-62
52-55
44
43
NMP2: Old Craighall Daytime (bank holiday 2014) 56 56 50 73-76 50
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 287
Daytime (weekend 2015) 59 63 53 68-69 54
NMP3: Whitehall Mains Daytime (bank holiday 2014)
Daytime (weekend 2015)
52
46
54
48
49
43
61-63
50-55
49
43
NMP4: Newton Cottages Daytime (bank holiday 2014)
Daytime (weekend 2015)
54
57
56
60
51
50
61-64
63-68
51
49
Table 11.12: Baseline Sound Levels at Monitoring Positions (Monday Daytime)
Position Time Period (Year) LAeq
dB
LA10
dB
LA90
dB
LAmax
dB
Representative
Daytime (complete survey
period) LA90 dB
P1.West of site (Shawfair zone B) Daytime (weekend 2015) 48 48 45 58-68 41
P2.Western boundary (zone D) Daytime (weekend 2015) 50 50 46 56-84 41
P3.South of site (zone R) Daytime (weekend 2015) 49 50 47 55-65 45
Table 11.13: Baseline Sound Levels at Monitoring Positions (Saturday – Sunday Night-time)
Position Time Period (Year) LAeq
dB
LA10
dB
LA90
dB
LAmax
dB
Representative night (complete survey period)
LA90 dB
P1.West of site (Shawfair zone B) Night (bank holiday 2014)
Night (weekend 2015)
44
41
46
43
42
39
53-62
45-65
42
38
P2.Western boundary (zone D) Night (weekend 2015) 44 46 42 47-61 41
P3.South of site (zone R) Night (bank holiday 2014)
Night (weekend 2015)
45
42
47
44
43
39
45-58
49-65
41
40
P7. Southwest of site (zone A) Night (bank holiday 2014) 51 53 46 48-73 46
NMP1: Harelaw Farm Night (bank holiday 2014) 45 46 42 56-58 42
NMP2: Old Craighall Night (bank holiday 2014) 53 54 49 64-74 47
NMP3: Whitehall Mains Night (bank holiday 2014) 50 53 46 60-64 46
NMP4: Newton Cottages Night (bank holiday 2014) 49 51 45 64-69 45
Table 11.14: Baseline Sound Levels at Monitoring Positions (Sunday – Monday) Night-time
Position Time Period (Year) LAeq
dB
LA10
dB
LA90
dB
LAmax
dB
Representative night-time
(complete survey
period) LA90 dB
P1.West of site (Shawfair zone B)
Night (bank holiday 2014)
Night (weekend 2015)
38
41
38
42
34
39
52-54
43-81
34*
38
P2.Western boundary (zone D) Night (weekend 2015) 45 46 42 48-67 41
P3.South of site
(zone R)
Night (bank holiday 2014)
Night (weekend 2015)
37
41
39
41
35
37
40-46
43-65
41
40
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 288
P4.Southwest of site (Bridge) Night (weekend 2015) 39 41 36 46-52 36
P5.Southwest of site (zone P) Night (weekend 2015) 42 44 39 45-58 39
P6. Southwest of site
(access road to bridge)
Night (weekend 2015) 47 49 40 52-66 39
P7.Southwest of site (zone A) Night (bank holiday 2014) 38 39 35 38-59 46
NMP1: Harelaw Farm
Night (bank holiday 2014)
Night (weekend 2015)
41
35
39
37
35
33
48-69
38-43
35
33
NMP2: Old Craighall
Night (bank holiday 2014)
Night (weekend 2015)
46
56
45
51
37
42
50-71
72-79
39
42
NMP3: Whitehall Mains Night (bank holiday 2014)
Night (weekend 2015)
40
42
41
43
36
38
53-61
48-56
35
38
NMP4: Newton Cottages Night (bank holiday 2014)
Night (weekend 2015)
43
56
47
49
39
43
56-60
66-83
39
43
*Note: This is based on limited set of readings during a quiet bank holiday period and not deemed to be ‘representative’ of typical baseline sound climate.
11.4.13 The results of baseline sound measurements taken at the fixed and spot
roaming monitoring positions in the vicinity of the Application Site during
daytime and night-time periods are summarised in Table 11.15 below.
Table 11.15: Summary of Representative Noise Levels in accordance with
BS4142:2014
Location Representative
Daytime
LA90 dB
Daytime
LAeq
dB
Representative
Night-time
LA90 dB
Night-time
LAeq
dB
P1.West of site (Shawfair zone B) 41 48 38 42
P2.Western boundary (zone D) 42 49 42 45
P3.South of site (zone R) 45 48 40 44
P4.Southwest of site (Bridge) 45* 50 36* 39
P5.Southwest of site (zone P) 40* 44 39* 42
P6. Southwest of site
(access road to bridge)
44* 50 43* 48
P7. Southwest of site (zone A) 45 53 46 50
NMP1: Harelaw Farm 42* 46 37* 42
NMP2: Old Craighall 50* 58 42* 52
NMP3: Whitehall Mains 49* 53 39* 46
NMP4: Newton Cottages 50* 55 42* 52
*Note: Levels are averaged due to spread of data and limited data set.
11.4.14 From the results of the background noise survey and observations at the
nearest residential receptors, it is clear that the noise climate is dominated by
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 289
local and distant road traffic noise (i.e. along A1(T) and the local road network)
and intermittent aircraft and occasional train noise from the rail sidings.
PPiP Future Baseline Scenario
11.4.15 The noise impacts predicted for the ZWF development indicates that the noise
levels from the development would not exceed background sound levels +5dB
and the combined effect of the AD Facility, EfW Facility and MBT Facility
would not exceed a design limit of background sound +5dB. The resultant
conclusion in terms of residual noise was a negligible to minor adverse impact
magnitude.
11.4.16 The Local Authority has sought to control the ZWF development through a
noise condition to ensure the residual impact is achieved.
Ground Vibration
11.4.17 Measurements of ground borne vibration from empirical data obtained from
measurements at a energy from waste facility, construction site, Waste
Management Facility (WMF) and HGVs travelling along a busy main road
have been referred to for an indication of ground borne vibration levels similar
to plant and vehicles proposed for the Millerhill RERC. Definitions of all
vibration measurement parameters noted during the survey are presented in
Appendix 11-7.
11.5 Assessment of Effects
Incorporated Mitigation
11.5.1 The Local Authority are able to impose planning conditions on any planning
permission to ensure that the planning guidance noise limits for daytime and
night-time operations is achieved.
11.5.2 Whilst this can be achieved by mitigation, it must be noted that this
assessment considers one method of treatment. There are a number of
different ways in which the criteria can be achieved, for example, the use of
noise control at source and / or the selection of different plant equipment,
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 290
which may be quieter, can be investigated. The chosen method(s) of
mitigation should be appropriate to meet the noise criteria and the application
of BAT.
11.5.3 The predicted noise levels from the Proposed Development have been
calculated using the noise levels provided within Appendix 11-5. The noise
levels are based on empirical test data provided by the technology provider
and include the following inherent mitigation measures:
(i) Building constructed from single skin cladding.
(ii) Air cooled condenser fans each operating at a sound power level of
89dBW.
(iii) Fan stack designed to a sound power level of 88dBW at end of stack.
(iv) Ventilation louvres attenuated to same level as the cladding acoustic
performance.
(v) Doors closed except for access to vehicles for offloading and collection
unless for maintenance or emergency.
(vi) Sound power levels of plant as detailed in Appendix 11-5.
Construction Phase
Noise
11.5.4 Initial site preparation works is likely to involve the movement of soils and the
construction of new buildings and infrastructure. It is considered that
excavators, haulage lorries, piling rigs, cranes, dumpers, concrete mixers,
diggers and paving machines would all, at some time during the construction
programme, be operating at the site. In addition, ancillary equipment such as
small generators and compressors may also be operating on occasions during
the construction period.
11.5.5 The above noise sources and their associated activities would vary from day
to day and may be in use at different stages of the Proposed Development for
relatively short durations. The noisiest activities are expected to be generated
during soil movement and piling work during the initial stages of the Proposed
Development when excavators, piling rigs, dozers or similar may be in use.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 291
11.5.6 The actual noise level produced by construction work would vary at the
nearest property boundary at any time depending upon a number of factors
including the plant location, duration of operation, hours of operation,
intervening topography and type of plant being used. Refer to Appendix 11-4
for construction plant inventory.
11.5.7 Detailed below is an indication of the highest likely noise levels at the nearest
receptors during different site activities. The calculations use the calculation
methodology given in BS5228-1: 2009.
11.5.8 The results of calculations (excluding mitigation measures) are shown in Table
11.16 below.
Table 11.16: Noise Predictions for Highest Likely Construction and
Decommissioning Noise for existing residential receptors
Position Distance
to
receptor
(m)
Activity Noise
Level, dB
LAeq 1hr
Typical
Residual
Noise LAeq
dB
Total noise
(residual +
constructi
on)
LAeq dB
BS5228
Threshold
Value LAeq
dB
(daytime)
R1 South West (NMP1)
660-720 Site Preparation Piling
General activities
Infrastructure
Building Constr
43-45
45-46
39-41
36-38
45-47
46 48-49
49
47
46-47
49-50
65
R2 South East (NMP2)
990-1150 Site Preparation Piling
General activities
Infrastructure
Building Constr
41-42
42-44
37-38
34-35
41-42
58 58
58
58
58
58
65
R3 North West (NMP3)
400-640 Site Preparation Piling
General activities
Infrastructure
Building Constr
46-50
47-51
42-46
39-43
46-50
53 54-55
54-55
53-54
53-54
54-55
65
R4 South (NMP4)
820-980 Site Preparation Piling
General activities
Infrastructure
42-44
44-45
38-40
55 55
55
55
65
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 292
Building Constr 35-37
42-43
55
55
R5 West
370-500 Site Preparation Piling
General activities
Infrastructure
Building Constr
48-50
50-52
44-47
41-44
48-50
48 51-52
52-53
49-51
49-50
51-52
65
R6 Western boundary (area D of Shawfair development)
40-200 Site Preparation Piling
General activities
Infrastructure
Building Constr
49-78
57-71
52-66
49-63
56-70
50 53-78
58-71
54-66
53-63
57-70
65
11.5.9 For the Proposed Development, the highest noise levels are likely to be
created during piling and building construction activities. The movement of soil
may be part of the initial site preparation works and it is unlikely that any other
significant sources of noise would be present on the site while these activities
were being carried out.
11.5.10 The increase in noise, as a result of construction, is likely to result in an
impact magnitude classification of negligible resulting in a neutral magnitude
impact significance at all receptors except the potential nearest receptor in
Shawfair area D, which indicates under worst case noise conditions to be
substantial impact without mitigation.
11.5.11 The application of applying best practice in accordance with BS5228:2009 will
assist in minimising impact from construction noise. As a result, the
assessment of impact magnitude from construction noise concludes that there
would be a neutral effect at all receptors except the potential receptor at
Shawfair development area D where worst case impacts could be of
moderate impact magnitude. It should be noted however that this assessment
assumes (in accordance with the baseline for assessment) that Shawfair Area
D development would be implemented and occupied as a sensitive receptor
prior to the commencement of construction works. The reality is that the
development within Shawfair area D is not expected to commence until after
the Proposed Development has been constructed. Therefore these
construction related noise issue would only actually be expected to occur
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 293
during the decommissioning phase. Accordingly, the predicted impact for
construction is deemed to be robust and pessimistic.
Construction Road Traffic Noise
11.5.12 Table TA6.1 of the Transport Assessment details the baseline traffic flows and
construction traffic demand for the Proposed Development.
11.5.13 The following table provides details of the impact due to the increased traffic
flow along the local road network. The dwelling positions off Whitehill Road
are the most sensitive receptors to any direct traffic flow increase.
Table 11.17: Predicted Change in Road Traffic Noise on local road
network during 24 hours due to construction works
Road Baseline noise
level
(no development)
LAeq24hours (dB)
Predicted noise
level LAeq24hours
(dB)
Change
(with development)
LA1018 hours
(dB)
A6095 Newcraighall Rd / The Wisp 69.5 69.6 +0.1
Fort Kinnaird Main Western R’bout 67.0 67.2 +0.2
Fort Kinnaird Main Eastern R’bout 67.2 67.3 +0.1
Whitehill Road / Redcroft Cottage Jnt 59.6 60.2 +0.6
A1 Interchange Western Jnt 69.2 69.3 +0.1
* The predicted noise levels are based on a notional 10m distance from the kerbside.
11.5.14 The results show no significant change in noise levels during daytime
operations in respect of traffic movements relative to the nearest local road
network and residential properties. In terms of the DMRB guidance, an
increase of <1dB(A) is negligible.
Construction Mitigation – Noise
11.5.15 In accordance with BS5228, best practical means would be employed to
control the noise generation (e.g. using equipment that is regularly
maintained, where practicable use equipment fitted with silencers or acoustic
hoods).
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 294
11.5.16 In consideration of the likely highest levels of construction noise, the following
approach would be considered as part of any CEMP:
Introduce any proposed operational boundary screening at the start of
the construction phase so that it provides additional screening benefits
during the construction phase.
Restriction of construction hours to non-sensitive times of day would
normally form part of the planning consent conditions.
Sensible routing of the construction plant to avoid the nearest residential
properties (where practicable).
Careful choice of piling rigs to minimise noise.
Avoid un-necessary plant operation and revving of plant or vehicles.
Locate plant away from nearest sensitive receptors or in locations which
provide good screening in the direction of sensitive receptors.
Use of broadband noise reverse alarms (where practicable) on mobile
plant.
Decommissioning Phase Effects – Noise
11.5.17 The decommissioning phase would involve dismantling, demolition and the re-
instatement of the site. The equipment used during the decommissioning
phase is likely to involve similar equipment to that described for the
construction phase (e.g. bulldozers, excavators, HGVs, dumpers,
compressors, generators etc). There are also likely to be concrete breakers
and crushers required to break-up the concrete foundations as part of the
decommissioning phase. The predicted noise levels during concrete removal
at receptors are not anticipated to be any higher than that predicted for piling
activities during the construction phase. The increase in noise, as a result of
decommissioning, is therefore likely to result in an impact magnitude
classification with noise mitigation measures to be negligible during general
and peak noise periods at all receptors except the potential Shawfair
Development Area D where impacts are likely to be of moderate impact
magnitude.
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Construction or De-commissioning Phase: Vibration
Typical Vibration Levels
11.5.18 The highest levels of vibration generated by Plant is likely to include the
following:
Piling rigs;
Vibratory rollers and compactors;
Material offloading onto hard surfaces; and
Concrete vibratory plant.
11.5.19 Typical field measurements taken at sites in the UK where piling or vibratory
rollers have been used (on clay-based ground, which is likely to be the highest
likely generated vibration) would indicate that at a distance of around 20
metres the peak particle velocity is around 14 – 17mm/s reducing to 1.5 to 2
mm/s at 30 metres distance and <1mm/s at 50 metres. For vibro piling
measured levels of vibration are shown to be between 1mm/sec and 3mm/s at
a distance of between 20 to 30 metres (ref. BS5228-2: 2009 Table D4).
BS5228:2009 Part 2: Vibration
11.5.20 Part 2 of the Standard deals with vibration from construction and open sites
and provides information on the effects of the levels of vibration, human and
structural response, response limits of structures and practical measures to
reduce vibration.
11.5.21 The distance from nearest residential receptors to any likely use of piling rigs
(i.e. building foundation construction) and vibratory compaction (i.e. during
road construction) is likely to exceed a distance of 400 metres based on the
nearest existing receptors. The potential sensitive receptors at the Shawfair
Development Area D are likely to be approximately 50m from piling under the
worst case scenario. The distance to any existing commercial or industrial
buildings would also be in excess of 150 metres (i.e. relative to the AD
facility).
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Conclusion
11.5.22 Based upon the above information, it is clear that even at the closest
approach to existing residential properties, the likely levels of ground-borne
vibration would be well below the limiting value for continuous vibration of 5.0
mm/s for cosmetic damage and also below perceptible levels of vibration (i.e.
0.3mm/s) at all receptors except the potential receptor at Shawfair Area D
where vibration levels are likely to be <1mm/sec. The levels of vibration at the
closest approach to existing industrial/commercial buildings would be greater
than 150 metres. It is unlikely therefore for vibration to be perceptible within
the nearest industrial / commercial buildings and certainly well below threshold
levels where cosmetic or structural damage occurs. The results of empirical
measurements of vibration from vibratory plant at distances greater than 30
metres according to BS6472:2008 would indicate that the vibration levels are
unlikely to give rise to an ‘adverse comment’ from a nuisance aspect.
11.5.23 It should be noted that the type of equipment, ground conditions and structural
form could all affect the resultant level of vibration. At this stage, it has been
assumed that the highest likely vibration level scenario occurs (i.e. a
conservative estimate of potential effects).
11.5.24 It is also normal practice to monitor the vibration levels during initial periods of
construction (e.g. where piling or vibration compaction equipment is being
used) if the activity is within 30-50 metres of a residential or commercial
property.
11.5.25 The levels of vibration, as a result of construction, are likely to result in an
impact magnitude classification of negligible to minor and a significance
level of neutral to slight during general and peak vibration. The highest
vibration levels would be at the nearest receptor (i.e. residential properties at
Shawfair Area D) but it is not anticipated to be significant. Use of concrete
breaking plant, dozers, mobile plant, cranes and excavators during any de-
commissioning phase are unlikely to generate any significant vibration and
impacts under a worst case scenario are predicted to be negligible to minor
and a neutral to slight impact significance.
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Operational Phase
Plant Noise
11.5.26 Tables 11.18 and 11.19 show the highest likely noise prediction relating to
fixed and mobile plant noise sources operating during daytime and fixed plant
noise sources during night-time periods at the Proposed Development. This
assumes that the development includes inherent noise control measures
similar to those outlined previously in this sub-section.
Daytime Operations
11.5.27 Table 11.18 over the page provides information on the predicted noise levels
during daytime operations at the Proposed Development.
Table 11.18: Predicted Noise Contribution from the RERC and HGV movement
(including inherent noise control measures) during Daytime
Receptor Position
(Refer to Figure 11.1)
Time Period Predicted Noise
Contribution from Site
LAeq1hr dB
Representative
Background Noise level
without site
LA901hr dB
[LAeq]
Rating compared
to background
noise LAeq1hr dB
Noise change
(after & before)
LAeq dB
R1 South West (NMP1) Daytime 28 42 [46] -14 0
R2 South East (NMP2) Daytime 27 50 [58] -23 0
R3 North West (NMP3) Daytime 27 49 [53] -22 0
R4 South (NMP4) Daytime 29 50 [55] -21 0
R5 West Daytime 31 41 [48] -10 0
R6. Western boundary (area D of Shawfair
development)
Daytime 39-44 42 [49] * 0 to +5 0 to +1.2
Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment an allowance of +3dB has been added for R6 due to proximity to the Site. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.
11.5.28 The predicted noise levels are for site attributable noise with the inherent
noise control measures. The fifth column in Table 11.18 shows the difference
between the predicted site noise and typical background noise at the receptor
positions. The Proposed Development would be designed to eliminate any
unusual noise characteristics. The rating level in column 5 is therefore in
accordance with the methodology found within BS4142:2014, which is the
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most relevant noise criterion. For the closest receptor (R6) a +3dB penalty is
added to allow for intermittent noise sources, which may occur during the
daytime.
11.5.29 Using the PAN1/2011 tables to establish the noise impact (i.e. refer to Tables
11.6 and 11.7) the sensitivity of the receptors is low to medium. The
magnitude of the impact during daytime periods based on the quantitative
assessment shows that the change in noise level ranges between zero and
+1.2dB LAeq and therefore shown to be no change to minor impact. The
level of significance according to PAN1/2011 is neutral to slight.
11.5.30 According to BS4142: 1997, the rating level relative to background noise
would indicate complaint is unlikely at all positions. The operational noise
impacts from the Proposed Development are therefore not considered to
represent any significant impact. In terms of BS4142: 2014 the impact is likely
to be low to adverse impact without further mitigation.
11.5.31 In relation to the noise condition proposed by the Local Authority during pre-
application discussions, this would be exceeded at position 6, which is the
closest potential receptor on the Shawfair development. Further noise
mitigation measures are therefore proposed in sub-section 11.6.
Night-time Operations
11.5.32 Table 11.19 below provides information on the predicted noise levels during
night-time activities (i.e. site operational without the receipt of waste and HGV
movement).
Table 11.19: Predicted Noise Contribution from the RERC (including inherent
noise control measures) during Night-time
Receptor Position
(Refer to Figure 11.1)
Time Period Predicted Noise Contribution from Site
LAeq1hr dB
Representative
Background Noise level
without site
LA901hr dB
[LAeq]
Rating compared to background noise LAeq1hr dB
Noise change
(after & before)
LAeq dB
R1 South West
(NMP1)
Night-time 27 37 [42] -10 0
R2 South East
(NMP2)
Night-time 27 42 [52] -15 0
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Receptor Position
(Refer to Figure 11.1)
Time Period Predicted Noise Contribution from Site
LAeq1hr dB
Representative
Background Noise level
without site
LA901hr dB
[LAeq]
Rating compared to background noise LAeq1hr dB
Noise change
(after & before)
LAeq dB
R3 North West
(NMP3)
Night-time 27 39 [46] -12 0
R4 South
(NMP4)
Night-time 29 42 [52] -13 0
R5 West
Night-time 31 38 [42] -7 0
R6. Western
boundary (area D
of Shawfair
development)
Night-time 42-44 42 [45] 0 to +2 +1.8 to +2.5
Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment no noise characteristic penalties are deemed to be appropriate. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.
11.5.33 Using the PAN1/2011 tables to establish the noise impact (refer to Tables
11.6 and 11.7) the sensitivity of the receptors is shown to be low. The
magnitude of the impact during night-time periods based on the quantitative
assessment shows that the change in noise level ranges between 0dB and
+2.5dB LAeq and therefore shown to be no change to minor impact. The
level of significance according to PAN1/2011 is neutral to slight.
11.5.34 According to BS4142:1997, the rating level relative to background noise would
indicate complaint is unlikely at all positions. The operational noise impacts
from the facility are therefore not considered to represent any significant
impact. In terms of BS4142: 2014 the impact is likely to be low to adverse
impact without further mitigation.
11.5.35 In relation to the noise condition proposed by the Local Authority during pre-
application discussions, this would be exceeded at position 6, which is the
closest potential receptor on the Shawfair development. Further noise
mitigation measures are therefore proposed in sub-section 11.6.
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Frequency Analysis
11.5.36 The predicted noise level in terms of frequency spectra compared with the
proposed internal room noise limit proposed by MLC is provided in Table
11.20 below.
11.5.37 The internal noise levels are predicted based on an open window (i.e. 15dB(A)
reduction as assumed in WHO guidance and BS8233: 2014) for comparison
with a limit of NR25 night-time..
Table 11.20: Comparison of RERC Predicted Noise Levels (inside dwellings) and
NR Night-time Noise Limits
Position Night- time
NR25
Noise limits – Octave band frequencies (Hz)
63 125 250 500 1k 2k 4k
55 44 35 29 25 22 19
R6. Western boundary with Shawfair development
48 39 31 24 21 20 8
11.5.38 The above table indicates that the internal noise limits would be achieved. The
external levels at the receptor are predicted to be approximately NR33.
Road Traffic Noise
11.5.39 The waste delivery demand would be spread across the daytime delivery
window which would be between 0800 and 2000 hours. According to the
Transport Assessment: “The maximum operation of the Proposed
Development could be anticipated to generate of the order of 128 HGV
movements on an average day (64 arrivals / 64 departures).”
11.5.40 The TA considers the PPiP for the ZWF with the traffic demand from the
Proposed Development and cumulative operation of the AD Facility. The
assessment concludes that the maximum traffic demand when compared with
the consented ZWF scheme is substantially less. It concludes: “Given that
ZWF predicted traffic levels have already been demonstrated as being
expected to result in only a negligible level of traffic and transport related
impact, there can be a high degree of confidence that the day-to-day
operation of the Proposed Development would also not give rise to material
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 301
traffic related operational or environmental effects. Indeed delivery of the
current proposals would result in an overall ‘net benefit’ in traffic and transport
impact terms when compared against the current reference planning position.”
11.5.41 Given the conclusions of the traffic analysis and number of HGV vehicle
movements compared with typical baseline traffic flows (e.g. in the order of
5,000 vehicles per day along Whitehill Road), it is therefore concluded that the
resultant noise impacts for the Proposed Development would be negligible.
Operational Phase: Vibration
Ground Vibration Monitoring – Fixed and Mobile Plant
11.5.42 Monitoring of ground-borne vibration have been previously undertaken at an
energy from waste facility, a construction site and a waste management
facility (WMF) having similar plant during typical operating conditions. Further
detail is provided in Appendix 11-8 and vibration parameters are presented in
Appendix 11-7
11.5.43 During the survey at the construction site, the seismograph transducer did not
trigger at the measurement distance of 3-5 metres from mobile plant,
indicating that the level of vibration was below the transducer sensitive
threshold of 0.3mm/sec. The only trigger recorded during the survey was
during measurements of a passing HGV at a distance of 1 metre, which
recorded a level of 0.635mm/sec.
11.5.44 At the WMF site, the seismograph was placed at 10 metres from the kerbside
of the access road to the site. The seismograph transducer did not trigger
when the HGVs were travelling along the access road prior to reaching the
speed hump (which was opposite the monitoring position). The seismograph
did however trigger during HGV movements when certain vehicles were
travelling over the speed `hump’. The maximum levels of vibration recorded
ranged between 0.45mm/s to 0.83mm/s at the 10-metre position. This level of
vibration is still relatively low and experience has shown that according to
BS6472: 2008, even when properties are at this distance, there is normally a
‘low probability of adverse comment’ over the operating period indicating that
nuisance conditions are unlikely.
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11.5.45 For the monitoring of night-time operations at the energy from waste facility,
the seismograph transducer did not trigger at the measurement distance of 50
metres from the plant, indicating that the level of vibration was below the
transducer sensitive threshold of 0.3mm/sec.
11.5.46 The vibration survey results at a similar facility would indicate that vibration
levels from site operations is negligible and would therefore be imperceptible
at nearest receptors. In terms of BS6472 this would conclude that vibration
levels would be well below a ‘low probability of adverse comment’ and
therefore nuisance conditions are highly unlikely to occur.
11.6 Additional Mitigation
11.6.1 The incorporated mitigation measures described previously adequately
address the needs to avoid, reduce and compensate for many of the
prevailing significant effects of the Proposed Development. However, in order
to comply with the proposed noise condition (as advised by the Local
Authority), and to meet the required noise levels at the nearest potential
receptor on the Shawfair development, further noise mitigation would be
required. These could include the following measures:
Fan stack reduced by 10dB(A) (i.e. approx. 70dBA @ 1m from end of
stack)
Turbine air cooler fans - acoustically screened to reduce noise by
approx. 8-9dBA
All buildings clad to Rw=25dB or equivalent except the MPT building in
insulated cladding and Boiler Hall (western wall) above MPT building
which would require Rw=35dB performance cladding
Turbine Hall 10dB(A) lower inside or cladding increased by 10dB(A) in
performance (i.e. SWL = 85dBW or Rw=45dB)
All doors closed during night-time periods except for maintenance or for
emergency.
Step Up Transformers – Walls and Roof acoustic panels and door made
with acoustic louvres
11.6.2 As noted in sub-section 11.5, a range of alternative measures could be
adopted to achieve noise criteria at the site. The aforementioned measures
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are just one combination that would be effective in achieving the requisite
noise levels during the daytime and night-time periods.
11.7 Residual Effects
11.7.1 The following tables (11.21 and 11.22 over the page) provide the results of re-
analysis during the daytime and night-time periods following the introduction of
the aforementioned additional noise mitigation measures.
Table 11.21: Predicted Noise Contribution from the RERC and HGV movement
(including additional noise control measures) during Daytime
Receptor Position
(Refer to Figure 11.1)
Time Period Predicted Noise Contribution from Site
LAeq1hr dB
Representative
Background Noise level
without site
LA901hr dB
[LAeq]
Rating compared to background noise LAeq1hr dB
Noise change
(after & before)
LAeq dB
R1 South West (NMP1) Daytime 24 42 [46] -18 0
R2 South East (NMP2) Daytime 26 50 [58] -24 0
R3 North West (NMP3) Daytime 26 49 [53] -23 0
R4 South (NMP4) Daytime 28 50 [55] -22 0
R5 West Daytime 28 41 [48] -13 0
R6. Western boundary (area D
of Shawfair development)
Daytime 35-40 42 [49] * -4 to +1 0 to +0.5
Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment an allowance of +3dB has been added for R6 due to proximity to the Site. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.
11.7.2 The predicted noise levels are for site attributable noise with the additional
noise control mitigation measures.
11.7.3 Using the PAN1/2011 tables establish the noise impact (i.e. refer to Tables
11.6 and 11.7) the sensitivity of the receptors is low. The magnitude of the
impact during daytime periods based on the quantitative assessment shows
that the change in noise level ranges between zero and +0.5dB LAeq and
therefore shown to be of negligible impact. The level of significance
according to PAN1/2011 is neutral to slight.
11.7.4 According to BS4142: 1997, the rating level relative to background noise
would indicate complaint is unlikely at all positions. The operational noise
impacts from the Proposed Development are therefore not considered to
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 304
represent any significant impact. In terms of BS4142: 2014 the impact is likely
to be low.
11.7.5 In relation to the noise condition proposed by the Local Authority during pre-
application discussions, the noise limit is achieved at position 6, which is the
closest potential receptor on the Shawfair development.
Night-time Operations
11.7.6 Table 11.22 over the page provides information on the predicted noise levels
during night-time activities (i.e. site operational without the receipt of waste
and HGV movement).
Table 11.22: Predicted Noise Contribution from the RERC (including additional
noise control measures) during Night-time
Receptor Position
(Refer to Figure 11.1)
Time Period Predicted Noise Contribution from Site
LAeq1hr dB
Representative
Background Noise level
without site
LA901hr dB
[LAeq]
Rating compared to background noise LAeq1hr dB
Noise change
(after & before)
LAeq dB
R1 South West (NMP1) Night-time 24 37 [42] -13 0
R2 South East (NMP2) Night-time 25 42 [52] -17 0
R3 North West (NMP3) Night-time 25 39 [46] -14 0
R4 South (NMP4) Night-time 27 42 [52] -15 0
R5 West Night-time 27 38 [42] -11 0
R6. Western
boundary (area D
of Shawfair
development)
Night-time 35-39 42 [45] -7 to -3 0 to +1.0
Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment no noise characteristic penalties are deemed to be appropriate. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.
11.7.7 Using the PAN1/2011 tables to establish the noise impact (refer to Tables
11.6 and 11.7) the sensitivity of the receptors is shown to be low. The
magnitude of the impact during night-time periods based on the quantitative
assessment shows that the change in noise level ranges between 0dB and
+1.0dB LAeq and therefore shown to be minor impact. The level of
significance according to PAN1/2011 is neutral to slight.
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11.7.8 According to BS4142:1997, the rating level relative to background noise would
indicate complaint is unlikely at all positions. The operational noise impacts
from the Proposed Development are therefore not considered to represent
any significant impact. In terms of BS4142: 2014 the impact is likely to be a
low.
11.7.9 In relation to the noise condition proposed by the Local Authority during pre-
application discussions, the noise limit is achieved at position 6, which is the
closest potential receptor on the Shawfair development.
Comparison with PPiP Future Baseline Scenario
11.7.10 The noise impacts predicted for the ZWF development indicate that the noise
levels from the EfW site would not exceed background sound levels +5dB and
the combined effect of the AD Facility, EfW and MBT Facility would not
exceed a design limit of background sound +5dB. The assessment concludes
that, in terms of residual noise, the ZWF development would give rise to
environmental effects of negligible to minor adverse significance. The noise
predictions from the Proposed Development and reported in this Chapter,
show noise levels to be below existing background sound levels and based on
a worst case assessment, would only give rise to a negligible to minor impact.
In light of this, it can be concluded that the Proposed Development would only
give rise to a ‘neutral’ impact when compared to the future baseline scenario.
11.7.11 Furthermore, MLC have advised that the noise assessment should be
designed to achieve a design criteria similar to that imposed on the ZWF. If
the same planning condition is applied to the Proposed Development, there it
would not be possible for it to give rise to greater impact than the ZWF
development.
11.8 Summary and Conclusions
Introduction
11.8.1 Noise and vibration levels have been considered and assessed during the
construction and operational phases of the Proposed Development. Relevant
and appropriate noise and vibration guidance and standards have been used
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to determine the impact. The assessment has been undertaken to inform and
guide the design of the Proposed Development, such that any likely noise and
vibration impact on existing dwellings is minimised.
11.8.2 To establish any likely impact from noise a baseline sound survey was
undertaken to establish the existing background levels at the nearest
receptors to the site.
11.8.3 The Environmental Health Officers and their appointed noise consultant at
Midlothian Council have been formally consulted to seek advice in respect of
appropriate noise criteria and receptor locations.
Existing Baseline Noise Conditions
11.8.4 In accordance with relevant planning policy guidance on noise the existing
baseline sound levels at the nearest receptors have been established. These
have been undertaken during daytime and night-time weekday and weekend
operating periods to establish the representative background sound levels.
11.8.5 As set out in Sub-section 11.4 the assessment has been undertaken on a
worst case basis in the context of the assumed baseline for assessment (set
out in detail in Chapter 2.0 of the ES).
Residual Effects
11.8.6 During the construction phase there would be a variety of noise sources in use
at different stages and their associated activities would vary from day to day.
The highest noise levels relative to nearest receptors are likely to occur during
site preparation and piling activities. The peak noise activities do not normally
occur over long periods of time and best practical means would be employed
to control the noise being generated. It is concluded that the increase in noise,
as a result of construction, is likely to result in an impact magnitude
classification of negligible to moderate at receptors and a neutral to
moderate impact significance.
11.8.7 During the operation of the site, it is concluded in respect of the resultant
residual impact, that with appropriate mitigation measures within the detailed
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 307
design, there is likely to be a negligible to minor impact at receptors. The
level of significance according to PAN1/2011 is neutral to slight.
11.8.8 The assessment of impact on existing residential areas from any increase in
road traffic noise during the daytime shows no significant change in noise
levels and therefore there is likely to be a negligible impact at receptors and
neutral impact significance.
11.8.9 In terms of ground borne vibration from the operation of the site or from HGVs,
this would be below the level of perceptibility and therefore a negligible
impact and a neutral level of significance.
11.8.10 During the construction period, in terms of vibration there would also be a
negligible to minor impact and neutral to slight impact significance at the
nearest residential receptor and well within guidance limits for nuisance and
cosmetic damage.
11.8.11 During the de-commissioning period if the Shawfair Area D is developed for
residential use the impact from noise is likely to be negligible to moderate
adverse impact and neutral to moderate significance and vibration based on
a worst case scenario would be negligible to minor adverse impact
magnitude and neutral to slight impact significance.
11.8.12 In summary, no significant noise effects have been identified by the noise
assessment in relation to operational plant noise or plant vibration. Table 9.23
below summarises the predicted effects of the construction, operational and
decommissioning phases of the Proposed Development.
Table 11.23: Residual Impact at Nearest Receptor after Amelioration Measures
Source Nature of
Effect
Time Period
Impact
Magnitude
Level of
Significance
Construction noise Temporary Daytime Negligible to
Moderate
Neutral to
Moderate
De-commissioning noise Temporary Daytime Negligible to
Moderate
Neutral to
Moderate
Road traffic noise (construction)
Temporary Daytime Negligible Neutral
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Road traffic noise (operation) Permanent Daytime Negligible Neutral
Industrial noise Permanent Daytime
Night-time
Negligible
Negligible to Minor
Neutral to Slight
Neutral to Slight
Construction Vibration Temporary Daytime Negligible to Minor Neutral to Slight
De-commissioning vibration Temporary Daytime Negligible to Minor Neutral to Slight
Industrial Vibration Permanent Daytime
Night-time
Negligible
Negligible
Neutral
Neutral
Road traffic vibration Permanent Daytime Negligible Neutral
Cumulative effect with AD Permanent Daytime
Night-time
Negligible to Minor
Negligible to Minor
Neutral to Slight
Neutral to Slight
Conclusions
11.8.13 For construction and de-commissioning noise, in accordance with appropriate
standards, best practical means would be employed to control noise
generation at the Proposed Development. Measures may include restriction
on operating hours, sensible routing of equipment to site and careful choice of
piling rigs to minimise noise. Such measures would be defined within the
CEMP.
11.8.14 For construction, operational and de-commissioning noise, a robust
assessment of baseline sound levels, excluding the effects of local and
significant permitted development, have been considered and the potential
nearest sensitive receptors relative to the undeveloped Shawfair Development
in order to ensure that a worst case scenario has been presented.
11.8.15 The introduction of appropriate mitigation measures would ensure that the
resultant noise levels are within appropriate guidance, standards and the limits
Midlothian Council intend to impose through a planning condition. The
measures would be based on the employment of Best Available Techniques
(BAT) to mitigate any potential peak noise sources.
11.8.16 The assessment confirms that:
1. there would be no significant impacts during the operation of the
proposed development and the noise and vibration related
environmental effects of the Proposed Development would be
negligible to slight.
2. during construction and de-commissioning under worst case conditions
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the noise related environmental effects of the Millerhill RERC
development would be neutral to moderate and the vibration neutral
to slight.
3. the Proposed Development would only give rise to a neutral effect when
compared to the future baseline scenario associated with the ZWF
development.
11.9 References
Noise
BS4142: 1997 Method for rating industrial noise affecting mixed
residential and industrial areas.
BS4142: 2014 `Methods for rating and assessing industrial and
commercial sound’
BS8233: 2014 `Guidance on sound insulation and noise
reduction for buildings’
Planning Advice Note (“PAN”) 1/2011, `Planning and Noise’ –
March 2011
PAN1/2011 Technical Advice Note
Guidelines for Community Noise – World Health Organisation:
April 1999
World Health Organisation `Night Noise Guidelines for Europe’
– 2009;
BS7445: 2003 - Description and measurement of environmental
noise.
BS5228-1 & 2 2009 Code of Practice for noise and vibration
control on construction and open sites.
ISO 9613-2: 1996 Acoustics – Attenuation of Sound During
Propagation Outdoors.
Design Manual for Roads and Bridges, Volume 11,
Environmental Assessment; June 2010 (Part 2 GD 01/08)
Vibration
BS7385:1990 Evaluation and measurement for vibration in
buildings: Part 1 Guide for measurement of vibrations and
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evaluation of their effects in buildings. British Standards
Institution
ISO4866:1990(E) Mechanical vibration and shock - Vibration in
buildings - Guidelines for the measurement of vibrations and the
evaluation of their effects on buildings. International
Organisation for Standardisation.
BS7385:1993 Evaluation and measurement for vibration in
buildings: Part 2 Guide to Damage Levels from Ground Borne
Vibration. British Standards Institution.
German Standard DIN 4150, Part 3 1986
Whiffin, A C and Leonard, D R (1971) "A Survey of Traffic-
Induced Vibrations" Transport and Road Research Laboratory
(TRRL) Report 418.
Steffens, R J Structural vibration and damage - Some notes on
aspects and a review of available information. Building
Research Establishment Report.
BS6472: 2008 Evaluation of human exposure to vibration in
buildings (1Hz to 80Hz). British Standards Institution
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12.0 AIR QUALITY
12.1 Introduction
12.1.1 This chapter of the ES has been prepared to consider the potential impacts of
the Proposed Development on air quality.
12.1.2 The approach undertaken in the air quality assessment that is presented
within this Chapter varies from that set out within Chapter 2.0 regarding the
assumed baseline position. The reason for this is that the monitored
background air quality data, for obvious reasons, does not include aerial
emissions from the AD Facility, SNCD and the Borders Railway. As such, this
Chapter presents an assessment of the proposed development on the existing
background air quality conditions and then, subsequently, goes on to assess
the cumulative effects of the Proposed Development and the AD Facility.
12.1.3 On the basis that the other developments (Borders Railway and SNCD) would
not have point source emissions, they have not been modelled. It is
considered that this methodology would provide the clearest approach to an
assessment of air quality effects.
Assessment Overview
12.1.4 The Air Quality Assessment (AQA) is based on an atmospheric dispersion
modelling study of releases from the Application Site in isolation and in
combination with the adjacent AD Facility; the study was undertaken using
one of the modelling packages (ADMS5) recognised as being suitable for
such assessments. It follows guidance issued by both the SEPA and, where
suitable Guidance from the SEPA is not available, the EA. The scope and
approach of all elements of the assessment was agreed with the SEPA
beforehand.
12.1.5 The assessment provides details on the sources, nature and potential impacts
of the emissions to air from the Application Site in isolation and then in
combination with those from the adjacent AD Facility. The study takes account
of the effects of meteorological conditions, local terrain, building downwash
and existing local air quality on emissions from both the Application Site in
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isolation and then in combination with the adjacent AD Facility. The model
predicted the impact of emissions at the points of maximum ground level
concentration (GLCs) on local air quality and at a range of sensitive human
and environmental receptors which could be affected by releases from the
Application Site.
12.1.6 The objectives of the study were:
To determine a suitable height for the Application Site’s discharge stack;
To determine the maximum GLCs arising from the emission of pollutants
from the Application Site discharge stack based on the discharges being
at the maximum permitted concentrations and the ERC operating
normally and abnormally;
To determine the maximum GLCs arising from the emission of pollutants
from the Application Site discharge stack based on the discharges being
at the actual concentrations measured in FCC’s sister plant, which is of
the same design and specification (at North Hykeham, Lincolnshire);
To assess the impact of emissions from the Proposed Development on
existing local air quality in relation to human health at a range of
potentially sensitive receptors by comparison with relevant air quality
standards (AQSs);
To predict deposition rates of acids and nutrient Nitrogen from the
modelled emissions and compare these with relevant Critical Loads and
Critical Levels at a range of sensitive habitat sites;
To assess plume visibility; and
To provide an assessment of cumulative impacts of the discharges from
the Proposed Development and the adjacent AD Facility.
12.1.7 A copy of the full study is provided in Appendix 12-1 of this ES.
Previous Assessment
12.1.8 As discussed in Chapter 1.0 of the ES, the Application Site benefits from PPiP
(granted in 2012) for the ZWF, comprising:
An EfW Facility;
An AD Facility; and
A MBT Facility.
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12.1.9 An AQA in the form of an atmospheric dispersion modelling study was carried
out for the ZWF. The results of the assessment indicated that a discharge
stack height of 65m for the EfW facility would be acceptable.
12.1.10 The Proposed Development would be implemented instead of the consented
EfW and MBT facilities. Given the difference in technology proposed and the
different discharge stack height proposed 75m (see below), the results of the
AQA for the Proposed Development would differ from those assessed for the
ZWF, and, hence, the current air quality assessment is required.
Description of the Proposed Development
12.1.11 A detailed description of the Proposed Development is set out Chapter 4.0 of
this ES. Key aspects of the development that are of relevance to this air
quality assessment are the emissions from the proposed 75m high exhaust
stack. All discharge stack parameters are fully described in the AQA which is
provided in Appendix 12-1.
Legislative and Policy Context
12.1.12 Key legislation and policies relevant to the air quality assessment are
summarised below.
National Planning Policy
12.1.13 PAN 51 (Revised 2006) sets out advice from the Government in terms of core
policies and principles in relation to planning and pollution control.
Accordingly, the planning system should focus on whether the development
itself is an acceptable use of the land and the impacts of those uses, rather
than seeking to control the processes or emissions themselves as these are
covered through other regulatory processes such as the PPC permitting
regime: “...the planning authority should have regard to the impact of a
proposal on air or water quality although the regulation of emissions or
discharges will fall to be dealt with under other legislation.” (Paragraph 57 of
SPP1)
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12.1.14 The Edinburgh and Lothian’s Structure Plan (ELSP) 2015 includes a policy
for the protection of habitats, ENV1 F: Environmental or Biodiversity
Assessments. The policy states: “Development proposals that would affect
any designated natural heritage site, protected priority habitat or species or
other important non-statutory locations will require an appropriate level of
environmental or biodiversity assessment.”
Local Planning Policy
12.1.15 The Midlothian Local Plan 2008 implements the ELSP 2015, Policy ENV1
Criterion F also states that: “the Local Plan will not permit development that
will adversely affect such species other than in circumstances where
appropriate measures can be taken to minimise the effect of the
development or make positive provision for the protection of such species
and habitats.”
Industrial Emissions Directive (2010/75/EU)
12.1.16 The key legislation relating to discharges to air from the Application Site is
the Industrial Emissions Directive (IED). The IED prescribes measures
relating to the control of emissions to air and sets limits on emissions of a
wide range of air pollutants, for both normal and abnormal operation.
12.1.17 Chapter IV, Articles 42 to 55, of the IED ‘Special Provisions for Waste
Incineration Plants and Waste Co-incineration Plants’, sets out the
requirements that need to be met for the EfW activities that would be
undertaken at the Application Site. These Articles specifically address:
Article 42 – Scope;
Article 43 – Definition of residue;
Article 44 – Application for permits;
Article 45 – Permit conditions;
Article 46 – Control of Emissions;
Article 47 – Breakdown;
Article 48 – Monitoring of emissions;
Article 49 – Compliance with emission limit values;
Article 50 – Operating conditions;
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Article 51 – Authorisation to change operating conditions;
Article 52 – Delivery and reception of waste;
Article 53 – Residues;
Article 54 – Substantial change; and
Article 55 – Reporting and public information on waste incineration
plants and waste co-incineration plants.
12.1.18 Furthermore, Annex VI of the IED: ‘Technical Provisions Relating to Waste
Incineration Plants and Waste Co-incineration Plants’, in Part 3: ‘Air
Emission Limit Values for Waste Incineration Plants ‘prescribes the limits
that releases to air must meet under both normal and abnormal operating
conditions.
Pollution Prevention and Control (Scotland) Regulations 2012 (as amended)
12.1.19 The proposed development would require an environmental permit to
operate under the provisions of the Pollution Prevention and Control
(Scotland) Regulations 2012 (as amended) (PPC Regulations). The
requirements of the IED are implemented through the PPC Regulations. In
order to be issued with a PPC Permit, the Application Site would need to
demonstrate that Best Available Techniques (BAT) are being used to
minimise emissions to all media. In relation to the proposed activities at the
Application Site, compliance with the requirements of the IED is regarded as
BAT.
The Air Quality Strategy for England, Scotland, Wales and Northern Ireland
2007
12.1.20 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland
2007 (AQ Strategy) sets out air quality objectives and options to further
improve air quality in the UK both in the present and in the long term.
12.1.21 The AQ Strategy provides an overview and outline of the ambient (outdoor)
air quality policy for all UK Governments / devolved administrations,
including the Scottish Government. It sets out a way forward for work and
planning on air quality issues, details objectives to be achieved, and
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proposes measures to be considered further to help reach them. The
Strategy document comprises three volumes, namely:
Volume 1 of the Strategy provides an overview of the approach taken
and details the actual standards and objectives for the UK. For the
purposes of the Strategy:
o ‘Standards’ are the concentrations of pollutants in the
atmosphere which can broadly be taken to achieve a certain
level of environmental quality; the standards are based on
assessment of the effects of each pollutant on human health,
including the effects on sensitive subgroups or on ecosystems;
and
o ‘Objectives’ are policy targets often expressed as a maximum
ambient concentration not to be exceed, either without exception
or with a permitted number of exceedances, within a specified
timescale.
Table 2 of Volume 1 details the: ‘National Air Quality Objectives and
European Directive Limit and target values for the protection of human
health.’ These, together with other relevant AQS have been used in this
AQA.
Volume 2 sets out the scientific and economic evidence base; and
Volume 3 represents a fully updated Third Report of the
Interdepartmental Group on Costs and Benefits (IGCB).
12.1.22 In the context of this assessment, the AQ Strategy defines objectives for
particulate matter (as both PM10 and PM2.5), Carbon Monoxide, Sulphur
Dioxide, Nitrogen Dioxide and Benzene.
12.1.23 The AQ Strategy also sets objectives for Nitrogen Oxides and Sulphur Dioxide
for the protection of vegetation and ecosystems.
Air Quality Standards (Scotland) Regulations (SSSI 2010 No 204)
12.1.24 The standards and objectives for air quality detailed in the AQ Strategy are
laid down in the Air Quality Standards (Scotland) Regulations (SSSI 2010 No
204). For substances not specified in these regulations, air quality guidelines
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Environment Assessment levels (EALs) – are provided in the SEPA guidance
(see below).
The Fourth Air Quality Daughter Directive (2004/107/EC)
12.1.25 The Fourth Air Quality Daughter Directive (AQDD, 2004/107/EC) details
Target Values for Arsenic, Cadmium and Nickel. These are all relevant to this
assessment.
Expert Panel on Air Quality Standards – Metals and Metalloids
12.1.26 The Expert Panel on Air Quality Standards (EPAQS), which advises the UK
Governments on air quality, has set recommended Guideline Values for
arsenic, chromium VI and nickel in their document: Metals and Metalloids
(2009). The EPAQS Guideline Value for nickel is the same as the AQDD
Target Value, but the EPAQS Guideline Value for arsenic is half that of the
AQDD value. The lowest of these values have been taken into account in this
study.
EPAQS – Guidelines for Halogens and Hydrogen Halides in Ambient Air
12.1.27 EPAQS, in its document: Guidelines for Halogens and Hydrogen Halides in
Ambient Air (2009), has also set recommended Guideline values for Hydrogen
Chloride and Hydrogen Fluoride and these have been taken into account in
this study.
Council Directive 92/43/EEC on the Conservation of Natural Habitats and of
Wild Flora and Fauna (the Habitats Directive)
12.1.28 The Habitats Directive (together with Council Directive 2009/147/EC on the
Conservation of Wild Birds (the Birds Directive), forms the cornerstone of
Europe's nature conservation policy. It is built around two pillars: the Natura
2000 network of protected sites and the strict system of species protection.
The Directive protects over 1,000 animals and plant species and over 200:
‘habitat types’ (e.g. special types of forests, meadows, wetlands, etc.), which
are of European importance.
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12.1.29 The requirements of the Directive are implemented through the
Conservation Habitats and Species Regulations (SI 2010 No 490) (see
below).
Conservation Habitats and Species Regulations (SI 2010 No 490) (as
amended in Scotland)
12.1.30 The Conservation Habitats and Species Regulations (SI 2010 No 490) (as
amended in Scotland) transpose the requirements of the Habitats Directive
into national law. The Regulations provide for the designation and protection
of: ‘European Sites’ and the protection of: ‘European Protected Species’. If an
assessment carried out as part of the planning process indicated that
predicted impacts at a European designated site could not be screened out as
insignificant, the decision-making authority would be required to carry out an:
‘Appropriate Assessment’ in close consultation with SNH. This is designed to
establish whether a proposed development would adversely affect the integrity
of any such European Sites.
12.2 Methodology
Current Guidance
12.2.1 The key guidance document in relation to the air quality assessment is the
SEPA’s Guidance Note H1, and this is discussed below.
SEPA Guidance Note H1: Environmental Assessment and Appraisal of BAT
12.2.2 The SEPA Guidance Note H1: Environmental Assessment and Appraisal of
BAT provides guidance on the assessment of Best Available Techniques for
the purposes of the PPC permitting system. In terms of air quality
assessment, it provides guidelines on how to assess impact and criteria on
how to determine whether an impact is significant or not. It also details,
where AQSs have not been assigned, what are known as EALs for a range
of polluting substances; these have been derived from a variety of published
UK and international sources (including the World Health Organisation
(WHO). The EAL is the concentration of a substance which in a particular
environmental medium the Regulators regard as a comparator value to
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enable a comparison to be made between the environmental effects of
different substances in that medium and between environmental effects in
different media and to enable the summation of those effects. EALs for air
are detailed in Appendix D4 of H1. In the context of the air quality
assessment for the Proposed Development, EALs for Ammonia. Antimony,
Chromium (III), Cobalt, Copper, Manganese, Mercury, Thallium and Vanadium
have been used.
12.2.3 Appendix D7 of H1 also details maximum deposition rates (MDRs) for
various substances. In the context of this study, deposition of the metals
Arsenic, Cadmium, Chromium, Copper, Lead, Mercury and Nickel were
considered (the only substances for which MDRs have been assigned that
are relevant to this assessment).
The UK ADMS Model
12.2.4 The UK-ADMS model was developed jointly by the Cambridge Environmental
Research Consultants (CERC), Her Majesty’s Inspectorate of Pollution (the
EA’s predecessor body), the Meteorological Office and National Power, with
sponsorship from the UK Government and a number of commercial
organisations. UK-ADMS is a computer based model of dispersion from both
point and non-point sources in the atmosphere and is one of the modelling
packages that are suitable for this type of study.
Scope of Modelling Study
12.2.5 The first part of the study comprised a screening assessment to determine a
suitable height for the facility’s discharge stack. Based on experience of
similar plants, the stack height screening assessment was undertaken using
oxides of nitrogen (NOx, expressed as nitrogen dioxide NO2) and the trace
metals Arsenic, Cadmium, Hexavalent Chromium and Nickel. The impacts of
NOx and ammonia at Habitat sites were also considered, together with the
effect of nutrient nitrogen deposition at thirty-two potentially sensitive
ecological sites (also agreed with the SEPA). The effects of emissions from
the facility operating under abnormal conditions, as defined in the IED, were
also considered. The impact of the facility on human health and sensitive
habitats was assessed for a range of stack heights between 50m and 90m.
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12.2.6 The main study determined the maximum predicted GLCs of the following
pollutants (using the stack height determined in the stack height screening
assessment):
Nitrogen Oxides (NOx, expressed as Nitrogen Dioxide (NO2));
Total fine particles (PM10 and PM2.5);
Carbon Monoxide (CO);
Gaseous and vaporous organic substances (VOCs), expressed as total
organic carbon and assumed to comprise entirely of benzene (in
accordance with the guidance provided in Guidance Note H1, which
indicates that, where characterisation of VOCs has not been
undertaken, a precautionary approach is taken and all VOCs are
assumed to present as benzene);
Sulphur Dioxide (SO2);
Hydrogen Chloride (HCl);
Hydrogen Fluoride (HF);
Ammonia (NH3);
Mercury (Hg) and its compounds;
Cadmium (Cd) and Thallium (Tl) and their compounds;
Antimony (Sb), Arsenic (As), Chromium (Cr), Cobalt (Co), Copper (Cu),
Lead (Pb), Manganese (Mn), Nickel (Ni), Vanadium (V) and their
compounds (note for ease of reporting, this group of nine metals and
their compounds are hereinafter referred to as: ‘Group 3 metals and
their compounds’;
Dioxins and Furans;
Polychlorinated Biphenyls(PCBs); and
Polyaromatic Hydrocarbons (PAH), expressed as Benzo[a]pyrene (the
AQS for PAH is expressed as Benzo[a]pyrene, and, accordingly, for the
purposes of the assessment, all PAH are assumed to be present as
Benzo[a]pyrene).
12.2.7 Modelling was carried out using the appropriate Emission Limit Values (ELVs)
as specified in the IED. Daily ELVs were used for the main assessment as the
frequency with which the half hourly limit can be exceeded is limited by the
provisions of Annex VI of the IED. Consequently, it would be unreasonable to
assume that the facility operates continually at the half hour limits even for the
prediction of short-term concentrations. Half-hourly ELVs, where such limits
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have been assigned, were used for assessing abnormal releases. The effects
of prevailing meteorological conditions, building downwash effects, local
terrain and existing ambient air quality were also taken into account.
12.2.8 The maximum predicted pollutant GLCs, also known as the process
contributions (PCs),- for each of the releases were compared with the relevant
AQSs i.e. the UK Air Quality Strategy Objective or Target Value, the EPAQS
Guideline Value or the EALs (as detailed in Table D4 of H1), as appropriate.
12.2.9 The impacts were also assessed using actual emissions monitoring data -
rather than the IED ELVs from FCC’s sister plant, which is of the same design
and specification, at North Hykeham, Lincoln.
12.2.10 The maximum predicted pollutant GLCs at thirty-four human receptors were
also compared to the relevant AQSs. There are no declared Air Quality
Management Areas (AQMAs); in Midlothian, however, there are five AQMAs
within the City of Edinburgh. The closest to the site being City Centre AQMA
at Cowgate (6.7km from the facility stack) which is declared for annual mean
concentrations of NO2. This location has also been included in the
assessment as a potentially sensitive receptor.
12.2.11 The predicted environmental concentrations (PECs), the sum of the pollutant
PC and the existing pollutant background concentration from other sources,
were also compared to the relevant standards where necessary.
12.2.12 Metals deposition was also considered. Maximum predicted deposition rates
for those substances for which MDRs have been assigned (see above) were
compared to the MDRs detailed in Table D7 of H1.
12.2.13 The maximum predicted annual mean GLCs of oxides of nitrogen, sulphur
dioxide, hydrogen fluoride and ammonia were compared with the critical levels
for the Protection of Ecosystems or Vegetation detailed in Table D3 of H1 at
thirty-two sensitive ecological receptors. (Critical levels are thresholds of
airborne pollutant concentrations above which damage may be sustained to
sensitive plants and animals).
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12.2.14 The rates of deposition for acids (nitrogen and sulphur) and nutrient nitrogen
were predicted for all relevant Habitat sites. These rates were then compared
to the appropriate critical loads for the type and location of each habitat.
Critical loads are defined as: “a quantitative estimate of exposure to one or
more pollutants below which significant harmful effects on specified sensitive
elements of the environment do not occur according to present knowledge.”
12.2.15 Abnormal operating conditions were also considered in the study to take
account of short-term abnormal conditions permitted under Article 46(6) of the
IED.
12.2.16 In relation to the cumulative effects, it is known that, at the time of writing, that
the only potential development within a 15km radius that should be considered
in a cumulative assessment is the neighbouring AD Facility (this was agreed
with the SEPA). Emissions from the CHP stack and the flare stack at the AD
Facility were considered.
The Study Area
12.2.17 For assessing the point of maximum ground level concentration of pollutants
an area 10km by 10km was used with the ERC stack as the central location.
12.2.18 For assessing the impact on ecologically protected sites, all sites within 15km
from the stack were included.
12.2.19 Sensitive human receptors within the assessment included residential
locations, schools, universities, farms and medical facilities. These vary in
distance from 0.5km to 3km from the ERC stack.
Model Parameters
Key Assumptions
12.2.20 The study has been undertaken on the basis of a worst case scenario.
Consequently, the following assumptions have been made:
The release concentrations of the pollutants would be at the ELVs and
emission rates as provided by the IED on a 24 hourly basis, 365 days
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of the year; in practice, when the plant is operating, the release
concentrations would be below the ELVs, and, for most pollutants,
considerably so; furthermore, taking shutdowns for planned
maintenance into account, the ERC would not operate for 365 days a
year.
The highest predicted pollutant GLCs for the five years of
meteorological data for each averaging period (annual mean, hourly,
24 hourly etc.) have been used;
All of the particulate releases would be present as PM2.5 and also as
PM10; this enables direct comparison with the particle AQSs, which are
expressed in terms of PM2.5 and PM10; in practice, this would not be the
case as some of the particles present would be larger than PM10;
For the purposes of the short-term assessments, 35% of the oxides of
nitrogen in the releases would be present as nitrogen dioxide; in
practice, at the time of discharge from the stack, the percentage of
nitrogen dioxide in the releases is likely to be below this; for the long-
term assessments, it has been assumed that 70% of the oxides of
nitrogen in the releases would be converted to nitrogen dioxide in the
atmosphere (these assumptions are in accord with current the SEPA
guidance); and
Maximum predicted GLCs at any location, irrespective of whether a
sensitive receptor is characteristic of public exposure, are compared
against the relevant AQSs for each pollutant; in addition, the predicted
maximum sensitive receptor GLC has also been assessed.
12.2.21 Taken together, the assumptions used for the modelling study are likely to
have resulted in a conservative estimate i.e. an overestimate, of the impact of
the proposed facility.
Model Input Parameters
Stack Emission Parameters
12.2.22 The stack emission parameters for the Proposed Development discharge
stack used in the study are presented in Table 10 of the modelling study
report, and the associated pollutant discharge rates are presented in Table 11
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of the modelling study report. The stack emission parameters for the AD
Facility CHP and flare stacks and the associated pollutant discharge rates are
presented in Tables 12 and 13, respectively, of the modelling study report.
Meteorological Data
12.2.23 Five years (2009 – 2013) of hourly sequentially analysed meteorological data
from Gogarbank, which is 16km north-west of the Application Site, was used;
it was agreed with the SEPA that this was the most appropriate data to use in
the assessment.
Building Parameters
12.2.24 The building parameters utilised for the study are detailed in Table 15 for the
Millerhill RERC and Table 16 for the AD Facility of the modelling study report,
respectively.
Terrain Data
12.2.25 Terrain data was used for an area of 1024km2 and was created by compiling
the data from the relevant Ordnance Survey tiles. The terrain data used was
of sufficient size to ensure that it would encompass all of the sensitive human
and ecological receptors.
Roughness Length
12.2.26 The surface nature of the terrain is defined in terms of roughness length. The
roughness length is dependent on the type of terrain and its physical
properties; agricultural areas are classed as 0.3m, parkland and open
suburbia as 0.5m and cities and woodlands as 1.0m. Given the nature of the
terrain, the intended end use of both the Application Site and the surrounding
area, it was considered that the most appropriate surface roughness would be
0.5m. To test this, three roughness lengths were assessed, namely 0.3m.
0.5m and 1.0m; the results of the assessment are presented in Table 18 of the
modelling study report. Following this assessment, a surface roughness of
0.5m was selected as being the most representative of the Application Site
and surrounding area.
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Deposition Parameters
12.2.27 The deposition rates modelled for metals were taken from Table D7 of H1.
12.2.28 The deposition rates for sulphur dioxide, oxides of nitrogen, ammonia and
hydrogen chloride were taken from Guidance Note AQTAG 06: Technical
Guidance on Detailed Modelling Approach for an Appropriate Assessment
(April 2010).
Significance of Effects
General Criteria for the Assessment of Significance
12.2.29 This section identifies the criteria used to determine the significance of the
effects produced by the Proposed Development on air quality.
12.2.30 Module 3 of H1 details the guidelines upon which the assessment of the
significance of impact can be established. In the first instance, it indicates that
process contributions (PCs) can be considered insignificant if:
The long-term PC is <1% of the long-term environmental standard; and
The short-term PC is <10% of the short-term environmental standard.
12.2.31 Where a PC exceeds the above criteria, then the impact is deemed ‘potentially
significant’, and further assessment has to be undertaken. The next step of
the assessment takes account of the existing background concentrations of
the pollutant of interest, and H1 indicates that environmental standards are
unlikely to be exceeded provided:
The long-term PEC is <70% of the long-term environmental standard
(where the long-term PEC is the sum of the long-term PC and the long-
term pollutant background concentration); and
The short-term PC is <20% (short-term standard 2 x long-term
pollutant background concentration).
12.2.32 However, it is important to note that, for the Group 3 metals, there is an
additional criterion that states that the environmental standard is unlikely to be
exceeded if:
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The long-term and short-term PEC is <100% of the long-term and
short-term environmental standard (as appropriate) (where the short-
term PEC is the sum of the short-term PC and twice the long-term
pollutant background concentration).
Additional Assessment of Significance Guidelines for Trace Metals
12.2.33 For trace metals, Annex VI of the IED assigns ELVs for three groups. Group 1
comprises Cadmium and Thallium, Group 2 comprises Mercury and Group 3
comprises Antimony, Arsenic, Chromium, Cobalt, Copper, Manganese, Lead,
Nickel and Vanadium. The ELVs are the total for the combined emissions, and
it would not be reasonable to assume that each metal emits at the maximum
ELV for the group. In this regard, the EA has provided guidance on the steps
required for assessing the impact of such metal emissions, namely: Releases
from Municipal Waste Incinerators: Guidance to Applicants on Impact
Assessment for Group 3 Metals (V3, September 2012), and these are
discussed below. The use of this guidance has been agreed in writing with the
SEPA. Also please note that although the guidance applies to Group 3 metals,
a similar approach has been adopted here for the Group 1 metals.
12.2.34 Step 1 of the guidance is to assume that all emissions are at the maximum
ELV for the group. For example, all of the Group 3 metals would be assumed
to be emitted at a concentration of 0.5mg/Nm3 and the Group 1 metals at a
concentration of 0.05mg/Nm3. For Step 1 it is assumed that hexavalent
chromium is 20% of total Cr. This is based on information on background
concentrations provided by EPAQS: Guidelines for Metals and Metalloids in
Ambient Air for the Protection of Human Health (May 2009).
12.2.35 Where the release is considered to be potentially significant, Step 2 of the
guidance allows the applicant to assume that all emissions are an equal
proportion of the ELV for the group. For example, all of the Group 3 metals
would be assumed to be emitted at 11% of the ELV (i.e. 0.056mg/Nm3), and
the Group 1 metals are assumed to be emitted at 50% of the ELV (i.e.
0.025mg/Nm3). For Step 2 it is assumed that chromium VI is 20% of total
chromium.
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12.2.36 Where the release is still considered to be potentially significant, Step 3 of the
guidance allows the applicant to justify lower percentages for each Group 3
metal. In this case, mean emissions from operational municipal waste
incineration plants as indicated in the EA Guidance have been used (as
agreed with the SEPA).
12.2.37 The effects of the Proposed Development would be considered significant in
the context of this EIA in the event that they exceed the stated thresholds for
impacts upon air quality.
Consultation
12.2.38 The SEPA was consulted with regard to all aspects of the modelling study.
The scope of the study described below was agreed with the SEPA.
12.3 Baseline
12.3.1 As described in the introduction, this sub-section provides baseline data on
the air quality conditions in and around the Application Site as they currently
exist. It does not allow for the other facilities that fall within the assumed
baseline for assessment.
Background Nitrogen Dioxide Concentrations
12.3.2 There are no measurements of NO2 undertaken by MLC, East Lothian Council
or the ECC in the vicinity of the site. The nearest measurements are taken in
Dalkeith, approximately 3km south of the site.
12.3.3 Accordingly, annual mean ambient background concentrations of NO2 for
2014 have been obtained from the DEFRA UK Background Air Pollution
Maps. The concentration of NO2 at NGR 332500, 670500, the appropriate
1km grid square - is 10.72µg/m3.
Background Sulphur Dioxide Concentrations
12.3.4 The DEFRA mapped SO2 concentration for the area surrounding the
proposed facility is 2.716µg/m3 and, accordingly, this value is assumed to be
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representative of the background concentration at the site and nearby
sensitive receptor locations.
Background Particulate Matter Concentrations
12.3.5 The 2015 DEFRA mapped PM10 concentration for the area surrounding the
Application Site is 13.49µg/m3, and, accordingly, this value is assumed to be
representative of the background concentration at the site and nearby
sensitive receptor locations.
12.3.6 The 2015 DEFRA mapped PM2.5 concentration for the area surrounding the
Application Site is 7.94µg/m3, and, again, this value is assumed to be
representative of the background concentration at the site and nearby
sensitive receptor locations.
Background Volatile Organic Compounds (as Benzene) Concentrations
12.3.7 The 2015 DEFRA mapped benzene concentration for the area surrounding
the Application Site is 0.329µg/m3, and, accordingly, this value is assumed to
be representative of the background concentration at the site and nearby
sensitive receptor locations.
Background Trace Metal Concentrations
12.3.8 Monitoring of trace elements has been undertaken by DEFRA since 1976.
Currently, monitoring of twelve metals is carried out locations throughout the
UK, predominantly in urban locations. In addition, concentrations of Arsenic,
Cadmium, Mercury, and Nickel are monitored at a further ten rural locations.
12.3.9 The closest location to the application site is the rural site at Auchencorth
Moss, approximately 18km to the south waste of the site. The mean
concentrations measured at the site in 2013 have been used for the
assessment and are as follows:
Arsenic – 0.213 ng/m3;
Cadmium – 0.0248 ng/m3;
Chromium – 0.790 ng/m3;
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Chromium VI* – 0.158 ng/m3; and
Nickel – 0.279 ng/m3.
*Note: For chromium VI, it has been assumed that the background concentration is 20% of the total Cr concentration (as indicated in the EPAQS May 2009 report: Guidelines for Metals and Metalloids in Ambient Air for the Protection of Human Health).
Background Polyaromatic Hydrocarbons (as Benzo[a]pyrene)
Concentrations
12.3.10 Ambient monitoring of benzo[a]pyrene (B[a]P) is carried out as part of the
DEFRA PAH Network at a number of locations around the UK.
12.3.11 There are two monitoring sites in close proximity to the Proposed
Developemnt, namely Edinburgh St Leonards and Auchencorth Moss. The
latest data available from Edinburgh St Leonards is for 2006, whilst for
Auchencorth Moss, 2013 data is available. Although the Edinburgh St
Leonards monitoring station is closer to the Proposed Development (6.5km
north-west of the stack) as the data is significantly older, the Auchencorth
Moss data (17.6km south-west of the stack) has been used. The average
annual mean B[a]P concentration for 2013 of 0.035ng/m3 is assumed to
provide a reasonable estimate of the background concentration at the
proposed facility and at sensitive receptor locations.
PPiP Future Baseline Scenario
12.3.12 The PPIP future baseline scenario (refer to Chapter 2.0 for full details) reflects
the fact that a major development located at the Application Site has been
granted planning consent. The assessment of effects in this Scenario seeks to
set out in brief any additional air quality effects that would derive from the
Proposed Development, over and above those deriving from the consented
ZWF development, which it would effectively replace. The principal differences
between the consented ZWF and the Proposed Development, in so far as
they relate to the assessment of air quality effects, as set out in paragraph
12.1.8 in this Chapter.
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12.4 Assessment of Effects
Incorporated Mitigation
12.4.1 A detailed description of the Proposed Development is set out in Chapter 4.0
of the ES. A series of measures have been incorporated into the design of the
Proposed Development, and into its construction and operational procedures,
which are intended to provide a suitable degree of mitigation against
potentially adverse air quality impacts from either controlled or fugitive
releases.
12.4.2 The mitigation measures that would be in place to control emissions to air
during the construction phase would be detailed in the CEMP. The CEMP
would include detailed method statements for, amongst other things, the
control of emissions to air from the construction activities, and as described in
Chapter 4.0 of the ES. The CEMP would include details of measures required
mitigate the adverse effects of the construction phase including:
Hard-surfaced haul roads;
Stockpiles of materials that have the potential to generate dust would be
securely sheeted;
Drop heights would be minimised;
Dust suppression, including measures to ensure the correct treatment of
disposal of run-off from dust suppression activities;
No-idling of vehicles;
Effective vehicle cleaning and wheel washing at site exit;
The covering of all loads which have the potential to generate dust;
No site run-off; and
All vehicles and plant would be well maintained.
12.4.3 A whole range of mitigation measures would be incorporated into the
Proposed Development to ensure that there are no unacceptable impacts on
air quality during its operational phase. These would comprise a combination
of design measures and management and operational procedures covering
both the MBT and the EfW plant, and would include those measures detailed
below.
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Management and Staffing Arrangements:
The Proposed Development would have an appropriate management
structure in place and would be suitably staffed;
It is FCC’s intention that the an integrated management system (IMS)
would be developed at the proposed development; the IMS would be
based on the requirements of:
The international quality management standard ISO9001,
The international environmental management standard ISO14001, and
the international occupational health and safety management standard
OHSAS18001;
These arrangements would ensure that the Proposed Development is
managed and operated to the highest standards at all times;
All operational procedures would be properly documented; this would l
help to ensure that the plant is operated in an appropriate manner at all
times; and
All staff would be properly trained in their respective duties; again, this
would help to ensure that the plant is operated in an appropriate manner
at all times.
Operational Measures:
General Arrangements
12.4.4 All aspects of the plant would be controlled by a series of sophisticated
computer control systems which would provide feedback to the plant
operators on the operational status of the plant at all times.
Mechanical Treatment Plant
All waste coming into the MBT would be off-loaded inside the Waste
Reception Building with the access doors closed;
All internal areas of the MBT would be kept under negative pressure;
and
When the EFW is not operational (approximately 2 weeks per year) air
from inside the mechanical treatment plant would not be under negative
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pressure and accordingly air from this area would be ducted through a
biofilter to control odour emissions from the plant.
12.4.5 These arrangements would help to ensure that the potential for fugitive dust
and odour emissions from the MBT would be minimised.
Energy from Waste Plant
All elements of the ERC plant have been designed to meet the
requirements of the IED;
The ERC would incorporate a selective non-catalytic reduction (SNCR)
system to ensure that NOx are reduced to a level that would ensure that
the emissions meet the requirements of the IED;
The ERC would incorporate a flue gas treatment stage to remove acid
gases and particulate matter from the gas stream before discharge to
atmosphere; this comprises a lime and activated carbon injection
system and a high specification bag filtration system; again, these
arrangements would ensure that IED requirements would be met in
relation to emissions of particulate matter, sulphur dioxide, hydrogen
chloride and hydrogen fluoride;
The plant would be equipped with a comprehensive range of continuous
monitoring devices to ensure that the plant operators are fully aware of
the status of the emissions from the plant at all times; these devices
would monitor: Particulate Matter, Carbon Monoxide, Oxides of Nitrogen
(Nitrogen Monoxide (NO) and Nitrogen Dioxide (NO2) expressed as
NO2), Ammonia, Sulphur Dioxide, Volatile Organic Compounds (VOCs,
expressed as Total Organic Carbon (TOC)), Hydrogen Chloride,
Ooxygen, moisture, temperature, pressure and velocity and flow; the
continuous emissions monitoring data generated by these devices
would enable the operators to adjust and / or shut down the Proposed
Development if necessary; and
The ERC would be equipped with a comprehensive series of alarms and
interlock systems throughout; these would provide an indication of any
potential or actual system faults and would, if necessary, automatically
close the ERC down.
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12.4.6 It is evident from the measures described above, that the Proposed
Development would benefit from extensive mitigation through a combination of
design, management procedures and operational procedures.
Construction Phase
Assessment of Effects against Existing Baseline
12.4.7 An overview of the key elements of the construction process for the Proposed
Development is set out in Chapter 4.0 of this ES. It is anticipated that
construction would last for a period of approximately 28 months. Initial works
would include site clearance, foundations and drainage, and these would be
likely to take place within the first 5 months. Erection of building frames, plant
and equipment and then cladding would follow.
12.4.8 Construction activity is already evident, both within the boundary of the
Application Site and in the surrounding area, associated with the Borders
Railway, the AD Facility and the SNCD. The baseline for the AQA assumes
that this construction activity is complete (see the introduction to this chapter
for further details). The construction of the Proposed Development would
introduce involve construction activity from approximately mid-2015 until
spring 2018. There would be some potentially adverse air quality impacts of
short-term duration associated with this construction activity.
12.4.9 The construction process would be managed in accordance with a project-
specific CEMP which would set out how construction would comply with any
specific environmental limitations, including control of air quality, imposed by
the planning consent, as well as the requirements of relevant legislation,
regulations and best practice guidance. The CEMP would include detailed
method statements for, amongst other things, the control of emissions to air
from the construction activities, and as described in Chapter 4.0 of the ES.
12.4.10 The likely effects on air quality from the construction phase would be from
dust (particulates) during construction and site clearance operations.
12.4.11 Within the Proposed Development, the main sources of dust would arise from
materials handling and removal, construction and road traffic passing over
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exposed soil surfaces, site excavations for foundations and groundwork and
batching of concrete on site (if required).
12.4.12 The effects of construction dust are likely to be limited to areas downwind
within 200m of dust generating activities, and are predicted to remain within
the boundary of the Proposed Development. Elevated concentrations of dust
are most likely to occur on dry windy days and areas downwind of the
prevailing wind direction would be affected more frequently. The nearest
sensitive receptors are immediately adjacent to the Application Site western
boundary (the housing proposed as part of the proposed Shawfair
development), with the measures implemented in the CEMP (see Section
12.4.2) it is unlikely that any significant dust emissions would arise.
12.4.13 Emissions from diesel construction equipment would be confined to the
construction area. This would increase levels of associated pollutants within a
localised area. However, these would be rapidly dispersed in the atmosphere
and are not expected to have any impact off-site. As a consequence, the
Proposed Development would not give rise to any significant effects in this
regard
Assessment of Effects against PPiP Future Baseline Scenario
12.4.14 The construction period for the ZWF was proposed to take place between
2013 / 2014 and 2015 / 2016, covering a period of approximately 24 months.
Whilst exact details relating to construction are limited in the ES prepared in
support of the application, it seems reasonable to assume that the
construction phase of the ZWF would involve similar activities, and, therefore
similar air quality impacts, as the Proposed Development.
12.4.15 The difference between the construction phase for the Proposed Development
when compared with that for the ZWF Development, would be the increased
duration of construction activity. However, as the footprint of the Proposed
Development is smaller, the physical extent of the construction area would be
reduced. As such, the temporary adverse effects of the Proposed
Development would be for a more prolonged duration, but would be of smaller
physical scale and are likely to be quantitatively less on a daily basis. It is not
considered that other aspects of the construction process would result in any
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effect that is appreciably different from that would could be anticipated from
the ZWF Development. Thus the Proposed Development would have a
‘neutral’ effect when compared to the future baseline.
Operational Phase
12.4.16 An atmospheric dispersion modelling study was undertaken to assess the
impact of releases from the discharge stack of the Proposed Development
during its operational phase. The study was undertaken after consultation with
the SEPA. The full scope of the study is described earlier in this Chapter. A
copy of the full modelling study report is provided in Appendix 12-1, and
should be read in conjunction with this Chapter. The findings of the study are
summarised below.
12.4.17 The results of the stack height screening assessment (see Appendix B of the
main modelling study report), which took account of the emissions from the
Proposed Development that could potentially have the highest impact,
demonstrated that the proposed stack height of 75m would not result in any
significant impacts on either human health or the environment.
12.4.18 The results of the assessment of the impact of the releases from the Proposed
Development discharge stack at the IED ELVs are presented in Section 4. and
Tables 21, 22 and 23 of the main modelling study report. It can be seen from
the data that the impacts of releases of all pollutants can be screened out as
not being significant and would not lead to any exceedance of air quality
standards. The pollutants assessed were:
Oxides of Nitrogen (expressed as nitrogen dioxide);
Sulphur Dioxide;
Particulate matter as PM10;
Particulate matter as PM2.5;
Carbon Monoxide;
VOCs (expressed as benzene);
Ammonia;
Hydrogen Chloride;
Hydrogen Fluoride;
Antimony;
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Arsenic;
Chromium III;
Chromium VI;
Cobalt;
Copper;
Lead;
Manganese;
Mercury;
Nickel;
Thallium;
Vanadium;
Polyaromatic Hydrocarbon (expressed as benzo[a]pyrene;
Polychlorinated Bphenyls; and
Dioxins and Furans.
12.4.19 The results of the assessment of the impact of the releases from the Proposed
Development discharge stack at the actual concentrations measured at FCC’s
sister plant at Lincoln are presented in Section 5 and Tables 24 and 25 of the
main modelling study report (Appendix 12-1). The data in Table 24 indicates
that the actual concentrations of pollutants at FCC’s Lincoln plant are, in most
cases, much lower than the IED ELVs. Accordingly, as would be expected, it
can be seen from the data in Table 25 that releases of all pollutants (as
detailed above) have a lower impact than at the IED ELVs. Again, as would be
expected, the impacts of the releases can be screened out as not being
significant and would not lead to any exceedance of any air quality standard.
12.4.20 The results of the assessment of the impact of metals deposition associated
with the releases from the Proposed Development discharge stack are
presented in Section 6 and Table 26 of the main modelling study report
(Appendix 12-1). It can be seen from the data in Table 26 that metals
deposition can be screened out as not being significant.
12.4.21 The results of the assessment of the emissions from the Proposed
Development discharge stack (at IED ELVs) at the thirty-four human sensitive
receptors considered are presented in Section 7 and Tables 27, 28 and 29 of
the main modelling study report (Appendix 12-1). It can be seen from the data
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 337
that all releases can be screened out as not being significant and would not
lead to any exceedance of any air quality standard at any of the human
sensitive receptors.
12.4.22 The results of the assessment of impact of the emissions from releases from
the Proposed Development discharge stack at the IED ELVs at the thirty-two
environmental receptors considered are presented in Section 8 and Tables
30, 31, 32 and 33 of the main modelling study report (Appendix 12-1). It can
be seen that:
From the data in Table 30, none of the annual or daily mean oxides of
nitrogen process contributions at any of the sensitive habitat sites are
significant in relation to critical levels;
From the data in Table 31, none of the annual mean sulphur dioxide
process contributions at any of the sensitive habitat sites are
significant in relation to critical levels, even at those with sensitive
lichen communities;
From the data in Table 32, none of the annual mean ammonia process
contributions at any of the sensitive habitat sites are significant in
relation to critical levels; and
From the data in Table 33, none of the 24 hour mean or weekly mean
hydrogen fluoride process contributions at any of the sensitive habitat
sites are significant in relation to critical levels.
12.4.23 The results of the assessment of impact of the nutrient nitrogen and acid
deposition from releases from the Proposed Development discharge stack at
the IED ELVs at the thirty-two environmental receptors considered are
presented in Section 9 and Tables 34 and 35 of the main modelling study
report (Appendix 12-1). It can be seen that:
From the data in Table 34, none of the nutrient nitrogen deposition
rates at any of the sensitive habitat sites are significant in relation to
either the upper or lower critical loads; and
From the data in Table 35, none of the acid deposition rates at any of
the sensitive habitat sites are significant in relation to the critical loads.
12.4.24 The results of the assessment of the impact of visible plumes from the
Proposed Development discharge stack are presented in Section 10 and
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Table 36 of the main modelling study (Appendix 12-1). Plumes would only
extend beyond the site boundary for less than 5% of daylight hours per year
and are therefore classed as being of low impact in accordance with the SEPA
guidance.
12.4.25 The results of the assessment of the impact of the releases from the Proposed
Development discharge stack under abnormal operating conditions are
presented in Section 11 and Tables 37 and 39 of the main modelling study
report (Appendix 12-1). It can be seen that:
From the data in Table 37, with the emissions at the half-hourly ELVs,
emissions of: Particulate Matter, VOCs, Hydrogen Chloride, Hydrogen
Fluoride, Sulphur Dioxide and Nitrogen Dioxide are not significant; and
From the data in Table 39, with the plant operating under abnormal
operating conditions, emissions of: Particulate Matter, Hydrogen
Chloride, Hydrogen Fluoride, Sulphur Dioxide, Nitrogen Dioxide and
Carbon Monoxide are not significant.
Cumulative Effects
12.4.26 The results of the assessment of the cumulative impact of releases of:
Nitrogen Dioxide, Sulphur Dioxide and Carbon Monoxide from the Proposed
Development discharge stack and the AD Facility CHP and flare stacks are
presented in Section 12 and Tables 42 – 48 of the main modelling study report
(Appendix 12-1). It can be seen that, the impacts in relation to all of the
scenarios addressed above for the Proposed Development in isolation are not
significant. (Note that abnormal emissions were not considered in the
cumulative assessment as the IED abnormal operating requirements do not
apply to the AD Facility).
From the data in Table 40, the emissions of: Nitrogen Dioxide, Sulphur
Dioxide and Carbon Monoxide at the points of maximum GLC are not
significant; and
From the data in Table 41, the emissions of: Nitrogen Dioxide, Sulphur
Dioxide and Carbon Monoxide at the points of maximum GLC are not
significant.
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Assessment of Effects against PPiP Future Baseline Scenario
12.4.27 The AQA prepared in support of the application for the ZWF, concluded that
the predicted concentrations of pollutants are within the relevant air quality
objective and guidelines for the maximum point of ground level concentration,
for all ecological and human receptors and in relation to the cumulative effects
including the AD Facility. The same conclusions are reached in this
application, albeit with an increased stack height of 75m. Thus the operational
air quality effects of the Proposed Development would be neutral when
compared to the ZWF.
Decommissioning Effects
12.4.28 The decommissioning stage of the project would be similar to the construction
phase. The main effects on human health would be from dust (particulate
matter) which would be generated during any demolition of buildings and site
clearance operations.
12.4.29 As with the construction phase, it is likely that the effects of dust would be
limited to areas downwind within 200m elevated concentrations of dust are
most likely to occur on dry windy days and areas downwind of the prevailing
wind direction would be affected more frequently. As part of the PPC Permit
the site would have to be decommissioned in accordance with a Site Closure
Report which would include dust control measures. Consequently, in the event
that emissions of dust were to arise during decommissioning, they would be
controlled in such a manner to prevent a risk to human health. Accordingly,
there would be no significant effects during the decommissioning phase.
12.4.30 Mobile plant used would also produce emissions which may temporarily
increase levels of pollutants within a localised area, However, they would be
rapidly dispersed in the atmosphere.
12.5 Additional Mitigation
12.5.1 No additional measures are proposed to mitigate against potential adverse
impacts on air quality.
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12.6 Residual Effects
Residual Effects against Existing Baseline
12.6.1 In the absence of additional mitigation measures, the residual effects of the
Proposed Development would be as set out in Section 8.4 above.
Residual Effects against PPiP Future Baseline Scenario
12.6.2 In the absence of additional mitigation measures, the residual effects of the
Proposed Development would be as set out in sub-section 12.4 above.
12.7 Conclusions
12.7.1 An assessment has been carried out to determine the local air quality impacts
associated with the emissions from the Proposed Development, both on its
own and in combination with emissions from the adjacent AD Facility.
12.7.2 Detailed air quality modelling using the ADMS dispersion model has been
undertaken to predict the impacts associated with stack emissions from the
facilities. As a worst-case, emissions from the Millerhill RERC stack has been
assumed to be at the maximum ELV for the purposes of carrying out the
assessment. This represents a conservative assessment of the impact as the
actual emissions from the site are likely to be significantly lower.
12.7.3 A detailed screening assessment has been carried out to derive conservative
assumptions for the assessment and to determine the optimum discharge
stack height for the facility. This confirmed that the optimum stack height
is75m.
12.7.4 Predicted maximum GLCs (PCs) are within the short and long term air quality
objectives and are assessed as not significant (less than 1% of the AQS /
EAL) for most pollutants assessed. For those are potentially significant, further
screening has demonstrated that it is unlikely that any AQSs would be
exceeded as a result of emissions from the Proposed Development.
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12.7.5 A comparison of the actual monitoring data for FCC’s sister plant at Lincoln
with the IED ELVs was undertaken on the basis that it uses the same EfW
technology as the proposed Millerhill RERC development. Based on the data
from FCC’s Lincoln plant, the actual emission concentrations are, in the
majority of cases, much lower that the IED ELVs. PCs based on actual
emissions data were calculated and are, in most cases, much lower than
those based on the IED ELVs. As such, they can all be screened out as not
being significant.
12.7.6 For the sensitive habitat sites, it has again been demonstrated that the impact
from the Proposed Development is unlikely to result in a breach of the relevant
Critical Loads or Critical Levels, or have a detrimental effect on local habitat
sites. Therefore, the Proposed Development would not give rise to any
significant effects in this regard.
12.7.7 An assessment was also made of the impact of the Proposed Development
when operating under the abnormal conditions permitted under Article 46(6) of
the IED. The results of the assessment indicated that it would be unlikely that
any AQSs would be exceeded under such abnormal operating conditions and
thus, no significant effects would occur.
12.7.8 The cumulative impact of the Proposed Development and AD Facility has also
been considered. The assessment concluded that there would not be a
significant impact on local air quality or sensitive habitat sites.
12.7.9 In summary, therefore, it can be concluded that during its construction,
operation or decommissioning, the Proposed Development would not give rise
to significant effects on local air quality, or sensitive habitat sites, either in
isolation or in combination with the adjacent AD Facility.
12.7.10 Finally, an assessment has also been carried out of the Proposed
Development against the future baseline position associated with the PPiP
development. The assessment concluded that in relation to air quality the
effects of the Proposed Development during its construction, operation and
decommissioning would be ‘neutral’.
12.8 References
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12.8.1 All references used can be found in the main report, Appendix 12-1
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13.0 ARCHAEOLOGY AND CULTURAL HERITAGE
13.1 Introduction
13.1.1 This Chapter of the ES describes the effects of the Proposed Development on
archaeological and cultural heritage receptors. The potential for direct effects
upon heritage assets within the development boundary are assessed, as is
the potential for indirect effects upon the setting of heritage assets in a wider,
5km, study area. The need for mitigation, beyond that incorporated in the
design, is discussed and any residual effects identified.
13.1.2 The assessment considers the effect of the Proposed Development, in terms
of the existing baseline conditions. These are here assumed to include the
completed AD Facility immediately to the north of the Proposed Development,
the Borders Railway which passes the Proposed Development, on a north /
south alignment, to the west, and the SNCD which is located to the west and
northwest of the Proposed Development. The effects predicated from the
Proposed Development would be compared to the: ‘Future Baseline
Scenario’, which assumes construction of the consented PPiP development
(see Chapter 2.0 for full details).
Planning Policy and Guidance
National Planning Policy
13.1.3 The statutory framework for heritage in Scotland is outlined in the Town and
Country Planning (Scotland) Act 1997, as supplemented and amended by the
Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997 and
the Ancient Monuments and Archaeological Areas Act 1979, both of which are
modified by the Historic Environment (Amendment) (Scotland) Act 2011.
13.1.4 The implications of these acts with regard to local government planning policy
are described within Scottish Planning Policy (SPP)6, Scottish Historic
Environment Policy (SHEP)7 and Planning Advice Notes (PAN) for Scotland.
6 Scottish Government 2014, Scottish Planning Policy 7 Historic Scotland 2011, Scottish Historic Environment Policy
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SPP, SHEP and PAN 2/2011 ‘Archaeology and Planning' (Scottish
Government 2014) deal specifically with planning policy in relation to heritage.
The planning guidance expresses a general presumption in favour of
preserving heritage remains ‘in situ’ wherever possible. Their ‘preservation by
record’ (i.e. through excavation and recording, followed by analysis and
publication, by qualified archaeologists) is a less desirable alternative. SPP
expresses the following policy principles: “The planning system should:
Promote the care and protection of the designated and non-designated
historic environment (including individual assets, related settings and the
wider cultural landscape) and its contribution to sense of place, cultural
identity, social well-being, economic growth, civic participation and
lifelong learning; and
Enable positive change in the historic environment which is informed by
a clear understanding of the importance of the heritage assets affected
and ensure their future use. Change should be sensitively managed to
avoid or minimise adverse impacts on the fabric and setting of the asset,
and ensure that its special characteristics are protected, conserved or
enhanced.” (Scottish Government 2014, Para 137).
13.1.5 Paragraph 145 of SPP details the consideration of Scheduled Monuments
(SM) within development management, stating: “Where there is potential for a
proposed development to have an adverse effect on a scheduled monument
or on the integrity of its setting, permission should only be granted where there
are exceptional circumstances. Where the proposal would have a direct
impact on a scheduled monument, the written consent of Scottish Ministers
via a separate process is required in addition to any other consents required
for the development.” (Scottish Government 2014, Para 145).
13.1.6 SHEP (Historic Scotland 2011) sets out the Scottish Government’s policy for
the sustainable management of the historic environment. Key principles of the
policy note that: “there should be a presumption in favour of preservation of
individual historic assets wherever possible and also the pattern of the wider
historic environment; no historic asset should be lost or radically changed
without adequate consideration of its significance and of all the means
available to manage and conserve it.” (1.14.b).
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Local Planning Policy
13.1.7 Strategic policy is provided by the Strategic Development Plan for Edinburgh
and South East Scotland8, 2013 (SESPlan). Whilst detailed Historic
Environment Matters fall outside the remit of the Strategic Development Plan it
clearly respects Scottish Planning Policy, which contains policies for the
protection and enhancement of environmental resources including heritage
assets. Policy 1B of the SESPlan requires local authorities to ensure within
their own development plans that there are no: “significant adverse impacts on
the integrity of international and national built or cultural heritage sites.”9
13.1.8 The Midlothian Local Plan10 was adopted by MLC on the 23rd of December
2008 and provides an important framework for coordinating future
development and guidance in dealing with development proposals in
Midlothian. The following policies, relating to indirect effects on the settings of
designated heritage assets, contained within the Midlothian Local Plan are
relevant to the Proposed Development (Table 13.1):
Table 13.1: Cultural Heritage Policies relating to Indirect Effects contained within
the Midlothian Local Plan 2008
Policy No. Policy Extract
Policy RP22: Conservation Areas
Within or adjacent to a Conservation Area, development will not be permitted which would have any adverse effect on its character and appearance.
Policy RP24: Listed Buildings
Development will not be permitted which would adversely affect the character of the Listed Building, its setting or any feature of special architectural or historic interest that it possesses.
Policy RP25: Nationally Important Gardens and Designed Landscapes
Development will not be permitted which would harm the character or appearance or setting of a garden or designed landscape which is included in the Inventory of Historic Gardens and Designed Landscapes.
Policy RP26: Scheduled Monuments
Development which could have an adverse effect on a Scheduled Monument or the integrity of its setting will not be permitted.
Policy RP27: Other Important Archaeological or Historical Sites
Development will not be permitted where it could adversely affect an identified regionally or locally important archaeological or historic site or its setting unless the applicant can show that:
A. There is a public interest to be gained from the proposed development which outweighs the archaeological importance of the site.
8 SESPlan 2013
9 SESPlan 2003, Policy 1B
10 Midlothian Council, 2008, Midlothian Local Plan
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B. There is no alternative location for the proposal: and C. The proposal has been sited and designed to minimise damage
to the archaeological resource.
Policy RP 28: Assessment, Evaluation and Recording
Where any development proposal could affect an identified site of archaeological importance, the applicant will be required to provide an assessment of the archaeological value of the site and of the impact of the proposal on the archaeological resource.
Emerging Policy
13.1.9 Midlothian Council is currently in the process of preparing the Midlothian Local
Development Plan to replace the 2008 Local Plan. MLC approved the
Midlothian Local Development Plan Proposed Plan in 2014 and a Draft Plan is
due to be published in May 2015.
Planning Considerations Pertaining to the Site
13.1.10 The setting of Listed Buildings is a competent planning matter; Section 14.2 of
the Planning (Listed Buildings and Conservation Areas) Act 1997 states that
when determining applications for development which could impact upon the
setting of a listed building: “…the planning authority or the Secretary of State,
as the case may be, shall have special regard to the desirability of preserving
the building or its setting or any features of special architectural or historic
interest which it possesses.”
13.1.11 A new development must not impact upon the area of a SM without the prior
formal consent of Historic Scotland (HS). A development may not have a
direct, i.e. physical, impact upon a SM without Scheduled Monument Consent.
Setting is also a key consideration when determining applications which could
impact upon the settings of SMs, This principle is outlined in SPP Paragraph
145: “Where there is potential for a proposed development to have an adverse
effect on a scheduled monument or on the integrity of its setting, permission
should only be granted where there are exceptional circumstances. Where a
proposal would have a direct impact on a scheduled monument, the written
consent of Scottish Ministers via a separate process is required in addition to
any other consents required for the development.”11
11 Scottish Government 2014, Para 145
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13.2 Methodology
Assessment Methodology
Standards
13.2.1 The scope of this assessment meets the requirements of current planning
policy and advice set out in SPP, SHEP and PAN2/2011.
13.2.2 AOC Archaeology Group, who have undertaken this assessment, conforms to
the standards of professional conduct outlined in the Chartered Institute for
Archaeologists' Code of Conduct, the CIfA Code of Approved Practice for the
Regulation of Contractual Arrangements in Field Archaeology, the CIfA
Standards and Guidance for Desk Based Assessments, Field Evaluations
etc., and the British Archaeologists and Developers Liaison Group Code of
Practice. AOC is a Registered Archaeological Organisation of the Chartered
Institute for Archaeologists. This status ensures that there is regular
monitoring and approval by external peers of our internal systems, standards
and skills development. The company is ISO 9001:2008 accredited, in
recognition of its Quality Management System.
Consultations
13.2.3 HS were consulted by MLC in March 2014 in advance of this application. HS
noted that with regard to the PPiP application they agreed with the
conclusions of the ES and found that: “there are unlikely to be any significant
impacts on historic environment features within our statutory remit, and
offered no objection to the proposal.” HS did raise concerns over a statement
in the ES that SMs which are visible only as cropmarks do not have a setting,
a concern which will be addressed in this ES. Commenting prior to the raising
of the stack height to 75m, HS noted that: “It is unlikely that the amended
development would result in a significant adverse impact on the setting of
other assets within our remit.”12
12
Historic Scotland 04 March 2014, Letter to Midlothian Council ,Reference AMN/16/LC
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Assessment Structure
13.2.4 Each heritage asset referred to in the text is listed in the Gazetteer in
Appendix 13-1, which lists all designated heritage assets which fall within the
scope of the assessment. Each has been assigned a ‘Site No.’ unique to this
assessment which is cross referenced with its designation number within the
Gazetteer.
13.2.5 Each designated heritage asset, including archaeological or historical sites,
monuments or buildings, referred to in the text is plotted on location maps
(Figures 13.1 and 13.2), using the assigned Site Nos. The Proposed
Development area (the site) is outlined in red.
13.2.6 This assessment follows the methodology proposed in the Informal Scoping
Report13. Known heritage assets within the Proposed Development area have
been identified as have all SMs, Category ‘A’ Listed Buildings, Conservation
Areas, Inventoried Battlefields and Inventoried Gardens and Designed
Landscapes within 5km. Category ‘B’ and ‘C’ Listed Buildings which lie within
2km have been identified. No World Heritage Sites lie within 5km of the
Proposed Development.
13.2.7 Figure 13.1 depicts known heritage assets within the red line boundary as well
as all designated heritage assets located within a 2km of the Proposed
Development, whilst Figure 13.2 shows all SMs, Category A Listed Buildings,
Conservation Areas, Inventoried Battlefields and Inventoried Gardens and
Designed Landscapes within 5km.
13.2.8 Following the methodology outlined by the Informal Scoping Report a three
stage approach was adopted which:
Identified the historic assets that might be impacted by a proposed
change (Stage 1);
Defined the setting by establishing how the surroundings contribute to
the ways in which the historic asset or place is understood, appreciated
and experienced (Stage 2); and
13
Axis 2014, Millerhill Energy Recovery Facility: Environmental Impact Assessment, Informal Scoping Report, January 2014
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Assessed how any change would impact upon that setting (Stage 3).
13.2.9 All three stages are reported in appropriate detail as part of the assessment.
13.2.10 As part of Stage 1, ZTV analysis and site visits were used to determine either
whether the Proposed Development would be visible from the heritage asset
or whether, both would be visible in a third view, in such a manner that the
cultural heritage value of the designated heritage asset could potentially be
adversely effected.
13.2.11 A screening exercise was undertaken during the second stage of the
assessment, in order to determine whether any of the assets identified within
the study area would be potentially vulnerable to changes in setting resulting
from the Proposed Development. The screening briefly assessed the cultural
heritage value of each designated heritage asset, based upon the Listing /
citation text (or equivalent) for each asset. A conclusion is then drawn as to
whether the cultural heritage value of each asset is sensitive to changes in its
setting and if so, whether that sensitivity is such that the development could
potentially result in an adverse effect on that value. Where the screening
exercise concludes that there is scope for such an effect, then the asset in
question has been carried forward to the third stage in the assessment,
detailed consideration.
Sensitivity Criteria
13.2.12 The definition of cultural significance is readily accepted by heritage
professionals both in the UK and internationally and was first fully outlined in
the Burra Charter, which states in article one that ‘cultural significance’ or
‘cultural heritage value’ means aesthetic, historic, scientific, social or spiritual
value for past, present or future generations (ICOMOS 1999, Article 1.2). This
definition has since been adopted by heritage organisations around the world,
including HS. In their SHEP, HS note that to have cultural significance an
asset must have a particular: “artistic; archaeological; architectural; historic;
traditional (factors listed in the 1979 Act, (HMSO 1979); aesthetic; scientific;
[and/or] social [significance] – for past, present or future generations.” (2011,
71). Heritage assets also have value in the sense that they: “...create a sense
of place, identity and physical and social wellbeing, and benefits the economy,
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civic participation, tourism and lifelong learning” (Scottish Government 2014,
1). For clarity and to avoid confusion, the term cultural value would be used
throughout this assessment though, as outlined above, it is acknowledged this
is the same as cultural significance as identified in SHEP.
13.2.13 All heritage assets have some value, however some assets are judged to be
more important than others. The level of that importance is, from a cultural
resource management perspective, determined by establishing the asset’s
capacity to inform present or future generations about the past. In the case of
many heritage assets their importance has already been established through
the designation (i.e. scheduling, listing and inventory) processes applied by
HS.
13.2.14 The criteria used to establish importance in this assessment are presented in
Table 13.2 below and are drawn from Annexes 1-6 of SHEP which outline the
criteria for establishing National Importance:
Table 13.2: Criteria for establishing relative importance of heritage assets
Asset Importance
Criteria
International and National
World Heritage Sites;
Scheduled Monuments (Actual and Potential);
Category ‘A’ Listed Buildings;
Inventory Gardens and Designed Landscapes;
Inventory Battlefields; and
Fine, little-altered examples of some particular period, style or type.
Regional Category ‘B’ Listed Buildings;
Conservation Areas; and
Major examples of some period, style or type, which may have been altered;
Asset types which would normally be considered of national importance that have been partially damaged (such that their ability to inform has been reduced).
Local Category ‘C’ Listed Buildings;
Lesser examples of any period, style
or type, as originally constructed or altered, and simple, traditional sites, which group well with other significant remains, or are part of a planned group such as an estate or an industrial complex;
Cropmarks of indeterminate origin; and
Asset types which would normally be considered of regional importance that have been partially damaged or asset types which would normally be considered of national importance that have been largely damaged (such that their ability to inform has be reduced).
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Negligible Relatively numerous types of remains;
Findspots of artefacts that have no definite archaeological remains known in their context; and
Asset types which would normally be considered of local importance that have been largely damaged (such that their ability to inform has been reduced).
Assessment of Direct Effect
Establishing Magnitude of Effect
13.2.15 The magnitude of the physical impact upon heritage assets caused by the
development has been rated using the classifications and criteria outlined in Table
13.3 below.
Table 13.3: Criteria for Classifying Magnitude of Physical Effect
Criteria Magnitude
High Major loss of information content resulting from total or large-scale removal of deposits from a site whether or not the site is associated with a monument;
Major alteration of a monument’s baseline condition;
Any physical alteration to a Scheduled Monument;
Any physical alteration to a Category A Listed Building;
Massive alterations to a Category B or Category C Listed Building.
Medium Moderate loss of information content resulting from material alteration of the baseline conditions by removal of part of a site whether or not the site is associated with a monument;
Moderate alteration of a monument’s baseline condition.
Low Minor detectable impacts leading to the loss of information content;
Minor alterations to the baseline condition of a monument.
Marginal Slight or barely measurable loss of information content;
Loss of a small percentage of the area of a site’s peripheral deposits;
Very slight and reversible alterations to a monument.
None No physical impact anticipated.
Establishing Significance of Effect
13.2.16 The predicted significance of effect upon each asset is determined by
considering its importance in conjunction with the magnitude of impact
predicted on it. The method of deriving the significance of impact
classifications is shown in Table 13.4 over the page.
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Table 13.4: Method of Rating Significance of Effect on Heritage Assets
by the Proposed Development
Magnitude of Effect
Importance of Heritage Asset
Negligible Local Regional National International
High Minor-Moderate
Moderate* Moderate-Major*
Major* Extreme*
Medium Minor Minor-Moderate
Moderate* Moderate-Major*
Major*
Low Negligible Minor Minor-Moderate
Moderate* Moderate-Major*
Marginal Negligible Negligible Minor Minor-Moderate
Moderate*
None None None None None None
*The effects recorded in grey highlighted cells are ‘significant’ in terms of the Environmental Impact Assessment (Scotland) Regulations 2011
Indirect Effects
Establishing Sensitivity of Assets
13.2.17 Whilst determining the relative cultural value of a heritage asset is a key
consideration in establishing the importance of an asset and therefore its
sensitivity to direct effects, it is widely recognised (see Lambrick 2008) that the
importance of an asset is not the same as its sensitivity to changes to its
setting. Thus in determining effects upon the setting of assets by a proposed
development, both importance and sensitivity to changes to setting need to be
considered.
13.2.18 Setting is a key issue in the case of some, but by no means all assets. A
nationally important heritage asset does not necessarily have high sensitivity
to changes to its setting (relative sensitivity). An asset’s sensitivity to changes
to its setting refers to its capacity to retain its ability to inform this and future
generations in the face of changes to its setting. The ability of the setting to
contribute to an understanding, appreciation and experience of the asset and
its value also has a bearing on the sensitivity of that asset to changes to its
setting. Assets with high sensitivity will be vulnerable to changes which affect
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their setting and even slight changes may reduce their information content or
the ability of setting to contribute to the understanding, appreciation and
experience (see HS Setting Guidance 2010) of that asset. Less sensitive
monuments would be able to accommodate greater changes to their settings
without significant reduction in their ability to inform and in spite of such
changes the relationship between the assets and its setting would still be
legible. The relative sensitivity of SMs, Listed Buildings and other statutory
monuments and non-statutory monuments of national importance within the
study area to changes to their settings was determined using the criteria
outlined in Table 13.5.
Table 13.5: Criteria for Establishing Relative Sensitivity to Changes in Setting
Relative sensitivity
Criteria
High An asset whose setting contributes significantly to an observer’s understanding, appreciation and experience (Factors noted in HS guidance on setting 2010) of it should be thought of as having High Sensitivity to changes to its setting. This is particularly relevant for assets whose settings, or elements thereof, contribute directly and substantially to their significance (e.g. form part of their Contextual Characteristic (SHEP 2011, Annex 1). For example an asset which retains an overtly intended or authentic relationship with its setting and the surrounding landscape. These may in particular be assets such as ritual monuments which have constructed sightlines to and/or from them or structures intended to be visually dominant within a wide landscape area i.e. castles, tower houses, prominent forts etc.
An asset, the current understanding, appreciation and experience of which, relies heavily on its modern aesthetic setting. In particular an asset whose setting is an important factor in its protection (as per SPP 2014 definition of setting) and in retention of its cultural value.
Medium An asset whose setting contributes moderately to an observer’s understanding, appreciation and experience of it should be thought of as having Medium Sensitivity to changes to its setting. This could be an asset for which setting makes a contribution to significance but whereby its value is derived mainly its intrinsic characteristics (SHEP 2011, Annex 1). This could for example include assets which had an overtly intended authentic relationship with their setting and the surrounding landscape but where that relationship (and therefore the ability of the assets’ surroundings to contribute to an understanding, appreciation and experience of them) has been moderately compromised either by previous modern intrusion in their setting or the landscape or where the monument itself is in such a state of disrepair that the relationship cannot be fully determined.
An asset, the current understanding, appreciation and experience of which, relies partially on its modern aesthetic setting regardless of whether or not this was intended by the original constructors or authentic users of the asset. An asset whose setting is a contributing factor to its protection and the retention of its cultural value.
Low An asset whose setting makes some contribution to an observer’s understanding, appreciation and experience of it should generally be thought of as having Low Sensitivity to changes to its setting. This may be an asset whose main significance lies in its intrinsic characteristics and whereby changes to its setting would not materially diminish our understanding, appreciation and experience of it. This could for example include assets which had an overtly intended authentic relationship with their setting and the surrounding landscape but where that relationship (and therefore the ability of the
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assets’ surroundings to contribute to an understanding, appreciation and experience of them) has been significantly compromised either by previous modern intrusion to its setting or landscape or where the asset itself is in such a state of disrepair that the relationship cannot be determined.
Marginal An asset whose setting makes minimal contribution to an observer’s understanding, appreciation and experience of it should generally be thought of as having Marginal Sensitivity to changes to its setting. This may include assets for which the authentic relationship with their surrounding has been lost, possibly having been compromised by previous modern intrusion, but who still retain cultural value in their intrinsic and possibly wider contextual characteristics.
13.2.19 The determination of an asset’s sensitivity is first and foremost reliant upon
the determination of its setting. The criteria set out in Table 13.3 above are
intended to be a guide. Assessment of individual assets will be informed by
knowledge of the asset itself, of the asset type if applicable and by site visits
to establish the current setting of the assets. This would allow for the use of
professional judgement and each asset would be assessed on an individual
basis. It should be noted that assets may fall into a number of the sensitivity
categories presented above e.g. a country house may have a high sensitivity
within its own landscaped park or garden but its level of sensitivity to changes
in the wider setting may be less.
13.2.20 In establishing the relative sensitivity of an asset to changes to its setting an
aesthetic appreciation of that asset and its setting must be arrived at.
Appendix 13-2 alongside Appendix 13-3 outlines the range of factors which
must be considered when establishing an aesthetic appreciation and therefore
determining sensitivity. These have been used as a guide in assessing each
asset from known records and in the field. In defining these criteria, emphasis
has been placed on establishing the current setting of each asset.
Magnitude of Effect
13.2.21 The magnitude of effect by a proposed development is an assessment of the
magnitude of change to the setting of any given designated heritage asset.
Table 13.6 (over the page) outlines the main factors affecting magnitude of
effect.
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Table 13.6: Factors Affecting Magnitude of Effect
Site Details Importance of detail for assessing Magnitude of Effect
1 Proximity to centre of development
The greater the distance an asset is from the proposed development would in most cases diminish the effects on its setting.
2 Visibility of development (based on ZTV model and
wire lines where appropriate)
The proportion of the development that would be intervisible with the asset would directly affect the magnitude of effect on its setting.
3 Complexity of landscape The more visually complex a landscape is, the less prominent the new development may seem within it. This is because where a landscape is visually complex the eye can be distracted by other features and would not focus exclusively on the new development. Visual complexity describes the extent to which a landscape varies visually and the extent to which there are various land types, land uses, and built features producing variety in the landscape.
4 Visual obstructions This refers to the existence of features (e.g. tree belts, forestry, landscaping or built features) that could partially or wholly obscure the development from view. The form of mapping called ZTV always presents a worst case scenario for visibility precisely because the readily accessible digital mapping does not take cognisance of vegetation, structures and local micro-topography. Site visits are always necessary for a real appraisal of the magnitude of effects.
13.2.22 It is acknowledged that Table 13.6 primarily deals with visual factors affecting
setting. While the importance of visual elements of settings, e.g. views,
intervisibility, prominence etc., are clear, it is acknowledged that there other,
non-visual factors which could potentially result in setting effects. Such factors
could be other sensory considerations, e.g. noise or smell, or could be
associative. Where applicable these would be considered in coming to a
conclusion about magnitude of effect. Once the above has been considered,
the prediction of magnitude of effect upon setting would be based upon the
criteria set out in Table 13.7 (over the page). In applying these criteria particular
consideration would be given to the relationship of the Proposed Development
to those elements of setting which have been defined as most important in
contributing to the ability to understand, appreciate and experience the heritage
assets and its value.
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Table 13.7 Criteria for Establishing Magnitude of Effect on Setting
Magnitude of setting effect
Criteria
High Direct and substantial visual impact on a significant sightline to or from a ritual monument or prominent fort;
Direct severance of the relationship between an asset and its setting;
Major alteration to the penumbral or close settings of a Scheduled Monument;
Major imposition within a Cultural Landscape;
An effect that changes the setting of an asset such that it threatens the protection of the asset (SPP 2014) and the understanding of its cultural value.
Medium Oblique visual impact on an axis adjacent to a significant sightline to or from a ritual monument but where the significant sightline of the monument is not obscured;
Impacts upon the glacis of a prominent fort (based on the proportion of the glacis that would be obscured);
Partial severance of the relationship between an asset and its setting;
Significant alteration to the setting of an asset of beyond those elements of the setting which directly contribute to the understanding of the cultural value of the asset;
Significant but not major imposition within a Cultural Landscape.
An effect that changes the setting of an asset such that the understanding of the asset and its cultural value is diminished.
Low Peripheral visual impact on a significant sightline to or from a ritual monument;
Insignificant alteration to the setting of an asset of beyond those elements of the setting which directly contribute to the understanding of the cultural value of the asset;
Minor imposition within a Cultural Landscape.
An effect that changes the setting of an asset, but where those changes do not materially affect an observer’s ability to understand, appreciate and experience the asset.
Marginal All other setting effects.
None No setting effects anticipated.
Establishing Significance of Effect
13.2.23 The significance of the effect on the setting of cultural heritage assets is
judged to be the interaction of the asset’s sensitivity to changes to its setting
(Table 13.5) and the magnitude of the effect (Table 13.7) and also takes into
consideration the importance of the asset (Table 13.2). In order to provide a
level of consistency to the assessment of sensitivity, the prediction of
magnitude of effect and the assessment of significance of effect have been
guided by pre-defined criteria.
13.2.24 The interactions determining significance of effect on settings is shown in
Table 13.8 over the page.
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Table 13.8: Significance of Effect on the Setting of Heritage Assets
Impact
magnitude
Relative Sensitivity
Marginal Low Medium High
High Minor Minor-Moderate Moderate* Major*
Medium Negligible Minor Minor-Moderate Moderate*
Low None/Negligible Negligible Minor Minor-Moderate
Marginal None None Negligible Minor
*The effects recorded in grey highlighted cells are ‘significant’ in terms of the Town and Country Planning (Environmental
Impact Assessment) (Scotland) Regulations 2011.
13.3 Baseline
Baseline Data Collection
13.3.1 The following data sources were consulted during preparation of this
assessment:
National Monuments Record for Scotland (NMRS) (RCAHMS, Bernard
Terrace, Edinburgh). For NMRS data, aerial photographs, archive
photographs, NMRS maps, various archaeological and historical
publications, and unpublished archaeological reports;
National Map Library (National Library of Scotland, Causewayside,
Edinburgh): For old Ordnance Survey maps (1st & 2nd Edition, small-
and large-scale) and pre-Ordnance Survey historical maps;
Historic Scotland (Longmore House, Salisbury Place, Edinburgh): For
SM data, Listed Buildings data, Conservation Area data, Inventoried
Battlefield Data and Inventory Garden and Designed Landscape data;
Midlothian Historic Environment Record (online; John Gray Centre,
Haddington): for Historic Environment Record Data; and
ES prepared in support of the application for PPiP (2011).
13.3.2 This assessment is based upon data obtained from publicly accessible
archives as described above and visits to designated heritage assets
undertaken during November 2014 and March 2015. All site visits to
designated heritage assets were undertaken in clear weather and a
photographic record was maintained.
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Baseline Conditions
13.3.3 The Proposed Development area lies between the operational Millerhill
railway marshalling yards and the site of the former Monktonhall Colliery a
now demolished 1960’s ‘super pit’. The marshalling yards originally extended
westwards across the Proposed Development area. The area is now derelict
and overgrown with young birch. This forms the Proposed Development site’s
current baseline context.
13.3.4 The existing baseline for this ES assumes that:
The site remains in its current undeveloped condition (see previous
paragraph);
The AD Facility immediately to the north of the Proposed Development
would be constructed and operational with a maximum roof height of
17.3m.
The SNCD to the west would have been constructed in accordance with
the approved masterplan;
The Borders Railway is constructed and operational and
That the site access bridge over the Borders Railway is in place and
operational.
Archaeological and Cultural Heritage Baselines within the Proposed
Development Area
13.3.5 There are three heritage assets recorded within the Proposed Development
boundaries. These include a portion of the Millerhill Marshalling Yards (Site
223) which was one of five large marshalling yards built in Scotland the early
1960s in an attempt to modernise British Railways. The western part of the
yards, where the Proposed Development is located, was closed in 1983 the
eastern part remains operational.14 The former Innocent Railway (Site 224)
was a tramway opened in 1831 and later purchased by the British Railway
Company who upgraded the track for use by trains and reopened the line in
1847.15 The former route of the railway runs along the eastern boundary of the
14
Rhodes, M. 1988. The illustrated history of British marshalling yards. passim. esp. 105-13 15
Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011) Appendix 11.1
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Proposed Development and crosses the south-eastern corner where it turned
southwest. An associated bit of track was located in the western portion of the
Proposed Development area, as shown on Figure 13.1.
13.3.6 The only other known heritage asset within the Proposed Development
boundaries is the site of the no longer extant Middlefield Farmstead (Site 225),
which was shown in the northeast corner of the Proposed Development on
Roy’s Map of 1747-55. It did not appear on later maps.16
13.3.7 The remains are considered to be of negligible importance as they are
common types and unremarkable. The ground disturbance caused by the
construction of the marshalling yards in the 1960s is likely to have resulted in
the destruction, or at least significant damage, of any archaeological remains
associated with the Innocent Railway and the former farmstead. The works
associated with the construction of the marshalling yard also means that there
is negligible potential for encountering hitherto unknown remains within the
Proposed Development boundaries. The marshalling yard is also considered
to be of negligible significance being of modern date and unremarkable type.
There are extant marshalling yards of this type.
Baselines for the 5km Assessment Area
13.3.8 With regard to the potential for indirect effects upon the settings of designated
heritage assets, GIS data downloads obtained from HS record 43 SMs, 86
Category ‘A’ Listed Buildings, 13 Conservation Areas, 13 Inventoried Gardens
and Designed Landscapes and one Inventoried Battlefield (Pinkie, 1547)
within 5km of the Proposed Development area. A further 24 Category ‘B’
Listed and 46 Category ‘C’ Listed Buildings are located within 2km of the
Proposed Development area. In total 222 designated heritage assets fall
within the scope of this assessment. The nearest of these, the Category B
Listed Building at Whitehill Mains farmhouse (Site 142) stands to the north of
the development, west of the northern end of the former railway siding and
within circa 100m of the site access track.
16
Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011) Appendix 11.1
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 360
13.3.9 All 222 designated assets are listed in the Gazetteer (Appendix 13-1) and
mapped on Figures 13.1 (2km assessment area) and 13.2 (5km assessment
area). The identification of these assets and their presentation within the
gazetteer was carried out as Stage 1 of the methodology described in 13.2.10
and 13.3.1 above).
13.3.10 Detailed consideration of the settings of these designated assets is included in
the sub-section 13.4, which references the current settings of these assets. It
is however appropriate to note here that the Proposed Development site is
located on the eastern fringe of Edinburgh across which an established
suburban and industrial landscape extends. The prominent building within this
landscape, Queen Margaret’s University stands to the north of the Proposed
Development, north of the A1 dual carriageway, whilst railway lines, overhead
power lines and the retail sheds both within and surrounding the Fort Kinnaird
Retail Park at Newcraighall appear in existing views of the Proposed
Development from many of the designated heritage assets. The 2km and 5km
assessment areas contain urban settlements including the Edinburgh suburbs
of Liberton, Gilmerton, Craigmillar, Prestonfield, Duddingston, Craigentinny
and Portobello; the East Lothian communities of Musselburgh and Inveresk
and the Midlothian settlements of Danderhall, Dalkeith and Lasswade. These
urban areas all prohibit views of the Proposed Development from certain
designated assets within them. The AD Facility, Borders Railway and the
SNCD form part of the baseline and also screen the Proposed Development
when viewed from a number of heritage assets. Whilst the Proposed
Development area is currently brownfield, a number of high floodlights stand
on the adjacent operational marshalling yards and these were of use in
locating the proximity of the Proposed Development within views when
undertaking the site visits.
13.3.11 It is within this landscape and townscape context, much altered from the
settings within which many of the designated assets were created, that any
visibility with the Proposed Development would occur.
PPiP Future Baseline Scenario
13.3.12 The PPiP ES determined that there is a potential for a: “major impact upon
known features of negligible sensitivity, leading to an impact of negligible
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 361
significance”.17 The PPiP ES also found that due to the previous ground
disturbance there is: “negligible potential for the survival of previously
unrecorded cultural heritage assets.”18 within the site. In the event that PPiP
development was progressed any existing archaeological remains on site
would be destroyed.
13.3.13 The PPiP ES’s Cultural Heritage Chapter concluded that there would be no
significant impacts upon the setting of any designated heritage assets within
the 5km study area. IGDLs were assessed in the LVIA chapter of the PPiP
ES. This assessment found a significant effect upon the designated
landscape at Newton House (Site 216)
13.3.14 The effects predicted for the future Baseline Scenario, as set out above, would
be compared against the predicted effects of the Proposed Development in
sub-section 13.4 below.
13.4 Assessment of Effects
Incorporated Mitigation
13.4.1 Design measures which have been incorporated to minimise the effects of the
development, including the potential for adverse effects on the settings of
designated heritage assets are summarised in Chapter 7.0 (Paragraph 7.4.1).
Measures which are particularly helpful in reducing the effect of the Proposed
Development on heritage assets include:
Form of buildings;
o The buildings have been designed using the principal that the
process equipment should be enclosed in a volumetrically efficient
manner so as to minimise the overall building height and volume.
Colour of buildings;
o The built form has been designed with a dark ‘plinth’ below a paler
upper structure. This has the effects of ‘grounding’ the building
and reducing the apparent overall scale.
17
Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011) Para 11.6.3 18
Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011)Para 11.6.4
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 362
Construction Phase - Direct Effects
Assessment of Effects against Existing Baseline
13.4.2 Potential effects on known or unknown buried archaeological remains in the
case of the Proposed Development relate to the possibility of disturbing,
removing or destroying in situ remains and artefacts during ground-breaking
works (including excavation, construction and other works associated with the
development) on the site.
13.4.3 Only three sites have been identified within the Proposed Development
boundary and these include the marshalling yard (Site 223), a post medieval
tram / railway (Site 224) and the former site of Middlefield Farmstead (Site
225). While it is unlikely that any remains of the Innocent Railway or the
farmstead survive, given the development of the marshalling yard in the
1960s; the development would result in a High magnitude effect to any
surviving remains. The Proposed Development would have a High magnitude
effect upon any surviving remains of the marshalling yard as well. Given the
negligible importance of these heritage assets such effects would result in, at
worst, effects of Minor-Moderate significance. Such effects are not considered
to be significant in terms of EIA Regulations.
13.4.4 There is a negligible potential for previously unrecorded remains to survive
within the Proposed Development area. Assessment of Effects against PPiP
Future Baseline Scenario
13.4.5 The PPiP ES also found that land within the Proposed Development
boundaries had been extensively disturbed during the construction of the
Millerhill marshalling yards and considered that, while there remains a
potential for direct effects on archaeological remains, these would not be
Significant. Whilst the location of the specific proposed groundworks may
differ, the Proposed Development lies within the boundaries of the site
consented under the PPiP scheme. Any direct effects resulting from the
Proposed Development, would be unchanged, in terms of significance of
effect, from those effects consented under the PPiP. The difference in effect
between the Proposed Development and the PPiP Future Baseline Scenario
is consequently neutral.
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Constructional Phase - Indirect Effects
13.4.6 Whilst it is acknowledged that there could be some indirect effects on setting
during the construction phase, for example as a result of the construction plant
and machinery such as cranes, as well as the partially constructed energy
plant itself, these would be temporary in nature and are not judged to be
significant. Any effects upon the setting of heritage assets during the
construction phase would be of lower magnitude than effects during the
operational phase. As such detailed consideration of effects upon setting are
discussed in the section on the operational phase below
Operational Phase - Direct Effects
Assessment of Effects against Existing Baseline
13.4.7 No direct effects on buried archaeological remains would occur during the
operational phase, as any direct effects would cease following the completion
of construction.
Assessment of Effects against PPiP Future Baseline Scenario
13.4.8 The Cultural Heritage Chapter for the PPiP ES noted that there would be no
direct effects on heritage assets during the operational phase as any effects
would cease following the completion of the construction phase. A comparison
of the effects of the Proposed Development with the effects of PPiP future
baseline scenario indicates that there would be no difference in the effects
and as such they are neutral.
Operational Phase - Indirect Effects
13.4.9 Indirect effects include effects upon the settings of designated heritage assets
including Listed Buildings, SMs, Historic Gardens and Designed Landscapes
and Inventoried Battlefields. No such designated assets are located within the
Proposed Development area although this assessment has identified 222
designated heritage assets within the 2km and 5km assessment areas (Stage
1). These designated assets are listed in the Site Gazetteer (Appendix 13-1).
Figure 13.1 records all designated heritage assets located within 2km of the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 364
Proposed Development, whilst Figure 13.2 shows all SMs, Category ‘A’ Listed
Buildings, Conservation Areas, Inventoried Battlefields and Inventoried
Gardens and Designed Landscapes within 5km. There are no World Heritage
Sites located within 5km of the Proposed Development although the
Edinburgh Old and New Town World Heritage Site extends to within 5.8km of
the Proposed Development.
13.4.10 Initially this section considers the effects of the Proposed Development, with a
41.6m roofline and a 75m stack upon the existing baseline. The subsequent
section, the Assessment of Effects against PPiP Future Baseline Scenario,
will measure this assessment against those predicted effects already
consented under the PPiP scheme, for a 20m roof height and a 65m stack
height, in order to assess the difference in the levels of effect resulting from
the two developments.
Assessment of Effects against Existing Baseline
13.4.11 ZTV Analysis has shown that 26 designated assets (Sites 28, 39, 51, 52, 57,
64, 70, 74-7, 86-7, 99-102, 108, 110, 112-3, 122, 124, 125 and 145) fall
outside the ZTV for both the 41.6m roofline and the 75m stack elements of the
Proposed Development and as a consequence no intervisibility with any
elements of the Proposed Development is predicted. Similarly site visits found
that intervening buildings, trees and townscapes will prohibit visibility from a
further 59 designated assets (Sites 27, 32-5, 37, 41, 44 -6, 53-6, 59, 65-7, 71
– 3, 78–80, 82, 88- 91, 93 -4, 97, 104-7, 109, 111, 118, 120-1, 130, 136, 162,
194, 196–201. 203, 213-5, 217-9). The Shawfair New Community
Development, assumed to have been built for the purposes of this
assessment, will screen the Proposed Development from the Category B
Listed Chalfont (Site 134) and from the Category ‘B’ Listed Edmonstone
House East Gate Lodge (Site 128). The North Danderhall element of the
SNCD will surround the Category A Listed Woolment House Gateway (Site
61) and impede views toward the Proposed Development. Consequently, the
setting of these assets would not be affected by the Proposed Development
and they are not discussed further.
13.4.12 Forty-three SMs fall within 5km of the Proposed Development, of which 23 of
the designations (Sites 2-6, 7-8, 10-15, 18-20, 22-6, 29, 31 and 43) represent
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 365
buried archaeological remains recorded only from cropmark evidence, whilst
Site 9 is only detectable on the ground surface as a vegetation mark. Whilst
upstanding remains associated with Site 6, the late prehistoric fort at St Mary’s
Mount do survive, these are only present within a wood and the majority of the
site is only identifiable through cropmarks. Cropmarks are often only
detectable from aircraft and are visible at certain times of the year within
specific types of crops. Cropmarks result from specific weather conditions
which cause the moisture levels within buried features to vary from the levels
within the surrounding soils. It can be reasonably argued that where no
upstanding remains survive, such as is the case with these Scheduled
Monuments, their value primarily lies in their intrinsic characteristics,
represented by their buried remains. The contribution that their setting makes
to an understanding of them and their cultural value is limited and as a
consequence does not have the potential to reach the level deemed
significant in terms of the EIA regulations. A further five Scheduled
Monuments (Sites 16-7, 36, 38 and 42), all associated with Inveresk Roman
Fort and settlement, now lie buried beneath the modern settlement and
therefore have no visual presence within the landscape. Consequently, whilst
all these SMs have been considered as part of this assessment no significant
effect has been found and as such they are not discussed further here.
13.4.13 A site visit to Duddingston Parish Church (Site 121), its churchyard (Site 47)
and watch tower (Site 58), found that visibility from the churchyard and church
would be entirely blocked by the intervening churchyard wall. Whilst the watch
tower rises above the height of the wall, the ‘windows’ on the two elevations
facing the Proposed Development are false, that is to say that they are
geometric Georgian window frames painted onto stone indentations.
Consequently there would be no visibility from any of these three assets and
no effect on their settings
13.4.14 Two villas Eskbank House (Site 81) and 12 Melville Road (Site 92) both lie
within the settlement of Eskbank. Whilst the potential for visibility from these
cannot be discounted, any visibility would be severely compromised by
intervening trees and the townscape. It is also clear that both the original
authentic setting of these villas and their modern associative setting, relates
solely to the settlement of Eskbank and adjacent market town of Dalkeith and
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 366
its gradual evolution, which the villas in part represent. For these reasons any
effect on the setting of these two buildings assets would not be Significant.
13.4.15 The settings of the Conservation Areas of Broomieknowe (Site 204) and
Lasswade and Kevock (Site 206), relate primarily to the immediate
surroundings of the settlements that the designations protect. The
Conservation Area Appraisal for Lasswade and Kevock defines the key views
within the Conservation Area as extending along the axis of the River North
Esk, which lies outwith the ZTV. The Scheduled remains of Lasswade Old
Church (Site 1) within the Conservation Area lies on the extreme periphery of
theoretical visibility. Any theoretical visibility from these Conservation Areas
would be further compromised by the presence of trees, within the thickly
planted designated areas and intervening buildings. For these reasons any
effect on the setting of these assets would not be Significant and they are not
considered further.
13.4.16 The Conservation Areas of Newbattle (Site 205) and Dalkeith House and Park
(Site 207) substantially overlap the boundaries of the Inventoried Gardens and
Designed Landscapes of Newbattle (Site 219) and Dalkeith Palace (Site 209)
and to avoid duplication would be considered in relation to the inventoried
areas.
13.4.17 Willie’s Temple (Site 73) stands within the grounds of Melville Castle.
Although it was originally intended to be a visual marker within the designed
landscape, the single storey structure now stands within woodland which
would prevent intervisibility with the Proposed Development and consequently
no effect on its setting is predicted.
13.4.18 Thirty nine Category ‘C’ Listed Buildings (Sites 149, 152-3, 155-160 and 164
to 193) extend to the north of the development along the axis of Newcraighall
Road. These buildings all relate to Newcraighall a small planned 19th century
colliery village formed around the Klondyke pit, which stood immediately north
of Newcraighall Road, between the two clusters of Listed Buildings. The mine
closed in the 1960’s and its site has now been developed as a leisure and
retail park, meaning that the relationship between the village and the mine has
now been lost and can only be understood through historical OS mapping.
The site visit demonstrated that visibility with the Proposed Development
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 367
would be largely blocked by intervening buildings which line the southern side
of Newcraighall Road. However, the possibility of very limited visibility
occurring from one or two of the cottages along the terraces cannot be
discounted. Visibility is more likely from the parish church and hall (Site 166),
the primary school (Site 183) and the miners’ welfare institute (Site 168),
although these views would be impeded by the intervening presence of the A1
embankment. However the significance of Sites 166, 183 and 168 is derived
from their common intent, to improve the wellbeing and education of the
miners and their families and the significance of all the Listed Buildings at
Newcraighall lies in their relationships to one another and the wider village in
which they are set and their geographical placing in relation to the mine. This
means that whilst limited visibility is predicted from the Newcraighall assets,
the Proposed Development would not have the potential to have a Significant
effect on their setting For these reasons these assets are not considered
further, although the Category B Listed Craigmillar Arts Centre (Site 129), a
former church at the extreme western end of Newcraighall would be
assessed.
13.4.19 Fifty three designated assets which have a potential for a Significant effect on
their settings, either because of their Relative Sensitivity to changes in their
settings or because of their proximity to the Proposed Development have
been taken forward to detailed assessment and are noted in Table 13.9
below.
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Table 13.9 Significance of Effect on the Setting of Heritage Assets
Site No.
Site Name Designation Distance to Stack
Current Factors Affecting Visibility within the Existing Baseline
Relative Sensitivity
Magnitude of Effects
Level of Effects (*
Significant Effect
21 Newton Church, Enclosures and Field System
Scheduled 1.9km None Medium Low Minor
30 Craigmillar Castle and Gardens
Scheduled, Category A
Listed
3.57km Only the eastern part of the Scheduled area falls within the ZTV
High Marginal Minor
40 Holyrood Park Scheduled 3.95km Only the eastern part of the Scheduled area falls within the ZTV
High Marginal Minor
49 Inveresk, Inveresk Lodge, Sundial
Category A Listed
2.85km Trees will partially impede view Low Low Negligible
50 Musselburgh, Newhailes Stables
Category A Listed
1.82km Trees and structures within the parkland will block visibility
High None None
62 Inveresk, Inveresk Village Road, Halkerston
Category A Listed
2.83km Trees may partially impede visibility from the garden
High Low Minor-Moderate
63 Inveresk, Inveresk Village Road, Halkerston Stable
Category A Listed
2.85km Intervening building will block visibility from the stable
- None None
68 Musselburgh Old Bridge Category A Listed
2.61km Trees and intervening buildings will at least partially block visibility
High Marginal Minor
83 Old Craighall, Old Craighall Road, Monkton House, Stable with Sundial
Category A Listed
1.13km Trees within the grounds and the northwest boundary wall will impede visibility
Medium Low Minor
84 Inveresk, The Manor House Category A Listed
2.83km Trees will partially impede visibility High Low Minor-Moderate
85 Inveresk, The Manor House, East Pavilion
Category A Listed
2.85km Trees will at least partially block visibility High Marginal Minor
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95 Old Craighall, Old Craighall Road, Monkton House
Category A Listed
1.15km Views to the northwest from the house are blocked by the intervening stable block, trees within the grounds and the wall along the northern boundary of the grounds. Limited windows in the north elevation
High Low Minor-Moderate
96 Inveresk, Inveresk Lodge, Outbuilding Remains
Category A Listed
2.83km Trees will partially impede visibility Low Low Negligible
98 Musselburgh, Newhailes Category A Listed
2.05km Trees will block visibility None None None
103 Dalkeith House Category A Listed
2.90km House on periphery of ZTV, tree belts will block visibility
High None None
115 Inveresk, Inveresk Lodge Category A Listed
2.85km Trees will partially block visibility High Low Minor-Moderate
116 Musselburgh, Inveresk Parish Church and Graveyard
Category A Listed
2.58km Intervening trees and buildings will block visibility from the church and graveyard
High None None
119 Edinburgh, Craigmillar Castle, Dovecot
Category A Listed
3.47km Intervening trees and buildings may partially block visibility
High Marginal Minor
123 Inveresk, The Manor House, Dovecot
Category A Listed
2.76km Trees will at least partially block visibility Low Marginal None
126 Millerhill, Newton Farmhouse Category B Listed
1.23km Visibility may be partially impeded by intervening features
Medium Low Minor
127 Newton House Category B Listed
1.29km Trees will impede visibility Medium Low Minor
129 Edinburgh, 58 Newcraighall Road, Craigmillar Arts Centre
Category B Listed
1.59km Visibility will be most apparent from the rear of the building and may be partially impeded by intervening buildings and trees. The Proposed Development would be mostly screened by the Shawfair New Community Development, AD Plant and
Medium Marginal Negligible
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Borders Railway.
131 Castlesteads House, Dovecot
Category B Listed
1.56km Trees will block visibility Low Marginal None
132 Edinburgh, Brunstane House Steading
Category B Listed
1.88km Intervening trees and townscape will block visibility
Low None None
133 Newton Village, Newton Church
Category B Listed
1.50km The Shawfair New Community Development will likely fully impede visibility of the Proposed Development though visibility of the stack cannot be completely discounted
High Marginal Minor
135 Musselburgh, Newhailes, Walled Gardens, Fruit Store and Terraced Walk
Category B Listed
1.89km Trees and structures within the parkland will block visibility
High None None
137 Millerhill, Newton House, Newton Dovecot
Category B Listed
1.3km Located within wooded garden adjacent to Newton House.
19
Medium Low Minor
138 Whitehill Mains Farmhouse Category B Listed
0.66km Property derelict and boarded up, trees will at least partially block visibility. The Proposed Development will be mostly screened by the AD Plant and Borders Railway
Low Marginal None
141 Musselburgh, Newhailes, Dovecot
Category B Listed
1.84km Trees and structures within the parkland will block visibility
High None None
142 Musselburgh Newhailes Grotto
Category B Listed
2.09km Trees and structures within the parkland will block visibility
High None None
143 Musselburgh, Stoneyhill, Former Steading
Category B Listed
2.09km Possible visibility from upper floor rear windows (possibly later insertions during residential conversion)
Low Marginal None
19
Historic Scotland’s co-ordinates incorrectly place the dovecot within a ploughed field c.1km west of its correct location.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 371
144 Musselburgh Newhailes, Earl of Stair’s Monument
Category B Listed
2.08km Trees and structures within the parkland will block visibility
High None None
146 Musselburgh, Newhailes, Ice House
Category B Listed
1.99km Trees and structures within the parkland will block visibility
High None None
147 Musselburgh, Newhailes, Main Gate with Gate Piers
Category B Listed
1.72km Trees and structures will partially block visibility
High Marginal Minor
148 Old Craighall, Monkton House, Gardener’s House with Sundial
Category B Listed
1.11km Trees and structures will partially block visibility
Medium Low Minor
150 Musselburgh, Newhailes, Gardener’s Cottage
Category C Listed
1.79km Trees and structures within the parkland will block visibility
High None None
151 Millerhill, Newton Farmsteading and Gatepiers
Category C Listed
1.22km Large metal sheds will block visibility from the core of the steading
Low Marginal None
154 Smeaton Shepherds Cottage, Stable Court
Category C Listed
1.90km A720 Edinburgh Bypass intervenes between stables and Proposed Development
Low Marginal None
161 Smeaton, Shepherd’s Cottage
Category C Listed
1.90km A720 Edinburgh Bypass intervenes between cottage and Proposed Development
Medium Marginal Negligible
163 Newton Village, Newton Church, Watch House
Category C Listed
1.54km The Shawfair New Community Development will likely fully impede visibility of the Proposed Development though visibility of the stack cannot be completely discounted
Low Marginal None
195 Musselburgh Conservation Area
2.37km Trees and the intervening townscape will largely block visibility
High Marginal Minor
202 Inveresk (Musselburgh) Conservation Area
1.90km The Proposed Development would only be partially visible in outward views from the southern side of the Conservation Area
High Low Minor-Moderate
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208 Inveresk Lodge Garden Inventoried Garden and Designed
Landscape
2.64km Intervening trees will partially block visibility
High Low Minor-Moderate
209 Dalkeith House (Palace) Inventoried Garden and Designed
Landscape
1.88km Tree belts will largely if not completely block visibility
High (core of IGDL)
Marginal (worst case,
core of IGDL)
Minor (worst case, core of
IGDL)
The Proposed Development will be visible from the northern part of the IGDL, including from a footbridge crossing the A68.
Low (footbridge
A68)
Low (footbridge
A68)
Negligible (footbridge
A68)
210 Carberry Tower Inventoried Garden and Designed
Landscape
3.67km Tree belts will partially impede visibility High Marginal Minor
211 Palace of Holyroodhouse Inventoried Garden and Designed
Landscape
4.25km Only the eastern part of the park falls within the ZTV
High Marginal Minor
212 Newhailes Inventoried Garden and Designed
Landscape
1.57km Trees and structures both within and beyond the parkland will largely block visibility
High Low Minor-Moderate
216 Newton House (Midlothian) Inventoried Garden and Designed
Landscape
1.07km Core garden area thickly planted with trees. Wider designated field system bisected by A720 Edinburgh bypass.
Medium Low Minor
220 Craigmillar Castle Inventoried Garden and Designed
Landscape
3.31km Only the eastern part of the Inventoried area falls within the ZTV
High Marginal Minor
221 Pinkie Inventoried 850 m The visibility of the development will be Medium Low Minor
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Battlefield variable throughout the Inventoried area, but it will be visible from Inveresk Fields and from certain locations on the slopes of Falside and Carberry Hill.
222 Edinburgh, Brunstane House Category A Listed
1.88km Intervening trees and townscape will at least partially block visibility at ground floor level
High Marginal Minor
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13.4.20 The Category ‘A’ Listed Monkton House (Site 95) (Plate 2) stands to the
southeast of the site and is a substantial, three storey, late 17th century, L plan
laird’s house attached to an earlier 16th century tower. The property’s origins
are unclear, although it is believed to have originated prior to the reformation
as a grange for the Cistercian abbey at Newbattle. The property faces
southeast over its gardens and the principal windows are located within this
elevation. The house’s northwest elevation, by contrast contains fewer
windows, all of which are either set within the stair turret or an adjacent
landing. The house’s separate one and a half storey stable block (Site 83) of
circa 1625 is set to the northwest of the house to form small courtyard and is
clearly ancillary to the main structure. Both the house and the stable block are
Category ‘A’ Listed and together have a coherent collective value as a well
preserved example of a 17th century Lothian lairds seat. It is therefore
reasonable to argue that the ’eminence’ of the house gives it a high relative
sensitivity as its setting clearly contributes significantly to its understanding.
The stable block by contrast was clearly intended to be subservient to the
main house and is best understood in relation to the house and it has a
medium sensitivity to changes beyond that immediate relationship.
13.4.21 The Proposed Development would stand to the northwest of Monkton House
and its stables and would be largely shielded from them both by trees within
the northern part of the Hall’s grounds and by a high wall which, in places
extend along the northwest boundary. However greater visibility is predicted
from the upper floor windows set within the northwest elevation of the stables.
The positioning of the principal windows in the southeast elevation indicates
that the builders and early occupiers of Monkton Hall placed greater emphasis
on the importance of views southeast from the house than they did for views
north-westwards from the house’s subsidiary elevation. Whilst limited visibility
is predicted from within the grounds of the house, this will be restricted by
trees and will not interfere with south-eastward views out from the principal
elevation. For these reasons the magnitude of effect of the Proposed
Development upon the settings of both Monkton Hall and the stable block is
predicted to be low as it would result in an insignificant alteration, beyond
those elements of the setting which directly contribute to the cultural heritage
value of the assets. Given that the house has a high relative sensitivity and
the stables a medium one, the Significance of these effects on the settings of
the assets is predicted to be Minor-Moderate in the case of Monkton Hall and
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Minor in the case of its stables. Neither of these effects will be Significant in
terms of the Town and Country Planning (Environmental Impact Assessment)
(Scotland) Regulations 2011.
13.4.22 The Category ‘B’ Listed Gardener’s House (Site 148), stands north of Monkton
House on the southeast side of Old Craighall Road. Of 17th century origin, the
building was altered and extended in the 18th century. The house is
positioned, flush against the road in the northern corner of the walled garden
which extends northwards from Monkton Hall. Whilst there are windows in the
external west elevation, the absence of a door shows that the house was
intended to be accessed exclusively from within the gardens. Although the
placing of windows in the west elevation would suggest that some value was
placed in the importance of views outward towards the Proposed
Development, it is clear that the house’s principal setting relates to the former
walled garden which is concealed from the Proposed Development behind a
high wall. This means that although the Gardener’s House may have a high
sensitivity to changes within the walled garden, outwith it, its relative sensitivity
can be assessed as Medium. Whilst the Proposed Development would
potentially appear in views of the house from the garden, it would not prevent
the observer from understanding the relationship between the house and the
garden. For these reasons the effect of the Proposed Development upon the
setting of the Gardeners House is predicted to be of Low Magnitude and Minor
Significance.
13.4.23 A second 17th century Lairds House, Newton House (Site 127) stands c.1km
to the south of Monkton House, southeast of the Proposed Development.
Although the house originally fronted northwest, the house was substantially
rebuilt c.1820 and now fronts to the southeast over looking its gardens. The
northwest elevation became secondary following the rebuild. The thickly
wooded gardens surrounding Newton House (Site 216) are included on the
Inventory of Historic Gardens and Designed Landscapes (IGDL) and define
the principal setting of the house. Whilst the Inventoried area includes
elements of the surrounding farmland, bisected by the A720 Edinburgh
Bypass, the Inventory Designation notes that:
“The garden at Newton is enclosed on all sides and as a result there are
limited views out across the adjacent low-lying farmland. The house set
in its garden, with its associated farm complex and enclosed parks,
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 376
occupy a prominent position in the landscape viewed from the south-
east round to the south-west.
The site is compact, defined by the walls of the walled garden, and the
approach ground leading off the old Dalkeith/ Musselburgh road
(B6415). The fields or ‘parks’ outwith the garden boundary which are
part of the 18th century enclosure are also included.” 20
13.4.24 Apart from the house, a distinct set of listed assets are present at Newton
including a dovecot (Site 137) and Newton Farmhouse (Site 126), both of
which are Category ‘B’ Listed and a Category ‘C’ Listed steading and set of
gate piers (Site 151). These assets are located within the area enclosed by
the garden and steading complex. Taken together this group of assets have a
distinct group value. Whilst Newton House (Site 127) undoubtedly has a high
relative sensitivity to changes to the southeast, the re-orientation of the house
in the 1820’s has reduced its sensitivity to change in the opposing, northwest
direction, where the house’s curtilage is in part functional, defined by the farm
house steading. For this reason Newton House is considered to have a
Medium sensitivity to change, to the northwest in the direction of the Proposed
Development. Newton Farmhouse (Site 126) is a late 18th century classically
embellished farmhouse, erected prior to the re-orientation of the main house
in the 1820’s, for these reasons it also has a Medium sensitivity to change.
Whilst dovecots are generally seen to have a Low relative sensitivity,
representing as they do a pragmatic method of food production, the Newton
example (Site 137) originated as a 16th century circular tower, presumably a
watch tower for an earlier antecedent to Newton House and for this reason
also has Medium relative sensitivity. The Category ‘C’ Listed steading
complex (Site 151) by contrast has been compromised by the erection of large
agricultural sheds adjacent to it. These, coupled with its own agricultural
function, give it a Low relative sensitivity to change. The boundaries of the
IGDL (Site 216) have been drawn so as to exclude the steading and
farmhouse although an area of open fields beyond the garden, bisected by the
A720 is included. The IGDL designation states that the walled gardens,
containing both the house and the dovecot is central to the definition of the
site, implying that IGDL is less sensitive to changes outwith its walled core.
20
http://data.historic-scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00301, Accessed 11th of
March 2015
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 377
For this reason whilst the IGDL is undoubtedly highly sensitive to changes
which either fall within or directly impinge upon its walled core, its sensitivity to
changes across the open fields is considered to be Medium.
13.4.25 The Proposed Development area is located northwest of the Newton asset
group and any visibility, beyond the assets would be across an open
landscape which includes both pylons and the existing Millerhill sidings.
Visibility from both Newton House (Site 127) and the dovecot (Site 137) would
be impeded by trees and the Proposed Development would not interfere with
the critical views south-eastward from the house’s principal elevation. Whilst
the farmhouse stands upon more open ground it fronts to the southwest away
from the Proposed Development area. Visibility from the steading will be
largely blocked by adjacent agricultural sheds. For these reasons the
Magnitude of change upon the settings of Newton House, its farmhouse and
the dovecot is predicted to be Low; whilst an effect of Negligible magnitude is
predicted for the steading. The Proposed Development would be visible from
across the open fields included within the IGDL designation, however views
from within the walled garden would be impeded by the tree cover within the
garden and as a consequence the magnitude of effect would be Low. The
Proposed Development would fall outwith those elements of the IGDL which
directly contribute to the understanding of its cultural value. Given these
magnitudes of effects, the effect of the Proposed Development on each asset
is predicted to be of Minor significance in the case of Newton House (Site
127), its farmhouse (Site 126), the dovecot (Site 137) and the IGDL (Site 216).
The effect on the steading (Site 151) will be of no significance.
13.4.26 Whitehill Mains Farm (Site 138), a Category ‘B’ Listed late 19th century
farmhouse, stands north of the Proposed Development area adjacent to the
northwest corner of the Millerhill Marshalling Yard and is the nearest
designated asset to the site. A site visit found the farmstead to be derelict and
boarded up. Given this and the fact that it is primarily a functional structure
related to its undesignated steading to the north, its relative sensitivity to
changes to its setting is considered to be Low. Viewpoint 14 taken from a
railway bridge to the east of the farm, suggests that whilst the Proposed
Development would be partially visible, though in the main it would be
screened by the AD Plant and Borders Railway. Given the limited visibility the
effect of the proposal on the setting of the farmhouse would be of Marginal
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 378
Magnitude. Consequently an effect of No Significance is predicted upon the
setting of the farmhouse.
13.4.27 Craigmillar Arts Centre (Site 129), the former Church of St Andrew stands to
the north of the Proposed Development area beside a roundabout on the
southern side of Newcraighall Road. It dates from 1900 and is Category ‘B’
Listed. Whilst intervisibility with the Proposed Development is predicted it
would be mostly screened by the AD Plant, Borders Railway and SNCD.
Indeed the development of land between the A1 and Whitehill Road as part of
the SNCD may screen the Proposed Development entirely, though some
visibility of the stack associated with the Proposed Development cannot be
discounted. The closure and removal of the colliery which the church was built
to serve, has robbed it of its context, whilst the erection of large retail
developments in proximity to it mean that its authentic immediate setting has
been compromised. The former church consequently has a Medium relative
sensitivity to changes to its setting. Whilst the Proposed Development would
be visible it would not interfere with the church's critical surviving setting
relationship, its relationship to its frontage and consequently any effect would
be of Marginal magnitude and Negligible significance.
13.4.28 Shepherds Cottage, Smeaton (Site 161) of c.1860 and its adjacent stable
court (Site 154) stand to the southeast of the Proposed Development on the
opposite side of the A720, both are Category ‘C’ Listed. Whilst the cottage’s
Tudor styling gives it a Medium relative sensitivity, any visibility with the
Proposed Development would be set at a distance of 1.90km and would be
across the intervening presence of the A720 dual carriageway. It would also
fall outwith the setting of the cottage which can reasonably be defined as the
land of the Dalkeith Estate upon which it was erected. For these reasons the
effect on the cottage is predicted to be of Marginal magnitude and Negligible
significance. The late 18th Century U-shaped stable court opens to the
southeast away from the Proposed Development and its setting is limited to its
immediate environs and its relationship with the adjacent, later cottage. Due to
its functional purpose it is judged to have a Low relative sensitivity. It is
therefore clear that any effect would fall outwith the setting of the stable and
consequently will be of Marginal Magnitude and No significance.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 379
13.4.29 The Category ‘B’ Listed dovecot, Castlesteads (Site 131) stands within thick
woodland to the southeast of the Proposed Development close to the A720
dual carriageway. The Listing description describes it as a single chambered
lean-to structure of probable 18th Century date, the only apertures being the
single door in the southern elevation and the flight holes in the centre of the
roof pitch. The remaining walls including those facing the Proposed
Development are blind. The dovecot’s practical form means that it is
considered to have a Low relative sensitivity. Given that any visibility will be
largely, if not entirely, impeded by tree cover and will fall considerably outwith
the dovecot’s immediate setting, the effect is predicted to be of Marginal
Magnitude and No significance.
13.4.30 Three Category B Listed buildings Stoneyhill (Site 130), Stoneyhill House (Site
136) and the former Stoneyhill Steading (Site 143) stand to the northeast of
the Proposed Development, subsumed within an intervening housing estate.
The housing estate would block all visibility with Sites 130 and 136, which
have consequently been excluded from the detailed assessment. However the
possibility of visibility occurring southward from the southwest elevation of the
former steading (Site 143) along the axis of Stoneyhill Road cannot be
discounted as the lighting masts of the existing marshalling yard appear in this
view. Whilst windows are set within the steading’s southwest elevation it is
unclear whether they are original to its design or result from its later residential
conversion. Given its functional purpose and the fact that the steading opens
to the northeast, in the opposite direction to the Proposed Development, it can
be argued that it has Low sensitivity to changes to the southwest and that any
effect resulting from the Proposed Development would be of Marginal
magnitude. Any effect will consequently be of No significance.
13.4.31 The Scheduled remains of Newton Old Church (Site 21) lie within its
churchyard and set within a field system southeast of the Proposed
Development area on the opposite side of the A720 dual carriageway. The
Category B Listed tower is the only element of the church to survive above
ground. The church was abandoned in 1742 when the new parish church (Site
133) was built, closer to the mines within which its congregation worked.
Whilst the core of the upstanding tower is early 17th century, the upper two
storeys appear to have been rebuilt circa 1915 and relate to its post
abandonment function as an eye catcher within the Duke of Buccleuch’s
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 380
Dalkeith Estate. Whilst the tower is well preserved it is shouldered by high
trees which mask it to a degree, making it less visually distinctive in views
from the northwest. The immediate setting of the tower has been
compromised by the routing of the A720 within 165m of it. As originally
constructed the tower was intended to be a visual marker within the parish of
Newton, and also a focal point within the immediate surroundings of the
church, namely the churchyard. However, the tower’s post abandonment use
as a folly re-focussed its setting to the south towards the core of the Dalkeith
Estate. The upper two storeys, the most visible, appear to have been rebuilt
post abandonment and consequently relate to this later setting. For these
reasons it is argued that the tower has a Medium sensitivity to changes in the
direction of the Proposed Development. Whilst visibility with the development
is predicted, the intervening A720 dual carriage way, is an overriding presence
within these views. For this reason the predicted visibility would represent an
insignificant alteration beyond those core elements of the setting which
directly contribute to the asset’s cultural value. Consequently the effect will be
of Low Magnitude and Minor Significance.
13.4.32 Newton old church was replaced in 1742 by a new church (Site 133) located
west of the original between the modern settlements of Danderhall and
Newton. Both the replacement church (Site 133) and the watch house and
boundary walls (Site 163) within its grounds are Category ‘B’ and ‘C’ Listed
respectively. The watch house was constructed c.1828, the year of the Burke
and Hare murders, in response to the ‘body snatching’ that Edinburgh was
notorious for. It is a small single storey functional building and given its
purpose its setting can be said to relate to the gate it guarded. It therefore has
a Low relative sensitivity. The Georgian church is by contrast a simple
classical structure and when built would have been clearly visible in westward
views from Millerhill Road (the A6106), whilst this view is now impeded by tree
growth within the churchyard, the church has a High relative sensitivity
although it would clearly be more susceptible to change within the churchyard
than outwith it. Visibility of the Proposed Development will be severely
impeded by the SNCD, though the possibility that the stack may be visible
beyond this cannot be entirely discounted. The Proposed Development would
stand considerably outwith the church’s immediate setting which can be
defined as the tree shielded graveyard and its immediate environs.
Consequently the effect of the Proposed Development upon the setting of the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 381
church is predicted to be of Marginal Magnitude, but given its High Relative
sensitivity of Minor Significance. Any visibility from the watch house would be
at worst of Marginal magnitude and given its Low sensitivity of No
Significance.
13.4.33 Eight Listed Buildings stand to the north of the Proposed Development within
the IGDL (Site 212) surrounding Newhailes House. Listed designations
include the House (Site 98, Category ‘A’), the Stables (Site 50, Category ‘A’),
the Walled Gardens Fruit Store and Terraced Walk (Site 135, Category ‘B’),
the Dovecot (Site 41, Category ‘B’), the Earl of Stair’s Monument (Site 144,
Category ‘B’), the Ice House (Site 146, Category ‘B’), the Main Gate and Pier’s
(Site 147, Category ‘B’) and the Gardeners Cottage (Site 150, Category ‘C’).
Whilst individually some of the assets may have a lower sensitivity, when
taken together and placed within the designed landscape to which they each
contribute, their group value is elevated and all are considered to have a High
relative sensitivity, although in many cases their setting can be reasonably
held to be restricted to the confines of the designed landscape. The
Inventoried Designed Landscape (Site 212) represents a rare survival of an
early to mid-18th century rococo landscape garden, surrounding a house
which has been little altered from that period. The IGDL designation notes
views southward towards the Moorfoot Hills and places emphasis on the
importance of views northwards and eastwards from the house noting that:
“although enclosed on its south-west and south sides, it commands extensive
views out to the north-east, over lawns and parkland, to the Firth of Forth.”21 It
is therefore clear that both the setting of the designed landscape and its
aesthetic value contribute directly to the observer’s experience of it and that
the IGDL therefore has a High relative sensitivity to change. Although it has a
greater degree of vulnerability to changes which fall either within its
boundaries or are visible from across the more open landscape to the north
and northeast.
13.4.34 A site visit demonstrated that there will be no visibility, either from Newhailes
House (Site 98) or six of the Listed Buildings within the IGDL (Sites 50, 135,
41, 144, 146 and 150) and consequently no effect upon the settings of these
21
http://data.historic-scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00296 accessed 12th
of
March 2015
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 382
assets is predicted (Plate 3). The site visit also found that there will be no
visibility from within the majority of the IGDL (Site 212). While there may be
some visibility from the Category ‘B’ Listed Main Gate and Piers (Site 147) this
will be restricted and distinct from the setting of the gate which is limited to the
much altered road which it fronts. Consequently, the effect on the setting of
the gate would be of Marginal magnitude, but given its High relative sensitivity
of Minor Significance.
13.4.35 The Listed Main Gate (Site 147) leads into an open grassed enclosure ringed
by a belt of trees, this forms the southwest tip of the IGDL (Site 212) and
views northwards towards Newhailes House are largely blocked by an
intervening wood. The integrity of the enclosure has in part been
compromised by the National Trust for Scotland’s asphalt car park which
extends along its northern edge. A site visit established that whilst visibility
with the stack, particularly during the winter months cannot be discounted, any
visibility would be extremely limited. The proposed stack would not appear in
views either towards or from Newhailes House via the enclosure. Given this
limited degree of predicted visibility, the effect of the Proposed Development
on the setting of the Newhailes IGDL (Site 212) would be of Low Magnitude,
representing at worst an insignificant alteration beyond those elements which
directly contribute to the cultural value of the landscape, and of Minor-
Moderate Significance.
13.4.36 Category ‘A’ Listed Brunstane House (Site 222) stands to the north of the
Proposed Development and any visibility would be across a complex
landscape featuring railway lines, the A1 dual carriageway, the settlement of
Newcraighall and elements of the Gilberstoun housing development.
Brunstane is a fine, comparatively intact example of a 17th century Lothian
mansion, built originally in 1639 for the Earl of Lauderdale, a prominent Scots
politician and altered by William Adam in 1733. It was clearly designed so as
to both appear prominent within its surroundings and enable views out across
the landscape from its windows and therefore, undeniably, has a High relative
sensitivity. The house was laid out on a distinct east-southeast / west-
northwest alignment and it is thus reasonable to argue that it is particularly
sensitive to changes in these directions. A site visit found that at ground level
visibility of the Proposed Development would likely be impeded or possibly
even blocked entirely by the intervening trees, townscapes and route networks
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 383
although it is possible that the stack would show. A greater degree of visibility
is predicted in views out from the upper storey windows although the
Proposed Development would neither impinge in views out eastward from the
principal elevation or westward along the approach to the house. Given this
predicted limited visibility and the fact that any views of the Proposed
Development would occur within a modern, complex landscape, totally
changed from the one within which Brunstane was erected and beyond its
immediate setting, the effect is predicted to be of Marginal Magnitude and of
Minor Significance. No visibility is predicted with the adjacent Category ‘B’
Listed steading and cottages (Site 132), which were being converted to
residential use at the time of the visit.
13.4.37 Nine designated assets within the Inveresk Conservation Area (Site 202) have
been included within the detailed assessment. The remaining assets within
the Conservation Area were excluded after the site visit established that there
would be no visibility with the Proposed Development. The nine designated
assets include the Inventoried Inveresk Lodge Garden (Site 208), as well as
three Category ‘A’ Listed assets; Inveresk Lodge (Site 115); the remains of an
outbuilding (Site 96) and a sundial (Site 49).
13.4.38 The Lodge and its garden stand northeast of the Proposed Development on a
ridge overlooking the east bank of the Esk. Inveresk Lodge is an L Plan
mansion of 1683 – 1700 built along the southwest side of Inveresk Village
Road and is one of a group of substantial villas laid out along the ridge by
prosperous Edinburgh citizens between the 17th and 19th Centuries. The
garden, which is open to the public, steps down to towards the floor of the Esk
Valley on a series of terraces which were laid out in the second half of the 19th
Century, although the present layout of the garden post-dates its acquisition
by the Trust. Whilst it is Category A Listed and dates to 1644, the sundial (Site
49) was moved to the garden by the Trust in 1968 from Pitreavie Castle, Fife.
Tradition holds that the ruinous outbuilding (Site 96) conceals a subterranean
passage to the neighbouring villa, Halkerston (Site 62) although no evidence
for this has been found. Overall, both the garden and the Lodge have a High
relative sensitivity to change, although the Lodge’s critical setting relationship
is with its garden, the significance of which is derived largely from its modern
aesthetic. The outbuilding’s ruinous condition and the sundial’s lack of any
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 384
historical provenance within the garden mean that their relative sensitivity is
considered to be Low.
13.4.39 A site visit to Inveresk Lodge Garden (Site 208), undertaken during winter,
found that whilst the Proposed Development is likely to be visible, intervening
trees both within the garden and beyond would substantially impede views
(Plate 4). It is likely that from within some parts of the garden the Proposed
Development would not be visible, whilst from other perspectives only the
stack or elements of the stack would show. As Plate 4, looking south-
westwards from the upper terrace of the garden shows, the Proposed
Development would be set within a wide, tree dominated vista extending out
to the Pentland ridge. Whilst the Inventory designation for the garden notes
that: “from within the garden, views can be obtained on a clear day to Arthurs
Seat in the west and the Pentland hills in the south, due to the south-westerly
aspect of the site, it acknowledges that ‘to the south beyond the River Esk lies
Monktonhall Golf Course and beyond, the sprawling industrial and suburban
landscape of Midlothian,”22 and it is within this vista that the Proposed
Development would appear. The degree of masking afforded by the tree cover
within the garden would also of course vary according to the season and
would be reduced during the winter. Although the garden is laid out along
terraces and the landscape outwith it to the southwest is visible, the focus of
the garden is essentially inward looking with distinct planned views along the
alignment of the terraces towards ornaments placed within the garden, such
as the sundial from Pitreavie. For these reasons, the Proposed Development
would result in an insignificant alteration to the setting of the garden beyond
those elements of its setting which directly contribute to its cultural value. The
predicted effect will therefore be of Low Magnitude and of Minor-Moderate
Significance.
13.4.40 Inveresk Lodge (Site 115) stands in the northern corner of the garden
adjacent to the road. The L Plan house has a principal elevation, the
southwest elevation which overlooks the Esk Valley and the southeast
elevation which fronts onto the garden terraces. Whilst the Proposed
Development may be visible from the windows of the southwest elevation, any
visibility would be impeded by trees, which during the summer could
22
http://data.historic-scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00225
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 385
potentially block visibility from some of the windows. Whilst the garden and the
Lodge and assets within the garden are distinctly different in date, they clearly
relate to each other and each contributes to the value of the other. The
southeast elevation, clearly relates to and opens out onto the garden, the
southwest elevation is separated from it in part by height and in part by a
small courtyard which excludes part of the ground floor from the garden. The
Proposed Development would not intrude into views out from the southeast
elevation across the garden although it would potentially appear in views out
across the Esk Valley from the southwest elevation. However, as the
designation for the IGDL acknowledges, views in this direction take in
industrial and suburban Midlothian and it is in this context that the Proposed
Development would be seen, and more critically understood by the observer.
For this reason the Proposed Development would result in an insignificant
effect on elements beyond the core setting of the house, its garden, and
consequently the effect would be of Low Magnitude and of Minor-Moderate
Significance.
13.4.41 Whilst the outbuilding (Site 96) and the sundial (Site 49) are Category ‘A’
Listed, the contribution that their setting makes to their value has been
diminished and they have a Low relative sensitivity. Any effect upon the
setting of these assets would, in the worst case represent an insignificant
alteration to their setting and would consequently be of Low Magnitude and
Minor-Moderate Significance.
13.4.42 Halkerston (Site 62), immediately northwest of Inveresk Lodge, is a Category
A Listed square plan house of c.1640 and is probably the oldest building in
Inveresk although it was restored in 1960. Halkerston is approached from the
road via a stable court and fronts south-westwards onto gardens which
overlook the Esk Valley. The stable block (Site 63) is also Category ‘A’ Listed
although it has been excluded as views of the Proposed Development from it
would be blocked by the main house. Visibility out from the house towards the
Proposed Development is predicted to be at similar level to those views out
from the adjacent Inveresk Lodge and would also likely be impeded at least to
a degree by intervening tree cover. Whilst Halkerston has a similar High
relative sensitivity to the Lodge and will be particularly sensitive to changes
which interact in views outwards across its garden, any visibility with the
Proposed Development would occur across the wider suburban and industrial
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Midlothian landscape and consequently the effect of any alteration would be of
Low magnitude and Minor-Moderate Significance.
13.4.43 Inveresk Manor (Site 84) is, after the Lodge and Halkerston, the third in the
line of mansions extending northwest along the Inveresk Ridge. The most
recent of the three, it is a substantial Category ‘A’ Listed, seven bay classical
villa of 1748, and like the others its rear, southwest elevation fronts onto a
substantial garden which extends down towards the Esk. The Manor has the
same level of High relative sensitivity as the Lodge and Halkerston, for similar
reasons; although unlike the others it’s formal classical elevation fronting
northeast onto to the road is considerably embellished and is clearly the
principal elevation. The Proposed Development could potentially be visible in
views out across the garden from the Manor, however any visibility would, at
least to a degree, be impeded by trees and given that the Proposed
Development would be set within the wider suburban and industrial landscape
would represent an insignificant alteration. Consequently any effect would, at
worst, be of Low Magnitude and Minor-Moderate significance.
13.4.44 Two Category ‘A’ Listed buildings; the East Pavilion (Site 85) and the Dovecot
(Site 84) stand within the grounds of Inveresk Manor. The Pavilion has a High
relative sensitivity, being an ornamental structure, positioned alongside the
road and was clearly intended to form part of the Manor's street front
composition. Although visibility from the rear of the Pavilion towards the
Proposed Development would be possible, any views would be at least
impeded by intervening trees and possibly the Manor House itself.
Consequently any effect on the setting of the Pavilion would be, in the worst
case, exceedingly limited, of Marginal magnitude, and of Minor Significance.
The dovecot stands within the rear garden. Although subsequently converted
into a summer house the building is now roofless and classified as being in
very poor condition on the Buildings at Risk Register for Scotland. Its primary
setting is within the garden and it is considered to have a Low relative
sensitivity particularly to changes outwith this immediate setting. Any visibility
with the Proposed Development would be limited by intervening trees.
Consequently any effect would be of Low magnitude and No Significance.
13.4.45 Site visits have found that there would be no visibility of the Proposed
Development either from the Category ‘A’ Listed Inveresk Church (Site 116) or
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 387
the historic core of its graveyard, even during those months when the
intervening tree cover is at its most diminished. Whilst the church and it's spire
form a prominent landmark, noted as a 'signature' by the Inveresk
Conservation Area Character Appraisal, the distance of separation between
the church and the Proposed Development coupled with the fact that
Proposed Development will stand within a markedly modern complex
landscape, mean that the stack will neither impinge in or challenge distant
views of the church. Consequently, despite its High relative sensitivity, No
effect is predicted on the setting of the church.
13.4.46 The core of the Inveresk Conservation Area (Site 202) can be defined by the
axis of Inveresk Village Road and the densely built up post-medieval
townscape of, predominantly Listed Buildings which line it. The Proposed
Development would not be visible in views from this townscape as outward
views are unobtainable due to the extent of the enclosure. Consequently No
effect is predicted from the core of the Conservation Area. However, a site
visit found that limited visibility is possible from the garden of Inveresk Lodge,
and a similar degree of visibility is predicted from those other southeast facing
gardens which extend to the rear of properties along the southern side of
Inveresk Village Road. Whilst these gardens fall beyond the core of the
Conservation Area, the Conservation Area Appraisal notes the 'buildings laid
out along the high flat ridge above the river and the large mature gardens that
sweep down towards the river' are part of the 'Essential Character' of the
designation. However, this assessment has found that views of the Proposed
Development from these gardens would be impeded by trees and furthermore,
as the designation for the IGDL acknowledges, views in the direction of the
Proposed Development area take in industrial and suburban Midlothian and it
is in this context that the Proposed Development will be seen, and more
critically understood by the observer. For these reasons whilst the Inveresk
Conservation Area has a High relative sensitivity, when considered overall,
the Proposed Development would represent an insignificant alteration beyond
those core elements of its setting which directly contribute to our
understanding of it. Consequently the effect on the setting of the Conservation
Area is predicted to be of Low magnitude and Minor-Moderate Significance.
13.4.47 Musselburgh Conservation Area (Site 195) lies north of Inveresk and covers
the historic core of Musselburgh. Site visits demonstrated that the intervening
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 388
townscape would block all visibility of the Proposed Development from the
greater proportion of the Conservation Area, including both the High Street
and the grounds of Pinkie House. However, visibility could potentially occur
from the centre of the Category ‘A’ Listed 16th century Musselburgh Old
Bridge (Site 68) as it crosses the Esk, although any visibility would be, at the
least, severely impeded by the intervening presence of trees. Any visibility
from within the Conservation Area is unlikely to extend too far beyond the
bridge due to the built up nature of the townscape. Although no Conservation
Area Appraisal has been published for Musselburgh, a Conservation Area
Character Statement published with the 2008 East Lothian Local Plan (East
Lothian Council 2008, Appendix 7, 32, para 1.2) notes that: “the river adds an
additional dimension to Musselburgh's townscape quality, along with its
bridges particularly the Roman Bridge (or Old Bridge) which is Category A
Listed.” Whilst the Old Bridge is essentially functional, it also has a High
relative sensitivity derived from both its own aesthetic quality and the
additional qualities which result from its interaction with the Esk. The core
setting of the bridge is limited to the river and its banks and the immediate
surroundings characterised by the townscape. This means that any visibility,
should it occur, from either the bridge or the banks of the Esk, would be both
restricted and would fall considerably outwith the setting of both the bridge
and the Conservation Area. Consequently the effects upon the settings of both
the bridge and the Conservation Area are predicted to be Marginal and of
Minor Significance.
13.4.48 Category ‘A’ Listed Dalkeith House (Site 103) (Plate 5) lies south-southeast of
the Proposed Development and is set within the extensively wooded Dalkeith
Palace IGDL (Site 209). Dalkeith House, or Palace as it is alternatively known,
dates from 1702-11 and incorporates fabric from the earlier 15th century
Dalkeith Castle. The Dalkeith Estate was purchased by the Earl of Buccleuch
in 1642 and both the house and park remain in the hands of his descendants.
The IGDL is thickly wooded, being characterised by thick belts of trees which
converge on the confluence of the rivers North and South Esk within the park.
The rivers pass through steeply incised valleys. The majority of the Listed
Buildings within the park, including Dalkeith House, stand in proximity to the
rivers and accordingly lie on the periphery of the ZTV. Following a site visit no
visibility from the Listed Buildings is predicted. The site visit also found that the
thick belts of trees which extend both through the park and define its edges
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comprehensively block any low level views out from the park. Whilst the
possibility of the proposed stack appearing above the tree line in certain views
cannot be discounted, this is unlikely given the distance of separation between
the IGDL and the 75m stack. It is likely that any visibility, should it occur would
be extremely limited and confined to the northern edge of the IGDL. The
House and the IGDL clearly have a High relative sensitivity. However, given
the above No effect is predicted upon the setting of the House, whilst any
visibility from within the IGDL would be extremely limited and would fall
considerably beyond the parkland elements of the landscape. Consequently
should any effect occur it would be of Marginal Magnitude and Minor
Significance.
13.4.49 Despite the above it needs to be acknowledged that the designated area of
the Dalkeith IGDL extends northwards to include areas of open fields and
plantations astride the Esk which comprised the core of the historic
agricultural estate. Whilst the Proposed Development will be visible from these
areas, this part of the IGDL has historically been segregated from the core
parkland surrounding Dalkeith House by belts of trees and has been further
compromised by the recent addition of the A1 and A68 trunk roads, from
which much of the visibility would occur. It is reasonable to argue that views
from the modern footbridge over the A68 are inconsequential to the historic
character and significance of the designed landscape and as a consequence
will not diminish our understanding of it. Whilst the core of the park has a high
relative sensitivity the bisection of the northern part of the IGDL by the A1 and
A68 has significantly compromised it, dislocating its association with the
Dalkeith Estate. Consequently in cultural heritage terms, this part of the IGDL
is considered to have a Low relative sensitivity to change and the predicted
visibility will represent an insignificant alteration beyond those core elements
of the IGDL (the park surrounding Dalkeith House). Any effect on the northern
part of the IGDL will therefore be of Negligible Significance.
13.4.50 Newbattle Abbey IGDL (Site 219) lies south of Dalkeith, within the valley of the
South Esk. The park was developed to provide an appropriate setting for
Newbattle Abbey (Site 112), the historic seat of the Marquess' of Lothian. The
core of the park along the banks of the South Esk falls outwith the ZTV and
consequently No effect is predicted upon the settings of any of the Category A
Listed Buildings within it. Whilst the ZTV does indicate that some visibility is
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possible, it would only occur in areas which lie beyond the core of the park.
Visibility would potentially be restricted to the higher ground in the northeast
corner of the IGDL where the original parkland has been compromised by the
laying out of the Newbattle Golf Course. Despite infringement by the golf
course, overall the IGDL retains a High Relative Sensitivity. Visibility would be
across a wide intervening landscape and would also be impeded by
intervening trees and plantations. Given only limited visibility is predicted
beyond the core of the IGDL any effect would be of Marginal magnitude, and
of Minor Significance.
13.4.51 Carberry IGDL (Site 210) extends along the ridge line to the east of Whitecraig
and was created to provide an appropriate setting for Carberry Tower, a
Category B Listed Stately home, the IGDL itself being largely an 18th and 19th
century creation. Whilst the IGDL has a High relative sensitivity to change, it is
surrounded by thick tree belts and is consequently more sensitive to change
within these confines. Although some visibility is predicted, from many parts of
the park views would either be blocked or severely impeded by the tree belts
which surround it. Whilst the Proposed Development would potentially be
visible from the open ground away from Carberry Tower, it would appear with
the wider suburban and industrial Lothian landscape and will represent only a
Marginal alteration to the setting of the IGDL of Minor Significance.
13.4.52 Two further IGDL's The Palace of Holyroodhouse (Site 211) and Craigmillar
Castle (Site 220) lie to the north and east of the Proposed Development within
Edinburgh. The boundaries of the Holyroodhouse IGDL largely correspond
with those of the Holyrood Park Scheduled Monument (Site 40) which will be
discussed with it. Arthur's Seat and Salisbury Crags, the landforms which
define the park will not be discussed specifically as they fall beyond the
cultural heritage remit of this assessment. Holyrood Park contains a wide
ranging assemblage of archaeological remains and Listed Buildings, including
Holyrood Abbey, the Palace of Holyroodhouse, St. Anthony’s Chapel, four
prehistoric or early historic hillforts, extensive ridge and furrow remains and
cultivation terraces on the eastern slopes, quarrying and 19th and 20th
century military ranges. Whilst as a whole both the IGDL and the Scheduled
Monument undoubtedly have a High Relative Sensitivity, this is largely due to
its high aesthetic quality as a 'highland' area set in the midst of the Scottish
capital. The park is completely encircled by suburban and industrial
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development which needs to be considered as part of its baseline, indeed it
could be argued that the contrast between urban and highland is one of the
principal qualities of the park. Only the eastern part of the park falls within the
ZTV, the western part of the park including the Salisbury Crags, Holyrood
Abbey, the Palace of Holyrood House and St. Anthony's Chapel all fall outwith
the ZTV and consequently No effect on their settings are predicted. Whilst the
Proposed Development would be visible from the eastern slopes, it would
represent an insignificant alteration to a wider urban and suburban landscape,
clearly outwith the setting of the park. Consequently any effect upon the
setting of both the Scheduled Monument (Site 40) and the IGDL (Site 211)
would be of Marginal magnitude, and of Minor Significance.
13.4.53 Craigmillar Castle IGDL (Site 220) lies east of the Proposed Development and
includes the Scheduled remains of the castle (Site 30) which is also Category
‘A’ Listed, along with a Category A Listed dovecot (Site 119) which is
incorporated into the structure of the castle. The Scheduled area extends east
from the castle to include the eastern part of its grounds. Taken together the
designated Craigmillar assets represent a fine example of a late medieval
castle set within its deer park, with remnants of its 16th century garden clearly
visible. Whilst collectively all the designated assets undoubtedly have a High
relative sensitivity, the IGDL is now largely surrounded by the eastern suburbs
of Edinburgh and it is across this modern landscape, clearly outwith the
castle's immediate setting which is confined to the IGDL that any predicted
visibility with the Proposed Development would occur (Plate 1). This means
that whilst the Proposed Development would be visible from the castle roof, it
would represent only a Marginal alteration to the already greatly changed
modern landscape. However given the High sensitivity of the IGDL and the
designated assets within it, any effect on their setting will be of Minor
Significance.
13.4.54 The Battlefield at Pinkie, 1547 is included on the Inventory of Nationally
Important Battlefields in Scotland. The Inventory boundary includes much of
modern day Musselburgh, Wallyford, Inveresk and Pinkie as well as Inveresk
Fields and Falside and Carberry Hills. This vast area encompasses the areas
of the Scottish and English camps, the skirmish on the 9th of September, the
manoeuvrings and ultimately the main engagement, followed by the rout of the
Scots on the 10th of September. While the landscape in which the battle took
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 392
place has changed significantly in the years since the battle, through the
development of settlements, enclosure and improvement of fields and
insertion of the railway and the A1 dual carriageway there are still many
features within the landscape which aid in understanding and appreciating the
battle and its outcome. These include St Michael’s Church at Inveresk, Pinkie
Cleugh, Carberry Road and Falside Hill and Castle as well as Inveresk Fields
and Carberry Hill. The relationship of the low ground at Inveresk Fields (now
bisected by the A1) with higher ground at Falside and Carberry Hill is
particularly important for the current understanding of the battle. Views to the
west and southwest along the lines of the rout also have value and add to our
understanding of the events of the battle. The battlefield is judged to be highly
sensitive to change within its boundaries and particularly to changes which
could obscure the relationships noted above. However, changes beyond the
boundaries of battlefield are less likely to impact upon the ability to
understand, appreciate and experience the battle. The battlefield is judged to
be of Medium Relative Sensitivity to changes beyond its boundaries.
13.4.55 The Proposed Development is located some 850 m to the west of the western
boundary of the Battlefield, beyond the area likely to have contained the
Scottish Camp. While the Proposed Development will be visible from Inveresk
Fields (LVIA VP1, Battlefield Memorial Salter’s Road) it will not interfere with
or inhibit the understanding of the relationship between the fields and the
higher ground to the south. Further, while located to the west, and in views in
this direction, the Proposed Development will not impede understanding of the
rout which was in the direction of Dalkieth, along the Esk, along the coast to
Leith and towards Edinburgh and Arthur’s Seat. As such the effect is judged to
be of Low Magnitude, the overall effect would therefore be of Minor
significance and not significant in terms of EIA regulations.
Assessment against PPiP Future Baseline Scenario
13.4.56 The cultural heritage chapter of the PPiP ES found that there would be no
significant effects upon the setting of heritage assets. IGDL were not
assessed in the cultural heritage chapter, but rather the LVIA chapter. The
assessment presented therein considered IGDLs within 3km of the PPiP
development and found a potential significant effect upon the IGDL at Newton
(Site 216 in this assessment). This assessment has not found significant
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 393
effects upon the IGDL at Newton. The PPiP assessment appears to have
been carried out by a landscape architect rather than a heritage specialist and
to only consider visual change in the direction of the Proposed Development,
without consideration of the other site specific factors set out in this chapter.
13.4.57 A comparison of the boiler house roof for the PPiP Development at 20m to
Proposed Development at 41.6m, and of the PPiP consented 65m stack
height with the Proposed Development 75m stack height, has not resulted in
an increase in the overall visibility of the Proposed Development from
designated heritage assets within the assessment area in terms of the ZTV.
That is comparisons between the consented PPiP ZTV and that of the
Proposed Development (Figures 13.1 and 13.2) have found that the
substitution of the consented PPiP scheme with the Proposed Development,
will not result in any further designated assets falling within the ZTV. The
possibility that the Proposed Development will be in view from assets, where
no visibility would have occurred under the consented PPiP development due
to the presence of intervening built and vegetation features cannot be
discounted.
13.4.58 The heights for the roof and the stack at 20m and 65m for the consented PPiP
scenario compared to 41.6 m and 75 m for Proposed Development may mean
that there is a marginal increases in visibility for the Proposed Development.
Thus there could be slightly higher effects upon the setting of a limited number
of heritage assets. Overall this assessment has found that the Proposed
Development will not result in any Significant effects upon the settings of
designated heritage assets. Consequently there is no material increase in
effects on the settings of designated heritage assets when comparing the
consented PPiP scheme with Proposed Development.
Decommissioning Phase
Assessment of Effects against Existing Baseline
13.4.59 The decommissioning and removal of the Proposed Development itself would
not result in any direct effects assuming there was no need for ground-
breaking works outwith areas impacted during the construction phase.
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13.4.60 No Significant indirect effect upon the setting of any designated heritage asset
would result from the decommissioning of the Proposed Development. Indeed,
where non-significant indirect effects have been identified, these would be
reversed following the decommissioning and removal of the development.
Assessment against PPiP Future Baseline Scenario
13.4.61 The culture heritage chapter for the PPiP ES noted that there would be no
direct effects on heritage assets resulting from the decommissioning, provided
ground works were limited to areas disturbed during the construction phase. It
did not address the potential for indirect effects resulting from
decommissioning. The difference in the effects on heritage assets resulting
from the decommissioning of the PPiP consented development compared with
the Proposed Development is considered to be neutral.
Cumulative Effects
Assessment of Effects against Existing Baseline
13.4.62 Cumulative Effects, in so far as they relate to cultural heritage, are limited to
indirect effects upon the settings of heritage assets.
13.4.63 Two developments require consideration in terms of potential cumulative
effects:
The Edinburgh Royal Infirmary (ERI), 51 Little France Crescent,
Edinburgh:
o Four applications (11/02/02454/PPP, 14/00078/AMC,
14/01796/AMC and 14/03599/AMC) relate to the proposed
erection of the Royal Hospital for Sick Children at Little France
c.2km west of the Proposed Development. The proposal includes
an energy centre with a 29m stack
Millerhill Marshalling Yard, Dalkeith:
o Three applications (12/00060/DPP, 12/00514/PAC and
12/00837/DPP) relate to the proposed redevelopment for
continued rail use of the marshalling yard immediately east of the
Proposed Development.
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13.4.64 The proposed developments at Millerhill Marshalling Yard are within very
close proximity to the Proposed Development. However, they are markedly
different in character and will be lower in height. This assessment has found
that for many designated assets the Proposed Development will be viewed
either across or in many cases, from within the wide suburban and industrial
landscape which extends eastwards from Edinburgh. The developments at
Millerhill Marshalling Yard taken together with the Proposed Development
would not result in a significant alteration to the current setting of the heritage
assets in the study area and no significant cumulative effects are predicted.
13.4.65 Whilst the proposed energy centre at the ERI will have a stack, at 29m it is
considerably shorter than the Proposed Development and will be set c.2km to
the west. Consequently it is unlikely that the two schemes will appear together
in views from many of the designated assets identified as part of this
assessment. They are likely to both be visible from Craigmillar Castle,
Holyrood IGDL and potentially from some locations within Pinkie Battlefield.
However, given the separation distance between the two developments and
the highly complex urban landscape, the insertion of the Proposed
Development into views which also include the ERI stack will not materially
elevate the level of effect beyond those predicted for the Proposed
Development when it is considered on its own. No significant cumulative
effects are predicted.
Assessment against the PPiP Future Baseline
13.4.66 The PPiP ES assessed cumulative effects based upon the PPiP proposals,
the SNCD and the Borders Railway (referenced in the PPiP cultural heritage
chapter as the Waverley Line Development). The latter two developments
have been taken as part of the baseline in this assessment and so their
presence in the landscape is accounted for. The PPiP ES also found that
there would be no significant cumulative effects upon the setting of heritage
assets.
13.4.67 Given the lower stack and roof height of the PPiP development it is unlikely
that there would be any significant cumulative effects resulting from its
development alongside the ERI and Millerhill Marshalling Yard developments.
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13.4.68 Comparison of cumulative effects for the PPiP Future Baseline Scenario and
the Proposed Development indicate that the level of effect between the two is
neutral.
13.5 Additional Mitigation
Construction Phase
13.5.1 This assessment has indicated that there three known heritage assets within
the Proposed Development boundaries. These include the site Middlefield
Farmstead (Site 225) and the Innocent Railway (Site 224). Both of these
assets are likely to have been removed during the construction of Millerhill
Marshalling Yard in the 1960s. The yard itself (Site 223) forms the third known
heritage asset. All of these assets are of negligible heritage value. Therefore,
while impacts upon any surviving remains by Proposed Development would
be of High magnitude, these effects would not be significant in terms of EIA
regulations. Given the previous ground disturbance within the Proposed
Development boundaries, the potential for hitherto unknown archaeological
remains to survive is negligible. As such no mitigation for direct effects is
considered necessary.
13.5.2 Indirect effects associated with construction phase will be temporary and will
not be significant in terms of EIA Regulations and as such no mitigation is
proposed.
Operational Phase
13.5.3 No direct effects are predicted during the operational phase and as such no
mitigation is proposed.
13.5.4 Indirect effects include effects upon the settings of designated assets such as
Listed Buildings, SMs, Conservation Areas and Inventoried Gardens and
Designed Landscapes and Battlefields. This chapter has assessed potential
effects upon the settings of designated heritage assets within both a 2km and
a 5km radius of the Proposed Development in detail and found no significant
effects. No mitigation measures, beyond those incorporated in the design, are
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 397
available to minimise or offset the predicted effects, neither are they
considered necessary.
Decommissioning Phase
13.5.5 No direct effects are predicted during the decommissioning phase, provided
that ground works are limited to those areas impacted during construction.
Setting effects will cease following decommissioning provided the building and
stack are removed. No mitigation measures are considered necessary.
13.6 Residual Effects and Conclusions
Residual Effects against Existing Baseline
13.6.1 Direct effects upon any archaeological remains which may be present within
the Proposed Development are possible. However this assessment has found
that the known heritage assets within Proposed Development boundary are of
negligible importance. There is negligible potential for hitherto unknown
remains to survive within the Proposed Development area given previous
ground disturbance on site. As such mitigation is not considered necessary
and no residual effects are predicted
13.6.2 This assessment has identified non-significant effects upon the settings of
designated heritage assets, in the absence of additional mitigation measures
these will be as predicted in sub-section 13.4. All Operational effects upon the
settings of designated assets would be reversed following decommissioning.
Residual Effects against PPiP Future Baseline Scenario
13.6.3 The cultural heritage chapter for the PPiP ES noted negligible potential for any
direct effects of EIA significance. It stated that no significant setting effects
had been predicted and as such no mitigation recommended. As such
residual effects, under the PPiP Future Baseline Scenario would be limited to
insignificant effects on the setting of heritage assets during the operational
period. There would be no material difference between residual effects for the
PPIP Future Baseline Scenario and the Proposed Development and the
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difference between the effects resulting from the two developments is
considered to be neutral.
Conclusions
13.6.4 This assessment has considered the potential for effects upon heritage assets
resulting from the Proposed Development in relation to a baseline scenario
agreed with MLC in which the: SNCD, Borders Railway and AD Facility are all
assumed to be completed. Direct effects were considered and it was found
that there would be no significant direct effects and that there was negligible
potential for hitherto unknown archaeological remains to survive within the
Proposed Development site. This is consistent with the findings of the PPiP
ES. Indirect effects upon the settings of designated heritage assets including
Listed Buildings, SMs, Historic Gardens and Designed Landscapes,
Inventoried Battlefields and World Heritage Sites were assessed. The
potential for such effects has been assessed for the Proposed Development
and the findings then compared with those for the PPiP Future Baseline
Scenario.
13.6.5 All designated assets within 2km of the Proposed Development have been
assessed along with all Category ‘A’ Listed Buildings, Scheduled Monuments,
Conservation Areas, Inventoried Battlefields and Inventoried Gardens and
Designed Landscapes within 5km. In total 222 designated assets were
assessed.
13.6.6 No Significant direct or indirect effects are predicted and any non-significant
effects on the setting of heritage assets will be confined to the operational
lifespan of the Proposed Development and will cease with its
decommissioning and removal. The Proposed Development would not
materially elevate the effects on the settings of designated assets beyond the
levels predicted for the PPiP Scheme. No mitigation is considered necessary.
13.7 References
Axis 2014, Millerhill Energy Recovery Facility: Environmental Impact Assessment,
Informal Scoping Report, January 2014
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 399
Environmental Statement Prepared in Support of the Application for Planning
Permission in Principle (2011)
HMSO. (1979). The Ancient Monuments and Archaeological Areas Act 1979.
HMSO. (1997). Town and Country Planning (Scotland) Act 1997.
HMSO. (1997). Planning (Listed Buildings and Conservation Areas (Scotland)) Act
1997.
HMSO. (2011). Historic Environment (Amendment) (Scotland) Act 2011.
HMSO. (2011). Town and Country Planning (Environmental Impact Assessment)
(Scotland) Regulations 2011.
Historic Scotland. (2010). Managing Change in the Historic Environment: Setting.
Historic Scotland. (2011). SHEP Scottish Historic Environment Policy.
ICOMOS. (1999). The Burra Charter.
ICOMOS. (2005). Xi’an Declaration on the Conservation of the Setting of Heritage
Structures, Sites and Areas.
Lambrick, G. (2008) Setting Standards: a review prepared on behalf of the IFA.
Midlothian Council, 2008, Midlothian Local Plan
Rhodes, M. 1988. The illustrated history of British marshalling yards. passim. esp.
105-13
Scottish Executive. (2002). PAN 45 Renewable Energy Technologies.
Scottish Government. (2011). PAN2/2011 Planning and Archaeology. Available at:
http://www.scotland.gov.uk/Resource/Doc/355385/0120020.pdf [Accessed on
30/01/15].
Scottish Government. (2014). Scottish Planning Policy. Available at:
http://www.scotland.gov.uk/Resource/0045/00453827.pdf [Accessed on 30/01/15].
SESPlan 2003, Policy 1B
Online Sources:
http://data.historic-
scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00301, Accessed 11th
of March 2015
http://data.historic-
scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00225 Accessed 11th
of March 2015
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 400
14.0 SOCIO-ECONOMIC EFFECTS
14.1 Introduction
14.1.1 This Chapter of the ES assesses the socio-economic effects arising from the
Proposed Development during its construction and operation. The
assessment considers the effects at the local level (i.e. Dalkeith Ward),
authority level (i.e. Edinburgh and Midlothian) and Scotland as a whole.
14.1.2 A key issue of this assessment is to understand the existing socio-economic
context and to consider whether the Proposed Development would result in
any beneficial or adverse socio-economic effects on identified receptors within
the local impact area. The significance of these is judged under a framework
outlined in the following sub-section.
14.1.3 This Chapter describes the methods used to assess the impacts, the baseline
conditions within Dalkeith, Edinburgh, Midlothian and Scotland; the potential
effects of the proposed development; any mitigation measures required to
prevent, reduce, or offset the impacts and the residual effects.
Planning Policy and Guidance
14.1.4 An appraisal of planning policy and guidance associated with the proposed
development is presented in the Planning Statement contained within Part 3 of
the Planning Application Document. For the purposes of this Chapter, a
summary of the most relevant socio-economic policies are identified below.
14.1.5 The Scottish Government published their Economic Strategy in September
2011. The strategy gives priority to accelerating economic recovery and seeks
to focus actions upon six strategic priorities including: a supportive business
environment; transition to a low carbon economy; learning, skills and well-
being; infrastructure development and place; effective government; and
equality. These priorities are intended to drive sustainable economic growth
and develop a more resilient and adaptable economy.
14.1.6 The National Performance Framework (NPF) December 2011 sets out a
range of high level targets and objectives through which Scotland’s
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performance is measured. It also includes 16 national outcomes and 50
national indicators. The Proposed Development would contribute to the
achievement of the NPF by assisting in the achievement of the:
“Greener” Strategic Objective;
“We value and enjoy our built and natural environment and protect it and
enhance it for future generations” and: “We reduce the local and global
environmental impact of our consumption and production” National
Outcomes; and
“Reduce Scotland’s Carbon Footprint” and “Reduce Waste Generated”
National Indicators.
14.1.7 The National Planning Framework (NPF) and the Scottish Planning Policy
(SPP) set the context for development planning and provide the spatial
development for Scotland. The latest versions of the NPF (i.e. NPF3) and SPP
were prepared and published concurrently (June 2014). Consequently, they
share a single vision which includes living in a growing, low carbon economy
with progressively narrowing disparities in wellbeing and opportunity.
14.1.8 The NPF3 identifies that the SES Plan area is projected to have the second
largest rate of growth of the four Strategic Development Plan Areas (SDPAs),
a 20% increase in population and 32% increase in households between 2010
and 2035. A planned approach is required to ensure the development needs
are met, whilst taking into account existing and future infrastructure capacity.
14.1.9 The Midlothian Local Plan identifies a range of aims and objectives, of
relevance to this Chapter including; providing positively for development which
secures long-term social, economic and environmental benefits.
14.2 Methodology
14.2.1 The assessment of socio-economic effects has been based on a widely used
and accepted methodology which considers the sensitivity of the socio-
economic receptors and the magnitude of the impact arising from the
proposed development on the identified receptors. The significance of effect is
then determined by considering both the sensitivity and the magnitude.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 402
14.2.2 The assessment considered the potential for the Proposed Development to
affect local socio-economic conditions within the impact area during both the
construction phase (potential temporary effects), and through its operation
phase (potential permanent effects) once the development is complete and
operational.
14.2.3 It has been carried out by undertaking a desk based study and reviewing key
statistical information. The background information employs key sources of
data including the: 200123 and 2011 Census24, NOMIS from the Office of
National Statistics (ONS)25, Scottish National Statistics (SNS)26, the Scottish
Government27 and Midlothian Council28 websites.
14.2.4 The proposed development has the potential to effect local socio-economic
conditions through five main forms of socio-economic impacts:
Direct economic impacts: jobs (measured as full time equivalents) and
wealth (measured as gross value added or GVA29) that are wholly or
largely related to the construction and operation of the proposed
development and generated in the impact area.
Indirect economic impacts: full-time equivalent jobs and gross value
added generated in the economy of the impact area via the supply chain
of goods and services which support the direct activities.
Induced economic impacts: full-time equivalent jobs and gross value
added created by direct and indirect employees’ spending in the impact
area.
Wider socio-economic impacts: impacts in both the construction and
operational phases, including wider construction worker effects in the
local area via expenditure, as well as by-products from the process and
fiscal benefits to Midlothian Council via the retention of business rates.
14.2.5 A significance of effect matrix for the socio-economic assessment has been
developed based upon the characteristics of the impact (magnitude and
23
http://www.nrscotland.gov.uk/statistics-and-data/census/2001-census 24
http://www.scotlandscensus.gov.uk/ 25
http://www.ons.gov.uk/ons/index.html 26
http://www.sns.gov.uk/ 27
http://www.gov.scot/Topics/Statistics 28
http://www.midlothian.gov.uk/info/695/about_us/1309/open_data 29 Gross value added or GVA is a standard measure of wealth creation used in economic impact assessments.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 403
nature) and the sensitivity of the receptor. This is summarised in the following
tables.
14.2.6 The framework for assessing the sensitivity of the receptor is outlined in Table
14.1 below. The assessment takes account of the importance attached to the
receptor (or indicator) in policy, together with professional judgement relating
to the scale of socio-economic challenges (drawing on analysis within the
socio-economic baseline).
Table 14.1: Framework for Assessing Sensitivity of the Receptor
Sensitivity of receptor
Criteria Example Criteria
Very High
Receptor is accorded a very high priority in local and
regional development and regeneration policy.
Identification as a highest ranking thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of severe socio-economic challenges, under-performance or vulnerability i.e. patterns of deprivation, employment and wealth generation, employment forecasts, exposure to socio-economic threats.
High
Receptor is accorded a high priority in local and regional economic development and
regeneration policy.
Identification as a key thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of major socio-economic challenges, under-performance or vulnerability i.e. patterns of deprivation, employment and wealth generation, employment forecasts, exposure to socio-economic threats.
Medium
Receptor is accorded a medium priority in local and
regional economic development and
regeneration policy.
No identification as a key thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of significant socio-economic challenges, under-performance or vulnerability.
Low
Receptor is accorded a low priority in local and regional economic development and
regeneration policy.
No identification as a key thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of economic prosperity, buoyancy and resilience (i.e. low levels of deprivation, relatively high employment and wealth generation rates, relatively strong employment forecasts).
Negligible
Receptor is accorded no particular priority in local and
regional economic development and
regeneration policy.
No identification as policy priority (i.e. as a result of economic potential and/or need). Evidence of good overall economic performance and long term prospects. No particular economic weaknesses or challenges.
14.2.7 Socio-economic impact magnitude is determined by consideration of the
predicted deviation from baseline conditions. The criteria used for the
assessment of magnitude of socio-economic impact (both positive and
negative) are shown in Table 14.2 over the page. An element of professional
judgement has been used in determining the magnitude of impacts.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 404
Table 14.2: Framework for Assessing Magnitude of Effects
Magnitude of Impact (Positive or Adverse)
Description
High Proposals would cause a large change – judged beneficial or adverse – to baseline environmental conditions in terms of absolute and/or percentage change.
Medium Proposals would cause a moderate change – judged as beneficial or adverse – to existing environmental conditions in terms of absolute and/or percentage change.
Low Proposals would cause a slight change – judged as beneficial or adverse – to existing environmental conditions in terms of absolute and/or percentage change.
Negligible No discernible change in baseline environmental conditions
No change No loss or alteration of characteristics, features or elements; no observable impact in either direction.
14.2.8 Magnitude and sensitivity are combined as shown in Table 14.3 below to
determine the significance of the impacts.
Table 14.3: Framework for Assessing Significance
Sensitivity of Receptor
Magnitude of Impact (Positive or Adverse)
No Change Negligible Low Medium High
Negligible Negligible Negligible Negligible Minor Minor
Low Negligible Negligible Minor Minor Moderate
Medium Negligible Negligible Minor Moderate Moderate
High Negligible Minor Moderate Moderate Major
Very high Negligible Minor Moderate Major Major
14.2.9 Using this scale, effects identified as major or moderate significance are
regards as being significant in EIA terms. Effect of minor or lesser significance
are also identified, but regarded as not significant in EIA terms.
14.2.10 During the preparation of this Chapter it has not been necessary to consult
with any technical consultees. Furthermore, during the preparation of this
Chapter no limitations to carrying out the survey / assessment have been
encountered.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 405
14.3 Baseline
14.3.1 This sub-section provides a summary of the baseline information that has
formed the basis of the socio-economic assessment. In addition, it also
identifies the future baseline scenario in the event that the development which
benefits from PPiP were to be developed at the site.
Baseline Data Collection
Baseline Conditions
14.3.2 The Local Government Boundary Commission for Scotland is responsible for
reviewing Local Government boundaries in Scotland. The Commission have
undertaken a number of reviews, however those of most relevance to this
assessment are:
The ‘Third Statutory Review’ which took place between 1996 and 1999
and came into force 1999. Figure 14.1 illustrates the geographical extent
of the Dalkeith / Newton Ward.
The ‘Fourth Statutory Review’ which took place between 2004 and 2006
and came into force 2007. Figure 14.2 illustrates the geographical extent
of the Dalkeith Ward.
14.3.3 As a result of amendments to ward boundaries in 2007, it is not possible to
make a direct comparison between the 2001 and 2011 Census (at a ward
level). However, direct comparison between the 2011 Census and subsequent
mid-year estimates can be compared alongside data for Edinburgh, Midlothian
and Scotland as a whole.
14.3.4 The Application Site is located in the Dalkeith Ward which forms part of the
Midlothian Local Authority Area. The Scottish National Statistics Area Profile
Report30 identifies that the Dalkeith ward was home to circa 11,730 residents
in 2011. Tables 14.4 – 14.6 over the page provide a breakdown of the
residential and working age populations.
30
http://www.sns.gov.uk/Reports/AreaProfile.aspx
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 406
Table 14.4: Resident Population
Area 2001 2011 2013
Absolute Change
(2001 – 2011)
Change
(%)
Change (%) p.a.
Dalkeith - 11,730 - - - -
Midlothian 80,941 82,370 84,700 1,429 1.73 0.17
Edinburgh 448,624 476,600 487,500 27,976 5.86 0.58
Scotland 5,062,011 5,254,800 5,327,700 192,789 3.66 0.36
Source: 2001, 2011 Census and NOMIS Local Authority Profile (ONS Mid-year population estimates 2013)
Table 14.5: Economic Activity (All Persons Aged 16 – 74)
Area 2001 2011 2013
Absolute Change
(2001 – 2011)
% Change
% Change
p.a.
Dalkeith - 8,707 - - - -
Midlothian 58,789 61,511 62,227 2,722 4.4 0.44
Edinburgh 342,431 376,018 377,945 33,587 8.9 0.89
Scotland 3,731,079 3,970,530 3,991,395 239,451 6.0 0.60
Source: Census 2001 and 2011 and NOMIS Local Authority Profile (ONS Mid-year population estimates 2013)
Table 14.6: All Persons 16 – 74 (as a Share of Total Population)
Area 2001 (%) 2011 (%) 2013 (%)
Dalkeith - 74.2 -
Midlothian 72.6 74.6 73.4
Edinburgh 76.3 77.6 77.5
Scotland 73.7 75.5 74.9
Source: Table 14.4 and 14.5)
14.3.5 As illustrated by the tables above, working age residents represent around
74.2% of the total residents in Dalkeith. The proportion of working age
residents is similar to Midlothian (74.6%) but below the national level (75.5%).
Whilst a comparison over time cannot be made for the Dalkeith ward, it is
clear that the general trends illustrate an increasing working age population
between 2001 and 2013, but a slight decrease thereafter.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 407
Economic Activity and Inactivity
14.3.6 Economic activity and inactivity data is provided by the SNS Annual
Population Survey31, and this is summarised in Tables 14.7, 14.8 and 14.9
below and over the page. The tables illustrate that for Midlothian the number
of ‘economically active but unemployed’ and ‘long-term unemployed’
individuals are below the national level. However, unemployed 16 – 24 year
olds and those who have never worked is above the national average. In
respect of Edinburgh the number of ‘economically active but unemployed’ and
‘long-term unemployed’ individuals is the same as the national level. However,
unemployed 16 – 24 year olds and those who have never worked is below the
national average. Finally, in terms of earnings in all instances Midlothian is
below and Edinburgh is above the national average.
Table 14.7: Economic Activity and Inactivity (2013)
Area Working
Age Population
%
Economically Active
Economically Inactive
Unemployed Other
Dalkeith 8,707 64.9 35.1 4.9 1.0
Midlothian 61,511 71.1 28.9 4.4 1.7
Edinburgh 376,018 69.0 31.0 3.9 1.9
Scotland 3,970,530 69.0 31.0 4.8 1.9
Source: NOMIS Scotland and Local Authority Profile (ONS mid-year population estimates 2013)
Table 14.8: Economically Active: Unemployment (2011)
Area Economically active:
Unemployed
Unemployed %
Age 16 to 24
Age 50 to 74
Never worked
Last worked in 2010 to 2011
Last worked in 2005 to 2009
Last worked before 2005
Dalkeith 431 36.4 14.8 16.8 17.4 24.2 41.6
Midlothian 2,700 35.6 15.6 14.8 49.7 27.3 8.2
Edinburgh 14,517 26.8 17.3 12.7 50.7 27.5 9.1
Scotland 18,414 30.2 18.4 13.9 47.4 28.0 10.7
Source: SNS Area Profiles Census 2011
31
http://www.scotland.gov.uk/Topics/Statistics/Browse/Labour-Market/Publications
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 408
Table 14.9: Earnings by Residence and Workplace (2014)
Area
Residence Workplace
Gross Weekly Pay Hourly Pay
Gross Weekly Pay Hourly Pay
Midlothian (£) 475.5 12.18 479.8 12.45
Edinburgh (£) 562.8 14.49 569.8 14.83
Scotland (£) 518.2 13.17 519.4 13.23
Source: NOMIS Local Authority Profile Midlothian and Scotland – ONS annual survey of hours and earnings 2014)
Unemployment and Worklessness
14.3.7 Job seekers allowance (JSA) claimants is one key measure of unemployment.
It enables analysis to be undertaken at a low spatial scale and at the time of
preparing this assessment the most contemporary data was from January
2015. The data contained within Table 14.10, illustrates that the percentage of
working age population seeking JSA in Midlothian and Edinburgh was 1.9%
which is lower than the national level of 3.1%.
Table 14.10: Total Jobseekers Allowance Claimants (January 2015)
Area Total Claimants %
Midlothian 1,027 1.9
Edinburgh 6,366 1.9
Scotland 84,304* 3.1*
Source: ONS Nomis, Job Seekers Allowance Claimants, December 2015 (Scotland JSA unadjusted figure)
Skills and Occupations
14.3.8 The qualification breakdown data contained within Table 14.11, over the page,
suggests that Midlothian has a lower than average proportion of residents with
NVQ levels 1-4+ and a higher than national average of residents with no
qualifications. This is the exact opposite for Edinburgh.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 409
Table 14.11: Qualifications Breakdown (2011)
No qualifications NVQ1-2 NVQ 3 NVQ 4+ Other
Qualifications
Midlothian 12.8 71.2 52.9 31.4 4.6
Edinburgh 5.3 87.7 73.4 54.6 3.7
Scotland 10.3 73.7 69.3 39.4 6.2
Source: Census 2011 and NOMIS Local Authority Profile – ONS annual population survey % is for 16 - 64 years)
14.3.9 Just over 40% of all employed working age residents in Midlothian are
employed in Standard Occupational Classification (SOC) Code Groups 1-3.
This is slightly below the national average of 41.6%. In terms of SOC Groups
4 – 5 and 6 – 7 Midlothian is above the national average, 23.1 and 19.7 when
compared to 22.2 and 18.3 respectively. However, whilst Midlothian is slightly
below the national average for SOC Groups 8 – 9 at 17.1 when compared to
17.8, it is clear that Midlothian has a higher than average percentage of
elementary occupations. In respect of Edinburgh SOC Groups 1-3 are
significantly higher than the national average, where are all other SOC Groups
are below national average.
Table 14.12: Employment by Occupational (Oct 2013 – Sept 2014)
Occupations (SOC) Midlothian
(%) Edinburgh
(%)
Scotland
(%)
SOC 2010 Major Group 1 - 3 40.1 53.5 41.6
1. Managers, directors and senior officials 8.4 9.2 8.7
2. Professional occupations 17.6 30.1 19.7
3. Associate professional and technical occupations 13.7 14.2 13.0
SOC 2010 Major Group 4 - 5 23.1 19.5 22.2
4. Administrative and secretarial occupations 9.0 12.8 10.6
5. Skilled trades occupations 13.9 6.7 11.5
SOC 2010 Major Group 6 - 7 19.7 14.7 18.3
6. Caring, leisure and other service occupations 11.7 6.5 9.4
7. Sales and customer service occupations 7.8 8.1 8.8
SOC 2010 Major Group 8 - 9 17.1 12.3 17.8
8. Process plant and machine operatives 3.9 3.4 6.3
9. Elementary occupations 13.0 8.9 11.4
Source: NOMIS Local Authority Profile (ONS annual population survey % is for 16+ years)
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 410
Travel to Work
14.3.10 Table 14.13 illustrates that 64% of people living in Midlothian travel to work by
car. This is slightly above the national average of 62.5%. In terms of
Edinburgh, 40% of people travel by car. Whilst travelling by train, walking and
working from home is below the national average for Midlothian it is clear that
traveling to work by bus is significantly higher at 18.2% when compared to the
national average of 10%. Figures for Edinburgh illustrate above average bus,
on foot and other travel.
Table 14.13: Travel to Work
Travel to Work Midlothian Edinburgh Scotland
All persons aged 16 to 74 who were in employment (excluding full-time students)
39,423 220,673 2,400,925
Car % (including passengers, car pools and taxis) 63.9 40.3 62.4
Train % 0.4 1.9 3.7
Bus % 18.2 25.6 10.0
On Foot % 6.4 16.3 9.9
Other % 2.2 5.5 3.1
Works mainly at or from home % 9.0 10.3 10.8
Source: NOMIS Local Authority Profile
Average House Prices
14.3.11 The Register of Scotland32 Quarterly House Price Statistical Report (February
2015) provides average house price data at a national and local authority
area. The latest data was gathered between October and December 2014 for
the four main housing tenures. Table 14.14 over the page provides data for
Midlothian, Edinburgh and Scotland.
32
https://www.ros.gov.uk/home
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 411
Table 14.14 Average House Price Data (Oct – Dec 2014)
Tenure Midlothian (£) Edinburgh (£) Scotland (£)
Detached 273,227 394,506 241,493
Semi-Dethatched 161,459 271,141 156,494
Terraced 139,443 262,326 133,725
Flatted 128,065 189,827 126,418
Source: Register of Scotland
Scottish Index of Multiple Deprivation
14.3.12 The most contemporary Scottish Index of Multiple Deprivation (SIMD) was
published in December 2012 and identifies small area concentrations of
multiple deprivation across Scotland.
14.3.13 The SIMD ranks the small areas, known as ‘datazones’, from most deprived
(Rank 1) to least deprived (Rank 6,505). This is calculated from the topic
based domains which are weighted 28% (Employment and Income), 14%
(Heath and Education), 9% (Access), 5% (Crime) and 2% (Housing).
14.3.14 The Application Site is located within the Midlothian Shawfair datazone
(reference: S01004228). As illustrated in Table 14.15 below, the overall SIMD
Score is 3,494 which illustrates that this datazone is slightly less deprived then
average.
Table 14.15: Scottish Index of Multiple Deprivation
Domains Midlothian Shawfair (S01004228) Rank
%
Overall SIMD Score 3,494 53.7
Income 4,013 61.7
Employment 3,544 54.4
Health 4,467 68.6
Education, skills and Training 4,054 62.3
Housing 3,404 52.3
Crime 2,149 33.0
Geographical Access 703 10.8
Source: Scottish Index of Multiple Deprivation (SIMD) 2012
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PPiP Future Baseline Scenario
14.3.15 The Environmental Statement prepared on support of the PPiP development
considered the socio-economic setting of the region in relation to the
population, employment, education, skills and deprivation. It focused more
upon the social aspects of the proposed development rather than the
economic aspects which form the basis of this assessment.
14.3.16 The socio-economic assessment carried out in support of the PPiP
development identified that, if developed, once operational the scheme would
on the whole give rise to generally beneficial effects in relation to the
assessment parameters, these are summarised in Table 14.16 below.
Table 14.16: PPiP Socio-Economic Effects
Topic Construction Operation
Accessibility and Recreation Temporary Negligible Permanent Negligible
Construction Vehicles Temporary Minor
Adverse Permanent Negligible
Employment Opportunities Temporary Moderate
Beneficial Permanent
Negligible Beneficial
Impact upon Local Businesses Temporary Minor
Adverse Permanent Minor
Adverse
Indirect Employment Temporary Minor
Beneficial Permanent Minor
Beneficial
Impact on Tourism Temporary Minor
Adverse Permanent Minor
Beneficial
The development will ensure that Edinburgh and Midlothian Councils are able to meeting the National and International future waste targets.
- Permanent Moderate
/ Major Beneficial
Source: PPiP ES Socio-Economic Chapter: Table 12.19
14.3.17 Thus in the event that the PPiP development were to be developed it would on
the whole give rise to environmental effects that range from Minor Adverse to
Moderate / Minor Beneficial in their significance but overall can be considered
beneficial.
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14.4 Assessment of Effects
Construction Phase
14.4.1 The proposed date for the commencement of construction on the Application
Site is September 2015. It is anticipated that the construction programme
would be structured into six key activities (site clearance / establishment,
earthworks, structure, mechanical fit-out, electrical fit-out and ‘cold’
commissioning) lasting circa 28 months. A seventh activity ‘hot’
commissioning would be undertaken by operational staff and as such, this is
excluded from the assessment of temporary construction impacts.
14.4.2 Current construction employment estimates consider the potential on-site
construction impacts of the proposed development over a circa 28 month
construction period. The scale of employment has been derived by the wider
construction team, on the range and types of construction activities which are
anticipated to be required on-site, to deliver the construction and commission
of the proposed development. This was informed by the consultant team’s
knowledge and experience from other energy facilities.
14.4.3 The proposed development has the potential to support, on average around
180 to 200 temporary on-site construction jobs per annum. However, peak on-
site employment is anticipated to be during the fit out and installation phase,
when the construction of the building has been completed, and the internal
fitting out of the facility is underway. During this period circa 300 jobs would be
supported on-site.
14.4.4 The key activity stages in the construction process were discussed with
technical advisors within the project team. Key tier 1 sub-contractors have
been identified, including: CNIM-Lagan (Engineering Procurement and
Construction (EPC) Contractor), Lagan (Civil Contractor) and CNIM
(Technology Provider).
14.4.5 It would be the sole responsibility of these contractors to deliver the project.
However, it is likely that the appointed EPC Contractor would develop a series
of sub-contracting work packages which would go out to tender. This is
anticipated to include further civil sub-contracting opportunities / work
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 414
packages such as ground works, steel work and block work etc. Given the
scale of the local construction business base in Midlothian and Edinburgh it is
assumed that many of these identified trades, many quite labour intensive,
could be fulfilled by local contractors from within the local study area.
14.4.6 The local area has a significant level of construction related businesses and
relevant skills base33. There is also demand within the labour market for this
type of employment opportunity based upon the JSA claimants and above
average number of SCO5 ‘Skilled Trades’ and SOC9 ‘Elementary
Occupations’ within Midlothian. It is estimated that around 25% of the overall
construction employment could be local circa 50 FTE).
14.4.7 It is also assumed that the contractors and some of the workforce for
specialised elements of the project (particularly the technical processes) could
come from outside of the local study area. These are most likely be
employees / contractors from national and international specialist contractors
which would be required throughout the construction period, this is an
important consideration.
14.4.8 While challenging, it is useful to get a sense of the potential level of
expenditure which could occur during the construction phase. It is estimated
that the non-local temporary construction workers could spend £170,000 per
annum on food and drink34. Whilst, those non-local workers who would require
overnight accommodation could spend £135,000 per annum35. The underlying
expenditure assumptions are on the conservative side. As a result, the total
injection of expenditure into the local economy, over the duration of the
construction phase, could be greater than the estimated £305,000 per annum.
14.4.9 In light of these estimates, there is clearly scope for some local businesses to
benefit from the short-term opportunities during the construction of the
33
Midlothian Economic Development Framework – Construction Sector Action Plan 2008 34
Evidence from YouGov in 2005 found that on average workers spent £6 per day on food and drink alone. This seems relatively high, so a daily expenditure of £5 per worker as applied. The construction phases leads to, on average 180 workers on-site per day. If local workers are discounted (circa 50), 130 workers could potential be buying food and drink locally, that otherwise would not have done so. Based on a 5 day working week and 52 weeks per year, this equates to a total expenditure of £170,000 per annum. 35
It is assumed that 10% of non-local workers may require overnight accommodation (on average 13 workers per day). Based on a 4 day requirement, an average cost of £50 per night. This equates to expenditure of circa £135,000 per annum.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 415
proposed development. In particular, those within the accommodation and
hospitality sectors.
Operational Phase
14.4.10 This sub-section focuses on the economic benefits of the Proposed
Development once it has become operational. It considers the direct, indirect
and induced employment benefits, as well as quantifies the annual Gross
Value Added (GVA) benefits of the proposal.
Direct employment refers to the workers employed directly at the
Proposed Development;
Indirect employment refers to jobs supported in the supply chain within
the Midlothian and Edinburgh area as a result of the expenditure of the
operator on bought goods and services;
Induced employment refers to jobs supported in the Midlothian and
Edinburgh area through the deployment of additional wage income of
the direct and indirect workers.
GVA is defined as the value of goods and services by an area, sector or
producer minus the cost of the raw materials and other inputs used to
produce them. GVA is mainly composed of the income made by
employees (earnings) and the business (profits / surplus) as a result of
production.
Direct Economic Impacts
14.4.11 The plant would provide permanent employment for up to 39 people, working
in shifts to maintain 24-hour / 7-day per week cover. The majority of
employees would be skilled operatives (electricians / fitters / crane operatives)
or technical engineers (control and plant).
14.4.12 It is anticipated that the proposal scheme would be operated by a total daily
staffing level of the order of 30 staff, broken down into a number of shifts.
Peak day time staffing levels on site are predicted to occur during the early
afternoon shift change period (13:00-14:00) when up to 22 staff could be
present on site. The EfW facility could be expected to operate a three shift
system (5 staff per shift) to support 24 hour operation of the plant, with the MT
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 416
facility operating a two shift system (1 staff), reflecting the 05:00 – 23:00
operating hours of this element of the Proposed Development. Up to 5 office /
management staff could be expected to work a more traditional 08:00 – 17:00
weekday pattern.
14.4.13 The proposed development would support a range of different occupations
across these two key elements. However, taking the proposed development
as a whole, the majority of jobs would be skilled trades’ occupations (SOC5).
These jobs would be mainly technician roles for the facility. However the
majority of jobs would be process plant or machine operatives (SOC8) or
elementary roles (SOC9) within the facility.
14.4.14 In light of the majority of jobs requiring lower-level skills, and given the
demand for lower-skilled roles across the local study area (identified in the
baseline analysis), it is assumed that the proposed development would attract
and recruit staff for the middle-level and low-skilled roles from within local
labour market, as well as neighbouring districts. While some experience in
similar roles would be beneficial (in waste or other relevant sectors), with
appropriate training local people could fulfil these roles. Given that a number
of actions could also be implemented to maximise local employment impacts
(see mitigation section), it is anticipated that leakage of job opportunities
outside of the district would be limited.
14.4.15 Given the nature of the more specialised and higher skilled managerial /
engineering roles at the proposed development, it is anticipated that these
roles would be filled by experienced individuals who have experience working
within a waste or energy role. Whilst these roles could potentially be filled by a
resident from within the local study area, this cannot be guaranteed at this
stage, as a recruitment strategy would be developed by the operator.
However, for the purposes of this assessment it has been assumed that the
manager and deputy manager would reside within Midlothian or Edinburgh
(either being an existing resident, or a new resident who moves to the area as
a result of the recruitment process).
14.4.16 In addition to the above, FCC Environment operate its own apprenticeship
programme and the Centre will create up to 3 apprenticeships on an on-going
basis and is committed to making a positive contribution towards the
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 417
sustainable economic growth of the area. The aspiration is to provide
employment and modern apprenticeships to people within the region through
the construction and operation of the RERC.
14.4.17 Table 14.17, over the page, highlights the potential roles at the proposed
development and potential average annual FTE salaries. The salary ranges
have been estimated by the project team as appropriate to the role’s skill
requirements in this area of the UK and based on experience with other
projects. It is estimated that the total gross salaries (i.e. employment income)
paid to staff would be in the region of £1M to £1.1M per annum. The analysis
of the potential induced economic impacts takes into consideration the
impacts of this employment income being spent in the local economy by
proposed development employees.
Table 14.17 Potential Average Annual Gross Employment Income
Standard Occupational Categories Total No of FTE jobs
Average FTE wage
Average Annual Gross Employment Income (£)
SOC1/2: Managerial / Professional Occupations
1 £70,000 £70,000
SOC3: Associate Professional and Technical Occupations
3 £40,000 £120,000
SOC5: Skilled Trades Occupations 11 £35,000 £385,000
SOC8: Process; Plant and Machine Operatives
10 £25,000 £250,000
SOC9: Elementary Occupations 14 £17,000 £238,000
Total 39 - 1,063,000
Note: Average annual gross full-time employment income is estimated by using salary estimates provided by the applicant, and employment estimates provided
by the technical consultant team’s previous experience.
Indirect and Induced Economic Impacts
14.4.18 This sub-section quantifies the level of direct jobs (i.e. jobs in the supply chain
supported by expenditure of the Proposed Development on bought goods and
services), as well as induced jobs supported locally (i.e. jobs in the local area
supported through the deployment of additional wage income of direct and
indirect workers). For the purposes of this assessment, impacts have been
considered at the local authority and national level.
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 418
Indirect Jobs – Impact from Bought in Goods and Services
14.4.19 The business planning process for the proposed development has indicated
that annual expenditure on bought in goods and services to support the
operation could potentially be in the region of £2.7M per annum. Whilst the
business planning process is ongoing, these costs have been derived from
sector knowledge and understanding of the requirements of operating such a
facility (i.e. purchasing key inputs, raw materials, to support the process);
maintaining the sophisticated mechanical and electronic equipment (both
operational and monitoring equipment); as well as other costs associated with
operating the proposed development.
14.4.20 The majority of this expenditure is expected to flow to businesses and service
providers outside of Midlothian and Edinburgh, predominantly national and
international providers. Notwithstanding this, the potential exists for the local
economy to adapt to the proposal and for new supply companies to establish
locally or local companies to seek to diversify the range of goods and services
they offer. Table 14.18, over the page, demonstrates it is judged that circa
£0.8M (circa 30%) of the centre’s annual expenditure on bought in goods and
services could potentially be spent within Midlothian and Edinburgh.
14.4.21 The following table outlines some of the main goods and services which could
be purchased from within Midlothian and Edinburgh. Annual contract costs
have been estimated for services such as:
Security (based on a CCTV and call out contract basis);
Site landscaping and maintenance;
Supplies of office materials and other services;
Office and communal area cleaning;
Consumables for the centre (i.e. water treatment, oils);
Water supply; and
Haulage of by-products off-site (i.e. bottom ash used as an aggregate
for the construction sector, recycled metals, reject material and APC
residues) which can be transported off site regularly by a locally
contracted haulier. The total amount of haulage of material off-site is
estimated at around 57,300 tonnes per annum.
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14.4.22 It is estimated that this level of expenditure could potentially support 7.1 (i.e.
7) full-time within the Midlothian and Edinburgh economy.
Table 14.18: Potential Local Expenditure on Bought in Goods and Services
Expenditure Item Annual Contract Value (£)
FTE Jobs Supported
Site landscaping £10,000 0.25
Office supplies £7,000 0.01
Office and communal area cleaning £9,500 0.5
Facility consumables £70,000 0.09
Haulage of by-products £355,130 3.78
Water supply £270,000 1.03
Security £75,000 1.5
Total 796,630 7.16
Note: This table does not cover all expenditure as information is not available. This table summarises potential local expenditure
from the proposed development.
Direct and Indirect Employee Salary Impacts – Induced Benefits
14.4.23 The induced employment effects for Midlothian and Edinburgh, as a result of
the direct and indirect employment arising from the proposed development,
have also been estimated. Induced employment effects are those jobs
supported in the area via the deployment of income from those employed
directly and indirectly by the Midlothian RERC development.
14.4.24 The estimates are based on the assumption that all of the directly employed
workers would reside within the area. For those workers indirectly employed,
via expenditure on contracted services (i.e. cleaning, maintenance, security
and landscaping), it is also considered that these roles would most likely by
filled by workers or contractors from within the area, given the nature of the
roles.
14.4.25 Estimates for total gross income for direct employees were determined using
experience from other projects. For indirect employees, the Annual Survey of
Hours and Earnings (ASHE)36 was used. In total, it is estimated that, directly
36
http://www.ons.gov.uk/ons/rel/ashe/annual-survey-of-hours-and-earnings/index.html
1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 420
and indirectly, the proposed development would support circa £1.4M of gross
employment income per annum in the local economy.
14.4.26 Net incomes were estimated by taking account of workers potential income
tax and employee national insurance contributions. Taking these into account,
total annual net employment income is expected to be £0.9M per annum. It is
estimated that around half (i.e. £0.45M) of net income would be spent within
the local study area. It is estimated that this level of expenditure could
potentially support circa 4 FTE induced jobs in the area.
Summary of Direct, Indirect and Induced Economic Impacts
14.4.27 The following table provides a summary of the potential total employment
impacts (including direct, indirect, and induced employment) of the proposed
development, as well as associated annual gross value added impacts.
14.4.28 It is estimated that the proposed development could support 50 FTE direct,
indirect and induced jobs within the area. This has the potential to lead to an
annual gross value added impact of circa £3.8M per annum.
Table 14.19: Summary of Total Economic Impacts (Employment and GVA)
Impacts FTE Jobs GVA (£m) Per Annum
Direct Impacts 39 3.3
Indirect Impacts 7 0.4
Induced Impacts 4 0.1
Total Economic Impacts 50 3.8
Note: Annual GVA impacts estimates are derived from using best-fit industries and their associated GVA per FTE worker estimates from within the ONS
Annual Business Survey, 2011. (See Appendix 14-1 for GVA Details)
Wider Socio-Economic Impacts
14.4.29 The above assessment calculates potential annual gross value added impacts
using national gross value added per full-time equivalent benchmarks for a
sub-sector of the waste industry.
14.4.30 The proposed development could also deliver some wider socio-economic
impacts.
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Non-domestic (Business) Rate Retention
14.4.31 The electrical generation capacity of the Proposed Development would be
13.45MWe. A small proportion 2.36MWe of this would be used to power the
Proposed Development itself, with the majority 11.09MWe exported to the
local electricity grid. Based upon maximum electricity output the Proposed
Development would export circa 87,012MWe hours per annum. This is
sufficient to meet the domestic electricity needs for over 26,000 homes.
14.4.32 The proposed development would be liable for non-domestic (business) rates
which would be paid to Midlothian Council. Following a government review,
there has been a shift in policy regarding business rate retention for local
authorities who support the development of renewable energy projects.
14.4.33 The biodegradable (or biomass) content of the waste is recognised as a
renewable source of energy. Thus around 50-55% of the energy produced by
the ERC, whether it would heat or electricity, would be classes as renewable
energy. Depending upon a range of factors, the proportion of renewable
energy generation could be subject to business rate relief but this would need
to be determined through a detailed assessment.
14.4.34 The Proposed Development would generate electricity, a proportion of which
would be classified as renewable. Therefore Midlothian Council now have the
ability to retain the business rates associated with these types of energy
generating projects. Business rates for other facilities have been researched
in various locations and sizes. Whilst the nature of the proposed development
could be different to some of those reviewed, the principle of the valuation
process used would be the same (i.e. based on energy generation output).
The review highlighted a range of rates at circa £44,000 per MW to £53,000
per MW.
Taking the conservative, lower position of £44,000 per MW and with
energy output of 11.09MW, this proposed project has the potential to
deliver a business rate contribution to Midlothian Council of circa
£487,960 per annum.
However, based on the percentage of renewable energy generated,
taking the conservative, 50% figure then the proposed project has the
potential to deliver a business rate contribution of circa £243,980.
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District Heating and Heat Off-Take
14.4.35 Through the combustion of SRF the Proposed Development could generate
up to 50MW of heat energy in the form of steam. A proportion of this steam
would be used to generate electricity with the balance exported as heat (either
steam or more likely hot water). A number of potential users of the hot water
have been identified in the surrounding area, including the SNCD.
Recyclable and By-products
14.4.36 Waste processing at the RERC development would also lead to outputs or by
products which could deliver economic value in other ways. These include:
Recyclables: The MT plant would recover ferrous and non-ferrous
material for recycling within a suitably licenced facility. While the
assessment has already considered the employment and economic
value associated with the haulage of this material, there would clearly be
further value in these products. The metals could be processed locally
and would assist in reducing demand upon our natural resources.
ERC by-products: The EfW process would lead to the generation of
bottom ash. This can be used in the construction industry as a
secondary aggregate. The RERC development would generate circa
46,500 tonnes per annum. While the assessment has already
considered the employment and economic value associated with the
haulage of this material, there would clearly be further value in these
products. The ash could be processed locally and would assist in
reducing demand upon our natural resources.
14.4.37 In addition to the above, social and community benefits would arise from the
new education and visitors centre which would enable the community and
schools to learn about waste management and how they can take more
responsibility for their own waste.
Decommissioning
14.4.38 It is considered that the decommissioning process would deliver positive
socio-economic impacts through the procurement of a demolition contractor
and standard sustainable demolition practices.
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14.5 Additional Mitigation
14.5.1 No specific mitigation measures are identified in respect of socio-economic
impacts which arise from the proposed development. The impacts for the local
employment and job market are judged to be positive.
14.5.2 Whist no mitigation measures are presented, there is potential scope to
ensure that employment and supplier opportunities are maximised to their full
potential in the local area. A number of potential actions are summarised in
Table 14.20 below and these can be discussed with the local authority, in due
course. Some of these actions could potentially be pursued by the developer
during the construction phase, and by the future operator.
Table 14.20: Possible Actions to Maximise Local Employment and Supplier
Impacts
Issue Actions
Construction contractors seeking to secure work from lead construction contractor.
Lead contractor could provide and disseminate an Annual Statement of Predicted Tender Work Packages – this would provide advance warning to local firms of upcoming opportunities. Facilitate ‘Supplier Days’ around key construction phase contracts – again to advertise upcoming opportunities.
Local construction workers seeking to access on and off-site employment opportunities.
Ensure lead contractors inform the local Council / other key agencies of all construction-related job vacancies. Ensure that any sub-consultant contracts require sub-consultants to advertise vacancies via the appropriate local channels.
Local traders (shops) wanting to maximise trade from visiting contractors.
Notification to local traders of when key waves of visiting contractors would be on site. Opportunities for local traders to visit site with key provisions (i.e. mobile snacks, drinks provisions), or to provide local discount offers to workers to encourage patronage. Establishment of a local liaison committee.
Local workers wishing to seek long term employment opportunities within the operational phase.
Work with local training providers during the construction phase to ensure they are aware of the upcoming permanent opportunities for staff and are scaling up their provision accordingly. In the peak recruitment period, a local ‘Job and Careers Fair’ could be hosted advertising upcoming opportunities to those in the labour market and those unemployed. Make available a number of local apprenticeships in key occupations to younger residents.
Local traders wanting to benefit from operators requirements for bought-in goods and services.
Operator to provide to local Council/business support organisations requirements for any major bought-in goods and services. Partners to make local businesses aware of any upcoming trading opportunities.
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14.6 Residual Effects and Conclusions
14.6.1 Given that there is no mitigation measures required in relation to the socio-
economic impacts, the following sub-section provides an assessment of the
significance of the identified socio-economic impacts, from both the
construction and operational phases under each scenario.
Residual Effects with Existing Baseline
Construction Phase
14.6.2 The following provides an overview of the judgement made on the sensitivity
of the local employment base receptor. The receptor is judged to have a High
sensitivity for the following reasons:
The socio-economic baseline has identified that there is a higher than
average number of people working in SOC5 ‘Skilled Trades’ and SOC9
‘Elementary Occupations’ in Midlothian. These skill occupation
classifications include the main occupations required to construct the
Proposed Development. Whilst, Edinburgh has a below average number
of people employed in SOC Groups 4 to 9 there considering the number
of economically active individuals in the city there is still a large number
of people working in these Groups.
The number of Individuals who are economically active but unemployed
in Midlothian is below the national average. For Edinburgh it is exactly
the same as the national average. However, for Midlothian the statistics
illustrate a higher than average number of unemployed 16 to 24 year
olds when compared to the national average. The implementation of
actions to maximise local employment opportunities for this age group
could assist.
FCC Environment operate its own apprenticeship programme and the
Centre will create up to 3 apprenticeships on an on-going basis and is
committed to making a positive contribution towards the sustainable
economic growth of the area. The aspiration is to provide employment
and modern apprenticeships to people within the region through the
construction and operation of the RERC.
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Total job seekers allowance claimants within Midlothian were 1,027
(January 2015) which equates to 1.9% of the working age population.
Edinburgh exhibits the same percentage. Both are below the national
average which is 3.1%. The Proposed Development could assist in
reducing the number of claimants through the mitigation measures
previously identified.
14.6.3 The following provides an overview of the judgement made on the magnitude
of impacts. This is judged to be of Medium magnitude for the following
reasons:
The construction phase has the potential to deliver up to 180 on-site
temporary employment jobs per annum (circa 28 months). The
Proposed Development has the potential to support on average around
180 to 200 temporary on-site construction jobs per annum.
Of those on-site jobs, it is estimated that circa 50 FTE jobs could be
secured during the construction period by local contractors and workers,
given the nature of the skills required for elements of the civil
engineering work package. For some elements of the construction, the
proportion of local workers could be greater (i.e. ground works).
There could be further benefits locally for some businesses (food and
drink, accommodation providers) that may ultimately benefit as a result
of any temporary visiting workforce.
14.6.4 Applying the identified assessment framework, the socio-economic effects of
the construction phase of the Proposed Development are judged to have
Moderate (beneficial) Significance in the impact area.
Operational Phase
14.6.5 The following provides an overview of the judgement made on the sensitivity
of the local employment base receptor. The receptor is judged to have a High
sensitivity for the following reasons:
The assessment has shown that there were 2,700 residents of a
working age in Midlothian who were seeking employment. There were
14,517 residents of a working age in Edinburgh who were seeking
employment.
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The JSA claimant rate for January 2015 illustrated that in Midlothian
1,027 (1.9%) of the working age population were claiming JSA. In
Edinburgh this figure was 6,366 (1.9%).
14.6.6 The following provides an overview of the judgement made on the magnitude
of impacts. This is judged to be of Medium magnitude for the following
reasons:
The proposed RERC is anticipated to directly support circa 39
permanent FTE jobs once fully operational.
The majority of all jobs would be skilled trades’ occupations (SOC5).
These jobs would be mainly technician roles for the ERC, as well as
some supervisory roles for the MT. Around 60% of all jobs would be
process plant or machine operatives (SOC8) or elementary roles
(SOC9). These jobs would be in operational roles within the ERC, as
well as drivers and operatives within the MT.
It is assumed that the operator would be able to recruit staff for the more
middle-level and low-skilled roles from within the Midlothian and
Edinburgh labour markets.
Once indirect and induced employment impacts are also considered, it
is estimated that the energy centre could support 50 permanent FTE
jobs within the impact area. This has the potential to lead to an annual
GVA impact of circa £3.8M per annum.
14.6.7 Applying the identified assessment framework, the socio-economic effects of
the operational phase of the Proposed Development are judged to have
Moderate (beneficial) Significance in the impact area.
Table 14.21: Summary of Significance of Residual Effects
Likely Significant Impact Sensitivity of Receptor
Magnitude of Impact
Significance of Effect
Construction Phase – Local Employment Base Receptor
High Medium Moderate (positive)
Operational Phase – Local Employment Base Receptor
High Medium Moderate (positive)
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Assessment against PPiP Future Baseline Scenario
14.6.8 The ES prepared in support of the development benefiting from PPiP
concludes that it would give rise to a number of socio-economic effects of
minor beneficial significance. These comprise:
Improved employment opportunities;
Improvements to security and health and safety at the site;
A positive contribution to socio-economic policy at all levels; and
A wider effect on the economy through direct business.
14.6.9 As demonstrated above, the anticipated residual socio-economic effects
associated with the Proposed Development have been assessed as being of
moderate beneficial significance. Accordingly, and whilst acknowledging
that the parameters for the two assessments differ, it is reasonable to
conclude that when compared to the future baseline scenario, the Proposed
Development, would, as a minimum, have a neutral impact.
14.7 Conclusions
14.7.1 This Chapter has reviewed the key socio-economic impacts has of the
Proposed Development, focussing on the direct, indirect, and induced impacts
for the impact area, as well as a series of wider impacts the development
could potentially deliver. The Chapter has considered the significance of the
effects upon the local employment base receptor.
14.7.2 The assessment of the significance of effects of these impacts demonstrated
that during both the construction and operational phases the Proposed
Development would deliver moderate beneficial effect for the local
employment base, given the scale of employment need and the number of
temporary and permanent jobs available.
14.7.3 In conclusion, it is judged that the Proposed Development would not have any
significant negative adverse socio-economic impacts in the impact area. The
development would in-fact deliver a range of socio-economic benefits for
residents and businesses. A summary of these benefits are as follows:
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39 FTE permanent direct jobs within the impact area. Given the nature
of the jobs supported (many of the roles require elementary or lower
level skills) and the local labour market need (levels of unemployment
locally and across the study area, types of jobs sought and range of
skills of labour force), it is anticipated that these jobs would be secured
by residents from within the local study area.
50 FTE direct, indirect (local supply chain) and induced permanent jobs
in the impact area. These jobs could support around £3.8M of gross
value added per annum.
Opportunities to ensure that local residents and businesses have access
to the employment and business supply chain opportunities which may
emerge. There are a range of actions which could be implemented
which can maximise and localise the economic benefits of the proposed
development.
FCC Environment operate its own apprenticeship programme and the
Centre will create up to 3 apprenticeships on an on-going basis and is
committed to making a positive contribution towards the sustainable
economic growth of the area. The aspiration is to provide employment
and modern apprenticeships to people within the region through the
construction and operation of the RERC.
Opportunities to deliver annual fiscal benefits of up to £0.4M to
Midlothian Council, through the retention of business rates.
Opportunities to create further value in the waste processing chain
through the sorting of recyclable materials and the creation of by-
products which can be used in other sectors (i.e. bottom ash in the
construction sector).
The generation of circa 13.46MW of electricity, a proportion of which
would be classified as renewable and circa 11.09MW can be exported to
the National Grid.
Through the combustion of SRF the Proposed Development would
generate up to 50MW of heat energy in the form of steam. A proportion
of this steam would be used to generate electricity with the balance
exported as heat (either steam or more likely hot water). A number of
potential users of the hot water have been identified in the surrounding
area, including the SNCD.
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14.7.4 In addition when compared to the future baseline scenario (the scheme
benefiting from PPiP), it has been concluded that the effects of the Proposed
Development would be at least a ‘neutral’.
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15.0 CUMULATIVE EFFECTS
15.1 Introduction
15.1.1 This Chapter of the ES provides an assessment of the likely significant
cumulative effects of the Proposed Development during its construction and
operation.
15.1.2 The EIA regulations require that a description of the likely significant effects of
the development on the environment should be included in the ES, including
cumulative effects. The EIA regulations do not define cumulative effect.
However, a commonly accepted definition is: “Impacts that result from
incremental changes caused by other past, present or reasonably foreseeable
actions together with the project” (EC, 1999).
Planning Policy and Guidance
15.1.3 The Planning Statement contained within the separately bound Planning
Application Document includes an appraisal of the planning policy context
associated with this proposal. A brief summary of the planning policy context
in so far as it relates to the assessment of cumulative effects is provided
below.
National Policy
15.1.4 SSP provides the Governments planning policies for Scotland. The key
relevant paragraphs with regard to cumulative effects are summarised below.
Paragraph 155 within the section relating to ‘A Low Carbon Place’
identifies that: “Development plans should seek to ensure an area’s full
potential for electricity and heat from renewable sources is achieved, in
line with national climate change targets, giving due regard to relevant
environmental, community and cumulative impact considerations.”
Paragraph 202 within the section relating to ‘A Natural, Resilient Place’
identifies that: “Development management decisions should take
account of potential effects on landscapes and the natural and water
environment, including cumulative effects.”
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Paragraph 286 within the section ‘A Connected Place’ identifies that:
“Where a new development or a change of use is likely to generate a
significant increase in the number of trips a transport assessment should
be carried out. This should identify any cumulative effects which need to
be addressed.”
15.1.5 The local development plan currently comprises the SESplan and the
Midlothian Local Plan. The SESplan does not contain any policies relevant to
this ES Chapter. However, there are a number of policies within the Midlothian
Local Plan which make reference to the cumulative effects of development.
The majority of these policies are not relevant to this application as they deal
with matters such as: retail, commercial and leisure development, town centre
development, mineral extraction and residential development. The only policy
of relevance is Policy NRG1, which states: “The cumulative landscape and / or
visual impact of such proposals will be taken into consideration when
assessing individual planning applications,” In this context it must be noted
that the policy specifically refers to renewable energy projects as including
‘biomass’ and combined heat and power generation.
15.2 Methodology
Cumulative Effects
15.2.1 There is no accepted standard methodology in the UK as to how cumulative
effects should be assessed. However, in determining the approach to this
assessment reference has been made to the following guidance:
Guidelines for the Assessment of Indirect and Cumulative Impacts as
well as Impact Interactions (EC, 1999)
Cumulative Effects Assessment Practitioners Guide (Canadian
Environmental Assessment Agency, 1999);
Guidelines for Environmental Impact Assessment (IEMA, 2006); and
Environmental Impact Assessment: A guide to good practice and
procedures – A consultation paper (DCLG, 2006).
15.2.2 The assessment of cumulative effects has been based upon a multi-stage
approach which comprised:
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Identification of potential schemes which together with the proposed
development could give rise to cumulative or in-combination effects. The
approach to identifying these ‘relevant’ projects is set out more fully
below.
Obtain information on each ‘relevant’ project in terms of its scale, type
and nature from the relevant planning authority. Where available, this
information has been sourced from the Environmental Statement for the
project. If environmental information is not available, reasonable
assumptions have been made on the likely significant environmental
effects of the project.
Stage 1 Assessment: consideration of the likelihood of significant
cumulative effects (of the construction and operational phases of the
project). Through a qualitative assessment for the following topic areas:
o Landscape and Visual Effects;
o Ecology and Nature Conservation;
o Flood Risk;
o Air Quality;
o Noise and Vibration;
o Traffic and Transportation;
o Archaeology and Heritage; and
o Socio-Economics.
Where the qualitative assessment identifies that there is no potential for
likely significant cumulative environmental effects to occur, no further
assessment is required. Where it concludes there could be a likely
significant cumulative environmental effect, the project (or more
specifically the topic area for the project) is carried forward for more
detailed assessment.
Stage 2 Assessment: carry out a detailed assessment of likely
significant cumulative environmental effects using the methodology
relevant to the topic areas to be appraised.
Approach to Identifying ‘Relevant’ Projects
15.2.3 Projects that have been considered in the cumulative assessment are major
projects that have been granted planning permission, are not yet operational,
or have yet to be constructed. Major projects are considered to be
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developments of 10,000m2 in size, or greater, projects that have been subject
to EIA or projects that involve tall buildings or structures. Projects that fall
outside the above criteria, including schemes that are in the planning system
but not approved, have only been included in the assessment where they
have been specifically identified by the planning authority, other statutory
consultees or the project team as being of particular relevance.
15.2.4 The cumulative effect of operational projects are considered to already form
part of the baseline and as such, would be assessed within each of the
discipline Chapters. Further details of the projects that have been included in
the baseline for assessment and the appraisal to the assessment are provided
in Chapter 2.0. Consequently, the focus of the cumulative effects assessment
would be the appraisal of potential significant environmental effects in the
context of reasonably foreseeable future major development proposals.
15.2.5 A search area of 5km has been adopted to identify projects to be included in
the cumulative effects assessment and it is considered that projects beyond
this distance are unlikely to give rise to significant cumulative effects, indeed
for many of the disciplines / environmental topic areas the effects of the
development are more localised than 5km. In such instances some of the
projects identified in the provisional search have been excluded from the
assessment. Figure 15.1 illustrates the geographical extent of the 5km radius.
15.2.6 Information on the scale, type and nature of the projects included within the
cumulative assessment has been obtained from records held by relevant
planning authorities. Where available, this information has been sourced from
a project EIA. If environmental information is not available reasonable
assumptions have been made on the likely significant environmental effects of
the project. Each technical discipline has considered the likelihood of
significant cumulative effects initially through a qualitative assessment and if
necessary, through quantitative modelling. Where significant cumulative
effects have been identified these have been clearly reported and where
necessary mitigation measures recommended.
15.2.7 It should also be noted that as part of the Transport Assessment (TA) the
Highways Authority has been consulted to identify if there were committed
developments that should be included in the TA (Appendix 6-1). As such, the
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TA and the Chapters that rely on the assessment (i.e. air quality and noise) by
their nature include cumulative effects of other projects that would be likely to
give rise to significant transport effects.
15.2.8 The project team have not found any limitations to carrying out the survey /
assessment work in association with this Chapter.
15.3 Baseline
Baseline Conditions
15.3.1 For the avoidance of doubt it should be recognised that the baseline position
against which this EIA has been undertaken assumes that:
The Application Site remains in its current state (brownfield site with
self-regenerated woodland;
The Anaerobic Digestion Plant being constructed to the north of the site
is finished and operational;
The Borders Railway being constructed to the north and west of the site
is completed and operational;
The Shawfair New Community development is built and operational in
accordance with the approved masterplan; and
The site access and bridge over the Borders Railway (also under
construction to the north) is in place and operational.
15.3.2 In light of the above, this Chapter has not taken these developments into
consideration as they form part of the baseline for the purposes of this
environmental impact assessment.
Baseline Data Collection
Identification of Potential Schemes
15.3.3 The first stage in the data collection process involved the identification of
‘relevant’ schemes which together with the proposed development could
potentially give rise to cumulative or in-combination effects. This involved a
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comprehensive review of the planning application records held by the
following local authorities falling within the 5km radius:
Edinburgh City Council;
East Lothian Council; and
Midlothian Council.
15.3.4 The process involved contacting each local authority and requesting details of
any reasonably foreseeable major development projects (i.e. projects subject
to EIA) within their jurisdiction and within 5km of the site. A list of potentially
‘relevant’ schemes provided by each authority is contained within Appendix
15-1.
15.3.5 In addition to the above, each environmental topic has been scoped with the
relevant individual, authority or technical body. As part of the air quality
scoping exercise, the SEPA identified that the proposed new gas fired
Cockenzie Power Station could be a cumulative development worthy of
consideration. The SEPA identified that whilst the development has planning
permission it is only one of a number of options for the site and no permit
application discussions have taken place. Considering it is outside of the area
of search (i.e. beyond the 5km radius) and the lack of certainty over the nature
of development it has not been considered further within this Chapter. The
SEPA did not identify any other proposed development in the vicinity of the
site that could have an in-combination effect with the Proposed Development.
Information on Each Potentially ‘Relevant’ Scheme
15.3.6 Following receipt of the lists, from each authority, a review process was
undertaken. During this process it became apparent that the vast majority of
the applications were not relevant as they were not major applications (i.e.
erection of a satellite dish) or featured multiple times. Therefore the number of
potentially ‘relevant’ schemes was reduced significantly.
15.3.7 The remaining potentially ‘relevant’ schemes are identified in Table 15.1
below. Additional information was obtained through a desk based assessment
process. This entailed reviewing the planning history and making reasonable
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assumptions on likely significant environmental effects based upon the
supporting documentation for each scheme.
Table 15.1: Projects Evaluated in Terms of Cumulative Effects
Development Potential for Significant Environmental Effects
Land at Todhills, Old
Dalkeith Road, Dalkeith
The site has been the subject of several applications:
04/00405/OUT – outline application for a business park with supporting facilities (including nursery, restaurant, conference and catering facilities) and hospital with associated landscaping, road car parking and access.
05/00337/FUL – construction of park and ride facility, including car parking, bus turning and waiting facilities, with SUDs drainage and landscaping.
06/00721/FUL – removal of condition 2(c) and 5 (a) of planning permission 04/00405/OUT to allow revised phasing of spine road.
08/00436/FUL – variation of planning permission 04/00405/OUT to allow the deletion of Condition 9
08/00435/FUL – variation of condition 1 of planning permission 04/00405/OUT to amend the developable area.
08/00552/FUL – amendment to condition 1 of planning permission 04/00405/FUL to allow for the erection of a hotel and associated works.
10/00098/DPP – Erection of office building and script management facility and formation of car parking and access road and associated works.
The site is located circa 1.5km to the south west of the Proposed Development within the Shawfair Business Park. Supporting infrastructure (roads) and phased development already existing alongside a park and ride facility. It is not considered that the proposed development would give rise to significant cumulative effects given the distance between the sites and nature of development. Therefore it has not been considered further.
Land on the South side of
Eskbank Road, Bonnyrigg, Midlothian
The site has been the subject of several applications:
08/00385/RES – Erection of Community Hospital and associated energy centre, sub-station, service yard, car park, landscaping and SUDS feature (approval of reserved matters relating to planning permission 01/00068/OUT).
The site is located circa 4km to the south of the Proposed Development. The community hospital was built in 2010 and consequently is considered within the baseline. Therefore, it has not been considered further.
Land North of Edmonstone,
The Wisp, Danderhill
The site has been the subject of several applications:
06/00439/OUT – outline application for the erection of a 120 bed nursing home and 24 bed private hospital and associated works.
11/00661/PPP – amendment to condition 13 of planning permission 06/00439/OUT to extend the time frame for submission of matters specified within Condition 1 of that permission.
The site is located circa 1.5km to the west of the Proposed Development. It currently comprises of dense vegetation and no development appears to have commenced. Given the distance and nature of the proposal it has not been considered further.
Former Jewel and Esk Valley College Site,
Newbattle Road, Eskbank
The site has been the subject of several applications:
06/00347/OUT – outline application for residential development (140 dwellings) with associated access and landscaping.
08/00410/RES – application for reserved matters for residential development, access and landscaping.
10/00172/MSC – application for approval of matters specified in conditions 1(d), 2(c) and 2(I) of planning permission 06/00347/OUT for residential development access and landscaping.
The site is located circa 4km to the south of the Proposed Development and is currently vacant. Given the distance and intervening development it has not been considered further.
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Bus Garage, Eskbank Road,
Dalkieth
The site has been the subject of several applications:
07/00303/FUL – mixed use development comprising of a supermarket, leisure, restaurant, bar, health and fitness, offices and formation of service yard.
12/00635/DPP – amendment to condition 31 of planning permission 07/00303/FUL to extend the time limit for implementation.
12/00418/PAC – Proposal of application notice for amendment to Condition 31 of planning permission 07/00303/FUL to extend the timescale for implementation.
13/00226/DPP – Erection of a supermarket and formation of associated car parking service area and road access.
The site is located circa 3.2km to the south of the Proposed Development. The site is currently vacant. Due to the distance and intervening development, it has not been considered further.
Land adjoining St Davids
Roman Catholic Primary School, Louder Road,
Dalkeith
The site has been the subject of several applications:
07/00465/FUL – erection of 223 dwellings, associated roads, landscaping and drainage.
14/00556/LA – application to partially discharge planning obligations with a legal agreement.
The site is located circa 4km to the south east of the RERC development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.
Millerhill Marshalling
Yard, Dalkeith
The site has been the subject of several applications:
12/00060/DPP – Formation of access road, bridge and associated infrastructure.
12/00514/PAC – proposed application notice for new railway depot, stabling, and cleaning facilities associated new railway lines, office and staff welfare and car parking and access.
12/00837/DPP – Formation of train maintenance, cleaning and stabling depot; erection of retaining wall and alterations to ground levels; formation of new railway lines; erection of boundary fencing; and formation of associated car parking and access.
The site is located immediately to the east of the Proposed Development. Given the distance from the Application Site and nature of the proposed development it has been considered in Table 15.2 below.
Wester Cowden,
Thornybank, Dalkeith
The site has been the subject numerous planning applications and is the subject of a Development Brief. Furthermore, a large number of residential properties have been constructed (i.e. Plots L1, L2, M1 and M3). However, it appears that a number of plots within the overall site currently benefit from planning permission for residential properties (i.e. Plot N2) and planning permission in principle is sought for others (i.e. Plot H1).
The site is located circa 3.5km to the south east of the Proposed Development. Given the distance, intervening geography (i.e. the A68 and Dalkeith County Park), and nature of the proposed development it is considered that no significant cumulative effects are anticipated and it has not been considered further.
Kinnard Park, Lowhouse Toll,
Edinburgh
The site has been the subject of several applications:
04/03706/OUT – reconfiguration and redevelopment of retail floorspace, provision of additional cafes and restaurants, ancillary development as a whole, transport hub and new access and circulation arrangements.
11/00874/FUL – amendment to Condition 3 to increase upper floorspace for retail from 64,665sqm to 71,502sqm.
12/02085/AMC – detailed design of cafes and restaurants and works to public realm.
12/02091/FUL – erection of a multiplex cinema.
13/02381/FUL – erection of retail unit incorporating 5,612sqm.
The site is located circa 1.5km to the north west of the Proposed Development. Kinnard Park comprises of a large retail / leisure complex which is being redeveloped in phases. From a desk-based assessment it is considered that the majority of this development is built. However, given the distance and nature of the proposal, no significant cumulative effects are anticipated and it has not been considered further.
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Land 447 Northeast of
545 Old Dalkeith Road,
Edinburgh
Cemetery, Crematorium, memorial gardens, chapel of rest and associated development. The site is located circa 2km to the west of the Proposed Development. The online planning register identifies that whilst this application (ref: 13/05302/PPP) has been heard at committee it has not been determined. Limited detail is available in relation to the crematorium and therefore it is difficult to determine the extent of potential cumulative effects. Furthermore, as the application has not been determined it is not clear whether it would be appealed, it also falls outside the criteria for inclusion in this assessment.
Cameron Toll Shopping
Centre, Lady Road, EH16
5PB
Extension to Cameron Toll Shopping Centre to include retail (Class 1), restaurant/cafe (Class 3) and leisure (Class 11) uses, external alterations to existing Shopping Centre, creation of pedestrian link from Liberton Road, additional car parking including formation of a car park deck and associated landscaping (as amended). The application (ref: 09/01141/FUL) was approved in 2012.
The site is located circa 4.5km to the west of the Proposed Development. Considering the distance and the intervening built development it is considered that no significant cumulative effects are anticipated and it has not been considered further.
Edinburgh Royal Infirmary, 51 Little France
Crescent Edinburgh
The site has been the subject of several applications:
11/02454/PPP – Planning permission in principle for erection of Children's Hospital including department for clinical neurosciences + ancillary facilities, helipad, associated enabling development including energy centre, Vacuum Insulated Evaporator (VIE), car parking, revised access + public transport arrangements, public realm works + landscaping (car parking, access + public transport arrangements in detail).
14/00078/AMC – Approval of Matters Specified in Conditions in relation to Condition 1(i) of application 11/02454/PPP in respect of erection of Children's Hospital including department for clinical neurosciences and ancillary facilities (relating to flood prevention works).
14/01796/AMC – New Royal Hospital for Sick Children, Accident and Emergency, Nero-sciences and adult metal health service unit. Works include heli-pad, energy centre, service yard, car parking and landscaping.
14/03599/AMC – Erection of flue stack at Energy Centre as part of re-provision of Royal Hospital for Sick Children and Department of Clinical Neurosciences, Condition 1(b) on PPP consent (11/02454/PPP).
The site is located circa 2km to the west of the RERC development within the existing Royal Infirmary of Edinburgh Hospital Complex. In March 2014 Integrated Health Solutions Lothian (IHSL) were appointed preferred bidders for the design, build, finance and manage the hospital by NHS Lothian
Amongst other infrastructure the hospital includes an energy centre and associated flue stack which extends 15m in height. As this is has the potential for source emissions within the 5km search area it has been assessed further in Table 15.3 below.
Edinburgh Bioquarter,
Little France
The site has been the subject of several applications:
02/04372/OUT – outline planning permission for centre for biomedical research including educational, health and supporting facilities.
05/00022/REM – submission of reserved matters in respect of the first phase of infrastructure works (including roads, drainage and landscaping.
13/05048/FUL – Section 42 application to vary conditions one and three of 02/04372/OUT centre for biomedical research including educational, health and supporting facilities.
Whilst this site is the subject of a range of applications those identified above are understood to the principal applications. The site is located circa 2.5km to the west of the Proposed Development and site enabling works have taken place to create a range of development plots some of which (Nine at the bioquarter) have been developed for medical research and development. Given that the enabling works and some unites have been built it is considered that this part of the development falls within the baseline for the purposes of this Chapter. It is not considered that any of the uses proposed at this site (office and research) would not generate any cumulative effects with the Proposed Development and it has not been considered further.
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1 Milton Road Edinburgh EH15 3BY
The site has been the subject of several applications:
10/02830/FUL – The erection of new Portobello High School and associated ancillary buildings, site works, car parking, landscaping, pitches and floodlighting Portobello Park And Golf Course.
13/03200/FUL - Renewal of consent 10/02830/FUL for the erection of the new Portobello High School and associated ancillary buildings, site works, car parking, landscaping, pitches and floodlighting.
The site is located circa 2.8km to the northwest of the Proposed Development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.
Pinkie Mains, Pinkie Road, Musselburgh,
EH21 7TY
The site has been the subject of several applications:
08/01090/OUT – Planning permission in principle for residential and retail development including associated landscaping and car parking.
11/00974/AMM – Approval or matters specified in conditions of outline planning permission 08/01090/OUT erection of 413 houses and 60 flats and associated works
The site is located circa 3.5km to the north east of the Proposed Development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.
Land to South, East and West of Wallyford, East Lothian
The site has been the subject of several applications:
09/00222/OUT | Outline Planning Permission for the proposed mixed use development incorporating residential uses, educational uses, library, retail, office units, restaurant, business units, general industrial units, storage and distribution units, trade counter units, residential institution, non-residential institution, hot food takeaways, playing fields, open space, allotments, drainage arrangements and all associated infrastructure, access, landscaping and site development
12/00924/PPM – Renewal of planning permission in principle 09/00222/OUT for a proposed mixed use development incorporating residential uses; education uses; library; retail (class 1); office units (class 2); restaurant (class 3); business units (class 4); storage and distribution (class 6); trade counter units; residential institution - nursing home (class 8) non - residential institution - day centre (class 10); hot food takeaways; playing fields; open space; allotments; drainage arrangements and all associated infrastructural access; landscaping and site development works on land lying predominantly to the south and east of Wallyford but also including the Strawberry Corner garden centre; the entire length of Salters Road from the interchange with the A1 to the Wallyford Toll roundabout where traffic calming and environmental improvements are proposed; and Inchview Road where road realignment and alterations are proposed in association with the proposed development
The site is located circa 4km to the east of the Proposed Development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.
15.3.8 Based on the above information, it is considered that the only potential for
cumulative effects would be from: the proposed train maintenance depot at
the Millerhill Marshalling Yards and the new children’s hospital at the
Edinburgh Royal Infirmary. These proposed developments have been
considered further within the following sub-section.
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15.4 Assessment of Effects
Stage 1: Assessment
15.4.1 The Stage 1 qualitative assessment of the schemes likely significant effects in
combination with the remaining projects is set out in Tables 15.2 and 15.3
below. These relate to the cumulative effects assessment of the proposed
development with each identified project individually.
Table 15.2 Millerhill Marshalling Yards: Stage 1 Cumulative Impact Assessment
Project Overview: The proposed development at the Millerhill Marshalling Yards is for the formation of a train maintenance cleaning and stabling depot, erection of retaining wall and alterations to ground levels, formation of new railway lines, erection of boundary fencing, and formation of associated car parking and access. The development would take place within the existing Marshalling Yards, i.e. within the bounds of an already developed site.
Assessment Topic
Identification and Assessment of Significant Environmental Effects.
Landscape and Visual Effects
The landscape and visual effects of the proposed development against a baseline where the consented development at the Marshalling Yards is present would be little different to those effects described in Chapter 7.0 of the ES.
The Marshalling Yards development would increase the amount of built development present immediately east of the Application Site and hence the Proposed Development would be introduced into a landscape where built / urban influences are incrementally greater.
This would not materially change the conclusions of the LVIA (Chapter 7.0) regarding effects upon either landscape character or upon views. The Marshalling Yards development would be much smaller than the Proposed Development in terms of building height / mass and its additional influence over and above the LVIA baseline would be very limited. Cumulative landscape and visual effects would be negligible.
Ecology and Nature
Conservation
The proposed development is located on site which has been used for a number of operations in relation to stabling and the maintenance of freight trains and for ballast storage. The Committee Report associated with the development confirms that, due to the nature of the proposed development it will not have any impact upon protected species.
However, the application was supported by a Phase 1 Habitat Survey which concludes that the site contains limited suitable habitats for protected mammals and some areas suitable for nesting birds and reptiles. In light of this habitat surveys were conducted. During this survey, it was considered that the site is of local value for wintering birds and due to the small mammal populations it is thought that thought that barn owl, a schedule 1 protected bird is present. Consequently, a condition was attached to the permission seeking further assessment work in relation to birds and reptiles should be undertaken. This condition was discharged in June 2013.
The effects of the proposed development on flora and fauna will not be significantly different in combination with the planned rail maintenance depot. Surveys undertaken to inform the development of the Marshalling Yard noted that the site supported limited suitable habitats for protected species, nesting birds or reptiles.
The development of the rail maintenance depot does introduce a further degree of incremental urban development onto land to the east of the site. However, the ecological impact assessment for the RERC site assumed a degree of disturbance of wildlife in the current baseline, with regular freight train movements, noise and light spillage. For the purposes of the ecological assessment the Marshalling Yard was not assessed as having any potential to
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support species displaced from the site as a consequence of the RERC development, and its development therefore does not affect the assessment of impacts against the current baseline.
In light of the forgoing, it is not considered that the in combination effects of the proposals would have any likely significant cumulative effects in respect of ecological and nature conservation interests.
Flood Risk
The proposed development includes a sustainable urban drainage system and attenuation pond which would ensure that there is no change to the existing hydrological regime at the site. Similar measures are being proposed on connection with the Proposed Development and as such, there would be no likely significant cumulative effects in respect of flood risk.
Air Quality
The planning application submitted in relation to the development does not include an air quality assessment and no issue is made of potential aerial emission from the development in comments received by consultees on the application or in the Officers Report to committee. This suggests that the proposed development would not generate any significant aerial emissions beyond those experience in relation to existing operations.
The only potential cumulative effect that could occur is in relation to dust in the event that the construction of the development occurred at the same time as the Millerhill RERC development. However, the construction of the Proposed Development would be controlled through a CEMP and assuming that standard industrial practices are observed during the construction of the maintenance depot, it is unlikely that any significant effects would occur in this regard.
Based upon the above, it is concluded that there would be not potential for likely significant effect in relation to air quality.
Noise and Vibration
The Committee Report associated with the application confirms that a noise report was submitted with the application and it concludes that noise emissions from the proposal are unlikely to give rise to a noise nuisance. Chapter 9.0 of this ES provides an assessment of cumulative effects in relation to noise concludes that the cumulative effect would be between negligible to minor and a neutral to slight impact significance at the nearest sensitive receptors. Accordingly, there should be no likely significant effects in relation to air quality.
Traffic and Transportation
The Transport Statement prepared to support the rail depot application identifies that the development could generate of the order of 172 additional movements per day (in + out). The majority of this additional traffic would be related to staff movements, with 80% of staff working an overnight (19:00-07:00) shift. The majority of traffic associated with the rail depot scheme could therefore be expected to take place outside of the core weekday day-time periods and traditional AM & PM network peak hours. Given this low level of predicted traffic flow and the ‘out of hours’ nature of the majority of these movements, it is anticipated that the cumulative traffic effects of the proposed rail depot scheme and the construction / operation of the Millerhill RERC development would be negligible.
This conclusion reflects the findings of the formal transport appraisal of the rail depot scheme, which was prepared with cognisance of predicted traffic movements associated with the ZWF.
Archaeology and Heritage
The proposed developments at Millerhill Marshalling Yard are within very close proximity to the Proposed Development. However, they are markedly different in character and will be lower in height. This assessment has found that for many designated assets the Proposed Development will be viewed either across or in many cases, from within the wide suburban and industrial landscape which extends eastwards from Edinburgh. The developments at Millerhill Marshalling Yard taken together with the Proposed Development would not result in a significant alteration to the current setting of the heritage assets in the study area and no significant cumulative effects are predicted.
Socio-Economics.
The application identifies that; the proposed development would increase future efficiency and improve services within the rail network. It represents investment in the area and will provide new employment opportunities. The same is also true of the Proposed Development and as such it is considered that in combination the proposals would have a positive socio-economic impact.
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Table 15.3 Edinburgh Royal Infirmary, 51 Little France Crescent Edinburgh: Stage 1
Cumulative Impact Assessment
Project Overview: The erection of a children’s hospital at the existing Edinburgh Royal Infirmary. The development would include a helipad, energy centre, car parking and access arrangements, public realm works and landscaping. A series of applications seeking to approval to matters reserved by the planning permission in principle have been submitted.
Assessment Topic
Identification and Assessment of Significant Environmental Effects.
Landscape and Visual Effects
The proposal would be constructed next to the existing hospital buildings which are located between the two developments. On this basis, it is concluded that there would not be any likely significant cumulative landscape or visual effects between the two developments.
Ecology and Nature
Conservation
Given the intervening distance between this proposal and the Millerhill RERC development any direct significant cumulative ecological effects are unlikely. As such, it is considered that the proposals would not result in any likely significant in combination effects, in terms of direct impacts upon habitats / species.
In terms of potential nature conservation effects through emissions to air, the proposal (i.e. the energy centre) and the Millerhill RERC would have aerial emissions. The air quality assessment which supported the energy centre concluded that negligible effects of local air quality are predicted due to the operational traffic associated with the development. As such it is not considered necessary to further evaluate the cumulative effects in respect of the proposal and the Millerhill RERC development.
Based upon the foregoing, it is concluded that there would be no likely significant cumulative effects in respect of ecological and nature conservation interests.
Flood Risk
As set out in Chapter 10.0, the Millerhill RERC development would not give rise to significant flood risk effects. Furthermore, the proposal is located a considerable distance from the Application Site and both have their own flood mitigation in terms of surface water run-off. As such no significant cumulative flood risk is predicted between the two developments.
Air Quality
During the pre-application consultation regarding the preparation of the PPC Permit application and AQA in connection with the Millerhill RERC development, the SPEA confirmed the other existing and proposed developments in the area surrounding the area surrounding the Application Site that they considered could give rise to in-combination air quality effects. They advised that the only facilities that needed to be considered in this regard were the AD Facility to the immediate north of the Application Site and the Cockenzie Power Station development (discussed elsewhere in this ES). They did not identify the proposed biomass boiler at the Edinburgh Royal Infirmary and as such, this has not been the subject of any further assessment.
Noise and Vibration
The assessment work carried out in support of the application concludes that it would not have the potential to give rise to significant effects in terms of noise and vibration effects on local receptors during both the operation and construction phases. The same conclusion has also been reached in realtion to the Millerhill RERC development. Given the separation distance between the proposal and the Millerhill RERC development and the position in respect of development related traffic, there would demonstrably be no significant cumulative effect in respect of noise or vibration.
Traffic and Transportation
The Millerhill RERC proposal site is located well outside of the core study area identified as part of the formal traffic and transport assessment of the children’s hospital development. It is therefore not anticipated that the hospital scheme would result in any discernible impact on baseline local network conditions to the Millerhill RERC development. The cumulative traffic effects of the children’s hospital development and the construction / operation of the Millerhill RERC proposals would be negligible.
Archaeology and Heritage
There would be no significant cumulative effect in terms of burred archaeology due to the distance between the two sites. Consequently the only potential effects could be through an impact on setting of heritage features.
Whilst the proposed energy centre at the ERI will have a stack, at 29m it is considerably shorter
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than the Proposed Development and will be set c.2km to the west. Consequently it is unlikely that the two schemes will appear together in views from many of the designated assets identified as part of this assessment. They are likely to both be visible from Craigmillar Castle, Holyrood IGDL and potentially from some locations within Pinkie Battlefield. However, given the separation distance between the two developments and the highly complex urban landscape, the insertion of the Proposed Development into views which also include the ERI stack will not materially elevate the level of effect beyond those predicted for the Proposed Development when it is considered on its own. No significant cumulative effects are predicted.
Socio-Economics.
In combination the projects are likely to have some cumulative socio-economic benefits. These benefits are likely to mainly relate to construction phase employment; although when they are considered in combination the permanent employment opportunities would also be considerable. It is considered that in combination the proposals would have a positive socio-economic impact.
In addition to the above, it is worthy of note that the hospital complex has been identified as a potential recipient of the heat from the Millerhill RERC development.
Findings of the Stage 1 Assessment
15.4.2 The Stage 1 qualitative assessment has shown that there would be no likely
significant environmental effects arising from the development of the RERC
development in combination with either the Millerhill Marshalling Yards or the
developments proposed at the Edinburgh Royal Infirmary.
15.5 Mitigation Measures
15.5.1 Given that the assessment has identified that there are no likely significant
cumulative effects arising from the Proposed Development in combination with
the other ‘relevant’ projects assessed within this Chapter, no mitigation
measures are considered necessary.
15.6 Residual Effects and Conclusions
15.6.1 There would be no significant residual cumulative effects arising from the
Proposed Development in combination with either the Millerhill Marshalling
Yards or the Edinburgh Royal Infirmary.
15.7 Conclusions
15.7.1 The project team has written to the three local planning authorities whose
administrative areas lie within 5km of the Application Site to request details of
any unimplemented developments (with planning permission), referred to as
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‘relevant’ projects, which could, in combination with the proposed
development, give rise to likely significant cumulative effects.
15.7.2 The stage 1 assessment has shown that there would be no likely significant
environmental effects arising from the development of the RERC development
in combination with either the Millerhill Marshalling Yards or the Edinburgh
Royal Infirmary.
15.7.3 In light of the above, no ‘relevant’ projects have been carried forward to the
Stage 2 assessment. On this basis, it has been concluded that there would be
no unacceptable cumulative environmental effects would arise from the
construction and operation of the Proposed Development.
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16.0 ENERGY EXPORT CONNECTIONS
16.1 Introduction
16.1.1 As described in Chapter 3.0, the Millerhil RERC development would recover
energy from the combustion of SRF by way of electricity and heat production.
This Chapter of the ES provides a high level assessment of the likely
significant environmental effects associated with the development of the
electrical grid connection and potential heat distribution network associated
with the proposed development.
16.1.2 The ERF component of the Millerhill RERC would have a design capacity to
treat up to 195,000t of SRF per annum. Through the combustion of the SRF it
would generate approximately 50MW of heat energy in the form of steam. A
proportion of this steam would be used to generate electricity and the balance
could be exported as heat (in either the form of steam or more likely hot water)
to users within the surrounding area.
Electrical Generation
16.1.3 Electricity from the Millerhill RERC development would be generated by a
steam turbine, the generation capacity of which would be up to 13.45MW. A
proportion of the electricity generated would be reused in the operation of the
facility with the majority of the electricity, 11.09MW, being exported to the local
electricity distribution grid.
16.1.4 The grid connection works required to export electricity from the facility do not
form part of the Planning Application and fall either under Section 37 of the
Electricity Act 1989 or under the permitted development rights of statutory
undertakers. However, on the basis that export of electricity is an integral part
of the scheme, it is considered appropriate that the potential environmental
impacts associated with the connection to the local electricity grid are
assessed within the ES. The application for the grid connection works would
be undertaken by the local District Network Operator (DNO), SP Networks.
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16.1.5 Consultation with the local DNO has confirmed that connection to the local
electricity distribution network is feasible. Through this consultation exercise
SP Networks have provided details of their preferred grid connection route.
16.1.6 The proposed route would provide a connection to the Niddrie primary sub-
station which is located circa 1.7km to the north-west of the site, as the crow
flies, or 3.1km by road. The connection would be via underground cabling for
the majority of the distance buried within existing highways carriageway. The
proposed route of the electrical grid connection is illustrated on Figure 16.2.
Heat Recovery
16.1.7 A separate Heat and Power Plan has been prepared in support of the
application (see Part 6 of the separately bound PAD). This confirms that heat
recovery from the Millerhill RERC development would be via steam extraction
points in the turbine to allow low pressure steam to be supplied directly to
consumers, or to be condensed in heat exchangers in order to provide hot
water. The facility would be able to generate up to 20 MW of heat for export to
a heat network.
16.1.8 The Heat Plan sets out the latest identified proposals for heat export, together
with the steps required to maximise benefits in this regard. It identifies the
potential heat pipe network route, which is based around the existing and
potential heat users surrounding the development site. The proposed heat
network includes a number of potential existing / proposed customers in close
proximity of the Millerhill RERC site. These users include:
16.1.9 The location of the identified heat off-take opportunities and potential routing
of a heat pipe network is illustrated on Figure 16.1.
16.1.10 Similar to the grid connection, the heat pipe network does not form part of the
planning application for the Millerhill RERC development and would be
authorised by either a separate planning application, or through permitted
development rights. However, on the basis that export of heat is an integral
part of the scheme, it is considered appropriate that the potential
environmental impacts associated with the delivery of the heat pipe network
are assessed within the ES.
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16.1.11 The work carried out in the Heat and Power Plan concludes that the optimum
potential for local heat usage is through the export of hot water.
16.1.12 For the purposes of the ES, it has been assumed that the heat pipe network
would extend to four principal locations from the Millerhill RERC, serving:
To the north / north east – the Queen Margaret University;
To the immediate West – the SNCD;
Further to the West – the Medical Quarter and the Royal Infirmary of
Edinburgh
To the north-west – the new developments within the Craigmillar
residential area.
Assessment Parameters
16.1.13 The following sections describe the potential grid connection and heat pipe
works in more detail and provide an assessment of potential environmental
impacts that may arise from the implementation of the routes that are under
consideration. The precise route of the grid connection and heat pipe network
would be subject to landowner negotiations and detailed design
considerations. As such, the following assessment provides an appraisal of
the likely environmental effects of the proposed grid connection option and
heat pipe network option in sufficient detail to identify any potential significant
effects and confirm the feasibility or otherwise of the proposed routes.
16.2 Description of Development
Electricity Connectivity – To Niddrie Primary Sub-station by Road
16.2.1 The Millerhill RERC development would generate electricity at 11kV. This
would be ‘stepped up’ to 33kV by an on-site transformer and exported from
the proposed site via an on-site substation. The construction of the on-site
substation which is located on the eastern boundary of the site, next to the
access road, has been considered within the main assessment in the
preceding Chapters of the ES.
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16.2.2 The description of the development provided below, describes the cabling
infrastructure, the cable route and the construction methods required to
connect the Millerhill RERC development to the local electricity distribution
network.
Cable Route
16.2.3 The cable route would exit the Millerhill RERC site via the private access road
which connects to Whitehill Road. The cable would then run west along
Whitehill Road until it reaches the junction with the un-named road. The cable
would then follow the un-named road in a westerly direction to its junction with
the A6106 Millerhill Road, before turning north onto the A6106 – The Whisp
for the remaining 0.5km to the Niddrie primary sub-station. The distance to
the substation would be circa 3.1km in total.
Construction Methods
16.2.4 The electricity cable would be buried within a trench located within the
metalled roadway. The precise location would be subject to discussion with
the Midlothian Council and (if necessary) Edinburgh City Council Highways
Departments, other utilities companies and as a result of any local limitations
i.e. avoidance of damage to trees, adjacent structures or sensitive habitats.
16.2.5 Rigid corrugated cable ducts would be laid within a trench excavated to a
depth of circa 1m and to a width of circa 0.7m (the approximate width of an
excavating bucket) using a wheeled excavator or similar. Hardstandings would
be broken out using a hand operated or machine mounted pneumatic
breaking hammer and mechanical road saws. The cabling duct would be
placed on a blinding layer of sand or screened earth to prevent damage from
sharp objects. A further blinding layer would then be placed on the ducting.
For the purposes of Health and Safety a marking tape or tiles would be laid
circa 75mm above the duct to indicate its location. The trench would then be
backfilled with the previously excavated material. The road surface would then
be reinstated and surfaced to a specification required by the highways
authority. The electric cabling would be pulled through the ducting once it had
been laid and secured in position. A working area of circa 3m to 4m in width
would be required during the trenching and cable laying works for the
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operation of machinery and temporary storage of excavated material prior to
backfilling. Traffic management (i.e. temporary traffic lights would need to be
put in place during the period of the construction works). The cabling would be
laid in short sections to minimise disruption to highways users.
16.2.6 It may be necessary for some sections of the cable route to be constructed
using directional drilling / micro-boring techniques as these methods would
avoid open excavations within the highway minimising traffic disruption. Such
works may be required where the cable crosses a main carriageway or at
major junctions where it would be desirable to avoid traffic management.
However, as no such junctions are in evidence on the proposed route, it is
highly unlikely that this technique would be necessary. Should these works be
required they would be carried out in accordance with the DMRB, ‘Guidance
on the trenchless installation of services beneath motorways and trunk
roads’37.
16.2.7 At the junction with the Niddrie sub-station the cable would be brought above
ground and connected into the transformers for onward distribution to the local
electricity network. There may be a requirement to upgrade some of the
equipment at the substation, but significant upgrades are considered unlikely.
Any upgrades would be undertaken within the boundary of the existing
substation. The contractor would implement best practice construction
methods throughout the period of the works to reduce potential environmental
impacts.
Description of the Heat Pipe Network and Installation Works
16.2.8 Given the types of heating requirements identified off-site to date as being
potentially available, heat could be supplied in the form of hot water to some
users subject to viable economics. The temperature of the water would be
supplied at up to 110oC depending on the end user’s requirements. Summer
supply temperatures would be lower to reduce energy losses.
37
DMRB, Volume 4, Section 1, HA120/08 Guidance on the trenchless installation of services beneath motorways and trunk roads. August 2008.
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16.2.9 Heat would be distributed in buried pipework. Preinsulated steel pipes would
be used to supply pressurised hot water to the customer, and to return cooler
water. Where pipes are small, two pipes may be integrated within a single
insulation sleeve. However, single pipes are likely to be used to meet large
heat demands. This technology is well proven and provides an energy
distribution system with a 30 year design life. Additional pipe work can be
added in the future and it is a straightforward process to add branches to
serve new developments. It is estimated that 350mm internal diameter (i/d)
pipes would be installed for the flow and return pipes.
16.2.10 Heat would be supplied to a secondary heat exchanger on a consumer’s
premises. Typically, the hot water in the distribution system is supplied to one
side of a heat exchanger at the end user, with the other side arranged to heat
up the hot water required by the user. This heat exchanger can be arranged
upstream of any back up boiler plant, so that the heat from the facility can top
up any heat from the boiler.
16.2.11 Water would be pumped continuously around the system. Pumps are
operated with 100% standby capacity to maintain heat in the event of a pump
fault. The pumps would have variable speed drives to minimise energy usage.
Booster pumps can be installed within the distribution pipe network to increase
the distance over which the energy can be delivered. Providing the system
design pressure is not exceeded there is no limit as to the distance the water
can be pumped. Heat exchangers can be used to provide pressure breaks to
enable the network to be extended.
16.2.12 The potential heat pipe network route is shown in Figure 16.1.
16.2.13 The heat off-take pipes would be buried below ground within trenches located
within the confines of the public highway, private roads, or other areas of
hardstanding e.g. car parking areas. The trench would be excavated to a
depth of approximately 1m and would be approximately 1.35m in width.
16.2.14 Pipe supports would be installed within the bottom of the trench prior to the
placement of the steel pipe. The pipes would then be lifted and positioned in
the trench by an excavator. Once placed in the trench the pipes would be
welded and jointed. Following installation of the pipework the trench would be
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backfilled with sand to cover the pipes, the trench would then be backfilled
with excavated material and the road surface or other hardstanding would be
reinstated.
16.2.15 During the trenching a working area of approximately 3-4 m in width would be
required for the operation of machinery and temporary storage of excavated
material prior to backfilling. As such appropriate traffic management (e.g.
temporary traffic lights) would need to be put in place along the affected
highways.
16.2.16 The indicative timetable for the construction of the plant and heat network is
provided in the Heat and Power Plan.
16.3 Approach to Assessment
16.3.1 As noted above the grid connection and heat pipe routes would need to be the
subject to refinement in order to take into account the requirements of affected
parties and any limitations identified along the proposed grid routes. This
assessment seeks to establish the likely significant environmental impacts
associated with the installation and operation of the grid connection works and
to determine if the routes are considered acceptable in relation to
environmental impacts. As such, the assessment identifies the nature of the
impacts that may arise from the connection works along or close to the
illustrated connection routes and defines the type of mitigation that would be
put in place to avoid or reduce impacts.
16.3.2 The assessments presented below utilise the baseline data gathered as part
of the main assessment. Where necessary this has been supplemented with
further environmental information gathered through desk study.
16.3.3 The assessment is based upon the methodologies used in the individual
Chapters of this ES, but seeks to summarise matters that are specific to the
proposed grid connection / heat pipe works. The findings are summarised in
Table 16.1 below.
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Table 16.1: Assessment of Environmental Impacts Associated with the Grid Connection and Heat Pipe Installation Works
EIA Topic Description of Potential Impacts Mitigation
Traffic and Transport
The main traffic and transport effects that could arise as a result of the proposed grid connection / heat pipe installation route relate to:
Construction traffic on the local highways associated with staff movements, export of excavated material and general movement of construction plant along the proposed cabling route; and
Potential road closures during the construction works.
Only a small number of construction staff would be required to construct the routes. The numbers of construction staff would be insignificant in comparison to the staff numbers being employed on the main site. As such, there is not anticipated to be any significant traffic impacts from staff movements.
The volume of soil requiring export from the works would be limited due to the fact that much of the material would be used in reinstatement works. In relation to export of excavated materials, it is considered unlikely that the works would generate more than one or two HGV movements per day. As such, this would not represent a significant traffic impact.
Temporary traffic management would be required during the construction period. The requirement for traffic management would be avoided where possible. Traffic management measures are likely to involve the use of temporary traffic lights and / or lane closures.
Whilst some delays would inevitably result from the introduction of traffic management, access along the routes affected would be maintained throughout the construction period and as such, the impacts are not considered to be significant.
No significant impacts on traffic and transportation are considered likely once the construction works have been completed and the grid connection is ‘live’.
Construction vehicle movements would be managed to avoid peak traffic periods and temporary traffic management measures would be put in place and would be agreed in advance with the Midlothian Council and (if necessary) Edinburgh City Council, the Local Highways Authorities. In addition, appropriate signage would be installed in advance of the works to inform local road users of the planned date and duration of the works.
If deemed necessary during consultation with the local highways authority, directional drilling / micro-boring techniques would be used where the cable route crosses highways or key junctions. However, at this stage, it is not considered that such techniques would be required in relation to the proposed grid connection route.
Landscape and Visual
The works to install the proposed grid connection / heat pipe installation routes would, as described previously, involve underground cabling / trenching from the Application Site. On the basis that cabling would be underground, no permanent landscape or visual effects would occur and as such, the impact is considered to be negligible.
No mitigation is considered necessary.
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Ecology and Nature Conservation
No statutory designated sites including SPAs, SACs, Ramsar Sites, SSSI, NNRs and LNRs are present along the proposed trenching routes.
Whilst the precise location of the trenching would be determined through consultation with the local highways authority, it is likely that the cable would be located under the metalled road. Thus, for the purposes of the assessment, it has been assumed that this would be the case with only limited works within the highway verges.
With regard to the aforementioned works within the highway, they would not result in the loss of any habitats of value. However, there are some mature and immature trees (and other vegetation) alongside the proposed trenching route. Whilst the impacts are unlikely to be significant and none of the trees would be lost as a result of the excavation works they could result in damage to roots. Accordingly, appropriate (standard) mitigation measures would need to be adopted during the construction of the trench to prevent any significant effects occurring.
Standard mitigation measures would be put in place regarding the protection of any tree roots. In the event that major structural roots are identified during excavation, hand digging should be undertaken to avoid damage to the roots.
Geology, Soils and Groundwater
With regard to the majority of the trenching, given the shallow nature of the excavations and the routine nature of the works proposed, no impacts associated with geology, soils or groundwater are predicted. It is possible that some isolated contaminated ground could be encountered in some parts of the proposed routes as a result of localised pollution events. However, standard construction working methods for the installation of utilities would be followed. This would include a health and safety risk assessment for site operatives. The assessment would identify the requirement for the use of personal protection equipment and would define operating procedures for working within areas of potentially contaminated ground.
It is considered that the adoption of these mitigation measures (which are based upon standard construction best practice) would prevent any significant effects occurring.
As described previously the contractor would undertake a health and safety risk assessment to identify any potential impacts on site operatives from contaminated material. The risk assessment would identify the requirement for the use of personal protective equipment by site operatives.
If any contaminated material was identified during the excavation works it would be disposed of at an appropriately permitted waste disposal facility.
Surface Waters and Flood Risk
The proposed grid connection / heat pipe installation route options are not considered likely to result in an increased flood risk as a result of the loss of floodplain, increased surface water run-off, or by affecting transmission of surface water flows during flood events.
The construction works would involve the excavation of soils and use of plant and machinery. As such, there is the potential for surface water pollution from suspended sediment, oils, lubricants or fuels.
The works would also not involve construction adjacent to any watercourses and standard best practice construction measures would be implemented to prevent pollution incidents occurring.
Best practice measures would be adopted during the excavation works in line with CIRIA C532 Control of Water Pollution from Construction Sites’.
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Noise and Vibration
Sources of noise that may arise from the construction works include mechanical excavators, road breakers with air compressors, mechanical road saws, tipper trucks with grab buckets, other general site vehicles and portable power generators for traffic control signals.
Typical construction hours for these works would be between the hours of 07:00 to 19:00. The nature of the work is not dissimilar to those that would be expected from routine road maintenance or replacement / repair of other utilities.
The proposed works would be carried out in close proximity to a relatively small number of residential properties, but would be similar in nature to standard road maintenance activities or replacement / repair of other utilities and no abnormal noisy operations such as piling are proposed. The proposed works would be undertaken during the day time within areas with elevated background noise levels associated primarily with existing road traffic. Furthermore, the proposed works would only be temporary in nature.
The application of best practice attenuation measures in accordance with BS5228 (2009) would assist in significantly reducing any impact (i.e. using equipment that is regularly maintained and where practicable using equipment that is fitted with silencers and hoods).
On the basis that the construction works would be temporary, carried out during the daytime, within areas where receptors are likely to experience elevated noise levels and would be carried out in accordance with best practice in accordance with BS5228 (2009), it is considered that the effects would be minor. Thus, no significant effects are predicted in respect of noise disturbance to residential properties.
No significant sources of vibration are anticipated in association with the construction methods proposed.
Noise attenuation measures would be applied at all times to plant and equipment to follow industry best practice and conform to BS5228.
Air Quality
Excavation of the trenches would have the potential to give rise to the release of fugitive dust during dry and windy conditions. However, given the minor scale of the works such impacts would not be significant and are unlikely to have any significant adverse effects on residential or ecological receptors. As such, no mitigation is proposed or necessary.
No mitigation is considered necessary
Archaeology and Cultural Heritage
On the basis that the construction works would be temporary in duration and would only involve activities that are often experienced along road corridors, no indirect effects on setting of heritage features are considered likely to arise from the construction of the various trenches.
In addition, as the cable would be buried underground no permanent indirect setting impacts would result from the construction of the proposed cable route.
With regard to buried archaeology, as stated above, the trench would be positioned
It is proposed that in the event that unforeseen buried archaeology is encountered during the works, it would be adequately mitigated through a programme of archaeological works, recording and reporting to the Council’s Archaeologist.
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within the existing highway boundary and the cabling works would take place at similar depths to other utility runs. The land within and immediately adjacent to the highway would have been previously disturbed as a result of the road construction. Whilst some potential for the disturbance of buried remains exists, this is considered highly unlikely and as such, the impacts associated with the construction of the trenching are considered to be negligible.
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16.4 Residual Effects and Conclusion
16.4.1 The proposed grid connection works would involve the laying of
approximately 3.1km of underground cable within the footprint of existing
metalled highways and other areas of hardstanding. This would link the
Millerhill RERC development to the Niddrie primary sub-station and facilitate
the export of electricity. The heat pipe network installation is likely to
comprise of a trench excavation and the laying of a double pipe which would
convey hot water to potential heat users and provide for water to be returned.
Potential heat users include: future residents, commercial premises and
public buildings within the SNCD; the Queen Margaret University; the Royal
Infirmary of Edinburgh and existing and future residents within Craigmillar.
The heat pipe trench would also lie wholly within metalled highways and
other areas of hardstanding.
16.4.2 A CEMP would be prepared as part of the Millerhill RERC project and would
include the construction works associated with the grid connection and heat
pipe installation. The CEMP would include standard best practice measures
that would help to avoid or reduce impacts from the construction works.
16.4.3 The environmental impacts associated with the underground cabling and
heat pipe installation works would be temporary and as the development
activity would be limited to metalled highways or other hardstandings,
impacts are considered likely to be similar in nature to those that arise from
minor highways maintenance works. On this basis, implementation of
standard best practice construction methods is likely to avoid any significant
environmental impacts arising. A number of such methods have been
identified.
16.4.4 In considering the results of this assessment, it can be concluded that the
proposed grid connection and heat pipe installation works would not give rise
to any significant adverse residual environmental impacts
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17.0 HUMAN HEALTH
17.1 Introduction
17.1.1 A Human Health Risk Assessment (HHRA) has been prepared in relation to
the Proposed Development (See Appendix 17-1) and provides information on
the likely impact on the health of local communities as a result of its
construction, operation and decommissioning.
17.1.2 As set out in Chapter 2.0 the assumed baseline position for the assessment
is that the AD Facility, SNCD and the Borders Railway are all built and
operational.
17.1.3 With regard to the assessment of human health, it is not considered that
either the SNCD or the Borders Railway would give rise to any significant
emissions of pollutants that would give rise to impact upon human health and
as such, they have not been modelled.
17.1.4 With regard to the AD Facility, the only emissions to air that are common with
the Proposed Development and would therefore need to be considered in this
Chapter are Oxides of Nitrogen, Sulphur Dioxide and Carbon Monoxide. The
emission of these pollutants in combination with those released by the
Proposed Development has already been assessed within the AQA (Chapter
12.0 and Appendix 12-1), which concludes that the effect of the
aforementioned pollutants on air quality would be insignificant. On this basis,
they would not give rise to any significant effects on Human Health.
17.1.5 Aside from the aforementioned pollutants all other remaining compounds of
potential concern (COPCs) to the assessment of Human Health would be
emitted by the Proposed Development. As a consequence, the remainder of
this ES Chapter focuses solely on the potential human health effects of the
other pollutants released by the Proposed Development (i.e. those listed in
Section 2.3.2 of the AQA in Appendix 12-1) and specifically Dioxins and
Furans as there are no air quality standards set for these COPCs.
17.1.6 HHRAs are applied to proposed developments in order to safeguard the
health of the local population. The assessment has been carried out in
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accordance with guidance published by the Scotland and Northern Ireland
Forum for Environmental Research (SNIFFER). This guidance document
sets out six stages for a risk assessment study which are described fully in
Section 17.2.2.
17.1.7 The substances emitted from the stack - termed hereafter the COPCs, can
be considered under the following categories:
Substances for which any effects are more likely to be acute, and which
tend to occur shortly after exposure; these substances can be
subdivided into two groups:
o Acid gases, such as sulphur dioxide, nitrogen dioxide, hydrogen
chloride and hydrogen fluoride; and
o Other substances, such as carbon monoxide and fine particulate
matter.
Substances for which any effects are likely to be chronic, and which
tend to arise from prolonged exposure; these substances can also be
subdivided into two groups:
o Heavy metals; and
o Semi-volatile and non-volatile organic chemicals, specifically
dioxins and furans and dioxin-like PCBs.
17.1.8 Air quality standards (AQSs) for the protection of human health have been
assigned for the majority of the COPCs emitted from the Proposed
Development. Accordingly, the risks to human health from these have been
assessed as part of the atmospheric dispersion modelling study (see Chapter
12.0 and Appendix 12-1), therefore, no further assessment is considered
necessary. For those COPCs where AQSs have not been assigned, i.e.
dioxins and furans, further assessment has been undertaken using the
United States Environmental Protection Agency’s (USEPA) Human Health
Risk Assessment Protocol (HHRAP) methodology with is one of the methods
approved for use by the SEPA. The assessment has evaluated potential
impacts on human health from potential dioxin emissions, both in terms of the
long-term inhalation, and the overall long-term exposure through additional
viable routes such as the food chain.
17.1.9 The full HRRA can be found Appendix 17-1 and details the specific
methodologies of assessment and determination of significance.
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17.1.10 It should be noted that the HHRA uses data obtained from the air quality
assessment and the results of that assessment have been used to inform the
HHRA. Consequently, there will be some duplication of information between
Chapter 12.0 and this Chapter, and reference will also be made to the AQA
contained in Appendix 12-1.
Previous Assessment
17.1.11 As discussed in Chapter 1.0 of this ES, the Application Site benefits from
PPiP (granted in 2012) for the ZWF, comprising:
An EfW Facility;
An AD Facility; and
A MBT Facility.
17.1.12 A HHRA was carried out for the ZWF. In order to address AMSC associated
with the ZWF, the air quality assessment submitted with the PPiP application
was revised in respect of the AD Facility, located immediately north of the
Application Site. Planning permission for the AD Facility was granted in June
2013, and construction was on-going at the time of writing.
17.1.13 The Proposed Development would be implemented instead of the consented
EfW and MBT facilities. Given the difference in stack emission parameters
the impacts on human health are likely to be different to those assessed for
the ZWF and hence the current HHRA is required. .
Description of the Proposed Development
17.1.14 A detailed description of the Proposed Development is provided Chapter 4.0
of this ES. Key aspects of the development that are of relevance to this
HHRA are the COPCs that are emitted from the 75m high RERC main
discharge stack. All discharge stack parameters are fully described in the
AQA in Appendix 12-1.
Legislation and Policy Context
17.1.15 Full details of the planning and policy background for the proposal, including
an appraisal of effects on relevant human health policies, as set out in the
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adopted statutory Development Plan and other material planning
considerations, are included in the PS (Part 3 of the PAD). Key legislation
and policies relevant to the HHRA are summarised below.
National Planning Policy
17.1.16 The NPF 3 (2014) highlights the responsibilities of planning authorities to
adhere to sustainable development; this includes the implementation of
policies on health. The document describes how environmental quality is:
“central to our health and wellbeing.”
17.1.17 National planning policy applicable to Scotland is set out in SPP (2014).
Policies of direct relevance to this HHRA include: “The planning system
should support the provision of infrastructure to allow Scotland’s waste and
secondary resources to be managed in one of the nearest installations by
means of the most appropriate methods and technologies, in order to protect
the environment and public health.” (Paragraph 182)
17.1.18 PANS provide advice on good practice and information. PAN 51: ‘Planning,
Environmental Protection and Regulatio’n is of most relevance which states
that: “any consideration of the quality of land, air or water and potential
impacts arising from development, possibly leading to a proven impact on
health, is capable of being a material consideration, insofar as it may arise
from any land use.” PAN 51 does, however, go on to state that: “the planning
authority should have regard to the impact of the proposal on air or water
quality although the regulation of emissions or discharges will fall to be dealt
with under other legislation.”
Industrial Emissions Directive (2010/75/EU)
17.1.19 The key legislation relating to discharges to air from the Application Site is
the IED. The IED prescribes measures relating to the control of emissions
to air and sets limits on emissions of a wide range of air pollutants, for both
normal and abnormal operation.
17.1.20 Chapter IV, Articles 42 to 55, of the IED: Special Provisions for Waste
Incineration Plants and Waste Co-incineration Plants sets out the
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requirements that need to be met for the EfW activities that will be
undertaken at the Application Site and are described in Chapter 12.0.
17.1.21 Furthermore, Annex VI of the IED: Technical Provisions Relating to Waste
Incineration Plants and Waste Co-incineration Plants, in Part 3: Air
Emission Limit Values for Waste Incineration Plants; prescribes the limits
that releases to air must meet under both normal and abnormal operating
conditions.
Pollution Prevention and Control (Scotland) Regulations
17.1.22 The SEPAs role is to minimise the harm to human health and the
environment. For industry this is enacted through the Pollution Prevention
and Control (Scotland) Regulations 2000 (as amended). These regulations
implement the requirements of the IPPC Directive, which aims to provide an
integrated approach to pollution control preventing emissions into air, water
or soil wherever practicable. Where the prevention of pollutants is not
practicable, steps should be taken to minimise the emissions.
17.1.23 In order for the Proposed Development to operate it must obtain a permit to
operate under the Pollution Prevention and Control (Scotland) Regulations
2000 (as amended).
17.1.24 The main purpose of the permitting process as a whole is to prevent
emissions where practicable. Where this is not possible, a high level of
environmental protection should be demonstrated. This study aims to
demonstrate that the impact of emissions from the Proposed Development on
human health is acceptable.
17.1.25 As the SEPA does not prescribe any particular assessment for risk
estimation, methods for permit applications for these types of processes
typically follow either the approach developed by Her Majesty’s Inspectorate
of Pollution (HMIP): Risk Assessment of Dioxin releases from Municipal
Waste Incinerators (1996) approach or the USEPA: Human Health Risk
Assessment Protocol for Hazardous Waste Combustion Facilities (EAP530-
R-05-006, September 2005) approach. For this assessment the USEPA
HHRAP methodology has been used.
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Regional and Local Policy
17.1.26 The Strategic Development Plan (2013) sets out strategic policies for south-
east Scotland. None of the policies contained therein have direct relevance to
this HHRA.
17.1.27 The Midlothian Local Plan 2008 states that where development proposal
affect any designated site or protected priority habitat or species or other
important non-statutory locations, an appropriate level of environmental or
biodiversity assessment should be carried out. It also notes that mitigation
measures should be included where appropriate.
Air Quality Standards for the Protection of Human Health
17.1.28 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland
(2007) details Air Quality Strategy Objectives for a range of pollutants,
including a number that are directly relevant to this study: Particulate Matter
(as both PM10 and PM2.5), Carbon Monoxide, Sulphur Dioxide, Nitrogen
Dioxide and Benzene.
17.1.29 In addition, the 4th AQDD details Target Values for arsenic, cadmium and
nickel. The EPAQS, which advises the UK Government on air quality, has set
recommended Guideline Values for: Arsenic, Chromium VI and Nickel; the
EPAQS Guideline Value for Nickel is the same as the AQDD Target Value,
but the EPAQS Guideline Value for Arsenic is half that of the AQDD value.
The lowest of these values have been taken into account in this study.
17.1.30 In the case of: Hydrogen Chloride, Hydrogen Fluoride, Chromium (VI) and
Arsenic, EPAQS has set recommended Guideline Values which have been
taken into account in this study.
17.1.31 EQS have been assigned by the SEPA to a number of the other pollutants
assessed in the modelling study; these are detailed (where assigned) in
Appendix D of SEPA Guidance Note H1. These have been derived from a
variety of published UK and international sources (including the WHO).
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17.2 Methodology
17.2.1 This assessment evaluates the possible effects on the health of the local
human population likely to be exposed to emissions from the Proposed
Development. The geographic scope of the study is based on the same area
which covers all the sensitive receptors that were used in the air dispersion
modelling study, namely a 10km by 10km grid using the main discharge stack
as a central point.
17.2.2 Given that the assessment is related to exposure through the direct inhalation
of affected air and indirect exposure through ingestion of affected food and
locally grown produce on soil, which may be affected by the deposition and
accumulation of emissions from the proposed facility, the only emissions
relevant to the assessment are those arising from the facility’s main
discharge stack. Fugitive emissions are not considered relevant to this
assessment.
Current Guidance
17.2.3 The study has been carried out in accordance with guidance published by the
SNIFFER. This guidance document sets out six stages for a risk assessment
study namely:
Step 1: Define the legislative context;
Step 2: Hazard identification;
Step 3: Hazard assessment;
Step 4: Risk estimation;
Step 5: Risk evaluation; and
Step 6: Risk management.
17.2.4 In accordance with the recommended UK tiered approach to risk
assessment, the HHRA has considered worst-case scenarios for all receptors
in assuming multiple exposure conditions where all pathways of exposure in
each land use scenario were considered to be viable. Some of these
assumptions are both extremely conservative and also very unlikely, and,
therefore, the assessment is likely to over-estimate any potential impacts.
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17.2.5 For the assessment and evaluation, detailed computer modelling has been
undertaken. The basis for the HHRA is predictive modelling using the
ADMS5 atmospheric dispersion model to estimate the likely ground level
concentrations of COPCs and deposition rates for dioxins and furans as a
result of emissions from the Proposed Development.
17.2.6 The methodology for the assessment of dioxin and furan is based on the
USEPA HHRAP which is fully discussed in the HHRA contained within
Appendix 17-1. The Industrial Risk Assessment Programme – Human Health
(IRAP-h View Version 4.1.87), which is based on the USEPA HHRAP, has
been used to calculate the transport and fate of dioxins and furans emitted
from the RERC main discharge stack.
The Study Area
17.2.7 The geographical area considered in the HHRA, together with the locations of
the various sources, is indicated in Figure 2154/F2 in Appendix 17-1.
Approach to Risk Assessment
17.2.8 The approach taken by the IRAP-h View software, which accords with that
set out in guidance, seeks to quantify the hazard faced by the receptor- the
exposure of the receptor to the substance identified as being a potential
hazard and then to assess the risk of exposure, as follows:
Quantification of the exposure – an exposure evaluation that
determines the dose and intake of key indicator chemicals for an
exposed person. The dose is defined as the amount of a substance
contacting the body (e.g. in the case of inhalation, the lungs) and intake
is the amount of the substance absorbed into the body. The evaluation
is based on, worst case, conservative scenarios, with respect to the
following:
o Location of the exposed individual and duration of exposure;
o Exposure rate; and
o Emission rate from the source.
Risk characterisation – following quantification of the exposure, the risk
is characterised by examining the toxicity of the substances to which
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the individual has been exposed and evaluating the significance of the
calculated dose in the context of probabilistic risk.
Methodology for Estimating Exposure to COPCs
17.2.9 In order to estimate exposure from the emissions from the facilities
considered in the assessment, the following steps have been undertaken:
Measurement or estimation of emissions from the source - in the case
of the proposed facility, emissions have been based on the relevant
ELVs, and, therefore, are likely to be an overestimate of the actual
emissions;
Modelling the fate and transport of the emitted substances through the
atmosphere and through soil, water and biota following deposition onto
land;
Atmospheric dispersion modelling has been undertaken using ADMS5
(see Appendix 12-1). Concentrations of the COPCs in the
environmental media are estimated at the point of exposure, which may
be through inhalation or ingestion; and
Calculation of the uptake of the emitted substances into humans
coming into contact with the affected media and the subsequent
distribution in the body; this element of the assessment is undertaken
using IRAP-h View.
Significance of Effect
17.2.10 The purpose of the EIA is to determine the likely significant effects of a
development proposal. It is essential that the likely effects of the Proposed
Development are assessed thoroughly in order for determining authorities to
make an educated decision for the development of the proposal. Not all
emissions produced from the Proposed Development will have a significant
effect on human health, however they must all be assessed.
17.2.11 The Cancer Risk, Hazard Quotient (Non-cancer Risk) and Tolerable Daily
Intake (TDI) are needed to determine significance of effects from the
Proposed Development. These are calculated from the combing the
quantities and toxicology benchmarks for each pathway and receptor.
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17.2.12 Cancer risk from exposure to emissions is the probability that a human
receptor will develop cancer, based on a unique set of exposure, model, and
toxicity assumptions. The current UK approach to HHRA utilises a range of
acceptable risk levels ranging from 0.00001 to 0.001 for the different
contaminants and pathways of exposure (for example, a risk of 0.00001 is
interpreted to mean that an individual has up to a one in 100,000 chance of
developing cancer during their lifetime from the evaluated exposure). In the
UK, a risk level of 0.00001 is used for all carcinogenic contaminants
considered in this assessment.
17.2.13 Non-cancer health risks can include acute, or short- term health problems
such as eye irritation, respiratory irritation, and headaches, and chronic, or
long-term problems such as permanent damage to organs, the central
nervous system, or reproductive functions, and developmental problems in
children. on-cancer health risk is defined by a Hazard Quotient (HQ). The
term HQ is used in the IRAP-h View model to describe the risk associated
with the potential for developing non-cancer health effects as a result of
exposure to COPC. The hazard quotient is not a probability but rather a
comparison of a receptor‘s potential exposure relative to a standard exposure
level. The standard exposure level is calculated over a similar exposure
period and is estimated to pose no unacceptable risk in terms of adverse
health effects to potential receptors. Standard risk assessment models
assume that, for most chemicals with non-cancer effects, the non-cancer
effects exhibit a threshold response. This means, there is a level of exposure
below which no adverse effects will be observed. A hazard quotient of less
than or equal to 1 is considered health-protective (USEPA Superfund). For
example, an HQ of 2 means the concentration of toxic substances in the air
at the point of exposure is predicted to be twice as high as is generally
thought to be safe, a HQ of 0.99 or below means the concentration of toxics
in the air at the point of exposure is thought to be safe. The levels defined as
‘safe’ are designed to protect the most sensitive individuals in a population.
17.2.14 The Committee of Toxicity (COT) sets out TDI levels for dioxins and furans
as 2pg TEQ/kg body weight / day. This is then compared with the predicted
total daily intake of dioxins and furans (averaged over a 70 year lifetime) at
each of the sensitive receptors of the Proposed Development.
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17.2.15 The effects of the proposed development will be considered significant in the
context of this EIA if they exceed the stated thresholds for impacts upon
human health.
Consultation
17.2.16 The scope of the HHRA is in accordance with the SEPAs requirements and
the SEPA were consulted with reference to the sensitive human receptor
locations, and any other sites to be considered as part of the cumulative
assessment.
17.3 Baseline
17.3.1 The life expectancy of people living in Midlothian in 2008 – 2010 is higher
than the life expectancy of Scotland as a whole. For example the life
expectancy of women at birth in Midlothian is 81.4 whereas in Scotland the
equivalent is 80.9. For men the Scottish life expectancy at birth is 76.8 but in
Midlothian the life expectancy at birth is 76.6. Since 1998 there has been a
steady rise in life expectancy in Scotland and Midlothian. However, the rate
of increase in life expectancy is significantly greater in women than men.
17.3.2 The life expectancy at birth of Edinburgh can also be considered due to the
proximity of the Proposed Development to the city. For central Edinburgh the
life expectancy at birth between years 2009-2013 is 77.5 for men and 81.8 for
women, both of which are higher than the national average.
PPiP Future Baseline Scenario
17.3.3 The PPiP future baseline scenario (refer to Chapter 2.0 for full details)
reflects the fact that a major development located at the Application Site has
been granted planning consent. The assessment of effects in this Scenario
seeks to set out in brief any additional human health effects that would derive
from the Proposed Development, over and above those deriving from the
consented ZWF development which it would effectively replace.
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17.4 Assessment of Effects
Incorporated Mitigation
17.4.1 A number of mitigation measures have been incorporated into the scheme
design, construction and operational procedures in order to avoid, reduce or
compensate for potential human health impacts.
17.4.2 The construction process would be managed in accordance with a project-
specific CEMP which would set out how construction would comply with any
specific environmental limitations imposed by the planning consent, as well
as relevant legislation, regulations and best practice guidance. The CEMP
would include detailed method statements for specific tasks where
necessary, as described in Chapter 4.0 of the ES. The CEMP would include
details of measures required mitigate the adverse effects of the construction
phase including:
Hard-surfaced haul roads;
Stockpiles of materials that have the potential to generate dust will be
securely sheeted;
Drop heights will be minimised;
Dust suppression, including measures to ensure the correct treatment
of disposal of run-off from dust suppression activities;
No-idling of vehicles;
Effective vehicle cleaning and wheel washing at site exit;
The covering of all loads which have the potential to generate dust;
No site run-off; and
All vehicles and plant will be well maintained.
17.4.3 A whole range of mitigation measures would be incorporated into the
Proposed Development to ensure that there are no unacceptable impacts on
air quality during its operational phase. These would comprise a combination
of design measures and management and operational procedures covering
both the Mechanical Treatment plant and the ERC plant, and would include
those measures detailed below.
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Management and Staffing Arrangements
The Proposed Development will have an appropriate management
structure in place and will be suitably staffed; and
It is FCC’s intention that the an integrated management system (IMS)
will be developed at the proposed development; the IMS will be based
on the requirements of:
o The international quality management standard ISO9001; and
o The international environmental management standard
ISO14001, and the international occupational health and safety
management standard OHSAS18001.
17.4.4 These arrangements will ensure that the Proposed Development is managed
and operated to the highest standards at all times:
All operational procedures will be properly documented; this would help
to ensure that the plant is operated in an appropriate manner at all
times; and
All staff will be properly trained in their respective duties; again, this
would help to ensure that the plant is operated in an appropriate
manner at all times;
Operational Measures
General Arrangements
17.4.5 All aspects of the ERC would be controlled by a series of sophisticated
computer control systems which will provide feedback to the plant operators
on the operational status of the ERC at all times.
Mechanical Treatment Plant
All waste coming into the MT plant would be offloaded inside the Waste
Reception Building with the access doors closed;
All internal areas of the MT plant would be kept under negative
pressure; and
When the EFW is not operational (approximately 2 weeks per year) air
from inside the MT plant would not be under negative pressure and
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accordingly air from this area will be ducted through a biofilter to control
odour emissions from the plant.
17.4.6 These arrangements will help to ensure that the potential for fugitive dust and
odour emissions form the MT plant would be minimised.
Energy from Waste Plant
All elements of the ERC plant have been designed to meet the
requirements of the IED;
The ERC would incorporate a SNCR system to ensure that NOx are
reduced to a level that will ensure that the emissions meet the
requirements of the IED;
The ERC would incorporate a flue gas treatment stage to remove acid
gases and particulate matter from the gas stream before discharge to
atmosphere; this comprises a lime and activated carbon injection
system and a high specification bag filtration system; again, these
arrangements will ensure that IED requirements will be met in relation
to emissions of particulate matter, sulphur dioxide, hydrogen chloride
and hydrogen fluoride;
The ERC would be equipped with a comprehensive range of
continuous monitoring devices to ensure that the plant operators are
fully aware of the status of the emissions from the plant at all times;
these devices will monitor particulate matter, carbon monoxide, oxides
of nitrogen (NO and NO2, Ammonia, Sulphur Dioxide, VOCs, expressed
as Total Organic Carbon TOC), Hydrogen Chloride, Oxygen, moisture,
temperature, pressure and velocity and flow; the continuous emissions
monitoring data generated by these devices will enable the operators to
adjust and / or shut down the plant if necessary;
The plant will be equipped with a comprehensive series of alarms and
interlock systems throughout; these would provide an indication of any
potential or actual system faults and would, if necessary, automatically
close the ERC down.
17.4.7 It is evident from the measures described above, that the Proposed
Development would benefit from extensive mitigation through a combination
of design, management procedures and operational procedures.
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Construction Phase
Assessment of Effects against Existing Baseline
17.4.8 An overview of the key elements of the construction process for the Proposed
Development is set out in Chapter 4.0 of this ES. It is anticipated that
construction would last for a period of approximately 28 months. Initial works
would include site clearance, foundations and drainage, and these would be
likely to take place early, within the first 5 months. Erection of building
frames, plant and equipment, and then cladding would follow. Landscaping
and other external works would generally be amongst the last tasks to be
completed.
17.4.9 Construction activity is already evident, both within the boundary of the
Application Site, and in the surrounding area, associated with the Borders
Railway, AD Facility and SNCD. The baseline for the HHRA assumes that
this construction activity is complete. The construction of Proposed
Development would introduce potential air quality effects from autumn-2015
until summer 2017 –There would be adverse effects of short-term duration
deriving from this construction activity.
17.4.10 The likely effect on human health from the construction phase would be from
dust (particulate matter) during construction and site clearance operations.
17.4.11 The main sources of dust from the Proposed Development will arise from the
following:
Material handling and removal,
Construction and road traffic passing over exposed soil surfaces and
vehicle exhaust emissions;
Site excavations for foundations and groundwork; and
Batching of concrete on site (if required).
17.4.12 The effects on construction dust are likely to be limited to areas downwind
within 200m of dust generating activities as particulate matter would drop out
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of the air at distances less than this. Elevated concentrations of dust are most
likely to occur on dry windy days and areas downwind of the prevailing wind
direction will be affected more frequently.
17.4.13 Mobile plant used would also produce emissions which may temporarily
increase levels of pollutants within a localised area. However, these would be
rapidly dispersed in the atmosphere.
17.4.14 The nearest sensitive receptors are immediately adjacent to the sites western
boundary (the housing proposed as part of the proposed Shawfair
development), with the measures implemented in the CEMP it is unlikely that
any significant dust emissions would arise.
Assessment of Effects against PPiP Future Baseline Scenario
17.4.15 The construction period for the ZWF development was proposed to occur
between 2013/2014 and 2015/2016 for a period of approximately 24 months.
The details regarding construction in the ES prepared in support of the
application for the ZWF, are limited, and as such, it seems reasonable to
assume construction would involve similar activities to those required for the
Proposed Development. The Air Quality Chapter prepared simply states that
dust emissions during the construction phase effects would be controlled
through formal agreement with the Local Authority, as would be the case with
this planning application.
17.4.16 The difference between the construction phase for the Proposed
Development, as compared with that for the ZWF Development, would be the
increased duration of construction activity. However, as the footprint of the
Proposed Development is smaller, the physical extent of the construction
area will be reduce. As such, the temporary adverse effects of the Proposed
Development would be for a longer duration, but would be of smaller physical
scale and are likely to be quantitatively less on a daily basis. It is not
considered that other aspects of the construction process would result in any
effect that is appreciably different from that would could be anticipated from
the PPiP Development. Accordingly, the effects of the Proposed
Development on human health during the construction phase would be
neutral when compared to the future bassline position.
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Operational Phase
Assessment of Effects against Existing Baseline
17.4.17 The potential effects of the Proposed Development on the health of the local
community have been considered in the context of the potential emissions
from the Proposed Development. Pollutants, excluding dioxins and furans
were subject to comparison with air quality objectives set for the protection of
human health; and dioxins and furans were subject to HHRA using the
methodology as described above.
Pollutants Assessment (excluding Dioxins and Furans)
17.4.18 The maximum pollutant GLC resulting from the emissions from the Proposed
Development have been predicted by the modelling undertaken for the AQA
(see Chapter 12.0). These have then been expressed as a percentage of
their AQSs. The modelling assessment concluded that none of the pollutants
in the releases from the proposed facility wouldl exceed either its short term
or long term AQSs.
17.4.19 In addition to the maximum GLC, the modelling study determines the impacts
at thirty-two potentially sensitive human receptors; the list of receptors
considered is provided in the HHRA report (see Appendix 17-1). The results
of the study indicate that at all of the sensitive receptors, the predicted
pollutant GLCs were significantly less than the maximum predicted pollutant
GLCs. As a consequence, the Proposed Development would not give rise to
any significant effects in this regard.
Dioxins and Furans Assessment
17.4.20 The results of the atmospheric dispersion modelling study were then used to
undertake a HHRA in relation to potential exposure to dioxins and furans.
The HHRA used Industrial Risk Assessment Program Human Health (IRAP-h
View) software, which is based on the USEPA methodology, to calculate the
transport and fate of dioxins and furans that could be in the discharge
exhaust stack gases from the Proposed Development. The full HHRA can be
found in Appendix 17-1.
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17.4.21 The following pathways were considered as part of the assessment:
Inhalation (including acute inhalation);
Ingestion of soil;
Consumption of fruit and vegetables;
Consumption of poultry and eggs;
Consumption of meat (beef, pork and fish);
Consumption of cow’s milk and human breast milk; and
Consumption of drinking water.
17.4.22 Members of the local population are only likely to be exposed to significant
effects associated with emission of dioxins and from the Proposed
Development if:
They spend significant periods of time at locations where and when
emissions from the proposed installation increase the concentration of
dioxins / furans above the existing background concentration;
They consume food grown at locations where emissions increase the
concentration of dioxins / furans above the concentration normally
present in food from those locations;
They undertake activities likely to lead to ingestion of soils at locations
where emissions have increased the concentration of dioxins / furans in
the soil above background levels; and
They drink water from sources exposed to increased concentrations of
dioxins/furans above the levels normally present.
17.4.23 The extent of exposure that any person may experience would depend
directly on the degree to which they engage in any or all of the above
activities, and by how much the existing background concentration of dioxins
/ furans increases as a result of the operation of the Proposed Development.
The drinking water pathway is considered to be highly unlikely as very few
people are likely to collect and drink rainwater in the vicinity of the site.
17.4.24 Using the IRAP-h View model, a human health risk assessment for exposure
to dioxins and furans has been undertaken. The following calculations were
undertaken:
Estimates of the combined cancer risks and non-cancer (Hazard
Quotients) for all identified receptors;
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Estimates of risk and hazards associated with pathways of exposure;
Evaluation of infant exposure via breast milk to COPCs with appropriate
bio-transfer factors; and
A comparison of the total daily intake of dioxins and furans and dioxin-
like PCBs with the the UK’s Committee on Toxicity of Chemicals in
Food, Consumer Products and the Environment COT* / TDI values.
* Note: The COT is an independent scientific committee that provides advice
to the Food Standards Agency, the Department of Health and other
Government Departments and Agencies on matters concerning the toxicity of
chemicals).
17.4.25 The total cancer risk estimated by the model, based on the air dispersion
modelling prediction of air concentrations and depositions by ADMS5, for the
worst case scenarios maximum emissions from the proposed installation
were calculated. It can be seen from the results in Table 4 of Appendix 12-1
that the highest identified cancer risk is for a Fisher Child at Stoneybank (R4)
- 5.18E-06 or 0.00000543. A risk level of 0.00001 (or 1.00E-05) is used as an
acceptable cancer risk, therefore based on the cancer risks calculated at all
sensitive receptor locations, the estimated cancer risk is well below the UK
acceptable risk of 0.00001. Consequently, it can be concluded that the
cancer risk from the proposed facility is well within acceptable limits, and, no
further assessment is considered necessary. As a consequence, the
Proposed Development would not give rise to any significant effects in this
regard.
17.4.26 The total hazard quotients estimated by the model, based on the air
dispersion modelling prediction of air concentrations and depositions by
ADMS5 for the worst case scenarios maximum emissions from the proposed
installation were calculated.
17.4.27 The results in Table 5 of Appendix 17-1 indicate that the highest hazard
quotient is for a Fisher Child at Stoneybank (R4) – 2.010E-03 or 0.00201. A
hazard quotient of less than or equal to 1 is considered health protective,
therefore based on the hazard quotients calculated at all sensitive receptor
locations, the hazard quotients are below the health protective value of 1.
Consequently, it can be concluded that the non-cancer risk from the
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Proposed Development is well within acceptable limits, and, again, no further
assessment is considered necessary. In light of this, it can be concluded that
the Proposed Development would not give rise to any significant effects in
this regard.
17.4.28 There are no UK or USEPA target levels for acceptable infant exposure.
However, one approach that the USEPA has taken to evaluate whether
dioxins and furans are likely to cause significant health effects is to compare
estimated toxicity equivalency (TEQ) exposures to national average
background exposure levels. In the absence of any UK figures, the average
background exposure level for dioxins/furans in the US is 60pg TEQ kg-1 day-
1 for infants.
17.4.29 The Former Ministry of Agriculture, Forestry and Fisheries (MAFF) in its Food
Surveillance Information Sheet No 105, June 1997 stated that dietary intake
of dioxins/furans by breast-fed infants to be 170pg TEQ kg-1 day-1 at two
months, dropping to 39pg TEQ kg-1 day-1 at 10 months. It is interesting to
note that, despite the high intakes of dioxins/furans experienced by nursing
infants (intake of an adult being approximately 1pg TEQ kg-1 day-1), the
impact of breast-feeding on infant body burden of dioxins/furans is markedly
less dramatic. Peak infant body burdens are only around twice those of an
adult, a consequence of the infant’s rapidly expanding body weight and lipid
volume, as well as a possibly faster elimination rate.
17.4.30 The predicted average daily dose (ADD) associated with the Proposed
Development for each of the infant receptors has been compared with this
background level in order to assess the impact on breast-fed infants from
exposure to the sum of all dioxins via ingestion of their mother’s breast milk.
17.4.31 The data in Table 6 and 7 of Appendix 17-1 indicates that the highest ADDs
are calculated for Fisher Infant at Stoneybank (0.478pg COPC/kg/ body
weight/day), and equates to 0.80% of the USEPA criteria (i.e. 60pg/day
intake), 0.28% of a 2 month old infant (i.e. 170pg/day intake) and 1.23% of 10
month old infant (i.e. 39pg/day intake) respectively, based on the MAFF
criteria. Consequently, the Millerhill RERC will not pose a significant risk via
the ingestion of breast milk. In light of this, it can be concluded that the
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Proposed Development would not give rise to any significant effects in this
regard.
17.4.32 The predicted total daily intake of dioxins and furans (averaged over a
lifetime (70 years)) has been compared against the COT total daily intake
value of 2pg TEQ/kg body weight/day at each of the sensitive receptors.
17.4.33 The total predicted total daily intake of dioxins and furans varies depending
on receptor type and location, ranges from 0.000043pg TEQ/kg body
weight/day for the resident child scenario at Dalkeith High School to
0.0905pg TEQ/kg body weight/day at Stoneybank. All values are less than
the COT total daily intake value of 2pg TEQ/kg body weight/day, and,
therefore, the Proposed Development would have negligible impact on
human health with regard to intake of dioxins and furans.
17.4.34 The background level of dioxins and furans within the area of assessment is
not known; therefore it is not practically feasible to quantify the total
concentration (i.e. the background plus the contribution from the Proposed
Development) at each receptor point. The highest estimated concentration of
dioxins and furans in soil due to the Proposed Development have been
calculated and compared to UK rural (4.7ng TEQ/kg) and urban (9.19ng
TEQ/kg) soil concentrations.
17.4.35 The highest predicted soil level is predicted to be 0.340ng TEQ/kg at Queen
Margret University Halls. This is less than 8% of the rural mean soil level, and
less than 4% of the urban soil level identified in the 2007 survey.
Consequently, it would not constitute a significant additional burden in the
context of the variability of soil levels of dioxins and furans.
Assessment of Effects against PPiP Future Baseline Scenario
17.4.36 The HRA for the ZWF was incorporated into the AQA. It concluded that the
predicted concentrations would be within the relevant air quality objective and
guidelines, as is the case with this application. In addition the PPiP dioxin and
furan assessment estimated that the highest forecast level of exposure would
be 5.5% of the tolerable daily intake. The highest forecast level of exposure
resulting from the Proposed Development would be 4.5% of the tolerable
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daily intake. Consequently, it can be concluded that there effect on human
health would be lower using the Proposed Development compared to the
PPiP scheme.
Decommissioning Effects
17.4.37 The decommissioning stage of the project would be similar to the
construction phase. The main effects on human health will be from dust
(particulate matter) which would be generated during any demolition of
buildings and site clearance operations.
17.4.38 As with the construction phase, it is likely that the effects of dust would be
limited to areas downwind and within 200m of dust generating activities.
Elevated concentrations of dust are most likely to occur on dry windy days
and areas downwind of the prevailing wind direction would be affected more
frequently.
17.4.39 Mobile plant used will also produce emissions which may temporarily
increase levels of pollutants within a localised area. However these would be
rapidly dispersed in the atmosphere.
17.4.40 The nearest sensitive receptors are directly adjacent to the western boundary
of the Application Site (associated with the SNCD). As part of the PPC Permit
the site would have to be decommissioned in accordance with a Site Closure
Report which would include dust control measures. Consequently, in the
event that emissions of dust arise they will be controlled in such a manner to
prevent a risk to human health. Accordingly, there will be no significant
effects during the decommissioning phase.
17.5 Additional Mitigation
17.5.1 No additional measures are proposed to mitigate against potential adverse
landscape and visual effects
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17.6 Residual Effects
Residual Effects against Existing Baseline
17.6.1 In the absence of additional mitigation measures, the residual effects of the
Proposed Development would be as set out in Section 17.4 above.
Residual Effects against PPiP Future Baseline Scenario
17.6.2 In the absence of additional mitigation measures, the residual effects of the
Proposed Development would be as set out in Section 17.4 above
17.7 Conclusions
17.7.1 An assessment of the likely significant effects on the health of humans due to
emissions from the Proposed Development was undertaken. This was
focused on COPCs including acid gases, metals, and dioxins and furans for
which any effects are likely to be chronic arising from prolonged exposure.
17.7.2 The methodology for the assessment of all pollutants with the exception of
dioxins, furans, was based on a comparison of the predicted maximum
ground level concentrations, including background air quality levels, i.e. the
predicted environmental concentrations, with the relevant air quality
standards which are set for the protection of human health. This assessment
also included the agreed EIA baseline which includes emissions from the
ADFacility.
17.7.3 The results demonstrated that the process contributions from the Proposed
Development and the existing background combined with the relevant
emissions from the AD Facility would not result in any predicted
environmental concentration values that exceed air quality standards.
Consequently, it can be concluded that there would be no significant effect on
human health from these COPCs.
17.7.4 In the absence of UK protocols for the assessment of dioxin/furan effects on
human health, and further to consultation with the SEPA, the USEPA
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methodology Human Health Risk Assessment Protocol 2005 was used
utilising the commercial software IRAP-h View.
17.7.5 A conceptual model was constructed for the site identifying all viable sources,
receptors and pathways of exposure relevant to each of the receptors.
17.7.6 COPC concentrations in the different receiving media were calculated from
the particle phase and vapour phase air concentrations and deposition to the
soil and surface water courses. The estimated concentrations were based on
a number of conservative assumptions to ensure that worst-case scenarios
were assessed.
17.7.7 To identify the level of potential risk from exposure to each COPC in all
relevant pathways of exposure, the hazard quotients for each medium were
calculated. Potential cancer risk was also estimated and compared with
relevant acceptable risk levels.
17.7.8 The modelling has demonstrated that the cancer risks and hazard quotients
for all receptors are below levels set for the protection of human health, and
the total dioxin intake is less than the health protective level of 2pg/day.
Consequently, the potential health impact on receptors in the vicinity of the
Proposed Development is not considered significant
17.7.9 It has also been concluded that there effect on human health would be lower
for the Proposed Development than the future baseline represented by the
ZWF.
17.7.10 It is, therefore, concluded that potential exposure to emissions from the
Proposed Development would not pose unacceptable risk to receptors
identified in the assessment area.
17.8 References
17.8.1 All references used can be found in the HHRA in Appendix 17-1.
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18.0 SUMMARY OF EFFECTS
18.1 Introduction
18.1.1 This ES describes the Millerhill Recycling and Energy Recovery Centre
(Millerhill RERC) development and provides an assessment of the likely
environmental effects that may arise from the construction and operation of
the facility.
18.1.2 The Proposed Development would comprise a purpose built integrated waste
recycling and recovery plant situated on the former Millerhill Marshalling
Yards, Whitehill Road, Dalkeith. It would have an installed electricity
generating capacity of approximately 13.45 Megawatts (MW) and would
generate electricity by way of a steam turbine, which would be driven through
the combustion of 189,471 tonnes per annum (tpa) of non-hazardous residual
waste, the majority of which would be municipal waste. A proportion of the
waste treated at the facility would be commercial and industrial wastes similar
in composition to the municipal waste. The facility would be capable of
delivering Combined Heat and Power (CHP) with the turbine equipped with
steam extraction points enabling export of heat to local heat users, it would
also allow for the recycling of ferrous and non-ferrous metals.
18.1.3 The scope of the ES was agreed in consultation with Midlothian Council and
other relevant technical bodies. The potential effects of the proposals are
described fully within the Main Report (Volume 1) with supporting data for the
assessments bound separately within the Technical Appendices (Volume 2).
A Non-technical Summary (Volume 3) is also provided.
18.1.4 The potential effects of the proposals, as identified in the ES, are
summarised below.
18.2 Traffic and Transportation
18.2.1 Chapter 6.0 provides an assessment of the highways and transport related
environmental impact of the Proposed Development. The assessment relies
on the findings of the formal Transport Assessment (TA) that has been
submitted in support of the Planning Application.
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18.2.2 The potential highways and transport related environmental impact of the
operation of the proposed facility has been assessed via reference to the
methodology set out in the Institution for Environmental Management &
Assessment (IEMA) document: Guidelines for the Environmental Assessment
of Road Traffic.
Construction Impacts
18.2.3 Traffic impacts associated with the construction of the site would be
temporary in nature and are likely to vary over the course of the construction
period dependent upon the nature of activities taking place. It is proposed
that a Construction Traffic Management Plan should be prepared (under the
control of a planning condition). This would form part of the Construction
Environmental Management Plan.
18.2.4 Construction of the Proposed Development would not generate a material
level of HGV demand. None of the construction phases are anticipated to
generate HGV levels in excess of those associated with the day to day
operation of the Proposed Development or indeed, those HGV thresholds
already established as being acceptable with respect to the Zero Waste
Facility (ZWF).
18.2.5 Appropriate levels of staff parking would be provided on site to avoid any
potential issues of overspill off-site parking on local routes, with the levels of
staff vehicle demand to be controlled by travel management initiatives such
as car sharing and off-site bus transfer where practical.
18.2.6 Maximum construction periods could result in the requirement for up to 288
staff to be based at the site. Such peak staff demand levels would not be
experienced across the full extent of the construction programme, being
typically related to the building fit out / installation phases. Indeed,
construction staffing levels of over 200 workers are only anticipated to occur
for approximately a quarter of the construction programme. Furthermore,
during these intensive staff demand periods, HGV construction traffic would
be at typically low levels (circa 20-30 HGV arrivals per day).
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18.2.7 Such combined peak daily construction traffic demand including for maximum
predicted staffing levels has been demonstrated as falling well within industry
standard screening thresholds for the assessment of operational and traffic
related environmental effects. It can therefore only be concluded that the
traffic and transport related environmental effects associated with the
construction of the Proposed Development would not be significant.
Operational Impacts
18.2.8 The traffic levels associated with the extant waste management consent (for
the ZWF) have established an acceptable threshold for traffic volumes
associated with development at the proposal site, below which traffic demand
has been demonstrated via formal environmental assessment as not likely to
give rise to discernible network operational or traffic related environmental
concerns.
18.2.9 The combined operation of the Proposed Development and the currently
under-construction AD Facility would result in substantially less development
related traffic demand (both in terms of overall vehicle numbers and,
importantly, HGV trips), when compared to the consented ZWF. There can
therefore be a high degree of confidence that the day-to-day operation of the
Proposed Development would also not give rise to material traffic related
operational or environmental effects. Indeed, delivery of the Proposed
Development would result in an overall ‘net benefit’ in traffic and transport
effects when compared against the current reference planning position. In
light of this, it is concluded that the traffic related environmental effects of the
day to day operation of the Proposed Development would not be significant.
18.3 Landscape and Visual Impact
18.3.1 Chapter 7.0 provides an assessment of the landscape and visual impacts of
the Proposed Development. The methodology used to carry out the
assessment is based upon that set out in Guidelines for Landscape and
Visual Impact Assessment (3rd edition 2013, Landscape Institute and Institute
of Environmental Management and Assessment).
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Construction Impacts
18.3.2 In overall terms, whilst there would undoubtedly be short term visual effects
during the construction phase, their temporary nature would not result in any
significant effect.
18.3.3 Effects upon landscape character would be set in the context of existing
development associated with the Borders railway, AD Facility and the
Shawfair New Community Development (SNCD). Current construction
activity is evidenced at several sites within the broader area. As such, whilst
the proposed development would introduce new construction activity the
construction activity is not unusual in the wider area and in that context; the
temporary and localised effects of the proposed development would not be
significant.
Operational Impacts
18.3.4 The overall effects upon the landscape fabric would not be significant. The
development would change the site from a vacant brownfield site with young
poor quality woodland, to an operational industrial facility with only a
proportion of the site covered in vegetation. The reduced amount of
vegetation cover within the site would be adverse, but the greater diversity of
vegetation and the enhanced management of the landscape fabric would be
beneficial.
18.3.5 Effects upon landscape character would not be significant in EIA terms. The
Proposed Development would be introduced into an urban fringe landscape
where the presence of built development, including electricity pylons and
road corridors is already strong, and will be even more so with the addition of
the new Borders railway, AD Facility and SNCD (all of which form part of the
LVIA baseline). Whilst the Proposed Development would be larger and more
visually apparent than other existing features the influence of the
development upon the wider character would nonetheless be limited, due to
the very strong influence of built features in the baseline landscape.
18.3.6 Significant visual effects (in EIA terms) would be experienced from only one
of the sixteen viewpoints assessed (at the western edge of Old Craighall).
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The ES for the consented ZWF development also found that there would be
significant effects from this location. Whilst effects would be significant,
views from the majority of the residential properties would be oblique or
obscured by other properties. It must also be noted that the parcels of land
situated between Old Craighall and the existing marshalling yards (to the
immediate east of the Application Site) have been allocated for mixed-use
development in the emerging East Lothian Local Development Plan. As
such, whilst it cannot be guaranteed that development will come forward,
there is a strong likelihood that the view will change significantly in the short
to medium term, with much of the foreground likely to take on an urbanised
character and with the Proposed Development becoming partially screened
and a much less conspicuous component of the view as a result.
18.3.7 More generally, visual effects would not be significant. Views available are
defined by the presence of built development, including large-scale urban
settlement, industrial / commercial buildings, major trunk roads and
prominent embankments (particularly the A1). The presence of the Shawfair
New Community development will increase the visual influence of built
development and will restrict views of the Proposed Development from
nearby locations. In this context, the Proposed Development, whilst
generally visible over a wide area, would have only a limited influence upon
the views available, which would remain characterised by the presence of
built development and road traffic.
Assessment against Future Baseline Scenario
18.3.8 When contrasted with the landscape and visual effects identified for the
consented ZWF development, the significant effects of the Proposed
Development would be less extensive, due to the on-going changes in the
surrounding area and the spread of built development, including the AD
Plant, Borders Railway and Shawfair New Community Development. The
presence of these developments changes the context of the receiving
landscape and greatly increases the influence of buildings and other
structures upon it. Hence whilst the Proposed Development would be a
larger structure than the PPiP development, it would have a lesser effect
upon its surroundings.
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18.4 Ecology and Nature Conservation
18.4.1 Chapter 8.0 provides an assessment of the ecological impacts of the
Proposed Development. The ecological assessment is based on evaluation
of local nature conservation records and the results of surveys carried out in
support of the application for the ZWF (Phase 1 Habitat and Invasive Plants
Survey, Lower Plants Survey, Breeding Bird Survey, Bat Survey Reptile
Survey Badger Survey), update surveys carried out in 2013 (vegetation
survey, Invasive Species Search, Bat Survey, Breeding Bird Survey and
Badger Survey); surveys commissioned in connection with the AD plant in
2012 and an extended Phase 1 Habitat Survey undertaken specifically for the
Proposed Development.
18.4.2 This impact assessment follows the methodology set out by the Institute of
Ecology and Environmental Management (IEEM 2006).
Construction Impacts
18.4.3 Construction works would result in loss of habitats including the loss of 2.3ha
of lowland mixed deciduous woodland habitat; the degradation of bat foraging
habitat over the site (albeit in an area with relatively low bat activity); the
displacement and loss of nesting habitat for up to 14 territories of five
woodland breeding bird species, including seven territories of an Amber List
species, willow warbler; and the displacement of common lizard from the site
and its surroundings. Without mitigation these impacts would vary between
moderate and minor adverse significance.
18.4.4 It is considered that the impacts during the construction phase would be
compensated through the implementation of the landscape scheme,
supported by a long term management plan targeted at key species and
habitats including birds and the creation of habitat for common lizard.
Measures would also need to be incorporated in the Construction
Environmental Management Plan to protect common lizard and breeding
birds in accordance with species protection legislation and policy.
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18.4.5 Following implementation of these measures the development would only
give rise to minor residual effect that would not be classed as significant in
ecological terms.
Operational Impacts
18.4.6 The operational phase of the Proposed Development would not result in any
additional direct impacts in terms of land-take and consequent habitat loss.
Potential indirect adverse impacts during the operational phase may arise
due to the ecological effects of lighting, noise, human disturbance and
emissions to air and water.
18.4.7 A detailed assessment of air quality impacts has demonstrated that the
development can proceed without a likely significant effect on European
conservation sites. This has been determined both by dispersion modelling
and by the assessment of the ecological status and sensitivity of Firth of
Forth SPA / Ramsar site / SSSI. No significant effects were identified in
relation to other interest features during the operation of the Proposed
Development.
Assessment against Future Baseline Scenario
18.4.8 The ecological assessment for the ZWF (Chapter 9 of the ES) reached
broadly similar conclusions on impact significance despite some differences
in assessment methodology. Impacts on woodland habitats and breeding
birds were assessed as slight / moderate adverse significance, based on a
matrix approach which valued the features as having ‘low’ value and the
impact magnitude as ‘moderate’. Given the greater scale of impact on these
features (e.g. loss of 39 breeding bird territories), the impacts of the ZWF
could be regarded as having a higher ecological significance than the
Proposed Development.
18.5 Geology and Hydrogeology
18.5.1 Chapter 9.0 provides an assessment of the geology, hydrogeology and
ground conditions impacts of the Proposed Development. As part of the
consideration of ground conditions the assessment considers the geological
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setting, designated geological sites, contaminated land, hydrogeology, geo-
hazards and geotechnical issues associated with the Proposed Development
and the Application Site.
18.5.2 The assessment has been based on the information gathered from a number
of desk study and ground investigation reports undertaken at the Application
Site and on the adjacent areas.
18.5.3 The only historical land uses that have been identified at the Application Site
are those associated with the construction, operation and removal of the
marshalling yards. No remediation measures have been carried out.
Construction Impacts
18.5.4 No significant impacts were identified by the assessment. However, there
remains the potential for some contamination to be present. As such, it is
recommended that standard best practice construction methods are
employed to ensure that site operatives are not exposed to contaminants that
may remain at the Application Site.
18.5.5 Measures to prevent the contamination of soils or groundwater during the
construction phase are recommended e.g. procedures for dealing with
accidental oil and fuel spillage and dust suppression. These measures would
be fully detailed within the Construction Environmental Management Plan.
Operational Impacts
18.5.6 With the implementation of mitigation measures during the construction of the
Proposed Development, no significant operational impacts have been
identified.
Assessment against Future Baseline Scenario
18.5.7 No additional impact or risks will be associated with the Proposed
Development compared to those identified in the ZWF development. Thus,
the development would have a neutral impact when compared with the future
baseline position.
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18.6 Surface Waters and Flood Risk
18.6.1 Chapter 10.0 provides an assessment of the surface water and flooding
impacts of the Proposed Development. The assessment has been based on
the information gathered from the ground investigation desk study,
topographic survey, the SEPA data and previous flood risk assessments
undertaken at the Application Site.
Construction Impacts
18.6.2 Potential adverse impacts associated with the construction phase include the
potential for pollution of the drainage ditch from suspended solids, oils and
hydrocarbons, cement and concrete products, heavy metals and metalloids,
bentonite and solvents/paints among others. Standard best practice
construction methods would be implemented at site to ensure that no water
quality impacts result from the construction works. These would be
documented in the Construction Environmental Management Plan and would
include measures such as storage of fuel, oils and chemicals in bunded
areas and use of settlement lagoons.
Operational Impacts
18.6.3 The proposed development does not lie within an identified area of flood plain
and the assessment has shown that there is ‘low risk’ of flooding from all
sources. As such the risks posed to the development from fluvial and
groundwater flooding sources are considered to be negligible.
18.6.4 The infrastructure serving the proposed development has been designed
using criteria, pre-agreed as part of the ZWF development, to ensure that the
resulting flows do not exceed those envisaged during the design of the off-
site infrastructure. Given that runoff from the site will be restricted to a pre-
agreed peak flow rate that cannot be exceeded, irrespective of the statistical
infrequency of storm events, it has been concluded that the residual effect
upon downstream properties is minor beneficial.
18.6.5 The proposed development would not affect the water quality of the
surrounding area as a result of the infrastructure that would be installed to
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service the site e.g. appropriately designed storage areas for fuels, chemicals
and oils and provision of interceptor tanks within the surface water drainage
system.
Assessment against Future Baseline Scenario
18.6.6 When assessed against the Future Baseline conditions, which assume that
the proposal site has been developed for the approved alternative waste
management facilities, it is evident that there would be very little difference
between, the scale of the facilities; the construction practises that would be
employed; and the drainage infrastructure that would be installed to serve
each development scenario. As a consequence, it is considered that the
Proposed Development would have a neutral effect in terms of flood risk and
surface water impacts.
18.7 Noise and Vibration
18.7.1 Chapter 11.0 provides an assessment of the noise and vibration impacts of
the Proposed Development. To establish any likely impact from noise a
baseline noise survey was undertaken to establish the existing noise climate
at the site. Relevant and appropriate noise guidance and standards have
been used to determine the potential noise impact from the proposal. Impacts
from both the plant operations and vehicle movements have been assessed.
Observations undertaken during the monitoring indicate that the local noise
climate is influenced by road traffic movements and intermittent aircraft noise.
Construction Impacts
18.7.2 The assessment of potential noise effects during the construction phase has
shown that there is a potential for construction noise to cause moderate
adverse effects at the nearest noise sensitive receptor to the development
site (Shawfair Area D). However, it should be noted, that this assessment
assumes (in accordance with the baseline for assessment) that development
would be implemented and occupied as a sensitive receptor prior to the
commencement of construction works. The reality is that the development
within Shawfair area D is not expected to commence until after the Proposed
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Development has been constructed. Accordingly, the predicted impact for
construction is deemed to be robust and pessimistic.
18.7.3 An assessment of potential vibration effects has indicated that receptors in
the vicinity of the site would not be adversely affected by vibration inducing
construction activities and therefore would not result in a significant impact.
Operational Impacts
18.7.4 During the operation of the site it is concluded that with the implementation of
appropriate mitigation within the detailed design, there would be no
significant effects from the facility.
18.7.5 The assessment has shown that the facility would be within appropriate
guidance, standards and the limits Midlothian Council intend to impose
through a planning condition. Accordingly, the predicted noise levels are not
expected to cause a significant impact to the current noise climate at
surrounding residential and commercial receptors.
18.7.6 The assessment of noise change due to variation in traffic flows on the local
road network has shown that the noise levels would not result in a significant
impact. In addition, ground-borne vibration from the operation of the site or
from HGVs, would also not result in a significant impact.
Assessment against Future Baseline Scenario
18.7.7 The noise impacts predicted for the ZWF development indicate that the noise
levels from the site would not exceed background sound levels +5dB and the
combined effect of the AD Facility, EfW and MBT Facility would not exceed a
design limit of background sound +5dB. The assessment concludes that, in
terms of residual noise, the ZWF development would give rise to
environmental effects of negligible to minor adverse significance. The noise
predictions from the Proposed Development show noise levels to be below
existing background sound levels and based on a worst case assessment,
would only give rise to a negligible to minor impact. In light of this, it can be
concluded that the Proposed Development would only give rise to a ‘neutral’
impact when compared to the future baseline scenario.
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18.8 Air Quality and Human Health
18.8.1 Chapter 12.0 provides an assessment of the air quality impacts of the
Proposed Development. The assessment has identified that the operation of
the facility would give rise to a number of substances that would be emitted to
the atmosphere. As a result, the potential environmental effects of these
emissions have been assessed using detailed dispersion modelling. The
results of the modelling have been assessed against relevant air quality
objectives and guidelines identified from national legislation and the SEPA’s
guidance documents.
18.8.2 The assumptions that have been adopted to determine the predicted
emission levels from the plant, maximum ground level concentrations and
background levels in the vicinity of the plant have been based on a ‘worst-
case’ scenario.
Construction Impacts
18.8.3 During the construction there would be the potential for short-term effects to
occur, mainly in the form of dust emissions generated by earthmoving
activities.
18.8.4 Standard best practice construction methods would be implemented at site to
reduce emissions to the air. These would be documented in the Construction
Environmental Management Plan and would include measures such as use
of water mists during dry periods, closed sheeting of vehicles and washing of
road surfaces leading to the construction site. With the implementation of
these measures no significant construction impacts are anticipated.
Operational Impacts
18.8.5 The results of the modelling have indicated that the proposed stack would
provide more than adequate dispersion to atmosphere and that the operation
of the facility is predicted to have a negligible impact on local air quality or
sensitive habitats. As a result, no significant effects on air quality are
predicted.
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Assessment against Future Baseline Scenario
18.8.6 An assessment has also been carried out of the Proposed Development
against the future baseline position associated with the ZWF development.
The assessment concluded that in relation to air quality the effects of the
Proposed Development during its construction, and operation would be
‘neutral’.
18.9 Cultural Heritage
18.9.1 Chapter 13.0 provides an assessment of the cultural heritage impacts of the
Proposed Development. The assessment includes an appraisal of cultural
heritage resources in a study area of 2km (for all cultural heritage features
recorded on the Historic Environment Gazetteer) and 5km (all World Heritage
Sites, Scheduled Monuments, Grade I and Grade II* Listed Buildings and
Registered Parks and Gardens, excluding Historic Environment Record
data).
Construction Impacts
18.9.2 Due to past development of the Application Site from the mid-20th century
onwards, it is likely that any archaeological remains that may have been
present have been removed. As such, it is considered that the construction of
the Proposed Development would have no direct or indirect impact on known
or potential cultural heritage receptors within the Application Site
Operational Impacts
18.9.3 A number of cultural heritage receptors were identified in the surrounding
landscape, these included Grade A listed buildings and Scheduled
Monuments. The operation of the facility would not result in any direct
impacts on the identified cultural heritage receptors but the facility does give
rise to potential indirect impacts on setting.
18.9.4 The assessment has concluded that the facility would result in minor-
moderate residual impacts on the setting of seven cultural heritage receptors
in the area surrounding the site and minor residual impacts on the setting of
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twenty-one cultural heritage receptors, these impacts are not considered to
be significant.
Assessment against Future Baseline Scenario
18.9.5 There would be no material difference between residual effects for the ZWF
development and the Proposed Development and the difference between the
effects resulting from the two developments is considered to be neutral.
18.10 Socio-Economic Effects
18.10.1 Chapter 14.0 of the ES considered the socio-economic and community
effects of the Proposed Development. It identified background information
from Edinburgh, Midlothian and its districts and wards, in particular Dalkieth
Ward, within which the Application Site is located. It then identified the main
socio-economic and community effects of the Proposed Development.
18.10.2 The key issue addressed in the assessment was to understand the existing
situation and consider whether the proposed development would result in any
adverse socio-economic impacts.
Construction Impacts
18.10.3 The construction of the facility would take circa 28 months to complete and
would provide up to 300 temporary jobs with an average of circa 180-200
over the entire construction period. It is expected that a large proportion of
these temporary jobs would be locally sourced.
18.10.4 The assessment estimates that of these jobs approximately 50 could be
secured during the construction period by local contractors and workers. In
addition there could also be further benefits locally for some businesses (food
and drink, accommodation providers) that may ultimately benefit as a result
of any temporary visiting workforce.
18.10.5 The socio-economic effects of the construction phase of the Proposed
Development are judged to have moderate beneficial effects in the impact
area.
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Operational Impacts
18.10.6 During the operational phase the facility would create 39 new permanent
jobs. The majority of the employees would be skilled operatives
(electricians/fitters/crane operatives) or technical engineers (control and
plant), with a small number of low skilled jobs also created. It is anticipated
that a new apprenticeships would be provided through FCCs apprenticeship
scheme.
18.10.7 Once indirect and induced employment impacts are also considered, it is
estimated that the energy centre could support 50 permanent FTE jobs within
the area. This has the potential to lead to an annual GVA impact of circa
£3.8M per annum. The development would also offer local supply chain
opportunities for local businesses.
18.10.8 Community benefit would also be provided as a result of the integrated visitor
and education centre within the facility. The centre would be a valuable
education resource and would provide local residents with information on the
operation of the facility and educate school children on sustainable waste
management and taking responsibility for their own waste. The visitor centre
would also available for use by other local groups as a meeting space.
18.10.9 In addition the plant would provide a local sustainable renewable source of
energy that would meet the domestic needs of circa 26,000 homes and
produce saleable by-products, in the form of recycled metals and bottom ash
which would be taken off site and re-processed as a secondary aggregate. It
would also offer significant potential to form the primary source of heat for a
district heating network.
18.10.10 The proposal would not have any significant adverse impact further to the
existing situation. The proposal would in fact create a number of social and
economic benefits for Edinburgh and Midlothian and its residents.
Assessment against Future Baseline Scenario
18.10.11 The ES prepared in support of the ZWF development concludes that it would
give rise to a number of beneficial socio-economic effects. The anticipated
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residual socio-economic effects associated with the Proposed Development
have also been assessed as being of beneficial significance. Accordingly,
when compared to the future baseline scenario, the Proposed Development,
as a minimum, result in a neutral impact.
18.11 Cumulative Effects
18.11.1 Chapter 15.0 of the ES considered the potential cumulative effects of the
Proposed Development. Two projects were identified that could have the
potential to result in material cumulative effects with the proposed
development. The assessments undertaken conclude that significant
cumulative environmental effects are unlikely to result from either the
construction or operation of the Proposed Development.
18.12 Energy Export Connection
18.12.1 Chapter 16.0 of the ES considered the potential effects associated with the
export of energy (electricity and heat) from the Proposed Development.
18.12.2 The Proposed Development would generate electricity for export to the local
electricity distribution network and it would also have the potential to
distribute heat to a District heating network. Neither the grid connection works
nor heat distribution network form part of the Planning Application. However,
on the basis that export of both electricity and heat is an integral part of the
scheme, it is considered appropriate that the potential environmental impacts
associated with the connection to the local electricity grid and district heating
network are assessed within the ES.
18.12.3 A potential grid connection route has been identified by Scottish Power
Networks and this has been the subject of assessment. A potential route has
also been identified for the distribution of heat within the heat and power plan
(contained within Part 6 of the Planning Application Document). The
potentially significant effects of both route options have been assessed.
18.12.4 The assessment concludes that no significant residual adverse impacts are
likely to arise from the construction or operation of either route option. Some
very minor adverse impacts have been identified and mitigation measures
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have been proposed to avoid or reduce these impacts. The development of
these energy export connections is not considered to give rise to significant
effects.
18.13 Human Health
18.13.1 Chapter 17.0 provides an assessment of the human health impacts of the
Proposed Development. The assessment has identified that the operation of
the facility would give rise to a number of substances that would be emitted to
the atmosphere and that these substances have the potential to accumulate
in the environment and have an impact on human health. As a result, the risk
to human health of these emissions has been assessed.
18.13.2 A detailed health risk assessment has been carried out using the Industrial
Risk Assessment Program-Human Health (IRAP-h View – Version 4.1.87).
The programme, created by Lakes Environmental is based on the United
States Environment Protection Agency (USEPA) Human Health Risk
Assessment Protocol. In addition an assessment was undertaken to consider
the impacts of on agriculture in the area.
Operational Impacts
18.13.3 Advice from human health specialists such as the Health Protection Scotland
(HPS) is that there is lack of a consistent or conclusive evidence of an
association between (non-occupational) human health effects and waste
incineration. However HPS do note that there will remain a need to take
account of background ambient air quality in assessing the potential impact
of a new facility.
18.13.4 The results of the modelling have indicated that the emissions from the
facility would not have any significant effect on human health, soils or
watercourses.
18.13.5 It is recognised that there is the potential for the proposal result in anxiety
and concern in the local population due to the perception of health effects
from emissions. However, on the basis of the health assessment there is no
evidence to suggest that the health of the local population would be at risk
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and consultation activities have been undertaken in order to keep local
residents informed of the project and its potential effects.
Assessment against Future Baseline Scenario
18.13.6 The human health risk assessment carried out in support of the ZWF
development (contained within the Air Quality Assessment) concluded that
the predicted concentrations would be within the relevant air quality objective
and guidelines, as is the case with the Proposed Development. In addition
the dioxin and furan assessment carried out for the ZWF estimated that the
highest forecast level of exposure would be 5.5% of the tolerable daily intake.
The highest forecast level of exposure resulting from the Proposed
Development would be 4.5% of the tolerable daily intake. Consequently, it
can be concluded that there effect on human health would be lower / more
beneficial than the ZWF development.
18.14 Summary
18.14.1 In considering the results of this ES, it can be concluded that the Proposed
Development would provide a sustainable waste management solution for
Edinburgh and Midlothian’s residual non-hazardous waste. The project would
assist in diverting waste from landfill, provide a source of low carbon and
renewable energy, create local job opportunities and provide a local
community resource in terms of a visitor centre.
18.14.2 The assessments contained in this ES have demonstrated that the only
potentially significant effects relate to visual impacts on a single viewpoint
located approximately 1km to the east of the site, where there are 30
residential properties. The assessments have shown that the proposal would
not result in a significant impact on local landscape character. No other
significant residual adverse environmental impacts have been identified.
FIGURES