5 EIA Process and Methodology

5.1 Introduction
5.1.1 This Chapter describes the EIA process and the key stages involved in that
process. Within the context of the EIA Regulations 2009 (see Section 1.5) it
explains the approach that has been used to identify current and future baseline
conditions and how the likely effect of the Scheme on various aspects of the
natural and built environment has been assessed, and how a level of
significance of that effect is determined. The assessment scenarios are defined
and an explanation of cumulative effects is provided.

5.1.2 The requirements of EIA are set out by the EIA Regulations 2009, which give
effect to Directive 85/337/EEC on the assessment of the effects of certain public
and private projects on the environment, as amended by Directive 97/11/EC.
Schedule 4 of the EIA Regulations 2009, which sets out the information required
in an environmental statement, is included in Appendix 5.1. In particular, the ES
must include:

such of the information referred to in Part 1 of Schedule 4 as is reasonably

required to assess the environmental effects of the development and of any
associated development and which the applicant can, having regard in
particular to current knowledge and methods of assessment, reasonably be
required to compile; and

at least the information referred to in Part 2 of Schedule 4.

5.2 EIA Development

5.2.1 The EIA Regulations 2009 identify two types of development projects: Schedule
1, for which the requirement to prepare an EIA is mandatory, and Schedule 2 for
which an EIA may be required. The Application is for consent to construct and
operate a combined heat and power plant with a thermal electricity generating
capacity in excess of 300MW and under schedule 1, paragraph 2(a) of the EIA

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 Regulations 2009, the Scheme is therefore, classified as mandatory EIA
development and as such the Application is accompanied by this ES.

5.3 The EIA Process

5.3.1 Generic policy advice on EIA and of relevance to the Scheme is provided by
NPSs EN-1 and EN-2. Particular advice on the EIA process for DCO
applications is provided by several advice notes published by PINS, whilst further
useful advice is afforded by Circular 11/99 Environmental Impact Assessment
from the Welsh Office (1999) and the draft guidance contained within the
Department for Communities and Local Government (DCLG) paper
Environmental Impact Assessment: A guide to good practice and procedures, a
consultation paper (2006). These sources of advice are considered further
below.

National Policy Statements

5.3.2 NPSs EN-1 and EN-2 (see Section 1.4) contain advice on the EIA process for
nationally significant energy related infrastructure projects. NPS EN-1 provides
guidance on the general approach to preparation of the Environmental
Statement (Section 4.2). This refers to the need to consider:

the likely significant social and economic effects of the development, and
how any likely significant negative effects would be avoided or mitigated
(paragraph 4.2.2);

the environmental, social and economic effects arising from pre-construction,

construction, operation and decommissioning of the project (paragraph
4.2.3);

likely significant effects, including any significant residual effects taking

account of any proposed mitigation measures or any adverse effects of those
measures (paragraph 4.2.4); and

cumulative effects: how the effects of the applicant’s proposal would combine
and interact with the effects of other development (including projects for

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 which consent has been sought or granted, as well as those already in
existence) (paragraph 4.2.5).

5.3.3 Where some aspects of a proposal have not been settled in precise detail, as is
the case in this Scheme, the applicant is required to explain which elements of
the proposal have yet to be finalised, and the reasons why this is the case
(paragraph 4.2.7). In such cases the ES should set out, to the best of the
applicant’s knowledge, what the maximum extent of the proposed development
may be in terms of site and plant specifications, and assess, on that basis, the
effects which the project could have to ensure that the impacts of the project as it
may be constructed have been properly assessed (paragraph 4.2.8), consistent
with the Rochdale Envelope principles referred to in Advice Note 9 published by
PINS (see below). A Rochdale Envelope approach has been adopted for the
Application.

5.3.4 Section 4.4 of NPS EN-1 is concerned with the consideration of alternatives and
advises at paragraph 4.4.2 that applicants are obliged to include in their ES, as a
matter of fact, information about the main alternatives they have studied. This
should include an indication of the main reasons for the applicant’s choice,
taking into account the environmental, social and economic effects and
including, where relevant, technical and commercial feasibility. In that context
the proposed CHP Plant’s synergistic relationship with the LNG Terminal has
determined the general location of the CHP Plant and the decision process in
that respect has been detailed in Chapter 3.

5.3.5 Part 5 of NPS EN-1 is concerned with generic impacts which arise from the
development of the types of infrastructure covered in the energy NPSs. These
are described under the various environmental topics to be included in the ES
and, where appropriate, are referred to in the individual assessment topic
chapters of this ES (Chapters 6 to 15).

5.3.6 NPS EN-2 is concerned with fossil fuel electricity generating infrastructure
including gas fired plants (Section 2.5). This includes topic specific guidance
relevant to the CHP Plant under the headings:

Air quality and emissions;

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 Landscape and visual;

Noise and vibration;

Waste management; and

Water quality and resources.

5.3.7 Relevant considerations are referred to in the individual assessment topic

chapters of this ES.

National Infrastructure Planning Guidance

5.3.8 Particular advice on the EIA process for DCO applications is provided in the
PINS guidance and advice notes. Those most relevant to the preparation of the
ES for the Scheme are:

PINS Advice Note 6: Preparation and submission of application documents

(Version 5);

PINS Advice Note 7: Environmental Impact Assessment, screening and

scoping (Version 3);

PINS Advice Note 9: Rochdale Envelope (Version 2);

PINS Advice Note 13: Preparation of a draft order granting development

consent and explanatory memorandum (Version 2); and

PINS Advice Note 16: The developer’s pre-application consultation, publicity

and notification duties (Version 1).

5.3.9 The guidance set out in PINS Advice Note 7 (Environmental Impact Assessment,
screening and scoping) was taken into account in preparing the Scoping Report
for the Scheme and thus the Scoping Report provided:

a description of the scheme or proposal;

interpretation of the site settings and surroundings;

outline of alternatives and methods used in reaching a preferred option;

results of desktop and baseline studies where available;

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 methods to predict impacts and the significance criteria framework;

mitigations and residual impacts to be considered;

key topics covered as part of the scoping exercise; and

an outline of the structure of the proposed environmental statement.

EIA overview
5.3.10 The main stages in the EIA process in respect of any project such as the
Scheme are as follows:

Screening to determine the need for EIA;

If EIA is required, scoping to determine the subject matter of the EIA and to
identify potentially significant issues;

Consultation on the Preliminary Environmental Information (PEI) pursuant to

Regulation 10 of the EIA Regulations 2009 which is required to be included
in the Statement of Community Consultation prepared under section 47 of
the Planning Act;

Data review involving the compiling and reviewing of available data and/or
the undertaking of baseline surveys to generate site specific data;

Assessment and design iteration whereby the likely significant effects of the
development during the construction, operational and decommissioning
stages of its life are assessed and feedback is provided to the design and
engineering team(s) to modify the development in order to prevent, reduce
and, where possible, offset any significant adverse effects on the
environment;

Assessment of the construction methodology and the final design of the

development;

Identifying any residual effects and any further mitigation or compensation

requirements; and

Preparing the ES (the report of the EIA).

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 Screening
5.3.11 As the Scheme falls under paragraph 2(a), schedule 1 of the EIA Regulations
2009, EIA is mandatory. In accordance with regulation 6(1)(b) of the EIA
Regulations 2009, PINS was informed by letter dated 21 June 2012 that an
environmental statement would accompany the Application (see Appendix 5.2).

Scoping
5.3.12 A Scoping Report setting out the proposed scope of the EIA was submitted to
PINS with the letter of 21 June 2012 together with a request for an EIA Scoping
Opinion under Regulation 8(1) of the EIA Regulations 2009 (Scoping Request).
After due consultation with statutory consultees as required under the EIA
Regulations 2009, the Scoping Opinion from PINS was issued on 31 July 2012
and is included herein as Appendix 5.3.

5.3.13 This ES has been prepared in accordance with the advice set out in the Scoping
Opinion, the consultees’ letters appended to the Scoping Opinion, and the EIA
Regulations 2009. A table or a short list of bullet points, outlining the key issues
identified in the Scoping Opinion as well as where in the ES and other
Application documents they are addressed is included at the beginning of each
individual assessment topic chapter (Chapters 6 to 15).

Consultation
5.3.14 Consultation has been undertaken with a wide range of consultees (both
prescribed and non-prescribed consultees as defined in the Planning Act). An
important part of the consultation process was the publication and distribution of
the PEI which contained the information referred to in Part 1 of Schedule 4 of the
EIA Regulations 2009 and which was provided to the local community in
accordance with the Statement of Community Consultation prepared under
section 47 of the Planning Act. The PEI was published in two stages to reflect
the changing design of the Scheme. The initial PEI, which was circulated as part
of an Information Pack on 24 September 2012 to the section 47 consultees, is
provided at Appendix 5.4 and the updated PEI Non Technical Summary (NTS),
which was circulated on 14 January 2012 to the same parties, is provided at
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 Appendix 5.5. For the sake of completeness, both the initial PEI and the
updated PEI NTS were also provided to the section 42 prescribed consultees (on
13 August 2012 and 15 March 2013). This is referred to in more detail in the
Consultation Report (Document 1.2) which accompanies the Application.

Environmental Topics Considered in the EIA

5.3.15 The appropriate environmental assessment topics identified at the scoping stage
of the EIA and subsequently assessed and reported upon in this ES (at Chapters
6 to 15) are:

ground conditions and hydrogeology (land quality);

hydrology, water quality and flood risk;

seascape, landscape and visual effects;

terrestrial ecology (including ornithology);

marine environment and ecology;

air quality;

noise and vibration;

historic environment (archaeology, cultural heritage);

traffic and transport;

socio-economics; and

cumulative effects.

5.3.16 Other potential issues including land use, alternatives, and waste and aviation
are described in Chapters 2, 3 and 4 respectively.

Study Area
5.3.17 For each assessment topic a study area is defined and described in the
methodology section of each assessment topic chapter. Where applicable, study
areas have been agreed in consultation with local authorities and/or statutory

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 bodies. In some instances more than one study area is defined in accordance
with relevant standards and guidance for that topic.

Baseline Conditions
5.3.18 In EIA, the likely significant effects of the proposed development or scheme need
to be identified and assessed against a clear baseline. For this Scheme the
following baselines are used:

The existing situation in 2010 – 2012 depending on the latest data available;

A future baseline of 2017 which is when the CHP Plant is anticipated to

become operational.

5.3.19 Baseline data are obtained from the collation of existing information or from the
results of surveys commissioned specifically for the Scheme, or both. The
existing baseline is informed by data that is ‘current’ and future baselines are
informed by an extrapolation of the currently available data by reference to, for
example, Government policy, planning applications and expert judgement of the
individual topic specialists. Clearly therefore the more distant a future baseline
is, the greater the uncertainty is on the conditions that would pertain at that time.

5.3.20 Information is constantly being updated and all data are therefore time
dependent. However, how critical this is varies between EIA topics. The
location of known cultural heritage assets for example is not time critical although
it is important to have the most up to date information available. Ecological
survey data by contrast becomes increasingly less reliable 3 or 4 years after
collection. All the data and information required to define the baseline for each
assessment topic are located in appendices to each respective chapter.

Duration and Frequency of Effects

5.3.21 When undertaking an EIA, environmental effects are classified as either
permanent or temporary, as appropriate. Permanent changes are those which
are irreversible (e.g. permanent land take) or will last for the foreseeable future
(e.g. noise from generated road traffic). The durations of temporary construction
effects are listed as follows:
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 short-term: less than one year;

medium-term: one to five years; and

long-term: greater than five years.

5.3.22 Where environmental effects are episodic, the frequency of the events is
predicted.

Assessment of Effects
5.3.23 The EIA Regulations 2009 state that the purpose of an EIA is to describe “the
likely significant effects of the development on the environment, which should
cover the direct effects and any indirect, secondary, cumulative, short, medium
and long term, permanent and temporary, positive and negative effects of the
development, resulting from:

(a) the existence of the development;

(b) the use of natural resources;

(c) the emission of pollutants, the creation of nuisances and the

elimination of waste, and the description by the applicant of the forecasting
methods used to assess the effects on the environment”.

5.3.24 With respect to consideration of effects in the context of the NPSs, paragraph
4.2.11 of NPS EN-1 states that:

“In this NPS and the technology-specific NPSs, the terms ‘effects’, ‘impacts’ or
‘benefits’ should be understood to mean likely significant effects, impacts or
benefits.”

5.3.25 Effects that are not likely to be significant are not required to be assessed or
included in the ES.

5.3.26 Each topic assessment has been carried out using the significance levels and
associated criteria derived from relevant guidance for that topic and these are set
out in the methodology section of each assessment topic chapter. Where
possible topic chapters have adopted the approach and terminology set out
below.
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 Determining Significance
5.3.27 Having described an effect on the environment or a specific receptor the EIA
process requires a level of significance to be assigned to that effect.

5.3.28 That may be determined by a number of factors including industry and

professional guidance, codes of practice, advice from statutory consultees and
other stakeholders, as well as expert judgement of the EIA practitioners
employed on the Scheme. Best practice however advocates that overall, where
and whenever possible, a three stage approach should be adopted:

assigning an environmental value to (or sensitivity of) a resource or receptor;

assigning a level of impact or effect[1]; and

assigning a level of significance.

5.3.29 With regard to the Scheme and its location within PCNP it is important to
recognise the purposes of PCNP and in particular its special qualities. In
summary, despite the largely industrial nature of the Waterway, the special
qualities are its “diversity of landscape; coastal scenery and islands; remoteness,
tranquility, remoteness and wildness; wildlife; access; distinctive settlement
character; the archaeology and the historic environment; cultural heritage, and
the diversity of geology” (National Park Management Plan 2009-2013).

5.3.30 Consequently for this EIA, the third stage, assigning a level of significance, is a
two phase process, the first of which is in accordance with the general
methodology described below, whilst the second phase allows for the
moderation of an assigned level of significance in light of the special qualities
and the purposes of PCNP.

1 The terms ‘impact’ and ‘effect’ are often used interchangeably. In this ES ‘impact’
means a consequence of the proposed scheme without mitigation in place whereas ‘effect’
means a consequence with mitigation measures in place.
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 Stage 1 - Assigning environmental value or sensitivity
5.3.31 Table 5.1 below (reproduced from the UK Government’s Design Manual for
Roads and Bridges (DMRB) 11.2.5, Table 2.1) provides a generic five point
scale for assigning environmental value or sensitivity.

Table 5.1: Generic Definitions of Sensitivity or Value

Value / Typical Descriptors

Sensitivity

Very High Very high importance and rarity, international scale and very
limited potential for substitution.

High High importance and rarity, national scale, and limited potential
for substitution.

Medium High or medium importance and rarity, regional scale, limited

potential for substitution.

Low Low or medium importance and rarity, local scale.

Negligible Very low importance and rarity, local scale.

Stage 2 - Assigning level of impact

5.3.32 Table 5.2 below (reproduced from DMRB 11.2.5, Table 2.2) provides a generic
five point scale for assigning magnitude of impact.

Table 5.2: Generic Definitions of Magnitude

Magnitude Typical Descriptors

Major Loss of resource and/or quality and integrity of resource;

severe damage to key characteristics, features or elements
(Adverse).

Large scale or major improvement of resource quality;

extensive restoration or enhancement; major improvement
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 of attribute quality (Beneficial).

Moderate Loss of resource, but not adversely affecting the integrity;

partial loss of/damage to key characteristics, features or
elements (Adverse).

Benefit to, or addition of, key characteristics, features or

elements; improvement of attribute quality (Beneficial).

Minor Some measurable change in attributes, quality or

vulnerability; minor loss of, or alteration to, one (maybe
more) key characteristics, features or elements

(Adverse).

Minor benefit to, or addition of, one (maybe more) key

characteristics, features or elements; some beneficial
impact on attribute or a reduced risk of negative impact
occurring (Beneficial).

Negligible Very minor loss or detrimental alteration to one or more

characteristics, features or elements (Adverse).

Very minor benefit to or positive addition of one or more

characteristics, features or elements (Beneficial).

No change No loss or alteration of characteristics, features or

elements; no observable impact in either direction.

5.3.33 It should be noted that the word “integrity” as used in the typical criteria
descriptor for an impact of moderate magnitude (Table 5.2 above) may seem
ambiguous, as in common usage a partial loss appears inconsistent with
retaining integrity. An effect on integrity is also a key element in determining
significance of effect on a European site or species in the HRA process (see
Section 1.8). It is therefore important to be clear about how an effect on integrity
is used in determining levels of significance within the EIA process.

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5.3.34 DMRB 11.4.1 which provides guidance on the HRA process for highway projects
defines integrity as ”the coherence of its ecological structure and function, across
its whole area, that enables it to sustain the habitat, complex of habitats and/or
the levels of populations of the species for which it was classified” (paragraph
3.7). It is in this context that the term “integrity” is used within this ES.

Stage 3 - Assigning a level of significance

5.3.35 Where sufficient information exists to value a receptor and to understand the
magnitude of the effect (as above), the assessment methodology often uses an
assessment matrix to determine the level of significance of the effect. Table 5.3
below (reproduced from DMRB 11.2.5, Table 2.4) sets out an assessment matrix
to determine the level of significance of the effect.

5.3.36 In this approach, the significance of the effect, in broad terms, is determined by a
combination of the value of the receptor being affected and the magnitude or
level of the effect. This is the case for example with ecological and cultural
heritage designations which have clear relative values (e.g. a site designated at
a national level is valued more highly than one that is undesignated or
designated at a local level).

5.3.37 In the absence of recognised assessment methodology general levels of

significance using criteria defined in DMRB Volume 11 – Environmental
Assessment (2009) and elsewhere have been employed.

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 Table 5.3: Assessment Matrix

Value / Magnitude of Impact

Sensitivity No Negligible Low Medium High
Change

Negligible Negligible Negligible Negligible Negligible / Minor

/ Minor Minor

Low Negligible Negligible Negligible/ Minor Minor/Moderate

/ Minor Minor

Medium Negligible Negligible Minor Moderate Moderate/Major

/ Minor

High Negligible Minor Minor/ Moderate/ Major/Substantial

Moderate Major

Very high Negligible Minor Moderate/ Major/ Substantial

Major Substantial

Stage 3 continued – Interpretation of significance criteria

5.3.38 In determining levels of significance, recognised assessment methods for
specific topics have been used where appropriate and as described above, but
in the absence of these, general levels of significance have been used as set out
below. Guidance for the determination of such levels is minimal and those
identified below have been informed by draft guidance contained within the
DCLG’s ‘Environmental Impact Assessment: A guide to good practice and
procedures, a consultation paper’ (June 2006). The general significance criteria
are:

Substantial Significance – effects represent key factors in the decision

making process. They are generally, but not exclusively, associated with
sites and features of national importance and resources/features which are
unique and which, if lost, cannot be replaced or relocated;

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 Major Significance – effects of the development of greater than local scale
and, if adverse, are potential concerns to the project depending upon the
relative importance attached to the issue during decision making;

Moderate Significance – effects of the development that may be judged to

be important at a local scale but are not likely to be key decision making
issues. Nevertheless, the cumulative effect of such issues may lead to an
increase in the overall effects on a particular area or on a particular resource;

Minor Significance – effects of the development that may be raised as a

local issue but which are of low importance in the decision making process.

5.3.39 These levels of significance apply to both adverse and beneficial effects. A
further category of ‘Negligible’ is used to describe effects which are of such low
importance that they are considered not to be important to the decision making
process.

5.3.40 For some topics where it is very difficult to value an asset and/or quantify the
magnitude of the effect (e.g. socio economics) a simple descriptor - beneficial,
neutral or adverse is used to describe the significance of the effect.

5.3.41 In terms of NSIPs, and in the context of the EIA Regulations 2009 (Part 1 of
Schedule 4), material effects are those where the significance of the effect is
‘moderate’ or greater.

5.4 Alternatives
5.4.1 The EIA Regulations 2009 (Part 2 of Schedule 4) require the inclusion in an
environmental statement of:

“An outline of the main alternatives studied by the applicant and an indication of
the main reasons for the applicant’s choice, taking into account the
environmental effects.” (paragraph 27).

5.4.2 Alternatives as part of the design evolution and development of the Scheme are
described in Chapter 3.

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5.5 Interrelationships and cumulative effects
5.5.1 The EIA Regulations 2009 (Part 1 of Schedule 4) require 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 interrelationship between the above factors”
(paragraph 19).

5.5.2 Inter-relationships between topics on specified receptors are considered in

Chapter 16 using topic specific information set out in the preceding assessment
topic chapters (Chapters 6 to 15).

5.5.3 The EIA Regulations 2009 (Part 1 of Schedule 4) also require the EIA to
consider cumulative effects:

“a description of the likely significant effects of the development on the

environment, which should cover the direct effects and any indirect, secondary,
cumulative, short, medium and long-term, permanent and temporary, positive
and negative effects of the development, resulting from:

(a) the existence of the development;

(b) the use of natural resources;

(c) the emission of pollutants, the creation of nuisances and the elimination of
waste,

and the description by the applicant of the forecasting methods used to assess
the effects on the environment.” (paragraph 20).

5.5.4 According to the Guidelines for Cumulative Effects Assessment prepared for the
EC by Hyder in 1999, cumulative effects are defined as “impacts that result from
incremental changes caused by other past, present, or reasonably foreseeable
actions together with the project”.

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5.5.5 The Scoping Opinion advises that major developments that should be
considered for the cumulative effects assessment should be identified within the
following categories:

built and operational development;

development under construction;

application(s) permitted but which are not yet implemented;

submitted applications not yet determined, and which, if permitted, would

affect the proposed development in the Scoping Request; and

development identified in the adopted and emerging development plan (with

appropriate weight being given as they move closer to adoption) recognising
that much information on any relevant proposals will be limited.

5.5.6 A list of other developments has been compiled in part through consultation with
PCNPA and the CCW (now part of NRW) (Appendix 5.6). The locations of those
developments are shown on Figure 5.1. The list includes schemes within the
area covered by the PCNPA and PCC, and, in respect of wind farms, within the
wider area of south west Wales and north Devon that are considered likely to be
present once the CHP Plant is operational in 2017.

5.5.7 It should be noted that not all of the developments listed in Appendix 5.6 would
necessarily have a cumulative effect in respect of any particular assessment
topic. Where cumulative effects are potentially relevant, each assessment topic
chapter (Chapters 6 to 15) has determined which of the developments listed
should be considered. This matter is considered further in Chapter 16.

5.6 De-commissioning
5.6.1 The CHP Plant would have an operational life of approximately 20 years,
although the DCO being sought is not time-limited. Decommissioning of the
CHP Plant would be carried out in accordance with legislative requirements at
that time. However, if market conditions and/or electricity supply requirements at

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 that time indicate that it would be appropriate to extend the life of the CHP Plant,
then decommissioning could be deferred to a later date.

5.6.2 Decommissioning in 2037 or later is not an event that can be accurately

predicted due to changes in policy, legislation and technology. The assessment
of the decommissioning phase therefore is limited to how the design of the
Scheme and use of materials would enable a minimum of disruption to be
achieved and the restoration of the Main CHP Plant Site and other land used for
the purposes of the CHP Plant to its former use.

5.7 EIA Assumptions

5.7.1 The following assumptions have been made in undertaking the EIA:

The design, construction and operation of the CHP Plant will be in

accordance with the description given and the parameters set out in Chapter
4.

The potential environmental effects of the construction of the CHP Plant will
be controlled through the draft Code of Construction Practice (Document
1.23) referred to in Chapter 4. The draft CEMP (included in Appendix 4.2)
and inclusive management plans will, after consultation with NRW, be
submitted to and approved by the relevant planning authorities before
commencement of the authorised development.

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