1 introduction 1.1 terms of reference for this...

ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED

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1 INTRODUCTION

1.1 TERMS OF REFERENCE FOR THIS ENVIRONMENTAL IMPACT ASSESSMENT REPORT

This Environmental Impact Assessment Report (EIA Report) has been

prepared by Environmental Resources Management Ltd (ERM) on behalf of

Keadby Developments Limited (the Company). This EIA Report has been

prepared to support an application under section 36C of The Electricity Act

1989 in accordance with the requirements of The Electricity Generating

Stations (Variation of Consents) (England and Wales) Regulations 2013 (‘the

2013 Regulations’).

1.2 APPLICATION HISTORY OF THE KEADBY II PROJECT

On 10 September 1993, the Company were granted consent pursuant to

section 36 of the Electricity Act 1989 and a Direction under section 90 of the

Town and Country Planning Act 1990 providing for the construction and

subsequent operation of a 710 MW combined cycle gas turbine generating

station at Keadby, North Lincolnshire.

The section 36 consent was subsequently varied on 3 November 2016

pursuant to section 36C of the Electricity Act 1989 (and the 2013 Regulations)

and section 90(2ZA) of the Town and Country Planning Act 1990 (2016

Consent) to accommodate an increase in the electrical output of the plant, up

to 820 MW (the Consented Development).

1.3 THIS APPLICATION

The Company now seeks a further variation pursuant to section 36C of the

Electricity Act 1989 (and the 2013 Regulations) and section 90 (2ZA) of the

Town and Country Planning Act 1990, to increase the electrical output of the

Consented Development, up to 910 MW and to deliver a higher efficiency in

electricity generation (the Proposed Development). The Proposed

Development is also known as Keadby II; its location is shown on Figure 1.1.

It is anticipated that the design changes for the Proposed Development will not

result in the need for any material changes to the existing consent conditions.

The application submitted in relation to the 2016 Consent was supported by

an Environmental Statement (ES) that was prepared in accordance with The

Electricity Works (Environmental Impact Assessment) (England and Wales)

Regulations 2000 (‘the 2000 EIA Regulations’). An Environmental Impact

Assessment (EIA) has been undertaken to determine the likely significant

effects of the Proposed Development to the extent these differ from those

previously assessed in the ES. The EIA has been undertaken in accordance

with The Electricity Works (Environmental Impact Assessment) (England and

Wales) Regulations 2017 (the ‘2017 Regulations’) which have come into force

since the 2016 Consent. The 2017 Regulations introduce several changes

from the 2000 Regulations and these are identified and discussed in Table

1.2.

Site Location

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In addition Regulation 17 of the 2017 Regulations requires:

(e) where the application is for a section 36 variation, the main respects

in which the developer thinks that the likely significant effects on the

environment of the development, as varied, will differ from those set out

in—

(i) any EIA report or environmental statement prepared in

connection with the application for the section 36 consent that it is

proposed be varied; and

(ii) if the section 36 consent has previously been varied by a

section 36 variation, any EIA report or environmental statement

prepared in connection with the application for that variation;

(f) a non-technical summary of the information referred to in sub-

paragraphs (a) to (e).

This EIA Report focusses on the design changes to the Consented

Development and on receptors and resources that will be potentially affected

(see Table 1.1 for the key design changes). It also addresses matters arising

from changes in legislation (most notably the introduction of the 2017

Regulations implementing the 2014 EIA Directive), updates the baseline

where appropriate and reviews other schemes that have emerged from the

planning process in terms of the potential for cumulative effects. In order for

the EIA Report to be proportionate it clearly sets out (Chapter 3) where the

assessment of effects relating to the Consented Development remains valid.

A copy of the ES can be found in Annex D.

Table 1.1 Comparison of Key Design Changes between the Consented

Development and the Proposed Development

Consented Development Proposed Development

Output Capacity

820 MW 910 MW

Dimensions of Main Structures of the Proposed Development

Multishaft configuration presented

Note: The corresponding building sizes

presented in the ES contained some minor

errors corrected here. The nature of the error

was by omission and labelling and not in the

dimensions actually used in the assessment.

Multishaft configuration presented

Note: the locations of some of the buildings

have changed slightly within the application

boundary.

Building appearance

The Consented Development gas turbine hall

and steam turbine hall were to be constructed

of clad steel with brickwork to the lower level.

The Proposed Development gas turbine hall

and steam turbine hall are to be constructed

of clad steel down to ground level.


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Consented Development Proposed Development

Supplementary firing

The Consented development included

supplementary firing i.e. combustion of natural

gas directly into the boiler inlet duct to provide

additional steam.

The Proposed Development will not use

supplementary firing as part of the power

generation process.

Commissioning duration

The commissioning phase for the Consented

Development was approximately 26 weeks.

The commissioning phase for the Proposed

Development has increased to 12 months.

Abnormal Indivisible Loads (AILs)

A maximum of 10 AILs will be required for the

Consented Development and will route

through the village of Ealand.

A higher number of AIL will be required for the

Proposed Development, although the number

routed through the village of Ealand over the

construction phase will remain the same (i.e.

10 AIL deliveries). All additional AIL deliveries

will take an alternative route.

1.4 POLICY AND LEGISLATION OVERVIEW

A comprehensive overview of the planning policy context relevant to the

Proposed Development is provided in Chapter 3 of the Consented

Development ES (see Annex D).

Since issue of the 2016 Consent, the principle legislative change of relevance

to the given application is the implementation of the 2017 EIA Regulations

which came into force transposing Directive 2014/52/EU (the ‘2014 Directive’)

into UK law. The 2017 Regulations were brought into force on the 16th May

2017. Although on the face of it the 2014 Directive introduced a number of

new matters to be addressed within an EIA, many aspects of these had been

routine elements of EIA in the UK for a number of years.

Table 1.2 sets out the new requirements and comments on them in the

context of this EIA Report.

Table 1.2 Implications of the 2014 Directive

EIA Directive 2014 Comment

Scoping Opinion

Where a scoping opinion is requested from

the decision maker the EIA Report will need to

be based on the response (Art.5 (1)).

A scoping opinion was sought and provided

for within the ES. Although this preceded the

implementation of the 2017 Regulations, the

ES was based on the response.

A scoping opinion has not been sought

specifically in relation to this EIA Report;

however the information contained herein is

based on the original Scoping Opinion, the

consultation comments in relation to the ES

and comments received from the pre-

application consultations undertaken with the

Council, BEIS, local communities and the

statutory consultees with specific regard to

this EIA Report.

Content

The 2014 Directive includes clear

requirements for content on a number of

areas, including (Annex IV):

impacts on biodiversity, climate change,

landscape and human health;

vulnerability to accidents and disasters

All these matters were fully addressed in the

ES and are supplemented as necessary within

this EIA Report


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EIA Directive 2014 Comment

and the environmental consequences of

such.

Alternatives

The 2014 Directive requires at Art.5 (1): “a

description of the reasonable alternatives

studied by the developer”. Alternatives

include: project design, technology, location,

size and scale (Annex IV, para.2).

Reasonable alternatives were considered to

the extent appropriate in the ES for the

Consented Development and those

alternatives apply equally to the Proposed

Development. See Section 2.7 for an overview

of the alternatives.

Uncertainty

The main uncertainties associated with

forecasting methods must be described.

The role of uncertainty in assessment was

addressed in the ES and also applied to this

EIA Report.

Cumulative effects

These have been defined as those arising

from the development with other existing and

approved developments.

The ES identifies cumulative schemes

following consultation with North Lincolnshire

Council and assesses their cumulative effects

with the Consented Development. This

assessment is updated for the purposes of the

Proposed Development.

Environmental management and

monitoring

In the event of consent for EIA development,

the 2014 Directive now includes requirements

for monitoring of implementation of mitigation

measures (Art.8a (4)).

Monitoring measures for the construction

phase are set out in the draft Construction

Environmental Management Plan (CEMP) in

the ES. Similar provisions will apply to the

Proposed Development along with operational

monitoring requirements to be set out in the

Environmental Permit and to be agreed with

the local planning authority regarding the

consent conditions.

Baseline, validity of data and evolution

The decision-maker must be satisfied that the

ES is “up to date” before determining the

application (Art.8a). There is also a new

requirement to outline the likely evolution of

the baseline scenario in the absence of the

development, as far as this can be assessed

‘with reasonable effort’ on the basis of

available information and scientific knowledge.

Data sources are set out in the ES and have

been updated to the extent necessary for this

EIA Report. Natural evolution of the baseline

where relevant is addressed in Table 3.2.

EIA and HRA

Authorities must choose whether to combine

the EIA process with ‘appropriate

assessments’ under the European Habitats

Directives or simply co-ordinate the

assessments (Art.2 (a) (3)).

The ES and this EIA Report contain an

ecological impact assessment and a Habitat

Regulations Assessment.

Competence of Practitioners

The 2014 Directive introduces a need for EIAs

to be produced by ‘competent experts’.

The ES and this EIA Report have been

prepared by Environmental Resources

Management (ERM). ERM is a member of the

Institute of Environmental Management and

Assessment’s (IEMA’s) EIA Quality Mark, a

scheme which allows organisations to make a

commitment to excellence in their EIA

activities, and have this commitment

independently reviewed.

1.5 REPORT CONTENT AND STRUCTURE

This EIA Report presents the outcome of the EIA in respect of the Proposed

Development building on the desktop studies, field surveys and assessments

conducted for the Consented Development. It is a summary of the EIA studies

carried out and is presented to accompany the given Section 36C variation

application.


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This EIA Report objectively records the assessment of likely significant effects

of the Proposed Development on the environment, including direct effects and

any indirect, secondary, cumulative, short, medium and long-term, permanent

and temporary, positive and negative effects (1), resulting from:

the existence of the Proposed Development;

the use of natural resources; and

the emission of pollutants, creation of nuisances and waste.

Table 1.3 shows the location within this EIA Report and the ES of pertinent information to satisfy the requirements set out in Schedule 4 of the 2017 Regulations. The general approach to the EIA is described in Section 1.6. The EIA Report

scope, including where the ES remains valid or supplementary information is

provided in the EIA Report, is presented in Chapter 3.

1.6 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMENT

This section provides an overview of the broad principles of the methodology

adopted within this EIA Report. A comprehensive description of the approach

to the EIA can be found in Chapter 4 of the ES (see Annex D).

This EIA Report presents a comparison of the Proposed Development and its

likely significant effects, when compared to those attributable to the

Consented Development. An informal scoping exercise has been undertaken

in the preparation of this ES Report and is set out in Chapter 3. In addition

Chapter 3 highlights topics where the likely significant effects have been

reassessed due to changes in the project design. For those topics where no

further assessment is required justification is provided and an overview of

impacts and effects as presented in the Consented Development ES is

provided. For those topics where additional assessment is required a full and

thorough assessment has been carried out.

Figure 1.2 sets out the approach to assessment of likely significant effects that

may arise from the Proposed Development. This approach has been applied

in undertaking the EIA for the Consented Development as well as the

Proposed Development, as part of the Section 36C variation application.

(1) Transboundary effects are scoped out.

Table 1.3 Contents of the EIA Report

Relevant

Paragraph of

Schedule 4 to

the EIA

Regulations

Required Information Report Reference

[Paragraph 1]

Description of the proposed development, including in particular:

a description of the location of the proposed development;

a description of the physical characteristics of the whole development

including, where relevant, requisite demolition works, and the land-use

requirements during the construction and operational phases;

a description of the main characteristics of the operational phase (in

particular any production processes), for instance, energy demand and

energy used, nature and quality of the materials used and natural

resources; and

an estimate, by type and quantity, of expected residues and emissions

(such as water, air and soil and subsoil pollution, noise, vibration, light, heat,

radiation) and quantities and types of waste produced during the

construction and operation phases of the proposed development.

This EIA Report provides a description of the location of the Proposed

Development (Figure 1.1) alongside a description of the physical

characteristics of the whole development and main characteristics of the

operational phase (see Chapter 2: Project Description). Types and

quantities of waste are also addressed in Chapter 2: Project Description.

The changes in project design and how these may affect the estimates

of various emissions have been considered in detail in Table 3.1. There

are no material changes to the project design during construction and so

construction emissions remain reported in the ES (see Annex D),

however, operational emissions to air are reassessed in this EIA Report

(see Chapter 4). See Table 3.1 for further detail on the EIA Report

Scope.

[Paragraph 2] A description of the reasonable alternatives (for example in terms of

development design, technology, location, size and scale) studied by the

developer, which are relevant to the proposed development and its specific

characteristics, and an indication of the main reasons for selecting the chosen

option, including a comparison of the environmental effects.

This EIA Report provides a description of the alternatives considered

and the main reasons for selection of the chosen option. See Section

2.7 for a description of the alternatives.

[Paragraph 3]

A description of the relevant aspects of the current state of the environment

(baseline scenario) and an outline of the likely evolution thereof without

implementation of the proposed development as far as natural changes from the

baseline scenario can be assessed with reasonable effort on the basis of the

availability of environmental information and scientific knowledge.

The ES provides a comprehensive description of the baseline scenario

for all topics that may be affected by the Project. However, this EIA

Report provides updated baselines, where appropriate, to those topics

that are being reassessed (see Table 3.1 for EIA Report Scope and

Chapters 4 and 5).

An outline of the likely natural evolution of the baseline without

implementation of the Proposed Development, where possible, is

provided in Table 3.2.

[Paragraph 4] A description of the factors specified in regulation 4(2) likely to be significantly affected by the development: population, human health, biodiversity (for example fauna and flora), land (for example land take), soil (for example organic matter, erosion, compaction, sealing), water (for example hydromorphological changes, quantity and quality), air, climate (for example greenhouse gas emissions, impacts relevant to adaptation), material assets, cultural heritage, including

The ES provides a comprehensive description of the baseline scenario.

See the following chapters in Annex D:

Chapter 6 - Land and water (including soils);

Chapter 7 - Ecology and nature conservation (including fauna and flora);

Chapter 8 - Noise and vibration;

Relevant

Paragraph of

Schedule 4 to

the EIA

Regulations


architectural and archaeological aspects, and landscape.

Chapter 9 - Air quality;

Chapter 10 - Archaeology and cultural heritage;

Chapter 11 - Traffic and transport;

Chapter 12 - Socio-economic characteristics;

Chapter 13 - Landscape and visual.

However, this EIA Report provides updated baselines, where

appropriate, to those topics that are being reassessed (see Table 3.1 for

EIA Report Scope and Chapters 4 and 5). Additional information on

landscape and visual impacts are provided in Figure 3.1. Land take is

shown in Figure 2.1.

[Paragraph 5] A description of the likely significant effects of the proposed development on the environment, resulting from, inter alia: (a) the construction and existence of the development, including, where relevant, demolition works; (b) the use of natural resources, in particular land, soil, water and biodiversity, considering as far as possible the sustainable availability of these resources; (c) the emission of pollutants, noise, vibration, light, heat and radiation, the creation of nuisances, and the disposal and recovery of waste; (d) the risks to human health, cultural heritage or the environment (for example due to accidents or disasters); (e) the cumulation of effects with other existing and/or approved projects, taking into account any existing environmental problems relating to areas of particular environmental importance likely to be affected or the use of natural resources; (f) the impact of the project on climate (for example the nature and magnitude of greenhouse gas emissions) and the vulnerability of the project to climate change; (g) the technologies and the substances used.

The description of the likely significant effects on the factors specified in

regulation 4(2) should cover the direct effects and any indirect, secondary,

cumulative, transboundary, short-term, medium-term and long-term, permanent

and temporary, positive and negative effects of the development. This

description should take into account the environmental protection objectives

established at Union or Member State level which are relevant to the project,

including in particular those established under Council Directive 92/43/EEC(a)

and Directive 2009/147/EC(b).

The ES provides a comprehensive description of the likely significant

effects of the Consented Development on the environment. Table 3.1 in

this EIA Report assesses the validity of the findings of the ES in relation

to the changes in project design presented in the EIA Report. For many

topics there are no material changes that would affect the significance of

the assessment in the ES and as such the ES remains valid. Where the

assessment of likely significant effects may be different to that assessed

in the ES, new information is presented in this EIA Report (see Chapter

4: Air quality and Chapter 5: Ecology and Nature Conservation).

Table 3.1 also provides supplementary information to fulfil the

requirements of the 2017 EIA regulations, as indicated within the table.

[Paragraph 6] A description of the forecasting methods or evidence, used to identify and assess the significant effects on the environment, including details of difficulties

The ES provides a comprehensive description of the approach to the

EIA (see Chapter 4 of the ES – Annex D). Further topic specific details

Relevant

Paragraph of

Schedule 4 to

the EIA

Regulations


(for example technical deficiencies or lack of knowledge) encountered compiling the required information and the main uncertainties involved.

are provided in ES Chapters 6 to 13 and Chapters 4 and 5 of this EIA

Report. A summary of the approach is provided in Figure 1.2 below.

Uncertainty, where relevant, is dealt with within the topic assessment

chapters of the ES and this EIA Report.

[Paragraph 7]

A description of the measures envisaged to avoid, prevent, reduce or, if

possible, offset any identified significant adverse effects on the environment and,

where appropriate, of any proposed monitoring arrangements (for example the

preparation of a post-project analysis). That description should explain the

extent, to which significant adverse effects on the environment are avoided,

prevented, reduced or offset, and should cover both the construction and

operational phases.

A description of the measures proposed to avoid, prevent and reduce

any identified significant adverse effects as well as monitoring and the

effect of implementing the proposed mitigation measures are provided in

the topic assessment chapters of the ES. A summary is provided in

Chapter 15 of the ES (See Annex D to this EIA Report). Where these

measures have been updated due to changes in project design

considered in this variation they are presented in Chapter 4: Air quality

and, Chapter 5: Ecology and Nature Conservation as well as Chapter 7,

which provides a summary of the updated mitigation measures.

[Paragraph 8] A description of the expected significant adverse effects of the development on the environment deriving from the vulnerability of the development to risks of major accidents and/or disasters which are relevant to the Proposed Development. Relevant information available and obtained through risk assessments pursuant to EU legislation such as Directive 2012/18/EU(c) of the

European Parliament and of the Council or Council Directive 2009/71/Euratom(d) or UK environmental assessments may be used for this

purpose provided that the requirements of this Directive are met. Where appropriate, this description should include measures envisaged to prevent or mitigate the significant adverse effects of such events on the environment and details of the preparedness for and proposed response to such emergencies.

The Proposed Development is not within the consultation zone for any

COMAH site and therefore is not at risk of being affected by a major

accident at one of these sites.

Flood risk has been addressed in the design levels of critical operational

infrastructure and the Proposed Development will be provided with a

sustainable drainage system sized to cope with future changes due to

climate change (see Chapter 3 and Annex D).

An emergency situation and response plan will be developed for the

Proposed Development prior to construction and updated for operation.

A Hazard and Operability Study and Process Hazard Review (HAZOP)

will also be conducted prior to construction to consider sources of major

accidents as part of preparing such a plan.

[Paragraph 9]

[A non-technical summary of the information provided under paragraphs 1 to 8] A Non-technical Summary of all relevant information, including

information presented in the ES, is provided with this EIA Report.

[Paragraph 10] A reference list detailing the sources used for the descriptions and assessments

included in the environmental statement.

References are provided as footnotes in each chapter of the ES and EIA

Report, as relevant.

Predict Magnitude

A project’s impacts are quantified in terms of eg:

landtake area or habitat loss;

proportion of an ecological population exposed to impact;

change in noise levels at a residence;

pollutant exposure at a receptor; and

numbers of jobs generated in the local economy.

In predicting magnitude the effect of all the project mitigation in place (ie

committed to by the applicant) is taken into account.

For some impacts, especially noise, air and water pollution, significance is

assessed directly against numerical criteria and standards. For

exceedances, further mitigation must be incorporated by a project to

reduce the magnitude of the impact (and the significance of its effect).

For other impacts nominal levels of magnitude (eg small, medium, large)

may be adopted based on widely recognised factors such as: the nature

of a change (what is affected and how); its size, scale or intensity; its

geographical extent and distribution; its duration, frequency, reversibility

and, for unplanned events, likelihood of occurrence.

Some activities will result in changes to the environment that may be

immeasurable or undetectable or within the range of normal natural

variation. Such changes are assessed as having no impact or to be of

negligible magnitude and will not lead to significant effects.

Predict

Magnitude

Evaluate

Significance

Report

Effects

Identify

Impacts

Describe Baseline

Baseline data are collected to better understand the potentially most

important impacts and effects identified in scoping. Baseline data may

quantify existing exposure levels (eg for noise, air and water pollution),

identify vulnerable populations of animals or people, more clearly delineate

valued cultural property and ecosystem services etc.

Where a baseline aspect cannot be quantified then nominal levels of

importance, quality or value (low, medium, high) are assigned based on

widely accepted criteria in fields such as ecology, cultural heritage, landscape

and socioeconomic assessment. Inter-relationships between elements of the

baseline are identified.

Interact with Project Design

The EIA process interacts with a project design team to develop a basis for the

assessment (for example quantities of emissions, noise levels of equipment,

sizes of structures). The EIA process also interacts with design to assess

alternatives, ‘best available technology’ and mitigation options, especially

when after initial assessment some impacts may need to be further reduced.

Consult Stakeholders

Ongoing stakeholder consultation, post-scoping, is good practice in EIA and is

undertaken to refine the assessment and present preliminary findings to

stakeholders to elicit early responses and help make the Environmental

Statement as fit for purpose as possible.

Informed by high

level baseline,

project infor-

mation and con-

sultation with key

stakeholders

Project as

currently planned

with mitigation

incorporated

Compared

against standards

or looking at

magnitude in

combination with

affected re-

source/receptor

Increasing interaction with baseline studies, project design and stakeholders Identify Impact

The scoping process identifies the potentially most important/significant

impacts and effects (including secondary, indirect and cumulative) for the

assessment to address. This is done through a combination of:

looking at the nature of a project’s activities and the impacts they will

give rise to;

looking at a project’s environmental and social settings and their

aspects which are likely to be most sensitive/vulnerable to impacts

from the project;

applying professional understanding gained from the evidence base;

and

considering inputs from stakeholders through consultation.

Decisions are then made on which impacts and effects to assess or to

prioritise in the assessment (scoping in and scoping out) and how to

assess them (proposed methodology).

Evaluate Significance

In evaluating significance, the EIA process is seeking to inform regulators and stakeholders about the effects of

a project in a way that helps them make decisions on whether to approve it and allows them to develop

suitable conditions to attach to an approval. The evaluation of significance ideally demonstrates legal

compliance at least (eg compliance with quantified standards, avoidance of effects on legally protected

resources).

In the absence of quantified standards, significance can be evaluated through considering the magnitude of an

impact in combination with the importance/quality/value of the receptor or resource that is affected, also

considering the response (or sensitivity) of a resource or a receptor to a particular impact. Impacts/effects of

more than minor significance may warrant re-examination to see if an impact magnitude can be reduced

further. Different mitigation options may be examined and the reasons for selecting one and rejecting others

explained. Some impacts/effects that cannot be adequately mitigated may need to be addressed through the

consideration of offsets or compensation.

The evaluation process may go through more than one iteration of working with project design to develop

suitable mitigation and re-evaluating impacts and effects.

For some impacts and

effects further or

different mitigation

may need to be con-

sidered and the effect

re-evaluated

While the above provides a general framework for identifying impacts and assessing the significance of their effects, in practice the approaches and criteria applied vary across

different environmental and socio-economic topics.

Magnitude of Impact

Small Medium Large

High

Medium

Low

Sen

siti

vity

/Qu

alit

y/Im

po

rtan

ce o

f R

ece

pto

r/R

eso

urc

e

Not significant

Minor

Moderate

Major

Figure 1.2 Overview of the EIA Process


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1.7 COMPARISON BETWEEN THE PROPOSED DEVELOPMENT AND THE CONSENTED

DEVELOPMENT

In accordance with Regulation 17 paragraph (e) of the 2017 Regulations, one

purpose of the EIA is to provide information on the main respects in which the

Company considers that the likely significant effects on the environment of the

Proposed Development will differ from those described in the ES. The

conclusions of this comparison are presented in Chapter 8 of this EIA Report.

1 introduction 1.1 terms of reference for this...

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