for proposed energy from waste (efw) facility at … · • an incinerator bottom ash (iba)...

E.ON Energy from Waste

October 2010

EIA SCOPING REPORT FOR PROPOSED ENERGY FROM WASTE (EFW) FACILITY AT HARPER LANE, RADLETT E.ON ENERGY FROM WASTE UK LIMITED (EEW)

EIA Scoping Report, Harper Lane EfW October 2010


CONTENTS

EXECUTIVE SUMMARY ................................................................................................................................... 3

1 INTRODUCTION ..................................................................................................................................... 5

2 DESCRIPTION OF THE PROPOSED DEVELOPMENT........................................................................ 7

3 THE SITE AND ITS SETTING ................................................................................................................ 9

4 PROPOSED CONTENT OF THE EIA .................................................................................................. 14

DRAWINGS ..................................................................................................................................................... 44



EXECUTIVE SUMMARY

Hertfordshire County Council (HCC) needs a long term solution for the treatment of residual (left after recycling / composting) municipal waste. Although residents are currently recycling and composting around 46% of their household waste, this still leaves a significant tonnage of residual waste being sent to landfill, which is not sustainable for the future. To meet this requirement, HCC has identified Energy from Waste (EfW) as the preferred technology for its long term waste treatment solution and is undergoing a procurement process for which E.ON Energy from Waste (EEW) is one of two remaining bidders for HCC’s Joint Municipal Waste Management Contract (JMWMC). The solution proposed by EEW will be able to treat and dispose of up to 345,000 tonnes of residual municipal solid waste (MSW) per year over a 25 year contract period (up to 2039/40).

Lafarge’s Harper Lane Complex, in Radlett Hertfordshire, comprises an existing operational integrated minerals processing and distribution centre with permanent planning permissions for rail served aggregate storage and distribution, a coated roadstone plant, a readymix concrete plant, an aggregate and glass recycling centre and all necessary infrastructure.

EEW is preparing proposals for the development of an EfW Facility that will meet Hertfordshire County Councils’ MSW requirements. It is proposed to locate the EfW Facility centrally within the existing rail loop and provide additional infrastructure to facilitate delivery of a combined heat and power opportunities where possible.

The Harper Lane site is approximately 0.5km north of Radlett (measured from a central position), with the major settlements of Shenley (1.9km east), London Colney (2.3km northeast) and Brickett Wood (2.4km northwest). It is south of the M25 – east of the mainline railway.

The Harper Lane site is identified within the Hertfordshire Minerals and Waste Development Framework (Waste Site Allocations Issues and Preferred Options 2 November 2009) as a ‘Proposed Preferred Waste Area’ within St Albans District Council for waste uses.

The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 specify certain types of development for which an Environmental Impact Assessment (EIA) is mandatory (Schedule 1 Development). Waste Treatment Facilities are deemed to fall under Category 10 of Schedule 1 of the EIA Regulations. This identifies ‘waste disposal installations for the incineration or chemical treatment of non hazardous waste with a capacity exceeding 100 tonnes per day’ as Schedule 1 development. The Regulations require an EIA in every case for Schedule 1 development.

One of the initial stages of the EIA process is the early preparation of an EIA Scoping Report. This will identify, review and consider the environmental impacts of the proposed development to be addressed as part of the EIA accompanying the planning application. The formal request for an EIA Scoping Opinion is made to Hertfordshire County Council as the Waste Planning Authority. If EEW reaches preferred bidder status in Spring 2011, the company will undertake a full public consultation and engagement programme as part of the preparation of the planning application and Environmental Impact Assessment to be submitted in support of the proposed EfW facility at Harper Lane.



This document sets out:

• Preliminary details of the proposed ‘CHP enabled’ EfW development (i.e. a plant which recovers energy from the controlled processing of waste to generate electrical power, and in addition is designed with the potential to supply steam and hot water to on-site and neighbouring industrial, commercial, residential energy users);

• Details of the site and its surroundings;

• Details of the proposed content of the EIA, following initial consideration of the relevant environmental issues. These include:

1. Need and Alternatives

2. Traffic and Transportation

3. Air & Climate (including Human Health)

4. Landscape and Visual Impact

5. Ecology and Nature Conservation

6. Hydrology and Flood Risk

7. Hydrogeology and Ground Conditions

8. Noise and Vibration

9. Archaeology and Cultural Heritage

10. Amenity

11. Site Waste Management Plan

12. Socio-Economic Impact

13. Summary



1 INTRODUCTION

1.1.1 Hertfordshire County Council needs a long term solution for the treatment of residual municipal solid waste (MSW). The solution proposed by E.ON Energy from Waste (EEW) will be able to treat and manage up to 345,000 tonnes of municipal solid waste (MSW) per year over a 25 year contract period (up to 2039/40).

1.1.2 EEW’s proposed solution consists of an Energy from Waste (EfW) facility to be located at Lafarge’s Harper Lane complex in Radlett. This site already includes an existing operational integrated minerals processing and distribution centre with permanent planning permissions for rail served aggregate storage and distribution, a coated stone plant, a ready mix concrete plant, an aggregate and glass recycling centre and all appropriate infrastructure.

1.1.3 The site is currently owned freehold by Lafarge Aggregates Limited.

1.1.4 The proposed EfW Facility will be located centrally within the existing rail loop which occupies a strategic location, supported by major road networks. The Harper Lane site is approximately 0.5km north of Radlett (measured from a central position), with the major settlements of Shenley (1.9km east), London Colney (2.3km northeast) and Brickett Wood (2.4km northwest) – south of the M25 and east of the mainline railway.

1.1.5 In summary, EEW’s application will comprise:

• an EfW facility processing residual MSW;

• an integrated steam turbine-generator plant for power generation and infrastructure to enable Combined Heat and Power (CHP), with the potential to provide steam and hot water to on-site and neighbouring industrial, commercial and residential energy users;

• an Incinerator Bottom Ash (IBA) reprocessing and recycling area;

• a Visitor/Education Centre (integrated within the main plant building); and

• ancillary plant and equipment including air cooled condensers, flue gas cleaning, stack, residue silos, weighbridges, access points, internal roads, parking facilities, administrative office accommodation and associated landscaping.

1.1.6 The site is identified as falling within a Minerals Consultation Area (MCA) in the Hertfordshire Minerals Local Plan Review (2007), on the basis of its use as a rail aggregates depot.

1.1.7 The other documents of the Development Plan, which incorporate the saved Policies of the Hertfordshire Waste Local Plan 1999 and the St Albans City and District Local Plan Review 1994, show the site to be within the Green Belt.

1.1.8 The site is within an Area of Archaeological Significance under Policy 111 of the City and District Local Plan (site where planning may be subject to a recording condition under reference AS.R.37). It also lies within a Landscape Development Area under Policy 105 and is a ‘Notifiable Site’ (hazardous installation) under Policy 84B (reference NS.6) of the City and District Local Plan Review 1994. Neither policy 105 nor 84B have been saved under the transitional arrangement of the Planning and Compulsory Purchase Act 2004.

1.1.9 The Harper Lane site is currently identified within the Hertfordshire Minerals and Waste Development Framework (Waste Site Allocations Issues and Preferred Options 2 November 2009)



as a ‘Proposed Preferred Waste Area within St Albans District’ for future use as a Waste Transfer Station, Materials Recovery Facility (existing use) or for inert waste recycling.

1.1.10 A proposed EfW facility of this size and nature is deemed to fall under category 10 of Schedule 1 of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (EIA Regulations thereafter). This identifies “Waste disposal installations for the incineration or chemical treatment (as defined in Annex IIA to Council Directive 75/442/EEC under heading D9) of non hazardous waste with a capacity exceeding 100 tonnes per day” as Schedule 1 development. The EIA Regulations require an EIA in every case for schedule 1 development. An EIA will therefore be carried out to access the environmental impacts of the proposed development. The resulting Environmental Statement (ES) will be submitted alongside the planning application for the proposed development.

1.1.11 Regulation 10(1) of the EIA Regulations provides for someone who is making an EIA application to ask the relevant planning authority to state in writing their opinion on the information to be provided in the Environmental Statement.

1.1.12 Although not legally required by the EIA Regulations, scoping is an important facet of an EIA. This importance was highlighted in para. 2.2 of the Department of the Environment’s Good Practice Guide 24, which states:

“Defining the scope is one of the most critical parts of an EIA in that it sets the context for what follows. If the scope is defined too narrowly, some critical area of uncertainty or adverse effect may emerge late in the day. Decisions on the shape of the project may then be too far advanced to allow for any real change. On the other hand, if the scope of the work is too loosely defined, then much time, effort and cost may be spent on pursuing unnecessary detail”.

1.1.13 This EIA Scoping Report has been prepared to assist with the early identification of the environmental and other impacts of the proposed development that will need to be addressed in the EIA and preliminary scheme design work. The scoping process will ensure that a full and robust EIA is undertaken and appropriate mitigation measures are built into the detailed design of the EfW facility.

1.1.14 EEW is currently one of two remaining bidders for HCC’s Joint Municipal Waste Management Contract (JMWMC). If EEW reaches preferred bidder status in Spring 2011, the company will undertake a full public consultation and engagement programme as part of the preparation of the planning application and Environmental Impact Assessment to be submitted in support of the proposed EfW facility at Harper Lane.



2 DESCRIPTION OF THE PROPOSED DEVELOPMENT

2.1 Proposal

2.1.1 The key details of the proposed EfW Facility are provided below. The content of this chapter reflects architectural or technical data available at the time of its submission. At this scoping stage, the design is still being formulated and may be amended as the result of issues identified through the Scoping and EIA processes.

2.1.2 EEW propose to locate the proposed EfW facility at Lafarge’s Harper Lane Complex, which already includes an existing operational integrated minerals processing and distribution centre producing a wide range of building and construction materials. There are permanent planning permissions for rail served aggregate storage and distribution, a coated stone plant, a readymix concrete plant, a recycling centre for inert materials and the appropriate infrastructure. Plan 1 ‘Location Plan’ show the location of the proposed EfW Facility. Plan 2 ‘Indicative Planning Application Area’ provides the red line boundary for the purposes of this Scoping Report, which includes the main proposed EfW facility as well as any ancillary developments, including the Incinerator Bottom Ash (IBA) treatment area and the access/egress arrangements to the facility from the adopted highway boundary which are currently being finalized. It is intended that the access point for the EfW facility will be constructed onto Harper Lane and accommodated on land within the ownership and control of Lafarge. The application boundary may be refined and reduced at a later stage when the access is confirmed and the planning application is submitted. An area, shown hatched dark red on Plan 2, indicates the proposed location of the EfW facility.

2.1.3 In summary, EEW’s application will comprise:

• an EfW facility processing residual MSW

• an integrated steam turbine-generator plant for power generation and infrastructure to enable Combined Heat and Power (CHP), with the potential to provide steam and hot water to on-site and neighbouring industrial, commercial and residential energy users

• an Incinerator Bottom Ash (IBA) reprocessing and recycling area.

• a Visitor/Education Centre (integrated within the main plant building).

• ancillary plant and equipment including air cooled condensers, flue gas cleaning, stack, residue silos, weighbridges, access points, internal roads, parking facilities, administrative office accommodation and associated landscaping.

2.1.4 The development of the proposed EfW facility at the Harper Lane would be co-located with the existing Lafarge integrated minerals processing and distribution centre. EEW will seek to develop their waste recycling operations so they are fully integrated with the Lafarge on-site operations to minimise the potential impact of the development both during construction and operation of the EfW facility.

2.1.5 The following site specific proposals have been identified for the proposed EfW development:

• Construction Phase & Transport – The opportunity for certain construction materials for the proposed EfW development to be delivered using the existing rail link. Building materials recycled on site will also be used within the development where appropriate.



• Combined Heat and Power - The potential to provide steam and hot water to existing on site uses as well as other nearby industrial, commercial and domestic energy users. The proposed facility will meet the criteria specified for a waste “recovery” facility under the Waste Framework Directive.

• Incinerator Bottom Ash (IBA) - Recycling and reprocessing the IBA material on site to be integrated into the current recycling operations of Lafarge.

2.1.6 The EfW facility will include two weighbridges controlled by a single gatehouse and parking for 40 vehicles.

2.1.7 The number of vehicle movements associated with the proposed development is currently being assessed. The EfW facility will be served by Refuse Collection Vehicles (RCVs) and container vehicles bringing waste from Waste Transfer Stations within Hertfordshire. Further HGVs will service the technical components of the EfW Facility (e.g. bringing in lime and other consumables). These vehicle movements are generally spread across the working day. Other traffic movements will be associated with staff and visitors to the site.

2.1.8 The proposed EfW facility will employ approximately 52 staff.

2.1.9 The proposed facility would become operational during 2015.



3 THE SITE AND ITS SETTING

3.1 Introduction

3.1.1 The proposed EfW facility will be located at Lafarge’s Harper Lane complex, which comprises an operational integrated minerals processing and distribution centre with permanent planning permissions for rail served aggregate storage and distribution, a coated roadstone plant, a ready mix concrete plant and an aggregate and glass recycling centre.

3.1.2 The EfW Facility will be located centrally within the existing rail loop and occupies a strategic location, supported by major road networks. The Harper Lane site is located approximately 0.5km north of Radlett (measured from a central position), with the major settlements of Shenley (1.9km east), London Colney (2.3km northeast) and Brickett Wood (2.4km northwest) ) – south of the M25 and east of the mainline railway.

3.2 Planning History and Planning Status

3.2.1 The Site is identified as falling within a Minerals Consultation Area (MCA) with a 250m buffer zone in the Hertfordshire Minerals Local Plan Review (2007), on the basis of its use as a rail aggregates depot.

3.2.2 The other documents of the Development Plan, which comprise the saved Policies of the Hertfordshire Waste Local Plan 1999 and the St Albans City and District Local Plan Review 1994; show the Site within the Green Belt.

3.2.3 The site is within an Area of Archaeological Significance under Policy 111 of the City and District Local Plan (site where planning may be subject to a recording condition under reference AS.R.37). The site also lies within a Landscape Development Area under Policy 105 and is a ‘Notifiable Site’ (hazardous installation) under Policy 84B (reference NS.6) of the City and District Local Plan Review 1994. Both policies 105 and 84B have not however been saved under the transitional arrangement of the Planning and Compulsory Purchase Act 2004.

3.2.4 The Harper Lane complex comprises of an integrated minerals processing and distribution centre with permanent planning permissions for rail served aggregate storage and distribution, a coated roadstone plant, a ready mix concrete plant and an aggregate and glass recycling centre.

3.2.5 Mineral extraction activities have been taking place since the late 19th century, with the main Harper Lane Quarry starting during the 1930’s. The quarry was fully established by 1970, which included an operational asphalt plant established in January 1967, and rail fed assets were introduced during the 1980’s. The planning consent granted in February 1985 for the erection of four storage silos and a chimney effectively replaced the first coated stone plant; approximately 400,000 tonnes of coated stone are produced annually from this plant.

3.2.6 The mineral quarrying and associated restoration was completed in the 1990’s. The ready mix concrete plant had been granted temporary planning permissions, which were superseded by a permanent consent in July 2007 and allowed the production of approximately 55,000m3 tonnes of product per year. Planning permission was also granted in May 2002 for the recycling of construction and demolition waste and glass for use as secondary aggregate.



3.2.7 A list of the most relevant planning consents associated with the Harper Lane Complex is provided below:

• C/0370-51 dated 30 October 1951 – winning and working of sand and gravel;

• W1231-66 dated 31 January 1967 – manufacture of coated road materials;

• 5/1387-74 dated 23 June 1975 for the construction of a railway siding to aggregate depot;

• 5/1257-75 dated 05 January 1976 for the construction of a railway siding to aggregate depot;

• 5/1604-84 dated 18 February 1985 for the erection of four silos and chimney;

• 5/0215-98 dated 24 May 1999 for the recycling of construction and demolition glass;

• 5/1343-01 dated 10 July 2007 – full planning consent for the ready mixed concrete plant; and

• 5/2598-08 (CM117) dated 19 March 2009 - erection and Operation of a Replacement Coated Stone Plant, Erection and Operation of Ancillary Facilities and Relocation of Existing Ready Mixed Concrete Plant.

3.2.8 Of these consents, glass recycling activities, permitted in 1999 (consent not. 5/0215-98 dated 24 May 1999) are specifically relating to the planning application site, within the railway loop area of the overall Harper Lane Complex.

3.3 Transport Issues

3.3.1 With respect to waste arisings, the site is served by major road networks. The Harper Lane site is located approximately 0.5km north of Radlett, with the settlements of Shenley (1.9km east), London Colney (2.3km northeast) and Brickett Wood (2.4km northwest).

3.3.2 The site is accessed from Harper Lane (B556), which has junctions with Watling Street (A5183) and Shemleybury approximately 600m (southwest) and 1.7km (north east) of the Harper Lane site respectively. The ‘Bell Roundabout’ (Junction 22 of the M25) is located approximately 3km north east of the site and allows further access to the strategic road network. On a wider scale the county has over 3000 miles of road network including a number of trunk roads running through it or on its borders, in particular, the M25, M1, A414 (key East-West route across the county) and A10.

3.3.3 The Lafarge Depot has an extant consent for the operation of a Coated Stone Plant, Ready Mixed Concrete Plant and ancillary facilities with operations benefitting from 24 hour working. The rail loop is used by Lafarge to import aggregate for processing at the Harper Lane Depot.

3.3.4 Under Planning Permission No:5/2596-08 (CM0117) “Application for the Erection and Operation of a Replacement Coated Stone Plant, Erection and Operation of Ancillary Facilities and Relocation of Existing Ready Mixed Concrete Plant” Approved (March 2009), condition 13 states:

“There shall be no more than 250 lorry movements (125 in and 125 out) at the site in any one working day entering from and/or leaving the site in a westerly direction via the Harpers Lane access.”

3.4 Historical Background Work

3.4.1 A number of historical reports and background documentation relating to the Harper Lane site, have been made available to EEW for review. EEW have also undertaken a number of additional assessments in order to establish the suitability, availability and deliverability of the site. The relevant assessments have been summarised below.



Planning Applications

3.4.2 Various documents accompanying previous Applications No: 5/0215-98 ‘Recycling of Demolition Waste, Glass and Rail Ballast for the Production of Secondary Aggregates’ (approved in May 1999) and No.5/2598-08 (CM117) ‘Erection and Operation of a Replacement Coated Stone Plant, Erection and Operation of Ancillary Facilities and Relocation of Existing Ready Mixed Concrete Plant’ (approved in March 2009), whilst it relates to land not including the rail loop, the information is available and provides a useful source of information as set out below:

• Detailed scheme for the formation and layout of the site;

• Ground Investigation Report; and

• Surface Water Drainage Scheme.

• Landscape and Visual Layout Assessment;

• Air Quality Assessment;

• Assessment of Noise;

• Flood Risk Assessment;

• Drainage Interceptor Capacity Assessment; and

• Contaminated Land Risk Assessment.

3.4.3 In order to satisfy the requirements of the Authority and to discharge conditions, the appropriate reports, surveys and schemes were submitted to the Authority for their written approval. All the relevant planning conditions have now been approved by the Authority and the content of these documents have been considered by EEW and will continue to be assessed in order to inform future assessments to be prepared and submitted in support of the proposed EfW Facility.

Land Stability and Ground Conditions

3.4.4 From a hydrogeological context, the site is located on a former outcrop of drift deposits under which Cretaceous chalks sub crop. Such solid deposits attain a Principal major aquifer designation under the Environment Agency’s groundwater protection policies added to which the site is located within an Inner Source Protection Zone.

3.4.5 A contaminated land assessment was undertaken in 2008 across the part of the Harper Lane site to the north of the boundary of the proposed EfW site, as part of planning application No: 5/2596-08 (CM0117). The findings of this report were as follows:

• hydrocarbon contamination (due to the presence of ash, clinker and tarmac) was present in relatively immobile forms;

• elevated concentrations of hydrocarbon fractions were having only a limited effect on groundwater;

• risk to the quality of groundwater and the River Colne from leaching Total Petroleum Hydrocarbons (TPH) was negligible; and

• monitoring in down hydraulic gradient boreholes demonstrated that there was no significant risk to groundwater from identified contaminants.

3.4.6 EEW commissioned a site investigation study in the southern part of the Harper Lane site in early April 2010. In total ten boreholes were advanced across the site to investigate ground conditions for



foundation design, and to collect shallow soil samples. The results of the investigation are set out below:

Geology:

• Topsoil c. 0.3m thick

• Chalk fill

• Chalky Clay with occasional flints 0.9-3.5 m thick. present in all boreholes with exception of borehole 3.

• Bedrock: Chalk

Boreholes record 0.3m of topsoil underlain by chalk fill and chalky clay to 2.6 metres below ground level (mbgl) in borehole 8 and 2.7mbgl in borehole 10.

Chalk bedrock proved from 8.4 to 12.mbgl in borehole 8 and from 3.1-13.mbgl in borehole 10. The chalk was clayey from 5.3-8.4mbgl in borehole 8.

Hydrogeology:

Groundwater monitoring facilities were not installed in the boreholes, however groundwater strikes indicated that the groundwater in the chalk aquifer is approximately 23 to 25 m below ground level.

Contamination:

The laboratory analysis of soil samples collected from made ground at the site revealed that none of the elements or compounds tested were recorded in excess of the human health guideline thresholds for commercial or industrial use.

3.4.7 The results of both the 2008 and 2010 site investigation will be taken into consideration from the outset and EEW will prepare a robust ‘Construction Environmental Management Plan’ which will guide all stages of development and ensure good management practices. The establishment of quality environmental management practices, will ensure deliverability and are in accordance with the policy framework.

Assessment of Heat Users

3.4.8 An ‘Assessment of Heat Users’ was undertaken in April 2010 by RPS Planning & Development and is summarised below.

3.4.9 The site’s proximity to educational, council, office/industrial (Ventura Business Park), retail, care and leisure facilities and industrial areas (Ventura Business Park), provides an opportunity for heat and/or power generated by the EfW Facility to benefit local users or be fed directly to the National Grid. In total 18 potential heat users have been identified, including Radlett Lodge School, Parkbury Business Park, Colney Fields Business Park, Harperbury Hospital and Hertsmere Leisure Centre. Studies are presently being undertaken to identify opportunities for energy users beyond the Harper Lane site.

3.4.10 In addition to these potential heat users, Lafarge’s operations at Harpers Lane offer a potential use of the heat waste produced. The potential heat demand of these operations has not yet been fully established, however operations are known to utilise heat throughout the year and the close proximity to the EfW Facility makes this industrial heat user particularly relevant.



3.5 Surrounding Land Uses and Proximity to Sensitive Receptors

Amenity

3.5.1 A number of potential receptors for amenity impacts have been identified. These include Harper Lodge Farm (0.4km south), Houndswood House (0.38km southeast), Houndswood Farm (0.51km southeast) and properties located to the west of Harperbury Hospital (0.8km east) (all measured from the centre of the rail loop).

Landscape

3.5.2 The Harper Lane site is within the Metropolitan Green Belt, a Landscape Character Development Area, the Upper Colne Valley and the Watling Chase Community Forest and lies 2km from the Shelley Ridge Landscape Conservation Area. Due to Hertfordshire’s proximity to London, the county is characterised by a series of major settlements including St Albans, Watford, Borehamwood and London Colney. The landscape is characterised by a landscape of woodland and agricultural land. The site contains and is located close to a number of woodland areas, which have been identified on the National Inventory of Woodland Trees (England).

Ecology

3.5.3 There are no nature or wildlife conservation designations within 1km of the Harper Lane site.

3.5.4 Within the neighbouring area a number of small ponds, drainage ditches, hedgerows and woodland features exist. An Ecological Impact Assessment (EcIA) has been undertaken following the guidelines of Institute of Ecology and Environmental Management and the following studies have already been completed:

• Extended Phase 1 Habitat Survey;

• Great crested newt Survey;

• Breeding bird survey;

• Bat Survey.

3.5.5 Existing information suggests that a reptile survey (to include potential for lizards to be present) would be required.

Flood Risk

3.5.6 The proposed site is located within Flood Zone 1, the Flood Zone that is least likely to flood. In sequential terms this means that the EfW Facility is not only an appropriate type of development within its flood zone, but that it is located within a sequentially preferable flood zone.

Cultural Heritage

3.5.7 There are no statutory or non statutory archaeological designations within the bounds of the site. As the site is within a former quarry, it is unlikely that any archaeological remains survive and by virtue of the sites historic use it is unlikely that any archaeological or cultural heritage features will be directly impacted upon.

Public Rights of Way

3.5.8 Footpaths 52 and 53 and Bridleway 5 are routed through or close to the Harper Lane site. Parts of these routes have recently been diverted and may well be subject to further realignments in the future.



4 PROPOSED CONTENT OF THE EIA

4.1 Introduction

4.1.1 The proposed content of the Environmental Impact Assessment (EIA) will be developed following a number of desk based topic specific assessments and site visits where appropriate, a review of the relevant development plan policy and using EEW’s planning advisors previous experience of similar developments.

4.1.2 The EIA will assess the potential significant impacts associated with the proposal. The individual EIA subjects/topics proposed include the following:

1. Background, Introduction and Context

2. The Site and its Setting

3. Planning History and Planning Policy Context

4. Description of Development

5. Need Alternatives

6. Traffic and Transportation

7. Air & Climate (including Human Health)

8. Landscape and Visual Impact

9. Ecology and Nature Conservation

10. Hydrology and Flood Risk

11. Hydrogeology and Ground Conditions

12. Noise & Vibration

13. Archaeology and Cultural Heritage

14. Amenity

15. Site Waste Management Plan

16. Socio-Economic Impact

17. Summary

4.1.3 Together, these topics will form the Environmental Statement document. Liaison between consultants will take place where necessary to ensure that where issues may cross over subjects, they are dealt with in the most appropriate way.

4.1.4 Each assessment will consider the impacts during both the construction and operational phases and also the cumulative impacts of the proposal. Each subject areas above will be discussed under a separate chapter within which the following matters will be addressed where relevant:

• Introduction

• Planning Context

• Assessment Methodology

• Baseline Conditions

• Incorporated Enhancement and Mitigation



• Identification and Evaluation of Key Impacts

• Mitigation

• Residual Impacts

• Conclusions

4.1.5 The following sections describe the context of each topic based upon information currently available and the proposed scope of each topic assessment to assist consultees in assessing its adequacy.

4.2 Background, Introduction and Context

4.2.1 This section will include narrative on the format and content of the ES and the statutory background to the EIA process.

4.2.2 It will also include information regarding the applicant, the assessment team and the organisation of the ES.

4.3 The Site and its Setting

4.3.1 This part of the Statement will describe the general physical and environmental characteristics of the application site and its surrounding environs. Other chapters of the Environmental Statement will provide detailed descriptions of the application site in relation to particular environmental topics, providing “baseline” surveys against which the effects of the proposals may be evaluated.

4.4 Planning History & Planning Legislation Context

Context

4.4.1 This section will include information regarding the planning history of the site and a summary of the policy context at the European, national, regional and local level. The relevant policies will be reviewed and key points of relevance summarised. This will set the context for more detailed topic analysis that will be included in the specific chapters of the ES.

Proposed Scope of Assessment

4.4.2 The proposal will be reviewed in the light of European and National Policy including The Landfill Directive, The Habitat Regulations, PPS10: Planning for Sustainable Waste Management, Waste Strategy for England 2007, PPS2: Green Belts, PPS22: Renewable Energy and PPS23: Planning and Pollution Control.

4.4.3 An initial review of the relevant development plan documents has identified the following documents and policies considered to be relevant to the proposals:

• Saved Policies of the Hertfordshire Waste Local Plan 1999;

• Hertfordshire Minerals Local Plan Review 2002-2016 (March 2007);

• Saved Policies of the City and District of St Albans District Local Plan Review 1994.

Saved Policies of the Hertfordshire Waste Local Plan 1999

4.4.4 The Hertfordshire Waste Local Plan (HWLP) was adopted in January 1999 and details policies in respect of development which involves the depositing of refuse or waste materials other than minerals waste. The HWLP is to be superseded by the Waste Development Framework (WDF), consisting of the following Development Plan Documents (DPDs):



• Waste Core Strategy and Development Policies

• Waste Site Allocations

4.4.5 In the interim period before the adoption of the WDF, all but one policy (Waste Policy 6 – Waste Minimisation) have been ‘saved’ through the issue of Direction issued by the Secretary of State in 2007. The following ‘saved’ policies remain part of the statutory Development Plan and are directly relevant to the proposed development.

4.4.6 Waste Policy 1 describes the overall policy of the Waste Local Plan setting out a number of key aims including the need to:

• reduce overall demand for resources (including land);

• increase the use of renewable resources;

• increase the reuse and recycling of resources;

• mitigate the possible effects of greenhouse gases;

• maintain critical national and local environmental assets (such as the Area of Outstanding Natural Beauty);

• maintain stocks of less critical environmental assets (such as ecological and landscape features whose overall spread and frequency are important for the environmental character and quality of the area).

4.4.7 Waste Policy 1 also considers the objectives set out within the Structure Plan Review which translate sustainable development into land use terms including:

• To maximise the benefits from, and minimise the environmental damage caused by waste;

• To reduce the gap between energy used and energy generated in the County.

4.4.8 Waste Policy 2 relates to the need for additional capacity and facilities and states that the establishment of facilities will be supported if a need can be identified, but only when balanced against other planning and environmental considerations.

4.4.9 Waste Policy 16 relates to the use of land in the Green Belt for the re-use, recovery, recycling and storage of waste and should be read in conjunction with advice contained in PPG2. It states that development will not be permitted unless it maintains openess and does not conflict with the purposes of including land in the Green Belt. The construction of new buildings in the Green Belt for such purposes will not be permitted except in very special circumstances.

4.4.10 The Authority will look to support the establishment of EfWs at suitable locations which contribute to the objective of enabling the equivalent of all waste arisings in Hertfordshire to be processed within the County. Waste Policy 19 sets out the locational criteria that should be considered as part of any proposed development and also seeks compliance with the requirements of Waste Policy 2. Similarly, Waste Policy 20 encourages energy recovery as part any proposed waste reduction facility, subject to compliance with Waste Policies 32 to 46.

Landscape, Nature Conservation and Heritage Features

4.4.11 The Authority, as Waste Planning Authority, will consider the impact of all waste management facilities on the landscape. Waste Policy 33 considers the general impact of waste management facilities on the wider landscape with the aim of ensuring that new developments are assimilated into



the landscape, that existing landscape features are conserved and enhanced and that new landscapes of quality are created.

4.4.12 Waste Policy 35 addresses Nature Conservation; with the principal aim being the protection and enhancement of the characteristic plants, animals and physical features which make up the natural heritage. Furthermore, the aim is also to prevent further decline in the quality of the natural environment of the County. Waste Policy 35 also acknowledges features of geological or geomorphological interest as worthy of protection because of their research, educational, historic or aesthetic value.

4.4.13 Waste Policy 36 relates to Heritage Features (e.g. Listed Buildings, Conservation Areas and Registered Parks and Gardens), setting out the Authority’s objectives for ensuring the continued use and maintenance of buildings of architectural and historic interest, both within settlements and outside them. Furthermore, it states that the settings of such buildings and other features of heritage interest should also be conserved and enhanced. Waste Policy 37 goes further by requiring a detailed archaeological assessment where waste management facilities are deemed to adversely affect any archaeological remains or their settings; where impacts are significant refusal of a planning application will be recommended.

4.4.14 Waste Policy 37 acknowledges that only small proportions of known archaeological sites are statutorily protected and aims to provide maximum protection for both archaeological sites and monuments.

Noise and Land Use

4.4.15 In considering planning applications for waste management facilities, housing, schools and hospitals will generally be regarded as noise sensitive development, but other forms of development may also warrant detailed consideration. Waste Policy 40 seeks the refusal of waste management proposals that adversely impact upon noise sensitive development or constrain the development of noise sensitive development. The provision of a supporting noise assessment, demonstrating that no significant harm exists, or the inclusion of specific conditions are identified as being adequate enough to address any perceived harm to sensitive receptors.

Water Pollution, Drainage and Flooding

4.4.16 The ‘water environment’ is subject to a range of demands and pressures where causes and effects are caught in a complex set of relationships. Waste Policies 41 and 42 coalesce to protect existing surface/groundwater resources and flood risk respectively. The policy seeks to ensure that waste management facilities are not detrimental to the water environment nor contribute to the flow of floodwater or increase the risk of flooding elsewhere.

Traffic

4.4.17 Lorry movements can be a key operational component of large waste management facilities, the potential impacts of which are addressed within the Waste Local Plan. Waste Policy 43 will look to preserve the existing status of local communities and residential areas, by refusing applications, which have inadequate transport provisions. The Authority will require traffic assessments, and where necessary and depending on local circumstances, the provision of road improvement works in order to mitigate any adverse harm.



4.4.18 Similarly, Waste Policy 44 looks to protect the amenity of neighbouring land uses (e.g. residential and employment) and requires consideration to be given to the potential impacts of noise and vibration, floodlighting, construction, traffic and air quality (amongst others) upon the local environment.

Hertfordshire Minerals Local Plan Review 2002-2016 (March 2007)

4.4.19 The Hertfordshire Minerals Local Plan (HMLP) was adopted in January 2007 and details policies in respect of development which involves the management and extraction of mineral resources. The HMLP is due for replacement in the form of a new-style Minerals Development Framework (WDF), consisting of the following Development Plan Documents (DPDs):

• Minerals Core Strategy, Development Policies and Preferred Areas DPD

• Minerals SPD – Minerals Safeguarding Areas

4.4.20 In the interim period before the adoption of the MDF, the HMLP remains part of the statutory Development Plan and the following policies are directly relevant to the proposed development.

4.4.21 Minerals Policy 10 relates to the safeguarding of Railheads and Wharves in the transportation of minerals. At present, it is acknowledged that road transport is usually the only feasible option, however, it is generally accepted that the best environmental option for the long distance movement of minerals is by rail.

4.4.22 The safeguarding of existing and disused facilities would help maximise the opportunities for the use of rail or water where it is appropriate and reduce infrastructure costs should water develop as a commercially viable mode.

4.4.23 Minerals Policy 14 relates to the after-use of proposals and states that all after-use schemes must be specified and if the after-use proposals involve a change of use from the existing use, a further planning permission will be required and should accord with the policies of the Development Plan. Mineral operators are required to facilitate proposals for sustainable after-use as part of the reclamation scheme ensuring the social, environmental and economic wellbeing of the site and surroundings.

City and District of St Albans District Local Plan Review 1994

4.4.24 As part of wider changes to the planning system introduced by the Planning and Compulsory Purchase Act 2004, provisions were made for City and District of St Albans Local Plan to automatically “expire” after 27th September 2007 unless “saved”, in whole or in part, by the Secretary of State (SoS).

4.4.25 In September 2007, the SOS issued a formal Direction to St Albans City & District Council under Paragraph 1(3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004. This Direction saves specified policies of the District Local Plan Review 1994, these policies are still formally recognised as part of the development plan for St Albans and those relevant to the Harper Lane site are set out below.

4.4.26 Policy 1 relates to Metropolitan Green Belt and sets out which areas of the District are defined as Green Belt and what form of development would be permitted. It states that new development within the green belt shall integrate with the existing landscape and that significant harm to the ecological value of the countryside must be avoided.



4.4.27 In relation to highways considerations in development control PPG13 states that ‘new development will often affect the road network surrounding it, and it is part of the role of planning control to ensure that any adverse effects are avoided or minimised.’ Policy 34 summarises this and considers road safety, the environmental impacts of traffic, road capacity, road hierarchy, car parking provision and local rural roads.

4.4.28 Paragraph 5.41 of the District Local Plan states that where a development may result in an identifiable impact on a number of particular locations, as well as an incremental loading throughout a wider area the council will, through Policy 35, seek highway improvements or contributions to highway improvements and/or improvements to the public transport system from developers.

4.4.29 Landscaping and Tree Preservation are considered in Policy 74 ensuring that the quality of the environment of the District will be maintained and enhanced. The policy highlights the need for retention of the existing landscaping as well as the provision of new landscaping.

4.4.30 Flooding and River Catchment Management is covered in Policy 84 which sets out principles in order to reduce the risk of flooding and to ensure proper management of the river catchment. Policy 84a relates to Drainage Infrastructure and the provision of drainage facilities as part of the overall construction of infrastructure in major development schemes.

4.4.31 The District Local Plan states that the principal aim of nature conservation is the protection and enhancement of the characteristic plants animals and physical features which make up the natural heritage. Policy 106 seeks to ensure that the council take account of ecological factors when considering planning applications and will refuse proposals which could adversely affect Sites of Special Scientific Interest, Nature Reserves, other sites of wildlife, geological or geomorphological importance, any sites supporting species protected by the Wildlife and Countryside Act 1981, and the natural regime of either surface or ground waters in river valleys and their wetlands. Policy 111 states the District Council will not normally refuse planning applications on archaeological grounds. However, following evaluation, planning permissions may be subjected to a condition requiring facilities for the Council to record remains by excavation in advance of construction and/or during construction. The Harper Lane site has a site reference AS.R.37 “Palaeolithic to Saxon finds, Colne Valley including site of the Medieval village of Hansteads” , therefore there may be a requirement for limited excavation or other work (e.g. geophysical survey), to be carried out.

Hertfordshire Minerals and Waste Development Framework

The Core Strategy and Development Policies

4.4.32 The document is at the revised Preferred Options (Preferred Options Plans 2) stage and responses to the consultation of this document will inform the final policies of the County Council that will be submitted to the Secretary of State.

4.4.33 The Hertfordshire’s Waste Development Framework aims to facilitate the provision of waste management facilities in Hertfordshire with sufficient capacity to manage the quantity of waste that the county is expected to produce. WCS Policies 1, 2, 4, 6 and 7 of the Core Strategy, combine to secure and promote the provision of a network of waste management facilities (capable of providing for the equivalent of existing and future waste arising) within ‘Preferred Areas and Employment Land Areas of Search’, with a general presumption to not permit waste management facilities within the Green Belt unless ‘very special circumstances’ can be demonstrated.

The Site Specific Allocations DPD



4.4.34 The Waste Site Allocations DPD is currently at an Issues and Preferred Option stage and when finalised will form part of the Minerals and Waste Development Framework for Hertfordshire.

4.4.35 The Site (Site HP0 032) has been identified within the Site Specific Allocation DPD as being a Preferred Waste Area within the St Albans District; for waste uses.

4.4.36 Heaton Planning Ltd, have submitted representations (set out below) to the Waste Site Allocations Issues and Preferred Options 2 (November 2009) on behalf of Lafarge Aggregates Ltd, in support of the site being allocated a ‘Preferred Waste Area’ and to ensure that any planning issues relating to the Site which could potentially frustrate or delay the determination of the application is suitably addressed through the Core Strategy and Waste Site Allocation DPDs.

“Lafarge support the inclusion of this site as a ‘Preferred Waste Area'. Current operations also include a coating plant and ready mix concrete plant in addition to the waste recycling/materials recovery facilities and operational aggregates railhead. Lafarge are keen to promote the extension of these activities but given the existing rail link believe that the site could be used for a range of waste treatment facilities, for example, anaerobic digestion; thermal treatment and MBT. We believe that the rail link could also be used for the transportation of refuse derived fuel.”

4.4.37 EEW will look to review the Hertfordshire Minerals and Waste Development Framework timetable to ensure further representations to the Waste Site Allocations Issues and Preferred Options document are made should the option become available.

4.4.38 Although identified as a Preferred Waste Area and capable of accommodating a waste treatment facility, the site is located within the designated Green Belt and therefore EEW would need to demonstrate ‘very special circumstances’ for developing the Site ahead of available suitable non Green Belt sites (WCS Policy 4).

St Albans Local Development Framework

4.4.39 The emerging Core Strategy has been prepared following consultations on Core Strategy Issues and Option in 2006 and 2007, and the assessment of responses received. This document is not yet the Council’s preferred strategic planning option; rather it provides an opportunity for stakeholders and the local community to comment on a proposed direction of travel; although St Albans City & District Council (SACDC) were proposing to prepare a Pre-Submission Core Strategy in Feb 2010, Councillors have amended the works programme resulting in the Pre-Submission Core Strategy being prepared in late 2010. The Core Strategy will guide all other document in the group of documents that make up the LDF.

4.4.40 From the outset the emerging core strategy suggests that an over-riding priority of the Core Strategy is to protect the Green Belt for current and future generations, while balancing the need to provide housing, jobs and services for local residents. SACDC has indicated that it will strongly resist any Government requirement for development to encroach upon the Green Belt and show a willingness to legally challenge any decisions which depart from Development Plan policy.

4.4.41 The emerging core strategy identifies housing need as having the greatest potential impact upon the Green Belt, and has shown a willingness to promote B1 office business park development on the provision of ‘very special circumstances’. Another key SACDC priority is to reduce environmental impact and improve environmental sustainability. An ambitious and aspirational target for a 60% reduction in the District’s carbon dioxide emissions between 2005/06 and 2021 have been set, with a



clear commitment towards the prudent use of resources, minimising pollution and waste, increasing energy efficiency and using low carbon and renewable energy resources.

4.5 Description of Development

4.5.1 This section will describe the development including the layout of the proposed EfW Facility together with the description of the processes to be undertaken on site and will set out the basis against which the Environmental Impact Assessment will be conducted. It will also include a description of management and procedures associated with the operations.

4.6 Need and Alternatives

Need

4.6.1 PPS10, Planning for Sustainable Waste Management, published in July 2005 states (para. 22) that where proposals are consistent with an up-to-date development plan, applicants do not have to demonstrate a quantitative market need for their proposal.

4.6.2 The current situation with regards to ‘Need’ will be examined against the available published data on waste arisings from the Environment Agency and Local Authority sources and a review of existing waste management capacity for the waste streams to be managed at the facility.

4.6.3 EEW will draw on statistics and targets for sustainable waste management in Hertfordshire. This will include identifying the recycling and composting targets as set out in the relevant national, regional and local policy documents and the making of informed judgements on the likelihood of Hertfordshire meeting targets without the proposed development. This will provide an evidence base on which the subsequent identification of any gaps in the provision of waste management facilities in the region can be based. With the site located within the designated Green Belt, it will also be important to demonstrate ‘very special circumstances’ as required by PPG2.

4.6.4 In considering ‘Very Special Circumstances’ for the EfW Facility the following issues will be considered:

• Residual waste forecasts for Hertfordshire that take into account of the anticipated growing contribution of recycling and better use of resources.

• The declining availability of landfill sites to accommodate the county’s residual waste and the general undesirability of this method of disposal.

• The absence of any suitable or available non-Green Belt sites – including industrially allocated sites – of the size required within the areas of search (or generally within the county).The site is already an established integrated minerals processing and distribution facility with aggregate storage and distribution, a coated roadstone plant, a ready mix concrete plant and an aggregate and glass recycling centre.

• Potential heat demand of the existing Lafarge facilities, coated roadstone operations are known to utilise heat throughout the year and the close proximity to the EfW Facility makes a particularly suitable heat and power user.

• Potential combination of bottom ash reprocessing with other aggregate and glass recycling by Lafarge on site

• Potential use of the existing rail link for bringing materials on to and taking materials off site.



4.6.5 Overall it will be important to demonstrate why the EfW Facility should be permitted with sufficient capacity to manage the waste stream within Hertfordshire as well as managing waste as high up the waste hierarchy as possible; and ultimately diverting waste from landfill disposal wherever possible.

Alternatives

4.6.6 The requirement to consider 'alternatives' stems primarily from the requirements of the 1999 EIA Regulations, which identify the information for inclusion in Environmental Statements. Parts 1(2) and 2(4) states:

"An outline of the alternative studies… and an indication of the main reasons for this choice, taking into account the environmental effects."

4.6.7 Para. 83 of Circular 02/99 which accompanies the EIA Regulations notes that:

"Although the Directives and the Regulations do not expressly require the developer to study alternatives, the nature of certain developments and their location may make the consideration of alternatives a material consideration…"

4.6.8 The Environmental Statement (ES) will identify, describe and evaluate the process and decisions underpinning the choice of location, technology and design, which define the proposals.

4.6.9 The ES will contain an ‘Alternative Site Assessment’, the methodology of which has been applied for a range of similar proposals, undertaken across the UK for waste and industrial developments. The Alternative Site assessment will adopt a staged and criteria based analysis to not only mitigate planning risk, but to demonstrate that the Site is the right site and the proposal is consistent with the adopted development plan and all other relevant material considerations.

4.7 Traffic and Transportation Issues

Policy Context

4.7.1 Current guidance for assessing the environmental effects of road traffic is set out in ‘Guidelines for the Environmental Assessment of Road Traffic, Guidance Note No. 1’, published by the Institute of Environmental Management and Assessment (IEMA) in 1993.

4.7.2 The guidelines are based upon the forecast increase in traffic on a link resulting from proposed development and sets out thresholds upon which more detailed assessments should be undertaken.

4.7.3 The guidelines suggest that more detailed assessments should be undertaken for links where traffic flows are predicted to increase by more than 30% as a result of proposed development. The guidelines suggest that in sensitive locations a 10% threshold should be used as a basis for undertaking assessments in more detail.

4.7.4 Table 2.1 of the Guidelines goes on to state that where more detailed assessments are required the following should be considered:

• Noise

• Vibration

• Visual Impact

• Severance

• Driver Delay



• Pedestrian Delay

• Pedestrian Amenity

• Accidents and Safety

• Hazardous Loads

• Air Pollution

• Dust and Dirt

4.7.5 The results of the assessment methodology will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD and PPG13 guidance.

Assessment Methodology

4.7.6 The environmental effect of road traffic resulting from the proposals will be assessed upon the local and wider highway network in accordance with the above IEMA guidelines.

4.7.7 Assessments will be undertaken across a typical working day and each hour will be considered together with 12 hour (0700-1900) and 24 hour (0000-2400) traffic flows. On any link where increases in traffic flow are in excess of the above threshold a detailed environmental assessment will be undertaken in accordance with Table 2.1 of the guidelines and set out above.

Construction Effects to be Assessed

4.7.8 The likely number of traffic movements resulting from the site clearance and construction process of the proposals will be estimated using the construction programme. The estimated number of vehicles, although temporary, will be assigned onto the adjacent highway network and be assessed in accordance with the IEMA guidelines throughout the working day. Where any increase in excess of the above threshold is predicted, a more detailed environmental assessment will be undertaken in accordance with Table 2.1 of the guidelines and as set out above.

4.7.9 If the detailed environmental assessments suggest there may be an impact as a result of the increased traffic movements, suitable mitigation measures will be identified with consideration to the temporary nature of the increased traffic flow.

Operational Effects to be Assessed

4.7.10 The likely number of traffic movements associated with the completed development will be estimated in accordance with an accompanying Transport Assessment. The estimated number of resultant vehicles will be assessed in accordance with the IEMA guidelines against the above threshold. Where this threshold is exceeded on any link, more detailed environmental assessments will be undertaken in accordance with Table 2.1 of the guidelines and as set out above.

4.7.11 The Transport Assessment will form an Appendix to the Environmental Statement and will consider all modes of travel to and from the site, sustainability issues and the impact of vehicles upon the capacity and operation of the adjacent transport network.

4.7.12 If the detailed environmental assessments suggest an impact may arise as a result of the proposals then suitable mitigation measures will be identified.

Baseline



4.7.13 Our traffic and transport consultants have already undertaken some preliminary assessment work during the earlier stage of the procurement process and are therefore familiar with the site and the transport and highways related aspects which will have to be considered within the ES.

4.7.14 The site is served by major road networks. The Harper Lane site is located approximately 0.5km north of Radlett, with the major settlements of Shenley (1.9km east), London Colney (2.3km northeast) and Brickett Wood (2.4km northwest).

4.7.15 The site is currently accessed from Harper Lane (B556), which has junctions with Watling Street (A5183) and Shemleybury approximately 600m (southwest) and 1.7km (north east) of the Harper Lane site respectively). The ‘Bell Roundabout’ (Junction 22) of the M25 is located approximately 3km north east of the site and allows further access to the strategic road network. On a wider scale the county has over 3000 miles of road network including a number of trunk roads running through it or on its borders, in particular, the M25, M1, A414 (key East-West route across the county) and A10.

4.7.16 The Lafarge Depot has an extant consent for the operation of a Coated Stone Plant, Ready Mixed Concrete Plant and ancillary facilities with operations benefitting from 24 hour working. The rail loop is used by Lafarge to import aggregate for processing at the Harper Lane Depot.

4.7.17 Under Planning Permission No:5/2596-08 (CM0117) “Application for the Erection and Operation of a Replacement Coated Stone Plant, Erection and Operation of Ancillary Facilities and Relocation of Existing Ready Mixed Concrete Plant” Approved (March 2009), condition 13 states:

‘There shall be no more than 250 lorry movements (125 in and 125 out) at the site in any one working day entering from and/or leaving the site in a westerly direction via the Harpers Lane access.’

4.8 Air Quality and Human Health Risk Assessment

Policy Context

4.8.1 The results of the methodology as set out below will be assessed against key European and National Legislation, which include the limit values contained within the European Air Quality Directive 2008, the Air Quality Standards Regulations 2010 and the Government’s objectives set out in the Air Quality Strategy. The results of the assessment methodology will be interpreted within the context of PPS23 and EPUK guidance for development control.


4.8.2 Air quality is a material issue that can act as a constraint to development in certain circumstances. All applications should be supported by the necessary information to allow full consideration of the impact of the proposal on the existing air quality of the area. For this application, the key aspects with regards to air quality are considered to be:

• Operational Effects: Combustion stack emissions from the EfW plant, and the associated effects on sensitive receptors for human health and ecology. Potential fugitive emissions of dust, odour and bioaerosols from the feedstock reception areas.

• Traffic Effects: Changes in traffic flows on the local road network, associated with both the construction and operation of the proposed development.

• Construction Effects: Construction plant emissions and dust generating activities associated with the construction of the proposed development on existing sensitive receptors.



4.8.3 The air quality assessment will include the following elements:

1. Consultation with Environmental Health Officers at SACDC and HBC to agree the approach to the assessment, to obtain the latest information on existing air quality in their respective areas and details of other proposed developments that may require consideration in terms of potential cumulative effects.

2. A description of the legislative and policy framework, the assessment methodology, model inputs, sensitive receptors and significance criteria.

3. A review of publicly available data on existing air quality conditions to characterise pollution levels in the vicinity of the proposed facility. Air Quality Management Areas that may be affected by the development are discussed below under the heading “Baseline”. The review will include data from the DEFRA national monitoring network, the Hertfordshire and Bedfordshire Air Quality Network and monitoring undertaken by the local authorities for Review and Assessment purposes. Site specific monitoring that may have been undertaken in the local area to support applications for, or the ongoing operation of, other major combustion plant that may be of relevance to the current project will also be identified. If it is concluded that there are insufficient data to adequately characterise existing conditions, a programme of air quality monitoring will be recommended.

4. A D1 stack height calculation to determine the minimum acceptable stack height for the EfW facility, taking into account the aerodynamic influence of nearby buildings. An initial stack height sensitivity study will then be undertaken using the US EPA’s advanced atmospheric dispersion model AERMOD to predict estimate ground level pollutant concentrations at sensitive receptor locations, to determine whether the D1 stack height is acceptable.

5. Consideration of the effect of stack emissions on human health. The main modelling of stack emissions for the EIA will include nearby buildings and complex terrain, and will be run using five years of hourly sequential meteorological data for the closest representative site with adequate records. The modelling will be carried out for a normal operational scenario, for all WID pollutants and relevant averaging periods, to allow comparison with the national and European air quality criteria for human health. The results will be interpreted in line with the Environment Agency (EA) Horizontal Guidance (H1).

6. Consideration of the effect of stack emissions on ecological sites. H1 requires that Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Ramsar sites within 10 km of the EfW; and Sites of Special Scientific Interest (SSSIs), Local Nature Reserves (LNRs), National Nature Reserves (NNRs) and ancient woodland within 2 km are considered. Initial analysis indicates that there are no European or internationally designated sites within 10 km, nor any SSSIs, LNRs or NNRs within 2 kilometres. There is, however, an area of ancient woodland, Hounds Wood, approximately 400 metres to the south east of the site. The assessment of ecological effects will include a comparison with appropriate critical levels for annual-mean NOx and SO2 concentrations, and with critical loads for nitrogen and acid deposition rates. The findings will be used by the ecologists to inform the ecological assessment.

7. An assessment of the effect of vehicle emissions on local air quality. This will follow the Highways Agency’s Design Manual for Roads and Bridges (DMRB) air quality assessment methodology. Traffic flow generated from the Traffic Assessment will be used to determine road links that are “affected” (in terms of a potential effect on air quality) by the construction and



operation of the proposed development. If affected roads are identified, a simple model will be used to estimate changes in concentrations of traffic-related pollutants due to traffic generated by the development. The assessment will look at changes in concentrations of NO2 and PM10 that may affect in particular existing areas of poor air quality i.e. Air Quality Management Areas.

8. The significance of the effects on air quality will be interpreted using criteria definitions from the EA H1 guidance; Environmental Protection UK (EPUK) Development Control: Planning for Air Quality (Update 2010) document; using professional judgement where appropriate.

9. A qualitative risk-based assessment of dust, bioaerosols and odour will be undertaken, following best practice guidance where available. Dust may be generated during the construction phase and during waste handling, which in the absence of effective mitigation may result in off-site effects. Thermal treatment of waste has no significant potential for odours as the combustion process effectively destroys any odorous compounds. However, the front-end waste handling may have some potential for fugitive releases of odour. The risk assessment of dust emissions will follow the Greater London Authority’s Best Practice Guidance, which provides a useful framework within which to evaluate air quality risks during the construction phase. The risk assessment of odour emissions will refer to EA H4 guidance where appropriate, while the EA position paper on bioaerosols will be considered when determining the type of assessment that is required.

10. Mitigation measures designed to control the potential for dust nuisance effects and emissions during construction, consistent with the level of risk, will be proposed according to best practice guidance.

11. Assessment of cumulative effects. Existing emission sources will be included within the modelling through the selection of appropriate, representative baseline data. During the consultation process details of any committed development with significant combustion point sources which may act in combination with the emissions from the propsed EfW facility, will be requested. The effects would be considered qualitatively, using the results from published Environmental Statements. For the assessment of traffic emissions, cumulative effects would be taken into account to the extent that committed developments generating traffic on the local road network will be included within the future traffic flow data provided.

Baseline

4.8.4 The Harper Lane site lies within the administrative area of St Albans City and District Council (SACDC). SACDC has designated three Air Quality Managements Areas (AQMAs) due to high concentrations of nitrogen dioxide (NO2) attributable to road traffic emissions. In addition, SACDC will be undertaking detailed assessments of air quality in three further locations where the results of monitoring suggest that the annual mean NO2 Air Quality Strategy objective is being breached.

4.8.5 The Application Site is not located within any of the designated AQMAs or the areas identified for detailed assessment. The closest AQMA to the site is approximately 1 kilometre north of the site on Radlett Road, where it passes over the M25.

4.8.6 The Harper Lane site is close to the boundary of Hertsmere Borough Council (HBC). HBC has designated six AQMAs, again due to high concentrations of NO2 attributable to road traffic emissions. None of these AQMAs are in areas representative of the development site and are all over 5 km away.



4.8.7 Information on air quality in the UK is available from a variety of sources including local authorities, national monitoring networks run on behalf of DEFRA and other published sources including:

• Local authorities’ published results of the review and assessment of air quality, with reference to local monitoring and modelling studies, providing a description of air quality at both near road and background locations.

• The “Herts and Bed Air Quality Network” - a network of automatic air quality monitoring sites within the two counties; this includes two representative urban background locations;

• The Automatic Urban and Rural Network and UK Heavy Metals Monitoring Network, operated on behalf of DEFRA;

• The National Air Quality Information Archive (NAQIA), which includes modelled projections of background concentrations for years up to 2020 for each 1 km grid square in the UK.

4.8.8 This information can be supplemented with reference to historical monitoring campaigns undertaken in the study area or by undertaking a study specific monitoring campaign. In the case of this assessment, however, there is sufficient information available from the NAQIA, the national and county level monitoring networks and the results of R&A undertaken by SACDC to be able to adequately characterise the air quality baseline in the area.

Human Health Risk Assessment

4.8.9 Although not a statutory requirement, it is accepted good practice in the UK for a human health risk assessment (HHRA) to be carried out as part of the planning and permitting process for certain types of developments, including EfW facilities. HHRA is a tool that can be used to address potential health concerns regarding emissions to air; it is a standard technique for evaluating the toxic properties of substances, assessing human exposure to the substances to ascertain the likelihood that the exposure will lead to adverse effects, and characterising the nature of the effects.

4.8.10 Whilst waste thermal treatment facilities generate a considerable amount of public concern, there have been few published epidemiological studies that examine the health of communities living in close proximity to them (DEFRA 2004). The majority of published studies concentrate on the effects of exposure to emissions from the older generation of incinerators, which were phased out in the UK after the introduction of stricter emission controls implemented through the Integrated Pollution Control regime. The risk of potential damage to the health of those living close-by to well regulated, modern-day municipal waste incinerators is likely to be very small, if detectable .

Methodology

4.8.11 In the absence of an equivalent UK methodology, the United States Environment Protection Agency (USEPA) Human Health Risk Assessment Protocol (HHRAP 2005), can be used to calculate the transport and fate of trace contaminants i.e. heavy metals and dioxins and furans, emitted from the stack. This methodology has been implemented in the Industrial Risk Assessment Program-Human Health (IRAP-h View) software. The output of the risk assessment model can be compared with health risk guidelines from the Health Protection Agency and World Health Organisation, such as tolerable daily intake levels of pollutants and cancer risk factors for carcinogenic substances.

4.8.12 Advanced health risk assessment models such as the IRAP model utilise other local factors that the previous HMIP approach for dioxins did not take into consideration. The model considers direct exposure through the inhalation of pollutants, but also food chain exposure following pollutant



deposition onto crops and ingestion by animals. The pathways considered are ingestion of home-grown or allotment produce, accidental ingestion of soils, ingestion of meat (pork, beef), poultry, egg and milk produced in farms, ingestion of contaminated fish and water. Exposure via minor pathways such as dermal exposure may also be considered although it is not a significant source of exposure.

4.8.13 The assessment is based on the maximum annual average ground level concentrations modelled to occur as a result of emissions from the facility, at locations of sensitive receptors such as residential properties, farms and water bodies. Worst case assumptions are used to ensure that the maximum hypothetical exposure to food chain concentrations is considered. For instance, it can be assumed that local farms produce all relevant food items (beef, pork, milk, poultry and eggs). This is likely to be a highly pessimistic assumption for UK farming practice.

4.8.14 Sensitive receptors within the vicinity of the site will be identified by inspection of local maps and aerial photographs to provide a list of receptors and their land use (residential properties, allotments, farms). Following the compilation of the list, a site walkover survey may be carried out to verify the selected land use and identify any premises that were not identified from mapping.

4.8.15 Default exposure parameters and toxicological data can be replaced by those recommended by DEFRA and the Environment Agency. These modified parameters include averaging times for carcinogens and non-carcinogens, body weight, consumption and inhalation rates, exposure frequencies and duration. Other USEPA default parameters such as the soil mixing depth can be replaced with values appropriate for the UK.

4.8.16 Exposure through the ingestion of surface water, where surface water abstraction for drinking purpose are present within 10 km radius of the site and through the ingestion of fish, where fisheries (including fish ponds) are identified within this radius, may be undertaken. However, the presence of surface water does not always necessitate the need for assessment of these pathways. Many surface water bodies are not a source of fish supply for human consumption, either due to the nature of the waterbody or because fishing is controlled on catch and release basis. A generic assessment to identify the importance of local surface water bodies for fish or/and drinking will be carried out. If these are found to be significant sources, a further assessment through these pathways may be carried out.

4.8.17 The DEFRA common framework for risk assessment and management will be used as the guidelines for the assessment and appraisal of potential impact on human health from the proposed facility.

4.8.18 These guidelines set out some basic principles which the regulators would normally intend to use in the assessment and management of environmental risks and which are recommended for all public-domain risk assessments. They are intended to provide decision-makers, practitioners and the public with a consistent language and approach for environmental risk assessment and management.

Consultation

4.8.19 The Environmental Health department of the local authority will be consulted at the outset of the assessment to agree the scope of work and methodology. Following the compilation of the list of receptors with their appropriate exposure pathways, the list will be sent to the Environmental Health Officer for comments/approval.

4.8.20 The Environment Agency will be consulted with regard to potential effects on surface water and fisheries, should this pathway require consideration.



4.9 Landscape and Visual Impact

Policy Context

4.9.1 The results of the assessment methodology set out below will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD and PPS1 guidance.


4.9.2 The principal guidance for the undertaking of this Landscape and Visual Impact Assessment has been sourced from:

• The Guidelines for Landscape and Visual Impact Assessment (second edition), published April 2002 by the Landscape Institute and Institute of Environmental Management and Assessment; and

• Landscape Character Assessment, Guidance for England and Scotland, published April 2002 by the Countryside Agency and Scottish Natural Heritage).

4.9.3 The basis of this assessment is the existing situation currently experienced within the Operational Site Area. Restoration is taken in account. It is against this baseline that the changes resulting from the Proposed Development are described and evaluated.

4.9.4 Change can result in beneficial, adverse or neutral effects. This report describes and considers the potential effects, all of which may not necessarily be 'significant' in terms of EIA.

4.9.5 The definition of impact terminology is specific to this study and has been developed to ensure that, wherever possible, an objective assessment is made and that the terminology used is appropriate to the development and the landscape setting.

4.9.6 Current guidelines advise that the assessment of an impact on visual amenity resulting from a particular development should take full account of the landscape (character) impacts, as well as the potential visual impacts. Although they are separate, it is difficult to isolate each category and so both landscape and visual effects are considered as part of the assessment process.

4.9.7 The methodology employed establishes the baseline conditions of the Site, against which the proposals can be tested in the Landscape and Visual Impact Assessment (LVIA).

4.9.8 The LVIA will be undertaken in accordance with ‘Guidelines for Landscape and Visual Impact Assessment’ (LI, 2002), ‘Guidelines for Landscape Character Assessment’ (2002) Countryside Agency, and other published best practice guidance.

4.9.9 The LVIA will comprise a report (written as an Environmental Statement Chapter) and will be prepared in accordance with the project Briefing Notes. The report(s) will be supported by figures and photographs representing Key Viewpoints (number and locations to be agreed with the LPA via office-based consultation). The baseline will be prepared on a 5km study area unless otherwise agreed with the Local Planning Authority. The assessments will consider the effects of the development during construction and occupation in winter years 1 and summer/winter year 15 unless agreed otherwise. The LVIA will be based on site visits during which photographs will be taken from the agreed locations. The assessment and site visits will be undertaken based on the design information contained in the indicative design proposals provided by others.



Baseline

4.9.10 The proposed site is located within the M25 corridor between the conurbations of Watford and St Albans, and adjacent to the settlement of Radlett. It lies at the junction of the A5183 (Watling St) and the B556 (Harper Lane), with the site entrance located on the latter, opposite the Radlett Golf Centre.

4.9.11 The site is located in the Vale of St Albans (Area 19 South Hertfordshire Landscape Character Assessment (SHLCA) 2002-05) and has “extensive views along the Vale and up to Shenley Ridge”. The area is typified by a “predominately arable landscape with few small and medium copses”, “areas of woodland and parkland to the northeast” and “institutional parkland... …at Napsbury and Harperbury”. Area 16 (Aldenham Plateau of the SHLCA) lies south of development site between Radlett and Watford and may have a bearing on the assessment.

4.9.12 The area is also affected by associated urban development and skyline clutter including overhead wires and pylons. There is some “new planting associated with the corridor and adjacent land uses”.

4.9.13 There are also a number of “active and restored mineral extraction sites along the course of the Colne and at Radlett aerodrome.”

4.9.14 Natural England designates the site to be within the Northern Thames Basin (JCA 111), on the Hertfordshire Plateau. As well as reinforcing the description of the site mentioned above the character area description states: “Smaller, intimate tree-lined valleys, supporting red brick villages supporting red brick villages provide a contrast to the more heavily developed major river valley floodplains. Within these river valleys, organic field shapes are common, defined by water courses and the legacy of woodland clearances rather than formal enclosure patterns.”

4.9.15 The immediate setting of the site is predominantly farmland consisting of large fields some still with hedgerows, pockets of wooded areas and the Harper Lane Quarry. Close by are the villages of Brickett Wood, London Colney, Colney Street, Shenley and Radlett. The rest of the area comprises a patchwork of farmland, blocks of woodland, 2 golf courses and some parkland.

4.9.16 The study area is also intersected by the M25 and M1 corridors and contains the road junction where they meet.

4.9.17 It is estimated that the majority of the sensitive receptors will comprise residential properties located on the edge of settlements or scattered across the intervening farmland.

4.9.18 Cultural heritage will form a separate element within the Environmental statement but the setting for designated sites may be considered as part of the LVIA following consultation with the LPA County Archaeologist and English Heritage. There are four scheduled ancient monuments in the study area one to the far north, two close by to the east and west and one to the far south.

4.9.19 The study area also contains three Registered Parks and Gardens, a Site of Special Scientific Interest and ancient and semi-natural woodland(s), some of which has been replanted. Views from the Registered Parks and Gardens will also be considered as part of the assessment.

4.9.20 There are also a number of designated listed buildings within the study area. There are four Grade II listed buildings of note namely; the ‘Stable Grange to South of Harperbury Hospital’, ‘Harper House, Harper Lane’, ‘Old Parkbury Farmhouse’ and ‘The George and Dragon Public House’.



4.9.21 At this preliminary stage no further baseline conditions in terms of Landscape and Visual Impact have been established.

4.10 Terrestrial Ecology and Nature Conservation

Policy Context

4.10.1 The results of the methodology as set out below will be assessed against all key European and National Legislation, which include the Conservation (Natural Habitats, & c.) Regulations 1994, Conservation (Natural Habitats, & c.) Regulations 1994 and the Wildlife and Countryside Act 1981 (as amended) and Wildlife and Countryside Act 1981 (as amended). The results of the assessment methodology will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD and PPS9 guidance.


4.10.2 The ecological assessment of the study area follows established guidelines. Throughout the investigation, the approach adopted has been based upon recognised techniques of ecological survey and impact assessment (e.g. Institute of Environmental Assessment (IEA), 1995; Treweek, 1999; and guidance developed by the Institute of Ecology and Environmental Management, 2006).

4.10.3 The formal scoping exercise will identify the issues relevant to ecology and nature conservation impacts such as:

• the potential direct and indirect impacts on BAP priority species, protected species and designated sites, including potential impacts on air quality should be assessed.

• The surveys required in addition to consulting with local wildlife recording groups for information.

• the impact of the development on the local, national and international designations.

• the methods required to minimise, mitigate, compensate for any adverse impacts along with proposed monitoring pre, during and post-development.

• the assessment requirements throughout the lifespan of the plant and examine all aspects of its construction and operation.

4.10.4 An Extended Phase 1 Habitat Survey, Great Crested Newt Survey, Breeding bird survey and Bat Survey have already been undertaken and completed at the site. Available information suggests that a Reptile survey (to include potential for lizards to be present) will be required.

4.10.5 The reptile survey will follow guidance provided by the Herpetofauna Workers’ Manual (JNCC, 1998). An experience ecologist will carry out the surveys using individually numbered and carefully placed 1 m x 1 m tins as artificial refuges or basking places. Roofing-felt tiles will be used as they are quick to warm in the sun and are therefore attractive to reptiles seeking to raise their body temperature.

4.10.6 In addition to basking sites, the tiles provide artificial refuges for sheltering reptiles and are an effective and acknowledged method of determining the presence or absence of species, and estimating population sizes, particularly in areas with few easily checked natural refuges.

Baseline

4.10.7 Baseline data will be collected to support the EcIA. The following studies have already been undertaken and completed.



• Extended Phase 1 Habitat Survey;

• Great crested newt Survey;

• Breeding bird survey;

• Bat Survey.

4.10.8 The EcIA will use this information in addition to that already gathered to assess the ecological impact of the proposed EfW facility.

4.10.9 At this preliminary stage no further baseline conditions in terms of Terrestrial Ecology and Nature Conservation have been established.

4.11 Hydrology and Flood Risk

Policy Context

4.11.1 The results of the methodology as set out below will be assessed against all key European and National Legislation, including the Water Framework Directive 2000/60/EC, the Environmental Protection Act (1990) and Water Resources Act (1991). The results of the methodology set out below will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD, PPS23 and PPS25 guidance.


4.11.2 It is proposed to carry out the EIA in two phases as outlined below.

4.11.3 Firstly, the hydrological site conditions, flooding, and water quality will be determined by consulting maps and published information regarding the topography, geology, and hydrology of the area. Much of the information will be obtained from an Envirocheck report. In addition, the Environment Agency (EA) will be consulted regarding the existing water quality of watercourses around the site and an agreed methodology for the Flood Risk Assessment (FRA). A site walkover and site investigation works were also undertaken to ascertain the site conditions establish key hydrological constraints to the development. This scoping phase will determine the level of detail required for the full EIA.

4.11.4 The scope for the EIA will then be determined with completion of the Scoping Assessment, and following further liaison with regulatory authorities and with the detail of the development. The works are likely to include some or all of the following:

• Confirmation of flood level for the site including potential impacts of climate change, and comparison of these flood levels against topographic levels over the site and surrounds.

• Identification of any hydrological or water quality constraints to the proposed development.

• Assessment of the existing surface-water runoff regime at the site, and determination of the potential impacts of the development on peak runoff rates and flow directions.

• Development of a conceptual mitigation strategy for the proposed development, including an outline for an appropriate surface-water SUDS.

• Consideration of flood storage compensation measures if required.

• Consideration of Sewerage assets and their capacity to cope with inputs from the proposed development.

• Preparation of a report for submission with the planning application.



Baseline

4.11.5 The proposed site is located within Flood Zone 1, the Flood Zone that is least likely to flood. At this preliminary stage no further baseline conditions in terms of Hydrology and Flood Risk have been established.

4.12 Geology, Hydrogeology and Land Contamination

Policy Context

4.12.1 The results of the methodology as set out below will be assessed against all key European and National Legislation, including the Water Framework Directive 2000/60/EC, the Environmental Protection Act (1990) and Water Resources Act (1991). The results of the methodology set out below will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD, PPS23 and PPS25 guidance.


4.12.2 The following data sources will be utilised to determine baseline ground conditions at the site.

• Ordnance Survey Landranger Sheet mapping. 1:50,000

• British Geological Survey (BGS) mapping

• Hydrogeological Mapping IGS

• Source Protection Zones (SPZ) – Environment Agency Web Site (EA)

• Groundwater Vulnerability Mapping

• Historical mapping

• Environment Agency and Local Authority records on landfill sites, contaminated land and pollution incidents

• Environment Agency Licensed Abstractions data

• Local Authority Private Water Supplies

Geology

4.12.3 The site is located on the Chalk. Further detail on the superficial and solid geology beneath the site will be determined from the BGS maps and borehole logs available through the BGS and from the ground investigation reports for the site.

Hydrogeology

4.12.4 The site is located on a Principal Aquifer (Chalk) within an inner Source Protection Zone. The location and type of any other licensed or private abstractions in the vicinity of the site will be identified in the baseline study.

4.12.5 The Groundwater Vulnerability maps will be used to identify the sensitivity of any aquifer unit beneath the site and also the soil leaching potential.

4.12.6 Groundwater levels will be estimated from the hydrogeological map and existing borehole data where possible.



Risk Assessment Procedure

4.12.7 The assessment system identifies the different environmental setting criteria that may affect the potential impact of a location on controlled waters arising by any contaminants both historical or brought to the site during its construction or operational phases. It will include an assessment of any existing, created or modified pathways for contaminant transport to any sensitive environmental receptors surrounding the site. A site conceptual model will be constructed following existing best practice to permit a robust and defensible risk assessment to be undertaken. The conceptual model would incorporate the following key site specific data: -

• The character, size and extent of any likely sources of contamination existing within the site soils (Current Source);

• The potential sources of contamination which could be derived from the construction of operation of the site (Potential Source);

• The thickness of the unsaturated zone/depth to water table (Pathway);

• The leaching potential of the soils and their ability to attenuate potential pollutants (Pathway);

• The location of any groundwater abstractions and Source Protection Zones (Receptors);

• The location of any nearby surface watercourses or other groundwater dependent water features (Receptors).

Contamination

4.12.8 Use will be made of regulatory guidance on the assessment of likely contamination being present on the site as part of a desk study. This would be undertaken following the interpretation of the following key data sources where available:

• Environmental Disclosure Report

• Historical Maps

• Historical Aerial Photographs

• Previous Client Held Site Investigation Reports

4.12.9 The key aspects with regards to geology hydrogeology and land contamination for this project are considered to be:

• Construction Effects: potential impacts, from additional sources of contamination, mobilisation of existing contaminants, and the creation of rapid pathways, associated with the construction of the proposed development on existing sensitive receptors; and

• Operational Effects: potential additional sources of soil or water contamination from materials stored or generated in the facility, on existing sensitive receptors.

Baseline

Land Stability and Ground Conditions

4.12.10 From a hydrogeological context, the site is located on a former outcrop of drift deposits under which Cretaceous chalks sub crop. Such solid deposits attain a Principal aquifer designation under the Environment Agency’s groundwater protection policies added to which the site is located within an Inner Source Protection Zone.



4.12.11 A contaminated land assessment undertaken in 2008 across the part of the Harper Lane site to the north of the boundary of the proposed EFW site, as part of planning application No: 5/2596-08 (CM0117). The findings of this report were as follows:

• hydrocarbon contamination (due to the presence of ash, clinker and tarmac) was present in relatively immobile forms;

• elevated concentrations of hydrocarbon fractions were having only a limited effect on groundwater;

• risk to the quality of groundwater and the River Colne from leaching Total Petroleum Hydrocarbons (TPH) was negligible; and

• monitoring in down hydraulic gradient boreholes demonstrated that there was no significant risk to groundwater from identified contaminants.

4.12.12 EEW commissioned a site investigation study in the southern part of the at the Harper Lane site in early April 2010. In total ten boreholes were advanced across the site to investigate ground conditions for foundation design, and to collect shallow soil samples. The results of the investigation are set out below:

Geology:

• Topsoil c. 0.3m thick

• Chalk fill

• Chalky Clay with occasional flints 0.9-3.5 m thick. present in all boreholes with exception of borehole 3.

• Bedrock: Chalk

Boreholes record 0.3m of topsoil underlain by chalk fill and chalky clay to 2.6 metres below ground level (mbgl) in borehole 8 and 2.7mbgl in borehole 10.

Chalk bedrock proved from 8.4 to 12.mbgl in borehole 8 and from 3.1-13.mbgl in borehole 10. The chalk was clayey from 5.3-8.4mbgl in borehole 8.

Hydrogeology:

Groundwater monitoring facilities were not installed in the boreholes, however groundwater strikes indicated that the groundwater in the chalk aquifer is approximately 23 to 25 m below ground level.

Contamination:

The laboratory analysis of soil samples collected from made ground at the site revealed that none of the elements or compounds tested were recorded in excess of the human health guideline thresholds for commercial or industrial use.

4.12.13 The results of both the 2008 and 2010 site investigation will be taken into consideration from the outset and EEW will prepare a robust ‘Construction Environmental Management Plan’ which will guide all stages of development and ensure good management practices. The establishment of quality environmental management practices, will ensure deliverability and are in accordance with the policy framework.

4.12.14 At this preliminary stage no further baseline conditions in terms of Geology, Hydrogeology and Land Contamination have been established.



4.13 Noise and Vibration

Policy Context

4.13.1 The results of the methodology as set out below will be assessed against all key European and National Legislation, including the British Standard 4142 ‘Method for Rating industrial noise affecting mixed residential and industrial areas’ (BS 4142, EU IPPC Directive: Environmental Permitting Regulations (England and Wales), 2007and Horizontal Guidance - H3 Part 2 Noise Assessment and Control. The results of the methodology will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD and PPG24 guidance.


4.13.2 Noise and vibration can have a significant effect on the environment and on the quality of life enjoyed by individuals and communities. The aim of the planning system is to minimise adverse effects of noise and vibration without placing unreasonable restrictions on development or adding unduly to the costs and administrative burdens of business.

4.13.3 The effects of noise and vibration can be a material consideration in the determination of planning applications. The planning system has the task of guiding development to the most appropriate locations and, wherever practicable, noise and vibration-sensitive developments are separated from major sources of noise and vibration. It is equally important that new development involving noisy activities should, if possible, be sited away from noise-sensitive land uses. Where it is not possible to achieve such a separation of land uses, developers may consider reduction of noise levels or the mitigation of adverse effects of noise, which may be enforced by the planning authority through the use of conditions or planning obligations.

4.13.4 The key aspects with regards to noise and vibration for this project are considered to be:

• Construction Effects: noise and vibration from plant and activities associated with the construction of the proposed development on existing sensitive receptors; and

• Operational Effects: noise from the development, including changes in traffic flow characteristics on the local road network associated with the proposed development, on existing sensitive receptors and any that are proposed within the development (significant vibration effects are unlikely).

4.13.5 The site is approximately 100 – 200 m from the closest noise sensitive receptors, which include Bridgefoot Cottages to the northwest; gated residential houses on the south side of Harper Lane; a golf driving range; and a building at the entrance to Houndswood House (opposite to the site entrance) that may be residential (to be confirmed by planners and/or during noise baseline site visit). There are also noise sensitive residential receptors several hundred metres to the west (Netherwylde Cottages and Netherwylde Farm); to the south (Watling Street); to the southeast (Harper Lodge Farm House and Harper House); and, subject to confirmation from planners and/or baseline noise survey, to the north (Old Parkbury). There are also potentially noise sensitive ecological sites close to the proposed development.

4.13.6 For such facilities, the most significant sources of noise emissions are (not in order of likely significance):

• the facades of the buildings (due to their large size);



• ventilation louvres (as areas with lower noise attenuation than the facades and as sources during the night-time, which is typically more noise sensitive than the daytime)

• external noise sources - delivery HGVs / unloading area, the stack outlet and cooling plant (e.g. air-cooled condensers).

Noise and Vibration Environmental Statement Chapter

4.13.7 The Environmental Statement chapter will have regard to:

1. Consultation with St Albans City and District Council (SACDC) and Hertfordshire County Council. It will quantitatively assess the noise and vibration effects associated with the construction of the proposed development based upon the methodology contained within BS 5228 ‘Noise and vibration control on construction and open sites’ (Parts 1 and 2) and an assumed indicative plant list and construction methodology.

2. It will quantitatively assess the noise effects of the proposed development based upon a SoundPLAN noise model that includes the significant noise generating items of plant and activities. The assessment will consider effects to residential receptors in accordance with BS 4142 and Environment Agency (EA) guidance and effects to recreational amenity (golf driving range and public footpaths) on the basis of professional judgement and noise change (no published criteria or methodologies).

3. Quantitatively assess the effects of delivery traffic (road and rail) using baseline data from the Transport Assessment and operational flow data from the client using the methodology contained within Calculation of Road Traffic Noise (CRTN) and Calculation of Railway Noise (CRN).

4. The chapter will include:

• descriptions of the standards and guidance upon which the assessment methodology and criteria are based;

• a summary of the assessment methodology and criteria;

• a description of the baseline surveys that were undertaken and a presentation of the results;

• a summary of the assessments, the results thereof and statements of significance in accordance with the adopted criteria;

• a description of recommended types of mitigation, if necessary, to reduce the significance of the effects; and

• an assessment of the cumulative effects with committed development in the area.

5. The chapter will provide noise technical data for the assessment of effects to ecological receptors undertaken by the ecologist. Data will include:

• Baseline noise levels for 3 ecological receptor areas for ecologically relevant periods – for example, evening or dawn chorus; and in ecologically relevant indices, such as spectral levels – because overall A-weighted noise levels are designed to be relevant to human hearing and may not be relevant to the species under consideration (to be directed by ecologist);

• Maximum impulsive noise levels during construction and operation of the project at each ecological receptor location and, if appropriate, noise contour maps; and



• Spectral continuous noise levels (octave-band Leq) during operation of the project at each ecological receptor location and noise contour maps (overall weighted or spectral band levels).

Baseline

4.13.8 At this preliminary stage the baseline conditions in terms of Noise and Vibration have not yet been established.

4.14 Archaeology and Cultural Heritage

Policy

4.14.1 The results of the methodology as set out below will be assessed against all key European and National Legislation, including the Ancient Monuments and Archaeological Areas Act 1979 and the Planning (Listed Buildings and Conservation Areas) Act 1990. The results of the assessment methodology will also be assessed against all the relevant development plan documents, including the HWLP, HMLP, CDSAD and PPS5 guidance.


4.14.2 The information provided has been reviewed and publically available information has been briefly consulted. It is noted that the proposed development area is located in an area adjacent to or containing archaeological and cultural heritage remains.

4.14.3 The LPA would normally wish to ensure that it has sufficient information to ensure that an appropriate mitigation strategy could be implemented with regard to cultural heritage and to ensure this through conditions. On this basis it would be appropriate to undertake a desk based assessment of the site at this stage, with any pre- application fieldwork to be undertaken on an iterative basis

Pre-application Consultation and Design Advice

4.14.4 On the basis of recent experience supporting planning applications in this area, a flexible approach to design will be followed and early consultation with English Heritage and the County Planning Archaeologist.

Desk Based Assessment

4.14.5 The desk based assessment of archaeology and cultural heritage would be carried out in accordance with current best practice guidance issued by the Institute for Archaeologists (IfA) and the Institute of Environmental Assessment and Management (IEMA).

4.14.6 The work would involve the gathering of baseline data relating to the known and potential cultural heritage resources within a defined study area centred on the site of the proposed development. Such resources would include nationally designated features such as Scheduled Monuments, listed buildings, Registered Parks and Gardens, locally designated features (i.e. Conservation Areas, Areas of High Archaeological Potential, locally listed buildings etc.), archaeological sites and find-spots recorded on the relevant Historic Environment Record (HER) and with English Heritage, as well as mapping evidence suggesting potential heritage assets. National guidance on archaeology and planning would be reviewed, along with relevant local and structure plan policies.

4.14.7 Sources would include the Historic Environment Record (HER) held by Hertfordshire County Council. In addition, information on Scheduled Ancient Monuments, listed buildings, Registered



Parks and Gardens and Registered Battlefields would be obtained from English Heritage. A review of relevant documentary and archival material held in libraries and archives would be undertaken. An iterative approach will be adopted during this process to determine the scope of the above consultations/searches.

4.14.8 A site visit and walkover survey will be undertaken to establish the presence of previously unrecorded above ground archaeology, and/ or to further assess the potential of recorded above ground archaeology. In addition, the field visit will assess the suitability of any further survey techniques and will also provide an indication of the likely effect of the proposed development on the settings of cultural heritage features.

4.14.9 The results of the baseline assessment will be discussed as appropriate with the archaeological advisor to Hertfordshire County Council, the Conservation Officer and English Heritage. The main aim of the discussions will be to appraise the quality of available information and to decide if further evaluation in the form of archaeological fieldwork (intrusive or non-intrusive, or a staged approach combining both methodologies), would be required as part of the EIA process. If necessary, archaeological surveys would be undertaken as appropriate in order to identify the nature and significance of any buried remains that may be adversely affected by any part of the proposed development.

4.14.10 Any archaeological fieldwork would be undertaken by a specialist contractor under the supervision of EEW or their advisors. The project designs would agreed with the Hertfordshire County Council Planning Archaeologist (and English Heritage if appropriate) prior to the appointment of the archaeological contractor.

4.14.11 The desk based assessment would be used as a consultation document for discussion with the statutory consultees. This would assist in the finalisation of the site layout.

Consultation with Hertfordshire County Council and Statutory Consultees

4.14.12 Consultations will also take place with key statutory and non-statutory organisations/ consultees. These are:

• English Heritage;

• Planning Archaeologists; and

• Appropriate Conservation Officers.

4.14.13 The County Archaeologist would be concerned primarily with direct physical impacts on archaeological remains, but will also be interested in effects on settings. English Heritage and the Conservation Officer are likely to focus on the impact of the proposals on the settings of designated sites and buildings, and on the broader historic landscape.

Scope of Assessment

4.14.14 The EIA chapter will include the following:

• an overview of relevant planning policy and guidance;

• a brief summary of the previously known historic and archaeological context of the site based on the desk-based assessment;

• a summary of the results of any archaeological fieldwork carried out as part of the assessment;

• a description of the methodology used for the assessment of effects on the settings of



designated historic and archaeological resources;

• appropriate illustrative materials;

• a site by site assessment of the effects of the proposal on the settings of designated historic and archaeological resources within the defined and agreed study areas;

• proposed mitigation measures to avoid/reduce impacts on buried archaeological remains as agreed with the County Archaeologist;

• summary of effects; and

• the desk-based assessment will be presented as a technical appendix, as will the results of any archaeological evaluation that has been carried out.

Guidance and Methodologies

4.14.15 The desk-based assessment and any archaeological field evaluation will be undertaken with reference to published guidance including:

• Planning Policy Guidance: Planning And The Historic Environment (PPG 15) Department of the Environment, DNH September 1994;

• Code of Conduct Institute of Field Archaeologists 2006 and

• Standard And Guidance for Archaeological Desk based Assessment Institute of Field Archaeologists 2001.

• A clear and robust methodology has been developed for the assessment of the potential effects of developments on the settings of designated historic environment resources. This has been used on many developments, and has been found to be accurate and defensible.

Types of Impact Assessed

4.14.16 The Archaeology and Cultural Heritage chapter will assess both the effects relating to the operation of the proposed development and also the effects associated with its construction.

4.14.17 It will consider direct physical and indirect visual impacts. It is assumed at this stage that no specialist assessment of visual impacts (i.e. wireframes, photomontages etc.) would be required.

Potential Cumulative Effects

4.14.18 The simultaneous, successive and sequential cumulative impacts of other developments within an agreed radius of the site which are either operational, under construction, consented or the subject of a full planning application will also be assessed.

Baseline

4.14.19 There are four scheduled ancient monuments in the area one to the far north, two close by to the east and west and one to the far south.

4.14.20 The area also contains three Registered Parks and Gardens, a Site of Special Scientific Interest and ancient and semi-natural woodland, some of which has been replanted. Views from the Registered Parks and Gardens will also be considered as part of the assessment.

4.14.21 English Heritage also has two buildings designated as Grade II listed in the area. One being the ‘Stable Grange to South of Harperbury Hospital’ and the other ‘Harper House, Harper Lane’.



4.15 Amenity Issues

Policy Context

4.15.1 The principal means of control over potential environmental nuisance due to the generation of litter or through the attraction of vermin and other pests to the site will be the site’s Environmental Permit.

4.15.2 Consideration of the effect on the amenity of local areas and their residents is, however, important when assessing the suitability of a site for the development proposed. Therefore, amenity issues will be assessed against all relevant material planning policies and guidance, including the HWLP, HMLP and CDSAD.

4.15.3 In addition to the air quality and noise issues which will be addressed separately within the ES, waste management facilities also have the potential to cause environmental nuisance due to the generation of litter or through the attraction of vermin and other pests to the site.


4.15.4 The chapter provides a qualitative assessment of the potential impacts.

Baseline

4.15.5 A number of potential receptors for amenity impacts have been identified. These include Harper Lodge Farm (0.4km south), Houndswood House (0.38km southeast), Houndswood Farm (0.51km southeast) and properties located to the west of Harperbury Hospital (0.8km east) (all measured from the centre of the rail loop).

4.15.6 At this preliminary stage no further baseline conditions in terms of amenity have been established.

4.16 Site Waste Assessment

Policy

4.16.1 All waste generated during the construction and operation will be managed in line with section 34 “Duty of Care” of the Environmental Protection Act 1990.


The site waste management plan will assess three key waste generation sources as set out below:

• Office and Visitor Facility Waste;

• Construction Phase Waste; and

• Operational Phase Waste.

Office and Visitor Facility Waste

4.16.2 Office and visitor facility waste arisings generally consist of general office waste such as paper, cardboard, food waste and other wastes generated during the operation of the EfW Facility (excluding process residues). It is intended that the Environment Agency’s Waste Benchmarker will be used to assess these wastes, based on the assumption of standard office and business waste streams.

4.16.3 The Waste Benchmarker tool provides estimated quantities of waste from specific categories of industry for a given number of employees. No specific category specifically identifies the operation of



an EfW facility, therefore the classification of ‘miscellaneous business activities not elsewhere classified will be used.

Construction Phase Waste

4.16.4 Construction waste arisings will be managed primarily through the production of a Site Waste Management Plan (SWMP) and will compliment the Construction and Environmental Management Plan (CEMP). This will be developed during the detailed design phase in order to make an assessment of the potential for waste minimisation in the site preparation and construction stages. It will also provide more detail of waste arisings and assess the management options for these. The key stages of a SWMP, in line with guidance published by the DTI can be summarised as:

• identify waste, highlighting potential for waste minimisation, reuse and recycling in the design stage;

• identify waste management options, prioritising reuse and recycling;

• identify waste management sites;

• plan site waste handling to minimise potential for wind-blown dust and runoff from waste stockpiles;

• communicate plan to all on-site;

• measure waste arising;

• monitor SWMP to identify areas for improvement; and

• review.

4.16.5 The SWMP will be a working document and will be updated at regular intervals throughout the project. It will identify and prioritise options for minimisation, reuse and recycling of construction wastes where practicable. In addition it will allow for emerging markets, best practice and any unforeseen changes to the project to be taken into account.

Operational Phase Waste

4.16.6 Operation Phase Waste arisings will be managed by the EfW Facility. The Environmental Statement will inform the assessment, setting out through design detailing and specific technical assessments, how waste feed stocks, incinerator bottom ash (IBA) and air pollution control residues will be managed and also identify specific mitigation measures.

4.16.7 Key issues to be addressed will include waste storage, reprocessing and management of residues, hazardous waste disposal facilities and waste transportation.

Baseline

4.16.8 At this preliminary stage no baseline conditions in terms of the site waste assessment have been established.

4.17 Social and Economic Impacts

4.17.1 A range of social and economic data sets will be drawn upon to carry out this assessment. The most important single source will be the 2001 Census, which contains a wide variety of economic and related data, including economic activity, industry, occupation, qualifications, travel to work, mode of travel to work and car ownership.



4.17.2 Since the data from the Census are now 9 years old, other sources will be used for more up to date information where available. These include the NOMIS Labour Market Profiles and any relevant studies published by the local authorities and other organisations.

4.17.3 The Census does not cover earnings. The Labour Market Profiles and other sources will be relied on for this information.

4.17.4 These data will be analysed in the context of the development plans for the area and other strategies, including economic and community strategies.

4.17.5 The assessment will establish the baseline conditions using all available data and other qualitative information where appropriate. The principal community effect is like to be the new employment, which will be created by the new development at both the construction and operational stages. This will be assessed in terms of the occupational structure of the resident population set against the requirements of the development, taking into account data on vacancies by occupational group if these can be obtained. The proposed development is unlikely to create sufficient employment to give rise to discernible multiplier effects.

4.18 Summary

4.18.1 This concluding section of the Environmental Statement will draw together the results of the topic specific assessments. It will describe the disciplines addressed, summarise how they have been assessed, identify the likely significant effects and detail further mitigation measures that are required and recommended. It will also give consideration to the following categories of impacts:

• Cumulative impacts, which are those effects of the development that may interact in an additive or subtractive manner with the impacts of other developments that are not currently in existence, but may be by the time the development is implemented

• Interactions between impacts, where impacts in different categories as set out in the individual topic chapters may act in conjunction with either beneficial or detrimental effect; and

• Residual impacts, which relate to those that remain significant following the application of mitigation measures.



DRAWINGS

Plan 1: Location Plan

Plan 2: Indicative Planning Application Area

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Proposed Location of the EfW Facility

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Indicative Planning Application Area