2. approach to eia

2.1

2. Approach to EIA

Introduction

2.1 This chapter sets out the approach and methodology that has been undertaken to complete

the assessment of the likely significant environmental effects of the Proposed Development

(as described in Chapter 4: The Proposed Development and supporting plans).

2.2 This Chapter sets out the following:

• Adoption and application of best practice within the EIA process;

• Scope of the EIA, including a summary of the EIA Scoping process and the technical

disciplines scoped in and out of the EIA;

• Stakeholder engagement, summarising the level of engagement with statutory and

non-statutory consultees, public consultation events and other forms of engagement;

and

• Approach to the assessment of likely significant effects, specifically covering: approach

to baseline; future baseline; identification of sensitive receptors; information to inform

assessment; use of tolerances; implementation of mitigation; significance criteria; and

limitations/assumptions.

Adoption of Best Practice

2.3 As confirmed within Chapter 1: Introduction, this ES meets the requirements set out in

Regulation 18, Paragraphs 3 – 4 and Schedule 4 of the EIA Regulations.

2.4 In addition, the EIA (and therefore the ES) has been undertaken with due consideration of

the following guidance documents:

• Ministry of Housing, Communities & Local Government, Planning Practice Guidance

(Ref 2.1);

• IEMA, EIA Guide to Shaping Quality Development (Ref 2.2); and

• IEMA, EIA Guide to Delivering Quality Development (Ref 2.3).

Scope of the ES

EIA Scoping

2.5 A request for an EIA Scoping Opinion, together with an EIA Scoping Report (Appendix 1.1),

prepared in line with Regulation 15, of the EIA Regulations was submitted to SBC in August

2018.

2.6 In response, SBC provided an EIA Scoping Opinion on the 16th October 2018 (Appendix 1.2),

supported by technical responses from consultees (both statutory and non-statutory) and

other interested parties.

2.2

2.7 Table 2.1 summarises the comments received as part of the EIA Scoping Opinion (full details

of which can be found in Appendix 1.2) and how these have been addressed within the ES,

or if more appropriate, within a standalone planning document supporting the overall

Application.

2.8 Whilst the EIA Scoping Report sought to establish the overall framework for the EIA in

relation to the environmental topics and likely significant effects, the Proposed Development

and the strategies that underpin it have been refined or informed by further technical

studies, modelling and analysis works and engagement with consultees.

2.9 As a result, where the scope of the assessment proposed within the EIA Scoping Report has

changed, this has been clearly identified within the Scope of Assessment section of Technical

Chapters 6 – 18.

2.3

Table 2.1: Summary of EIA Scoping Opinion Comments

Summary of Scoping Comment Consultee How/ Where the comment has been addressed

“The proposed development, for which the above Opinion

is sought, conflicts with Swindon Local Plan Policy NC3

which covers development to the east of the A419 as

defined on the Policies Map. The site lies within the

Indicative Non-Coalescence area of NC3 and outwith the

allocated development area.”

Campaign for the

Protection of Rural

England (CPRE) and

North Wessex Downs

AONB

Compliance with policy is assessed within the Planning

Statement submitted in support of the Application.

“This Science Park is in reality an industrial site with some

specialised manufacturing. There is no estimated number

of jobs to be created. It appears to be a hybrid application

of low density.”

CPRE The job numbers that are anticipated during construction and

operation of the Proposed Development, and the

methodology to reach these numbers is described in Chapter

6: Socio-Economics.

“A Science and Technology centre is being developed at the

former Hullavington Airfield, being brownfield this would

be a more appropriate site.”

CPRE The alternatives considered by the Applicant are reported in

Chapter 5: Consideration of Alternatives.

“We consider the following areas necessary for inclusion

within the Environmental Statement / planning submission:

• Surface Water Drainage and Flood Risk

• Water Resources (supply) and Water Efficiency

• Wastewater

• Groundwater Protection

• Impact on protected species and habitat

Environment Agency The following are included in the ES as follows:

• Surface Water Drainage and Flood Risk

considered in Chapter 11: Water Resources, Food

Risk and Drainage.

• Water Resources (supply) and Water Efficiency

considered in Chapter 11: Water Resources, Food

Risk and Drainage.

• Wastewater considered in Chapter 11: Water

Resources, Food Risk and Drainage.

2.4


• Construction Environment Management Plan,

including pollution prevention measures, and

• Waste management”

• Groundwater Protection considered in Chapter

11: Water Resources, Food Risk and Drainage.

• Impact on protected species and habitat

considered in Chapter 18: Ecology.

• Construction Environment Management Plan,

including pollution prevention measures – these

are referenced throughout the Technical

Chapters (6 – 18) in the Primary and Tertiary

Mitigation section as well as Chapter 4: The

Proposed Development.

• Waste management is considered in Chapter 16:

Waste.

“The site may be at risk from other sources of flooding (e.g.

groundwater, surface water), which are not considered in

the mapping of flood zones.”

Environment Agency Groundwater and surface water are considered in Chapter 11:

Water Resources, Food Risk and Drainage.

“When drawing up wastewater treatment proposals for

any development, the first presumption is to discharge foul

drainage into a public sewer to be treated at a public

sewage treatment works (those provided and operated by

the water and sewerage companies). This should be done

in consultation with the local sewerage company.

Where a connection to a public foul sewer is not feasible (in

terms of cost and/or practicality) a package sewage

treatment plant can be considered. This should offer

treatment so that its final discharge meets the standards

set by the required Environment Agency Environmental

Environment Agency Under the new charging arrangements brought out in April

2018 (Charging Rules for New Connection Services, OFWAT),

Thames Water has an obligation to provide infrastructure to

the Site once planning permission has been obtained. Thames

Water has proposed to provide a foul pumping station(s)

adjacent to Wanborough Wastewater Treatment Works to

divert flows from the existing 225mm foul sewer and the

proposed development up to the Swindon New Eastern

Villages development to support the Proposed Development.

Further details can be found in Chapter 11: Water Resources

2.5


Permit A proposal for a package sewage treatment plant

and infrastructure should set out clearly the responsibility

and means of operation and management to ensure that

the Permit is not likely to be breached during the life of the

plant.”

Flood Risk and Drainage and the Utilities Statement

(Appendix 11.3).

“Sustainable design and construction should be

implemented across the proposed development. This is

important in limiting the effects of, and adapting to climate

change.”

Environment Agency Chapter 4: The Proposed Development and Chapter 17:

Climate Change outline the measures to be implemented by

the Proposed Development to adapt to climate change.

“Information on biodiversity impacts and opportunities

should inform all stages of development including, for

instance, site selection and design including any pre-

application consultation as well as the application itself.”

Environment Agency The factors that have been considered in the site selection and

design are described in Chapter 5: Consideration of

Alternatives. Strategic landscape zones have been

incorporated into the design of the Proposed Development

and enhance biodiversity.

“If historic use of the site may have caused land

contamination then paragraph 109 of the NPPF states that

the planning system should help prevent both new and

existing development from contributing to, or being put at

risk from unacceptable levels of water pollution. Thorough

site investigation information must be prepared and

presented by a competent person.”

Environment Agency The potential risk of contamination of controlled waters from

ground contaminants and surface run-off is assessed during

construction and operation in Chapter 10: Geology and Soils.

“Safeguards should be considered for implementation

during the construction phase to minimise the risks of

pollution from the development.”

Environment Agency The mitigation to reduce the risk of pollution from

construction of the Proposed Development is outlined in

Chapter 4: The Proposed Development, Chapter 10: Geology

and Soils and Chapter 11: Water Resources, Flood Risk and

Drainage, and summarised in Chapter 20: Summary of the ES

and Schedule of Mitigation.

2.6


“Should this proposal be granted planning permission, then

in accordance with the waste hierarchy, we wish the

applicant to consider reduction, reuse and recovery of

waste in preference to offsite incineration and disposal to

landfill during site construction.”

Environment Agency Chapter 16: Waste has considered reuse and recycling of

materials in the assessment of the increase in waste

generation during construction.

“Environmental impacts arising from any disruption during

construction, traffic volume, composition or routing change

and transport infrastructure modification should be fully

assessed and reported, along with the environmental

impact of the road network upon the development itself.”

Highways England The environmental impacts from construction traffic are

assessed within Chapter 12: Transportation, Chapter 13: Air

Quality, and Chapter 14: Noise and Vibration.

“Information relating to the flooding zone that the site is

located is required and we stress that development must

not lead to any surface water flooding on the SRN

carriageway.”

Highways England Chapter 11: Water Resources, Flood Risk and Drainage

confirms that the Site is in Flood Zone 1, so at low risk of

flooding, and that the Surface Water Drainage Strategy will

ensure that the risk of flooding is not increased elsewhere.

“Any assessment should consider the operation of the

Strategic Road Network – in this case M4 J15 and the A419

carriageway; specifically any links to the network which

could detrimentally affect its performance. This includes

the M4 J15 / A419 and A419 / Purley Road / Pack Hill /

A4259 interchanges.”

Highways England The traffic flows are based upon the SBC Strategic Saturn

Model covering Swindon and the wider area in agreement

with SBC. Further information on this is detailed in Chapter 12:

Transportation.

“Highways England should be involved in any discussions

regarding use of the Swindon Borough Council traffic

model in order to assess the impact of the proposed

development. This is to ensure that the scope of the model

and model outputs will be acceptable to Highways

England, before work is undertaken.”

Highways England Chapter 12: Transportation outlines the consultation that has

been undertaken with regards to the traffic model. Further

information on additional modelling is explained in the

Limitations and Assumptions section of this chapter.

“Analysis of accident data for the latest available full five-

year period regarding the SRN surrounding the site should

Highways England The assessment of accidents in Chapter 12: Transportation

has considered data for a five year period. The Baseline

2.7


be undertaken. Any relevant collision clusters or recurring

accident causation factors should be assessed and properly

mitigated where the proposed scheme is shown to make

conditions worse.”

Conditions section of this chapter considers collisions on key

routes and whether there are any trends in these accidents.

“The potential impact of construction vehicles on the SRN

should be included within the assessment work.”

Highways England The traffic flows are based upon the SBC Strategic Saturn

Model covering Swindon and the wider area, which was

agreed with SBC. Further information on this is detailed in

Chapter 12: Transportation.

“However, we have concerns with the scoping exercise

already undertaken (pages 32 to 42 of the Scoping Opinion

Request; Turley 2018), in particular the lack of a reference

to the Lower Wanborough Conservation Area or suitable

maps or figures to locate assets scoped in or out at this

stage.”

Historic England The Built Heritage Statement (Appendix 8.1) clarifies that

although the Lower Wanborough Conservation Area falls

within the study area, the analysis indicates that the

understanding or appreciation of the significance of this area

would be unlikely to be impacted by the Proposed

Development. The location of this Conservation Area is shown

in Appendix 3 of Appendix 8.1.

“We also note a degree of apparent confusion between the

built heritage and archaeological assets: the Hall Place

Scheduled Monument (above) is referred to as part of the

historic built environment.”

Historic England Hall Place has been scoped out of the assessment of built

heritage assets in Chapter 8: Built Heritage.

“In terms of detailed assessment methodology, we would

expect any assessment of settings to be undertaken in

accordance with our recently-published guidance (HE 2017

[rev] Good Practice Advice in Planning, Note 3, The Setting

of Heritage Assets). Similarly, we would expect any over-

arching EIA methodology to accord with the guidance given

in Highways Agency note 20807 of 2007, commonly known

as DMBRB 2.”

Historic England Chapter 8: Built Heritage has given consideration to Good

Practice Advice Note 3: The Setting of Heritage Assets (2nd

Edition) (2017) and the Design Manual for Roads and Bridges

(Vol. 11 Section Part 2) (2nd Edition 2019).

2.8


“The landscape assessment should also consider views to

the north Wessex downs as it is part of the experience

taken when using the PROW network on the edge of

Swindon and not merely views from as noted in para 7.1 of

the report.

Due to the potential for long distance views a 5km radius

should be set rather than 2km with a couple of ad hoc

locations. ZTVs would set the groundwork for an LVIA in

terms of potential viewpoints.

Liddington Castle should be included and the Ridgeway

national trail should also be landscape receptors (para

7.11).

Additional representative views should be included in an

LVIA from the PROW south of Wanborough House with

views towards the SE, the PROW to the NW of Marsh Farm

with a view SE from part way between the A419 and Marsh

Farm and a view N to NW from below Hill Barn adjacent to

the Ridgeway (road) at the base of Liddington Hill.

Representative view 13 should include a view from

Liddington castle and view 15 should include the Ridgeway

National Trail and simply the Road.”

North Wessex Downs

AONB

Chapter 7: Landscape and Visual contains a summary of

consultation and actions taken in response. This outlines that:

• Setting of the AONB was scoped into the

assessment;

• The ZTV study area was increased;

• The view from Liddington Castle was considered

but a separate representative viewpoint has not

been included due to similarity with VP13 and

VP15;

• The views from PRoW at Hill Barn were not

included, as this area is represented by VP15; and

• PRoW from south of Wanborough House and NW

of Marsh are included as part of a visual receptor

group, but were not included as additional

viewpoints, as VP03 is considered to be

representative of views from this side of the Site.

“Would disagree with para 15.3 in terms of the

Environmental Zone classification for lighting, given its

agricultural use and lack of street lights the site would be

categorised under EZ1 not EZ2 as stated. Dark skies are a

special quality of the AONB and this extends beyond the set

boundary into the setting.”

North Wessex Downs

AONB

The Baseline Conditions section of Chapter 15: Lighting

categorises the Site as on the border of Environmental Zones

E1 and E2.

2.9


“Lighting effects need to be considered against the

landscape particularly the AONB and not simply to the

users of local road and footpath networks.”

North Wessex Downs

AONB

The changes from lighting on the North Wessex Downs AONB

are considered in Chapter 7: Landscape and Visual.

“A full ecological assessment should be carried out due to

the proximity of the local wildlife site and Coate Water

SSSI.”

North Wessex Downs

AONB

No effects on the Coate Water SSSI/LNR’ are expected due to

(i) distance from the Site, (ii) the habitats present within the

Site being highly sub-optimal for species the SSSI is designated

for, (iii) the nature of the Proposed Development which is

unlikely to increase recreational pressure on the SSSI, and (iv)

the relative resistance of habitats within the SSSI to the effects

of nitrogen deposition. Therefore this is scoped out of the EIA.

Chapter 18: Ecology contains further details.

“Thames Water considers the following issues should be

considered and covered in either the EIA or planning

application submission:

1) The developments demand for Sewage Treatment and

network infrastructure both on and off site and can it be

met.

2) The surface water drainage requirements and flood risk

of the development both on and off site and can it be met.

3) The developments demand for water supply and

network infrastructure both on and off site and can it be

met.

4) Build – out/ phasing details to ensure infrastructure can

be delivered ahead of occupation.

5) Any piling methodology and will it adversely affect

neighbouring utility services.”

Thames Water These issues are covered in Chapter 11: Water Resources,

Flood Risk and Drainage, Appendix 11.3: Utilities Statement

and Chapter 4: The Proposed Development.

2.10


“I would except to see an EIA with a comprehensive

chapter on cultural heritage submitted with any planning

application to develop this site. The Chapter will be need to

include the results from a programme of archaeological

evaluation to include geophysical survey and trial

trenching.”

Archaeological

Advisor (Wiltshire

Council)

Cultural heritage is assessed in Chapter 8: Built Heritage and

Chapter 9: Archaeology. The results of the geophysical survey

and field evaluation (trenching) have informed Chapter 9:

Archaeology.

“Consideration of the effects of the proposed development

upon the setting of heritage assets includes the asset’s

physical surroundings as well as the experience of the

asset.”

SBC Conservation

Officer

Chapter 8: Built Heritage considers the effects upon setting of

heritage assets during construction and operation.

“Some of the omitted designated assets as identified at pre

application are now generically included in Table 8.1 (EIA

SOR Table 8.1) for example listed buildings which are also

contained within Conservation Areas. I note that those for

Upper Wanborough are seemingly restricted to those in

‘closer proximity’ whereas there is no seemingly

comparable limitation to those in Liddington (or Lower

Wanborough Conservation Area). Again the basis for

consideration for those included or excluded needs to be

fully evidenced.”

SBC Conservation

Officer

The evidence base for scoping designated assets in and out of

the EIA is explained in the Scope of the Assessment section in

Chapter 8: Built Heritage. Since submission of the EIA Scoping

Report (Appendix 1.1), a number of assets are not considered

to have the potential to experience significant effects. The

evidence for this is also included in the Scope of the

Assessment section of this chapter.

“Regarding this request (EIA Scoping Opinion Request,

Turley, August 2018) to scope ecology out of the EIA, I am

of the opinion that it should be included within the EIA.”

SBC Ecology Officer Ecology has been scoped into the EIA, the assessment of

which can be found at Chapter 18: Ecology. The scope of the

ecology assessment is outlined in the Scope of the Assessment

section in Chapter 18: Ecology.

“Noise during the construction phase, especially from haul

routes in/out of the site. I would be concerned if the current

trackway serving Inlands Farm was used as the primary

haul route, as this would result in all construction traffic

SBC Environmental

Health Officer (Air

Quality & Noise)

Construction noise at residential receptors has been assessed

in Chapter 14: Noise and Vibration.

2.11


passing a noise sensitive receptor on the quiet north west

border of the proposed development.”

“Noise during the operational phase from plant equipment

and vehicle traffic on site, a robust BS 4142:2014

assessment should identify any potential issues at this

stage. Where the rating level of any noise source exceeds

5dB below the background level (LA90), as determined by a

BS 4142:2014 assessment, details of noise mitigation

would be expected.”

SBC Environmental

Health Officer (Air

Quality & Noise)

The assessment of noise from external fixed plant items and

heavy goods vehicles manoeuvring and loading/unloading

within the Site has used BS 4142 Noise Emission Limits.

Further information can be found in Chapter 14: Noise and

Vibration.

“Concerns surrounding dust and air quality will be

answered in the construction environmental management

plan.”

SBC Environmental

Health Officer (Air

Quality & Noise)

Chapter 13: Air Quality and Chapter 4: The Proposed

Development outline the measures to control dust and air

quality during construction, which will be included in a

Construction Environmental Management Plan.

“The final, and perhaps biggest concern is the risk of a

perceived loss of amenity for Wanborough residents

because the development will inevitably impact upon the

existing night-time scene between Wanborough and the

A419/Swindon, as well as the potential for light intrusion at

nearby sensitive receptor properties.”

SBC Environmental

Health Officer (Air

Quality & Noise)

The changes in night time scene for residential receptors with

direct and partial views of the Site during construction and

operation has been assesses in Chapter 15: Lighting.

“The study area needs to be informed by a robust ZTV

study, not a subjective one without apparent evidence

basis, as appears to have been proposed. Pending receipt

of this, the effects and receptors as described in the ESSR

(7.7/10, 7.11, 7.12) are not accepted. A ZTV study is

required with these parameters be

considered/amended/added to, as appropriate in

response.”

SBC Landscape Officer ZTV modelling has been undertaken and is included as Figure

7.7. This assessed the visibility of the Site and Proposed

Development and identifies the maximum area from which

part or all of the Proposed Development would potentially be

visible from a 1.6m high receptor. Further details are included

in the Assessment Methodology section of Chapter 7:

Landscape and Visual.

2.12


“The study area needs to reflect identified effects in line

with accepted GLVIA terminology.”

SBC Landscape Officer The Extent of the Study Area section in Chapter 7: Landscape

and Visual explains that the approach to the study area is

supported by GLVIA3.

“The effect of sky glow needs to be properly assessed, not

discounted. This needs to be presented for inclusion in

Table 15.1: Likely Significant Effects. The findings of the

requested ZTV study needs to be accommodated in 15.10

‘Identification of Sensitive Receptors’.”

SBC Landscape Officer Changes in sky glow has been scoped out of the EIA. The

evidence for this is presented in Chapter 15: Lighting.

“As per these comments, a Tree survey to BS5837:2012,

incorporating an Arboricultural Impact Assessment (AIA)

must be undertaken as a minimum, which we would

anticipate being incorporated into the baseline studies as

part of the LVIA process.”

SBC Landscape Officer The Arboricultural Impact Assessment is submitted as a

standalone report to support the Application. Chapter 7:

Landscape and Visual refers to this assessment for the tree

and hedgerow removal.

“A flood Risk Assessment (FRA) and/or Drainage Strategy

(DS) will need to be submitted with any outline or full

application in relation to this site.”

Lead Local Flood

Authority

The Flood Risk Assessment is included as Appendix 13.2.

Detailed comments regarding trip generation and traffic

distribution (see Appendix 1.2).

Local Highway

Authority

Trip generation and traffic distribution are outlined in the

Transport Assessment (Appendix 14.1). This was agreed with

SBC and input into SBC’s SATURN strategic traffic model.

Further details are contained in Chapter 7 of Appendix 14.1.

“The application in para 7.3 of the Scoping Opinion Request

document has generally identified the public rights of way

that cross the application site. If the site is developed those

routes will need to be considered within any development

along with their connections outside of the site.”

SBC Rights of Way

Officer

Chapter 4: The Proposed Development outlines where Public

Rights of Way will be retained or diverted during construction.

2.13


“This is an extremely archaeological sensitive site and

therefore a detailed assessment of the site and surrounding

area should be carried out and not just a desk based

assessment.”

Wanborough Parish

Council

The effect of the Proposed Development on archaeology is

reported in Chapter 9: Archaeology. This has been informed

by a geophysical survey and trial trenching surveys.

“Section 11.4 states low ground water levels during a three

month survey period from March 2018. This is not a true

indicator of the ground water levels when the survey was

carried out during one of the driest periods known. Parish

Council would like the ground water levels surveyed in a

more realistic period of time and also during the winter

months.”

Wanborough Parish

Council

Six months of groundwater monitoring has been completed on

Site. The results of this have been detailed in the Flood Risk

Assessment (Appendix 11.2).

“The Environmental Statement must fully consider and

address all implications arising from the proposed scheme,

particularly in relation to those which would have a wider

impact on the NEV and surrounding settlements.”

SBC Chapter 19: Cumulative Effects Assessment looks at the

effects of the Proposed Development in-combination with

seven Approved Projects, six of which form part of the New

Eastern Villages allocation.

“In reference to the chapters proposed for the

Environmental Statement, the Council broadly agree with

recommendations outlined within the ‘EIA: Scoping Opinion

Request’ (August 2018). Notwithstanding this, the Council

disagree with the proposals to scope out Ecology, and

therefore recommend that Ecology be fully assessed

through the EIA process, and form part of any submitted

Environmental Statement.”

SBC Ecology has now been included in the scope of the EIA. The

scope and assessment is presented in Chapter 18: Ecology.

2.14

Technical Disciplines Scoped In

2.10 Following the EIA Scoping exercise, the following technical disciplines and their associated

likely significant environmental effects have been taken forward and assessed within the EIA:

• Socio-Economics (Chapter 6);

• Landscape and Visual (Chapter

7);

• Built Heritage (Chapter 8);

• Archaeology (Chapter 9);

• Geology and Soils (Chapter 10);

• Water Resources, Flood Risk

and Drainage (Chapter 11);

• Transportation (Chapter 12);

• Air Quality (Chapter 13);

• Noise and Vibration (Chapter

14);

• Lighting (Chapter 15);

• Waste (Chapter 16);

• Climate Change (Chapter 17);

and

• Ecology (Chapter 18).

2.11 The likely significant environmental effects considered within each technical discipline are

detailed within the relevant technical chapters (Chapters 6 – 18).

2.12 As detailed within Schedule 4, Paragraphs 5 and 8 of the EIA Regulations, there is the

requirement to consider the risk of major accidents and/or disasters relevant to the

Proposed Development. Although there is the potential for a wide range of major accidents

and disasters that could occur, the Proposed Development is not of a nature that is

associated with high risks. The Proposed Development will accord with relevant health and

safety legislation, including the Construction (Design and Management) Regulations 2015

and Health and Safety at Work Act 1974. Further risks associated with potential exposure to

contamination and harmful materials and flooding are contained in Chapter 10: Geology and

Soils and Chapter 11: Water Resources, Flood Risk and Drainage. The risks associated with

road accidents are contained in Chapter 12: Transportation.

Effects Scoped Out

2.13 As part of the EIA process, there are several environmental effects which are considered not

significant and therefore ‘scoped out’ of the EIA. The evidence base to support ‘scoping out’

these environmental effects is presented in the EIA Scoping Report (Appendix 1.1) and

Scoping Opinion (Appendix 1.2), and these not significant effects have been documented in

the ‘Scope of the Assessment’ section of each Chapter (Technical Chapters 6 – 18).

Stakeholder Engagement

2.14 In addition to the consultation undertaken to inform SBC’s EIA Scoping Opinion (Appendix

1.2), the Project Team have undertaken technical consultation with relevant consultees to

inform the scope, assessment methodology/approach and in some instances the outputs of

baseline studies/surveys. The specifics of technical consultation are reported within

Technical Chapters 6 – 18.

2.15

Approach to Assessment of Likely Significant Environmental Effects

2.15 This section outlines the approach to the assessment of likely significant environment effects

adopted, as reported within this ES. This includes details on baseline conditions, future

baseline, identification of sensitive receptors, information to inform assessment, the use of

tolerances, implementation of mitigation, significance criteria and limitations and

assumptions.

2.16 The exact methodology for the assessment of likely significant effects of the Proposed

Development during demolition and construction and operational phases is varied across

each of the technical disciplines considered within the EIA, largely due to technical specific

guidance and best practice. Therefore, each of the Technical Chapters 6 – 18 specifically sets

out the relevant technical assessment methodologies.

Baseline Conditions

2.17 The boundary upon which baseline data has been collected (i.e. study area) varies between

the technical topics and therefore are reported specifically within Technical Chapters 6 – 18.

However, all study areas will be additional to the Site, as defined in the Planning Application

Boundary.

2.18 Schedule 4, Paragraph 3 of the EIA Regulations, states that an ES should include:

‘a description of the relevant aspects of the current state of the environment (baseline

scenario)’

2.19 Likely significant effects as a result of the Proposed Development has been described in the

ES in relation to the deviation from the baseline environment within the Site or/and relevant

technical study areas. Therefore, it is necessary to establish the existing baseline

environmental condition of the Site and study area.

2.20 The baseline environment comprises the prevailing existing environmental characteristics

and conditions of the Site, based upon:

• Site visits and surveys;

• Desk-based studies;

• Review of existing site-specific information or public literature;

• Modelling;

• Review of relevant national and local planning policies; and

• Consultation with the relevant statutory consultees through the EIA process.

2.21 The baseline conditions for the purpose of the ES will vary dependent on the timing of the

survey or the date when data sources will have been accessed. All baseline conditions are

based upon data accessed or surveys completed during 2018 and 2019.

2.16

2.22 Some data obtained from third parties may be older; however, this is largely associated with

below ground data which is not anticipated to have significantly changed and therefore still

remains relevant.

2.23 Throughout the EIA, the origin of all third party data, the dates of surveys and the dates

when data sources have been accessed will be clearly outlined within the relevant Technical

Chapters 6 – 18, alongside any limitations or assumptions.

Future Baseline

2.24 Schedule 4, Paragraph 3 of the EIA Regulations states that an ES should include:

‘…an outline of the likely evolution thereof (without implementation of the development) as

far as natural changes from the baseline scenario can be assessed with reasonable effort on

the basis of availability of environmental information and scientific knowledge’

2.25 As required under the EIA Regulations the ES reports the future baseline scenario under a ‘do

nothing’ scenario, as further discussed in Chapter 5: Consideration of Alternatives. However,

the future baseline scenario is discussed within each of the Technical Chapters 6 – 18. The

discussion is associated with how the Site and study area may change assuming the Site was

not developed further and the existing management regime was maintained.

2.26 The assessments presented in the ES are based on the deviation from the existing baseline

scenario. In some cases, where helpful to the overall assessment, a future baseline condition

is also presented.

Identification of Sensitive Receptors


‘a description of the factors specified in Regulation 4(2) likely to be significantly affected by

the development: population, human health, biodiversity (for example fauna and flora); land

(for example land-take), soil, (for example organic matter, erosion, compaction, sealing),

water (for example hydromorphological changes, quantity and quality), air, climate (for

example greenhouse gas emissions, impacts relevant to adaption), material assets, cultural

heritage, including architectural and archaeological aspects, and landscape’

2.28 Consistent with the EIA Regulations, the identification of the aspects of the environment

likely to be significantly affected by the Proposed Development has been identified. Table

2.2 confirms the sensitive receptors (as identified across Technical Chapters 6 – 18) at which

likely significant effects may occur and their relationship to the aspects of the environment

outlined in Schedule 4.

Table 2.2: Identified Sensitive Receptors

Sensitive Receptors Relation to Schedule 4 ‘factors’

• The economy in the local impact area

(the administrative area of SBC) and the

wider impact area (comprising

Wiltshire, Cotswold, West Berkshire,

Population and human health

2.17


Vale of White Horse and West

Oxfordshire);

• Construction workforce in the local and

wider impact areas;

• The workforce in the local and wider

impact areas, across all industries;

• Residential properties: Applegate

House, 1 – 2 The Marsh, Keepers

Cottage, The Chantry, Chelwood House,

Marshlea, Nether Fenn, Winchmore,

The Verne, Marshside, Saratoga, Marsh

Cottages, Dema Cottage, Farncombe;

No. 10, 35, 44, 46, 48, 50, 56, 58, 60,

62, 62a and 64 Church Road; No. 1- 17

Underdown Close, Little Orchard,

Whynot, Nethercote, Le Chalet, Lae

Dakka, Coverback; Croftdene,

Clearwell, Wynnstay, Trevenna,

Borrowdale, Thornhill, Blenheim,

Ashview, Autumn View, Springfield,

Hillside; Sharpes Farm Stables;

Underdown Farm; Kings Lane Farm;

Great Moor Leaze Farm; Receptors E1-

E12 and N1-N19 as identified in Table

13.5;

• ‘Human receptors’ within 350m of the

Site boundary, or within 50m of the

route(s) used by construction vehicles

on the public highway, up to 500m

from the Site entrance(s);

• ‘ecological receptors’ within 50m of the

Site boundary, or within 50m of the

route(s) used by construction vehicles

on the public highway, up to 500m

from the Site entrance(s);

• Local road network: The Marsh; Pack

Hill; Kite Hill; Church Road; Links 1 – 19

(as described in Chapter 12:

Transportation); Upper Wanboroughl

A419l Ham Road; The Ridgeway; and

• Current Site users.

2.18


• Network of hedgerows, treelines and

scattered trees;

• Ponds and ditches;

• Bats: roosting;

• Badgers: setts;

• Great Crested Newts (terrestrial phase);

and

• Woodland, wetland, grassland, tree and

scrub habitats; and

• Plants and vegetation.

Biodiversity

N/A Land and soil

• Groundwater body;

• Water resources – Thames Valley WRZ;

• Third parties, nearby development and

construction workers; and

• Thames Water Sewer and Drainage

Network; and

• Controlled waters (groundwater and

surface water).

Water

• Climatic system. Air and climate

• Local waste treatment and disposal

facilities;

• Public Rights of Way: Footpaths within

the Site; footpaths west of The Marsh;

Footpaths between Upper

Wanborough, Lower Wanborough and

The Marsh; footbath between Purley

Road and Pack Hill; Public footpath

between Medbourne and Glebe Farm;

Liddington Hill PRoW and permissive

paths; WA5, WA6, WA7, WA8, WA21

and WA22;

• Buildings;

Landscape and material assets

2.19


• Underground service infrastructure;

• North Wessex Downs AONB;

• LLCA1 – LLCA6 (as identified in Chapter

7: Landscape and Visual); and

• Users of publically accessible open

spaces (Warneage Wood and Pack Hill

Wood).

• Parish Church of St Andrew (Grade I

listed building);

• Disney Cottage (Grade II listed

building);

• The White House (Grade II listed

building);

• Upper Wanborough Conservation Area;

and

• Buried archaeological assets within and

in the immediate vicinity of the Site.

Cultural heritage

Information to Inform Assessment

2.29 As indicated in Chapter 1: Introduction, the Application is hybrid, with Phase 1 submitted in

detail and Phase 2 submitted in outline.

2.30 The Application is required to provide sufficient information about the design, size and scale

of the Proposed Development, such that SBC can reasonably be satisfied that they have

sufficient information to decide that they have full knowledge of the likely significant

environmental effects of the Proposed Development. As such, the assessments within the

EIA and presented in the ES have been based on detailed plans for Phase 1 and a ‘parameter

based approach’ based on maximum parameters shown on Figure 4.10 for Phase 2, in

conjunction with the information set out within Chapter 4: The Proposed Development. The

parameter plan approach for the outline component of the Application is based on

established methodology, the 'Rochdale Envelope' (Ref 2.4) in which the maximum

parameters proposed can be tested in the EIA to demonstrate a 'worst-case' scenario. This

approach allows for the Proposed Development to evolve within the approved parameters,

with future detailed design controlled through planning conditions.

2.31 The quantum of development, set out in detail in Chapter 4: The Proposed Development, is

an upper limit within which the Proposed Development will come forward and has been a

key parameter used to assess likely significant environmental effects for the following

disciplines:

• Chapter 6: Socio-Economics, specifically in relation to the calculation of employment;

2.20

• Chapter 12: Transportation, specifically in relation to the trip generation and modal

split (which indirectly impacts upon Chapter 13: Air Quality and Chapter 14: Noise and

Vibration, given that they include road traffic related effects);

• Chapter 16: Waste, specifically regarding calculation of waste arisings; and

• Chapter 17: Climate Change, specifically in relation to the Greenhouse Gas (GHG)

emissions assessment.

2.32 The scale and location of development are shown and defined on Figures 4.1 – 4.9 for Phase

1 and Figure 4.10 for Phase 2, as well as described in Chapter 4: The Proposed Development.

These plans (including any necessary technical study areas) have been used to asses likely

significant environmental effects for the following disciplines:

• Chapter 7: Landscape and

Visual;

• Chapter 8: Built Heritage

• Chapter 9: Archaeology;

• Chapter 10: Geology and Soils;

• Chapter 11: Water Resources,

Flood Risk and Drainage;

• Chapter 12: Transportation;

• Chapter 13: Air Quality;

• Chapter 14: Noise and

Vibration;

• Chapter 15: Lighting; and

• Chapter 16: Ecology.

Assessment Scenarios

2.33 As outlined in Chapter 4: The Proposed Development, construction will commence in 2020

with Phase 1 operational by 2021, and Phase 2 operational by 2025. The Proposed

Development will become fully operational in 2025. The assessments within Technical

Chapters 6 – 18 have therefore considered the construction and operational phase of the

Proposed Development in line with these dates.

2.34 Chapter 12: Transportation, Chapter 13: Air Quality and Chapter 14: Noise and Vibration

consider an opening year of 2026, reflecting the first full year of operation. The assessment

years have been agreed with SBC and this is considered to represent a robust and worst case

assessment. Chapters 12, 13 and 14 provide further commentary on this point.

2.35 For the landscape and visual assessment (Chapter 7), there is a need to assess addition

specific scenarios, in line with relevant technical guidance. Chapter 7: Landscape and Visual

has assessed the effects at the operational phase at the Year 1 and Year 15.

Implementation of Mitigation


‘a description of the measures to avoid, prevent, reduce, or if possible offset any identified

significant adverse effects on the environment and, where appropriate, of any proposed

monitoring arrangements (for example the preparation of a post-project analysis). That

description should explain the extent, to which significant adverse effects on the environment

2.21

are avoided, prevented, reduced or offset, and should cover construction and operational

phases.’

2.37 In accordance with IEMA Guidance, three types of mitigation have been identified and used

within the ES, comprising;

• Primary – modifications to the location or design of the Proposed Development made

during the pre-application stage that are in inherent part of the project;

• Secondary – actions that will require further activity in order to achieve the

anticipated outcome; and

• Tertiary – actions that would occur with or without input from the EIA feeding into the

design process. These include actions that will be undertaken to meet other existing

legislative requirements, or actions that are considered to be standard practices used

to manage commonly occurring environmental effects.

2.38 The design process has been informed by extensive studies/surveys/modelling so that

potential effects are well understood and primary and tertiary mitigation has been identified

and developed. The Proposed Development has evolved to take account of the

environmental constraints and opportunities within the Site and study area.

2.39 Such evolution, as defined above, constitutes primary mitigation and therefore for the

purpose of the EIA such measures are considered as part of the Proposed Development and

therefore set out in Chapter 4: The Proposed Development.

2.40 Those measures considered to constitute tertiary mitigation are also considered part of the

Proposed Development and set out in Chapter 4: The Proposed Development.

2.41 Therefore, Technical Chapters 6 – 18 have considered relevant primary and tertiary

mitigation for both the construction and operational phases prior to undertaking their

assessment of likely significant effects. Following the conclusion of effects based on the

Proposed Development (inclusive of primary and tertiary mitigation) any further mitigation

measures or monitoring arrangements have been identified (i.e. secondary mitigation).

2.42 The primary, secondary and tertiary mitigation detailed within Technical Chapters 6 – 18 are

summarised in Chapter 20: Summary of ES and Mitigation Schedule.

Significance Criteria

2.43 The assessments within this ES reports likely significant environment effects for the

construction and operational phases of the Proposed Development.

2.44 In general, the following criteria have been taken into account when determining

significance:

• Relevant legislation;

• International, national, regional and/or local standards/guidance;

• Probability/likelihood of occurrence of likely effect;

2.22

• Geographical extent of likely effect;

• Magnitude and complexity of likely effects;

• Sensitivity/value/importance of the receptor/receiving environment;

• Duration of effect (short – up to 1 year, medium – 1 to 10 years, or long-term – over

10 years);

• Frequency and reversibility of effect (temporary/permanent); and

• Inter-relationship between effects (both cumulatively and in terms of potential effect

interactions).

2.45 The method for assessing significance of effects varies between environmental topics but in

principle is based on the environmental sensitivity (or value/importance) of an identified

receptor and the anticipated magnitude of change from the baseline conditions. Sensitivity

(or value/importance) has been reported on a scale of high, medium, low and negligible and

magnitude of change on a scale of large, medium, small and negligible.

2.46 Where a technical specific assessment methodology has been applied which uses differing

criteria, in order to align with applicable best practice or relevant guidance, the concluding

assessment of significance has been aligned with the above in order to provide continuity

across the entire EIA (especially with respect to cumulative effects) whilst aligning with

applicable guidance and best practice. This ensures that the conclusions of the different

effects can be compared during the decision making process and robustly considered within

the cumulative assessment. Where this has been applied the assessment methodology is

clearly set out within Technical Chapters 6 – 18.

2.47 In addition, a distinction has been made between direct and indirect (including secondary

effects); permanent and temporary; and positive and negative effects (reported as beneficial

or adverse within this ES). The duration of the effect is often linked to the demolition and

construction phases (i.e. 15 years and therefore long-term, albeit temporary) or operational

phase (also defined as long term, albeit permanent). Further consideration of whether the

effect is short (less than 1 year), medium (1 – 10 years) or long-term (more than 10 years has

been identified where necessary and different to the assumption provided above.

2.48 Cumulative effects have been considered as a single coordinated assessment (Chapter 19:

Assessment of Cumulative Effects).

2.49 The assignment of significance has been based on professional judgement and the matrix

below (Table 2.3) is intended to be a tool to assist with the process. Whilst the matrix

provides ranges this is to guide the competent expert and therefore a definitive level of

effect is concluded, wherever possible. A conclusion has also been provided as to whether

the effect is significant or not, again based on professional judgement.

2.23

Table 2.3: Matrix to Support Determining the Level of Effect

Sensitivity (or value / importance) M

agn

itu

de

of

Ch

ange

High Medium Low Negligible

Large Major Moderate to

Major

Minor to

Moderate

Negligible

Medium Moderate to

Major

Moderate Minor Negligible

Small Minor to

Moderate

Minor Negligible to

Minor

Negligible

Negligible Negligible Negligible Negligible Negligible

2.50 The following terms have been used to define the significance of the effects identified and

these can be ‘beneficial’ or ‘adverse’:

• Major effect: where the Proposed Development is likely to cause a considerable

change from the baseline conditions and the receptor has limited adaptability,

tolerance or recoverability or is of the highest sensitivity. This effect is considered to

be ‘Significant’;

• Moderate effect: where the Proposed Development is likely to cause either a

considerable change from the baseline conditions at a receptor which has a degree of

adaptability, tolerance or recoverability or a less than considerable change at a

receptor that has limited adaptability, tolerance or recoverability. This effect is

considered more likely to be ‘Significant’ but will be subject to professional judgement;

• Minor effect: where the Proposed Development is likely to cause a small, but

noticeable change from the baseline conditions on a receptor which has limited

adaptability, tolerance or recoverability or is of the highest sensitivity or a

considerable change from the baseline conditions at a receptor which can adapt, is

tolerant of the change or/and can recover from the change. This effect is considered

less likely to be ‘Significant’ but will be subject to professional judgement; and

• Negligible: where the Proposed Development is unlikely to cause a noticeable change

at a receptor, despite its level of sensitivity or there is a considerable change at a

receptor which is not considered sensitive to a change. This effect is ‘Not Significant’.

2.51 Technical Chapters 6 – 18 provide a summary of effects table, which outlines the effects

assessed, associated sensitive receptors, residual effects and whether the effect is significant

or not.

Limitation and Assumptions

2.52 Schedule 4, Paragraph 6 of the EIA Regulations state that an ES should include:

‘...details of difficulties (for example technical deficiencies or lack of knowledge) encountered

compiling the require information and the main uncertainties involved’

2.24

2.53 Where Technical Chapters 6 – 18 experience limitations or are based on assumptions these

have been clearly identified within the relevant chapter.

Reference List

Ref 2.1 Ministry of Housing, Communities & Local Government, Planning Practice

Guidance [Online], available at:

https://www.gov.uk/government/collections/planning-practice-guidance

(Accessed on 05.11.2019).

Ref 2.2 IEMA, Environmental Impact Assessment Guide to: Shaping Quality

Development, November, 2015.

Ref 2.3 IEMA, Environmental Impact Assessment Guide to: Delivering Quality

Development, July, 2016.

Ref 2.4 Rochdale (No. 1) - R v Rochdale MBC ex parte Tew 1999 and Rochdale (No.

2) - R v Rochdale MBC ex parte Milne 2001.

2. approach to eia

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