energy plant & reclamation scheme...table 6-1 – potential environmental impact summary table...

38
SEPT 2019 CONFIDENTIAL Bersham (Glenside) Ltd ENERGY PLANT & RECLAMATION SCHEME Bersham Colliery, Rhostyllen, L14 3EG Environmental Impact Assessment Screening Report

Upload: others

Post on 18-Aug-2020

1 views

Category:

Documents


0 download

TRANSCRIPT

SEPT 2019 CONFIDENTIAL

Bersham (Glenside) Ltd

ENERGY PLANT & RECLAMATION

SCHEME

Bersham Colliery, Rhostyllen, L14 3EG

Environmental Impact Assessment Screening

Report

Bersham (Glenside) Ltd

ENERGY PLANT & RECLAMATION SCHEME

Bersham Colliery, Rhostyllen, L14 3EG

CONFIDENTIAL

TYPE OF DOCUMENT (VERSION) CONFIDENTIAL

PROJECT NO. 70054016

DATE: SEPT 2019

WSP

1 Capital Quarter

Tyndall Street

Cardiff

CF10 4BZ

Phone: +44 2920 769 200

WSP.com

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd

QUALITY CONTROL

Issue/revision First issue Revision 1 Revision 2 Revision 3

Remarks

Date 25.09.2019

Prepared by Rebekah Thompson

Signature

Checked by Jack Pugsley

Signature

Authorised by Gavin Lewis

Signature

Project number

Report number

File reference

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd

CONTENTS

1 INTRODUCTION 1

2 CONSIDERATION OF EIA REGULATIONS 3

3 SITE LOCATION AND CONTEXT 7

4 CHARACTERISTICS OF DEVELOPMENT 8

5 ENVIRONMENTAL BASELINE ASSESSMENT 10

6 CHARACTERISTICS OF POTENTIAL IMPACTS 23

7 CONCLUSION 32

TABLES

Table 2-1 – Schedule 2 of the 2017 Regulations 3

Table 2-2 – Regulation 6 (2) of the 2017 Regulations 5

Table 5-1 - Annual Mean NO2 Concentrations (µg/m3)* 10

Table 5-2 - Scheduled Monuments within the 500m Study Area and outside of the Red Line

Boundary 12

Table 5-3 - Grade II* Listed Buildings within the 500m Study Area and outside of the Red

Line Boundary 12

Table 5-4 - Grade II Listed Buildings within the 500m Study Area and outside of the Red

Line Boundary 12

Table 5-5 - Non-Designated Heritage Assets within the 500m Study Area and outside of the

Red Line Boundary 13

Table 5-6 - Non-designated Heritage Assets within the 500m Study Area and Inside the

Redline Boundary 14

Table 5-7 - Geology 17

Table 5-8 - Sensitive Receptors within 0.5km from the scheme proposals 18

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd

Table 5-9 – Bus Services 19

Table 6-1 – Potential Environmental Impact Summary Table 24

FIGURES

Figure 3-1 Location of Proposed Development 7

Figure 5-1 - Public Right of Way though the Site 20

Figure 5-2 - Environmental Constraints Map 21

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 1 of 32

1 INTRODUCTION

1.1 PROPOSED DEVELOPMENT

1.1.1. WSP have been appointed by Bersham (Glenside) Ltd to provide an Environmental

Impact Assessment (EIA) Screening Opinion for a new circa 30MW energy plant (the

Proposed Development) to be located on the existing, disused colliery site in Rhostyllen.

1.1.2. The Site of the Proposed Development is located at the Bersham Bank Colliery Tip,

Rhostyllen, Wrexham, immediately south of Rhostyllen. The Site is bounded by Glan yr

Afon brook on its northern boundary, Bersham Enterprise Centre to the east of Plas

Grono Road, railway line to the south and the A483 to the west.

1.1.3. The Site area is circa 13 hectares (13,000 m2) within the red line boundary. As shown on

the plans submitted with this report, the energy plant is located within the south-western

corner of the Site. The Proposed Development will provide an innovative method of on-

site reclamation and additional benefits in the processing of the existing colliery spoil

material on-site (a secondary resource), enabling both on-site sustainable energy

generation, reclamation of the Site and the production of brick/blocks using the excess

material. The plant would remain in situ for until the on-site resource, the colliery spoil

(an alternative and sustainable source of fuel) has been depleted, approximately 27

years, as well as other sustainable fuel sources.

1.1.4. Plans submitted with this enquiry illustrate that the energy plant would have the following

indicative dimensions:

Maximum width: 232.50m

Maximum length: 119.50m

Height of flue above ground level*: 21.0m

*Ground levels are likely to be altered as part of proposed development.

1.1.5. The energy plant would use the calorific combustible material within the colliery spoil to

generate energy which would otherwise be left on or exported from the Site.

Furthermore, the energy plant would include additional processes, including the

production of concrete blocks from the waste generated during the energy generation

process. The output of the energy plant is variable and can be up or down graded but is

intended to be 30MW at this stage. Finally, the Site benefits from direct, onsite access to

an electricity substation.

1.1.6. In line with Policy EC16 of the Wrexham County Borough Unitary Development Plan, the

Proposed Development seeks to reclaim and restore the site for a beneficial use.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 2 of 32

1.2 BASELINED POSITION

1.2.1. The Site benefits from an extant planning permission for the extraction of the former

colliery spoil tip, including the processing of the material. Mitigation measures in respect

of noise, dust, ecology, highways and other effects have previously been assessed and

agreed with the LPA. Accordingly, the key consideration is whether the energy plant

would affect the existing environmental mitigation measures proposed and what

additional measures may be required.

1.2.2. To note, the extant planning permission does not state or specify the methods of

reclaiming and processing the spoil material. As such, the Proposed Development

recognises this gap in the processing of the spoil and considers the technological

advances made since the original planning permission was granted. The Proposed

Development proposes a sustainable option for the reclamation of the material at the

Site, including using it to generate electrical energy which will be connected to the

National Grid and the production of building materials.

1.2.3. Given the compelling national need for the additional capacity within the electricity

generating network, it is considered that any potential adverse local impacts, which could

be appropriately mitigated, would be outweighed by the energy benefits of a project for

which a presumption in favour is established in the Energy National Policy Statements

and PPW10.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 3 of 32

2 CONSIDERATION OF EIA REGULATIONS

2.1 LEGISLATIVE REQUIREMENTS

2.1.1. On 16th May 2017, the Town and Country Planning (Environmental Impact Assessment)

(Wales) Regulations 2017 (“the 2017 Regulations”) superseded the Town and Country

Planning (Environmental Impact Assessment) (Wales) Regulations 2016. The main changes

to the 2017 Regulations were focused on: Screening, Environmental Statements; Publicity

and consultation; and Decision making.

2.1.2. With regard to this Environmental Screening Report and request for screening a number of

changes were made to the 2017 Regulations. These include, but are not limited to, the

process of screening “schedule 2” development. The changes included what information the

applicant must submit with a screening request (regulation 6) and what the Local Planning

Authority (LPA) must take into account when making a screening opinion (Regulation 5). The

21-day period for making an opinion remains. However, where an extension is agreed, the

maximum time before an opinion must be given is 90 days.

2.1.3. The 2017 Regulations define “EIA development means development which is either:

Schedule 1 development; or Schedule 2 development that is likely to have significant effects

on the environment by virtue of factors such as its nature, size or location”.

2.1.4. The thresholds for Schedule 1 development generally relate to major projects which, by

virtue of their scale, location, appearance or the type of activity, have the potential to impact

on the environment. These types of project are specifically defined in the 2017 Regulations

and automatically require EIA.

2.1.5. The Proposed Development does not fall into Schedule 1 development. Consequently, the

Site must be considered under Schedule 2.

2.1.6. It is considered that the Proposed Development falls within a category of development in

Schedule 2, specifically Section 3. Energy Industry, as noted in Table 2-1 below:

Table 2-1 – Schedule 2 of the 2017 Regulations

Column 1

Description of Development

Column 2

Applicable thresholds and criteria

The carrying out of development to provide any of the following –

3. Energy Industry

(a) Industrial installations for the production of electricity, steam and hot water (unless included in Schedule 1).

The area of the development exceeds 0.5 hectare.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 4 of 32

2.1.7. The Proposed Development exceeds the 0.5ha thresholds noted in Table 2-1 (the EIA

boundary is approximately 13ha). The following screening exercise considers the proposal

against the selection criteria identified within Schedule 3 of the 2017 Regulations and will

outline any likely level of impact as a result of the development so to allow a decision to be

made as to whether the proposed comprises EIA development and would require an

Environmental Statement.

2.1.8. The selection criteria for screening Schedule 2 development within the 2017 regulations

includes:

Characteristics of development

1. The characteristics of development must be considered having regard, in particular, to—

a) the size and design of the development;

b) the cumulation with other existing development and/or approved development;

c) the use of natural resources, in particular land, soil, water and biodiversity;

d) the production of waste;

e) pollution and nuisances;

f) the risk of major accidents and/or disasters relevant to the development concerned,

including those caused by climate change, in accordance with scientific knowledge;

g) the risks to human health (for example due to water contamination or air pollution).

Location of development

2. The environmental sensitivity of geographical areas likely to be affected by development

must be considered, having regard, in particular, to—

a) the existing and approved land use;

b) the relative abundance, availability, quality and regenerative capacity of natural

resources (including soil, land, water and biodiversity) in the area and its

underground;

c) the absorption capacity of the natural environment, paying particular attention to the

following areas—

i. wetlands, riparian areas, river mouths;

ii. coastal zones and the marine environment;

iii. mountain and forest areas;

iv. nature reserves and parks;

v. European sites and other areas classified or protected under national

legislation;

vi. areas in which there has already been a failure to meet the environmental

quality standards laid down in Union legislation and relevant to the project, or

in which it is considered there is such a failure;

vii. densely populated areas;

landscapes and sites of historical, cultural or archaeological significance.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 5 of 32

Types and characteristics of the potential impact

3. The likely significant effects of the development on the environment must be considered in

relation to criteria set out under paragraphs 1 and 2, with regard to the impact of the

development on the factors specified in regulation 4(2), taking into account—

a) the magnitude and spatial extent of the impact (for example geographical area and

size of the population likely to be affected);

b) the nature of the impact;

c) the transboundary nature of the impact;

d) the intensity and complexity of the impact;

e) the probability of the impact;

f) the expected onset, duration, frequency and reversibility of the impact;

g) the cumulation of the impact with the impact of other existing and/or approved

development;

h) the possibility of effectively reducing the impact.

2.2 REQUIRED INFORMATION

2.2.1. As per Regulation 6 of the 2017 Regulations, this request for a screening opinion is

accompanied by the following information, as shown in Table 2-2 below:

Table 2-2 – Regulation 6 (2) of the 2017 Regulations

Regulation 6 Submitted information

(a) A plan sufficient to identify the land; See attached Site Location Plan

(b) A description of the development, including in particular:

i. A description of the physical characteristics of the development and, where relevant, of demolition works;

ii. A description of the location of the development, with particular regard to the environmental sensitivity of geographical areas likely to be affected;

See Section 1 & 3 of this Report

(c) A description of the aspects of the environment likely to be significantly affected by the development;

See Section 6 of this Report

(d) A description of any likely significant effects, to the extent of the information available on those effects, of the Proposed Development on the environment resulting from-

i. The expected residues and emissions and the production of waste, where relevant; and

See Section 4 of this Report

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 6 of 32

Regulation 6 Submitted information

ii. The use of natural resources, in particular soil, land, water and biodiversity;

(e) Such other information or representations as the person making the request may wish to provide or make including any features of the Proposed Development or any measures envisaged to avoid or prevent what might otherwise have been significant adverse effects on the environment.

See Section 5 of this Report

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 7 of 32

3 SITE LOCATION AND CONTEXT

3.1 LOCATION OF THE SCHEME

3.1.1. The Site is located at the former Bersham Bank Colliery Tip, Rhostyllen, Wrexham LL14 4EG

at National Grid Reference SJ 31247 48158. A location plan is enclosed within this

submission so to provide context to the Site and its surroundings, with an aerial overview

provided in Figure 3-1 below.

3.1.2. The Site is adjacent to the A483 on its western edge, with the A5152 on its northern

boundary and a railway line, linking Wrexham and Chirk, on the Site’s south-eastern

boundary. Beyond the immediate boundaries of the Site, to the east, south and west of the

Site lie agricultural fields with commercial units located to the north.

Figure 3-1 Location of Proposed Development

3.1.3. Furthermore, the town of Rhostyllen is located to the north-east of the Site, with Wrexham

beyond this. the Site is also bounded by Glan yr Afon brook on its northern boundary,

Bersham Enterprise Centre to the east of Plas Grono Road. Former colliery builders are

located to the east and north east of the Site, which include a Scheduled Ancient Monument

(also a Grade II* Listed Building) and other Grade II listed buildings.

3.1.4. The colliery was closed in December 1986, albeit salvage operations continued into 1987.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 8 of 32

4 CHARACTERISTICS OF DEVELOPMENT

4.1 INTRODUCTION

4.1.1. The following information sets out the likely significant effects of the Proposed Development

on the environment in line with Article 1 of Schedule 3 of the 2017 Regulations.

4.2 SIZE AND DESIGN OF DEVELOPMENT

4.2.1. The size and design of the proposal is at a relatively early stage and are yet to be finalised.

In terms of land take, circa 13ha of land is included within the red line for the purposes of

screening the development.

4.2.2. At this stage, a conservative approach has been taken to the extent of the red line so to

include all works may be required as part of any consented planning application.

4.2.3. Following the submission of, and response to, the EIA screening opinion, further survey work

will be undertaken which should enable the red line to be further refined and reduced in

scale.

4.3 THE CUMULATION WITH OTHER DEVELOPMENTS

4.3.1. The Proposed Development is not expected to have any adverse cumulative impacts

because of this designation or with any extant applications in proximity to the Site.

4.4 THE USE OF NATURAL RESOURCES

4.4.1. It is assumed that the Proposed Development would use a significant quantum of natural

resources during construction and potentially during the maintenance of the buildings.

However, an ambition of the project is to source materials, wherever possible, from local

(notably on-site) and sustainable sources.

4.5 THE PRODUCTION OF WASTE

4.5.1. Construction of the Proposed Development would generate waste typical of a project of this

scale and type. There would also be waste generated through the clearance of existing

vegetation, any further excavated material, packaging and excess materials brought to site.

4.5.2. It should be noted that the Proposed Development would utilise the existing spoil waste on

site through the dual processes (energy generation and the creation of brick/blocks) thereby

reducing the quantum of waste which would otherwise be removed from the Site.

4.5.3. During the operational stage, the energy plant will use the calorific combustible material from

the colliery spoil tip to generate electricity and provide a site-based reclamation of the

material. It is proposed that energy plant can also provide for additional processes from

reclaiming material in terms of block construction (which will require additional material).

4.6 POLLUTION AND NUISANCES

4.6.1. The Site is adjacent to predominately industrial units with several residential dwellings which

are separated from the Site by a woodland area. It is unlikely that nearby residents will

experience significant increased nuisance in the form of elevated noise levels during the

operation of the Site, but it is likely that the residents adjacent to the A5152 may experience

an increase in noise levels if an increased number of vehicles are using the road travelling

from the colliery.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 9 of 32

4.6.2. There may be some temporary nuisance caused during the construction of the Site due to

increases in noise and dust, but with mitigation measures in place, the impact is expected to

be minimal.

4.7 RISK OF MAJOR ACCIDENTS

4.7.1. During the construction of the Site, given the distance of receptors and the human population

from the Site, alongside pollution prevention measures and best practise measures in place,

no major accidents are anticipated.

4.8 HUMAN HEALTH

4.8.1. The Proposed Development is situated to the south of an established industrial and

residential area. There is a potential for a decrease in air quality and increase in noise levels

due to the activities associated with construction. However, with best practice measures and

pollution prevention measures in place, this potential impact is expected to be minimal.

4.8.2. There is limited potential for the development to have significant adverse effects on human

health during the operational phase.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 10 of 32

5 ENVIRONMENTAL BASELINE ASSESSMENT

5.1 INTRODUCTION

5.1.1. This section will identify the environmental baseline and constraints within 2km of the scheme

proposals (Figure 5.1), including those aspects identified within article 2 of schedule 3 of the

2017 Regulations.

5.2 AIR QUALITY

5.2.1. At the time of writing, Wrexham County Borough Council (WCBC) has declared no Air

Quality Management Areas (AQMAs) within its administrative boundary. The main sources of

air pollution in the surrounding locale of the Application Site are vehicles using the local road

network.

5.2.2. The Rossett to Chirk Railway Line borders the Application Site to the south, beyond which

lies agricultural land. A review of Defra’s Local Air Quality Management (LAQM) webpages1

indicates that this railway line does not carry a heavy traffic of diesel locomotives and,

therefore, is unlikely to have a significant influence on air quality in the vicinity of the

Application Site.

5.2.3. There are currently no industrial pollution sources in the immediate vicinity of the Application

Site would have a significant influence on local air quality.

LOCAL MONITORING DATA

5.2.4. WCBC undertake air quality monitoring at a number of locations across their administrative

area. Two of their Nitrogen Dioxide (NO2) diffusion tube monitoring sites are located close to

the Proposed Scheme. Annual mean NO2 concentrations for the past five years are provided

in Table 5.1:

Table 5-1 - Annual Mean NO2 Concentrations (µg/m3)*

Site ID Site Type Distance from Site (m)

Distance from nearest kerb (m)

2013 2014 2015 2016 2017

WBC-018 Roadside 900 – North East 2 18.5 18.8 17.0 16.9 18.3

WBC-030 Roadside 100 – West 4 36.5 39.9 36.9 35.8 33.1

NO2 AQS Objective (µg/m3) 40

*Exceedances of the AQS objective highlighted in bold.

1 https://laqm.defra.gov.uk/documents/Railway_Locomotives_100209.pdf

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 11 of 32

5.2.5. Monitoring results demonstrate that NO2 concentrations in the area have remained below the

UK Air Quality Objective (AQO) for annual mean NO2. However, monitoring location WBC-

030, adjacent to the A483 roundabout, reported levels of NO2 just below the objective during

2014 and has been within 10% of the objective in 2013 and 2015.

5.2.6. Defra mapped background concentrations for annual mean NO2 and Particulate Matter

(PM10 and PM2.5) within the Site and surrounding locale are well below the relevant AQO’s.

SENSITIVE RECEPTORS

5.2.7. The area to the west of the A483 is predominantly agricultural land, encompassing Hafod-y-

bwch Hall approximately 50m from the Application Site boundary. Commercial and industrial

units border the Application Site to the east, with residential properties located immediately to

the north situated on Glan-y-Afon. Review of the surrounding Site locale illustrates there are

approximately 10 residential dwellings and 5-10 commercial/industrial units within 20m of the

Application Site boundary. A further >100 residential dwellings are situated within a 350m

radius of the Application Site.

5.2.8. The Johnstown Newt Sites (SAC) and Stryt Las A’r Haford (SSSI) ecological designated

sites are situated approximately 500m south of the Proposed Scheme. Features of these

designated sites could be sensitive to changes in ambient concentrations of nitrogen oxides

(NOx), nutrient nitrogen (N) deposition and dust, which could be brought about by the

proposed energy plant. Other ecological receptors in the wider area include the Sontley

March (SSSI) located approximately 2.5km east, Rubaon/Llantysilio Mountains and Minera

(SSSI) and Berwyn a Mynyddoedd De Clwyd / Berwyn and South Clwyd Mountains (SAC)

situated approximately 4.3km west

5.3 CULTURAL HERITAGE

5.3.1. A study area of approximately 500m extending out from the limits of the Proposed

Development was applied for the identification of all types of heritage assets (statutory

designated, non-designated and potential archaeological remains). Due to the topography of

the land (which lies lower than the A483 which is raised) and the presence of mature tree

screening west of the Proposed Development, a 500m study area is considered appropriate.

LISTED BUILDINGS AND SCHEDULED MONUMENTS

5.3.2. A total of 33 heritage assets are present within the 500m study area (Tables 5.2 to 5.6

below). Of these 12 are statutory designated: three Scheduled Monuments, two Grade II*

Listed Buildings and seven Grade II Listed Buildings of national/high value.

NON-DESIGNATED HERITAGE ASSETS

5.3.3. A total of 21 non-designated heritage assets lie within the 500m study area, comprising nine

recorded on the HER and 12 on the National Monuments Records for Wales (NMR). There is

also the potential for previously unknown below-ground archaeological remains to be present

within the study area. Tables 5-2, 5-3, 5-4, 5-5 and 5-6 list the designated and non-

designated heritage assets.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 12 of 32

GAZETTEER

Table 5-2 - Scheduled Monuments within the 500m Study Area and outside of the Red

Line Boundary

Ref Number Name Period

DE047 Hadfod-y-Bwlch Round Barrow Prehistoric (Bronze Age)

DE048 Croes-Foel Round Barrow Prehistoric (Bronze Age)

DE199 Bersham Colliery: No 2 Winding Gear Industrial

Table 5-3 - Grade II* Listed Buildings within the 500m Study Area and outside of the

Red Line Boundary

Ref Number Name Period

1587 Hafod-y-Bwch Hall Medieval

16567 Bersham Colliery No 2 Headframe Modern

Table 5-4 - Grade II Listed Buildings within the 500m Study Area and outside of the

Red Line Boundary

Ref Number Name Period

15825 Bersham Colliery Winding Engine House Modern

15826 Former Bersham Colliery Baths, Canteen and Offices

Modern

16569 Timber-framed Barn in Yard at Hafod-y-Bwch Hall

Post-medieval

16571 Croesfoel Farmhouse Post-medieval

16572 Gate Piers at Hafod-y-Bwch Hall Post-medieval

16573 Timber-framed Building in Yard at Croesfoel Farm

Post-medieval

87572 Church of The Holy Trinity Post-medieval

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 13 of 32

Table 5-5 - Non-Designated Heritage Assets within the 500m Study Area and outside of

the Red Line Boundary

Ref Number Name Period

CPAT15693 Rhostyllen Unknown

CPAT17253 Rhostyllen Church Unknown

CPAT17255 Rhostyllen Church (Holy Trinity), yard Unknown

CPAT36696 Bersham Colliery, Mine office Modern

CPAT101824 Croes Foel Ring Ditch Prehistoric

CPAT102645 Croes Foel Placename, Cross Medieval

CPAT104350 Croes Foel Smithy Unknown

CPAT105077 Croes Foel ring ditch Unknown

CPAT125771 Wrexham R.Ds Council, sewage works Modern

NMR 7603 Williams O'r Wern Salem Independent Chapel,Rhostyllen

Post-medieval

NMR 7604 Ainon Welsh Baptist Chapel, Rhostyllen Post-medieval

NMR 37133 Hafod-Y-Bwch, Barn Post-medieval

NMR 91684 Bersham Colliery: Lamp Room Modern

NMR 91685 Bersham Colliery: Workshops Modern

NMR 91688 Bersham Colliery: Glan-Yr-Afon Offices Modern

NMR 91689 Bersham Colliery: Glan-Yr-Afon Pithead Baths

Modern

NMR 302188 Hafod-Y-Bwch Hall: Outbuildings, Rhostyllen

Post-medieval

NMR 308764 Barrow North East of Rhosllanechrugog Prehistoric (Bronze Age)

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 14 of 32

Ref Number Name Period

NMR 411176 Rhostyllen Infants County Primary School, Post-medieval

NMR 411177 Rhostyllen County Secondary School Modern

NMR 423987 Rhostyllen Village Multiperiod

Table 5-6 - Non-designated Heritage Assets within the 500m Study Area and Inside the

Redline Boundary

Ref Number Name Period

NMR 85024 Bersham Colliery, Wrexham Post-medieval

NMR 91686 Bersham Colliery: Electricity Sub Station Modern

NMR 91687 Bersham Colliery: Spoil Tip Post-medieval

CONSERVATION AREAS AND OTHER LANDSCAPE DESIGNATIONS

5.3.4. There are no designated landscapes within 2km of the Scheme proposals.

5.4 LANDSCAPE

5.4.1. The proposed energy plant buildings will lie within the south west corner of the Site. It’s

proposed stack (c.25m) and silo (c.20m) are the elements with most potential to have

landscape and visual impacts.

5.4.2. The Site is contained on all boundaries by the following:

West and South: Semi-mature tree belt along boundary with the A483;

South and South East: railway line with intermittent vegetation;

East: Woodland boundary adjacent to light industry and commercial buildings; and

North: Semi-mature woodland along the Glanyrafon brook between the commercial and

residential development along Wrexham Road (and currently the slag bank).

5.4.3. The height and depth of the existing woodland to the west, north and east has the potential

to provide screening of the proposed energy plant buildings in views from these directions.

The existing vegetation will be retained where possible, but it is acknowledged some

vegetation removal may be necessary along the south and south west boundaries to allow

construction of the building. The slag-bank would in the initial project stages also provide

screening before its gradual removal. The most open aspect is to the south east where the

existing boundary vegetation along the railway line is more intermittent.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 15 of 32

LANDSCAPE CHARACTER

5.4.4. The Site’s former colliery use and prominent slag-bank make it a distinctive industrial feature

within the locality. The landscape to the north and north east is characterised by the urban

edge of Rhostyllen and Wrexham. The surrounding landscape to the west, south and east is

relatively typical of that described in the National Landscape Character Area NLCA 13

Deeside and Wrexham as an attractive rolling farmed landscape with elements of estate

farming and a mix of small to medium field patterns and woodland blocks and copses,

bordering the southern and eastern edge of Wrexham. The woodland, hedgerows, and

individual trees across this landscape in addition to the woodland around the Site limit the

opportunities for open and expansive views.

5.4.5. Local landscape characteristics are described by LANDMAP. The Cultural Landscape aspect

acknowledges the Site as having a high regional value for ‘articulating WCBC’s historic

dependence on the coal industry’. LANDMAP’s Visual and Sensory Aspect considers a

moderate value based on the following evaluation: “The area, particularly the tip is a

prominent landmark as seen from the A483 which passes close to its western edge. As such

it provides a potent visual link to Wrexham's past, the area is not classically attractive or

aesthetically pleasing but is an exciting and ''dangerous'' landscape it also engenders the

heritage of the central industrial belt of Wrexham. However, on a Visual and Sensory

evaluation this area can only be considered Moderate in its value as the pressure of

development surrounding the area and the relatively poor scenic quality of the workings and

the adjacent area must reduce the overall evaluation. A prominent and clearly defined

landmark for the area reinforcing links with the industrial heritage of the area and providing a

strong focus for travellers on the adjacent A483. Very high degree of local distinctiveness

and regional identity. The view has been somewhat degraded by commercial development to

north.”

5.4.6. Accepting that permission has been granted for the removal and re-use of the slag-bank, the

sensitivity of the landscape character of the Site and surroundings to the type of

development proposed is not considered particularly high. The proposed energy plant

buildings will sit within the existing industrial landscape which has consent to become active

again. It will be in proximity to adjacent light industry buildings at Bersham Enterprise Park,

and as such will not appear incongruous in this setting. Proposed strengthening of the south

west boundary along the railway line and proposed rail sidings, as well as management and

enhancement of the vegetation along other boundaries will further contain the proposed

building within the Site and limit views from the wider landscape.

5.4.7.

5.4.8. Thus, it is considered that the potential to have any significant effects on the landscape

character of the Site or wider landscape is limited.

VISUAL AMENITY

5.4.9. The potential for significant impacts on visual receptors in the wider area is also likely to be

very limited given the existing industrial context the Proposed Development lies within and

the limited visual envelope resulting from the screening provided by vegetation, and also in

the early stages of operation from the slag-bank.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 16 of 32

5.4.10. It is understood that the PROW that lies within the Site (ESC/15) will be stopped up as part of

the previous consent and so any visual impacts upon users of this route would not be a

consideration in this application.

5.4.11. The taller elements of the Proposed Development (silo and stack) may be potentially visible

to local residents primarily to the west of the Site, road users on the A483 and local B roads,

travellers on the railway, and users of PROW that lie to the south east and south west of the

Site. It is not anticipated the views of these taller elements would create significant visual

impacts given the industrial and urban edge context, and that most of the structure height

would be likely screened by the existing vegetation.

LANDSCAPE DESIGNATIONS

5.4.12. There are no nationally designated landscapes on the Site and within its immediate

surroundings. The Clwydian Range and Dee Valley AONB lies 2.5km to the west. The

proposed energy plant has potential to be visible from the higher panoramic viewpoints within

the AONB, but seen within the existing industrial context, surrounded by a busy A road,

railway, and industrial and commercial development, and urban edge of Wrexham.

Therefore, there would be limited potential for the Proposed Development to have any

significant effects on the special qualities of the AONB and its reasons for designation.

5.4.13. The National Trust’s Erddig estate lies just over 1km to the east and there is potential

intervisibility with the Site from the front of the house. Historic designations are an indication

of the quality of the landscape, and identify sites where potential visual receptors may be

highly sensitive, such as visitors to designated sites experiencing them in the context of their

setting. On review, only the upper part of the existing slag-bank is notable from Erddig, with

the rest of the Site screened by intervening hedgerows and woodland. As the slag-bank is

c.40m high, double the height of the proposed silo for example, it can be considered unlikely

that the proposed energy plant would be clearly visible from Erddig. As such, and also taking

into account that the Site does not lie directly in line with the key views from Erddig’s house

and formal gardens, it is considered that there is little potential for significant visual impacts

upon its visitors.

5.5 ECOLOGY

STATUTORY DESIGNATIONS

European Designated Sites

5.5.1. There is one European Designated Site in proximity to the Scheme proposals. This is

Johnstown Newt Sites which is a Special Area of Conservation (SAC), and is situated

approximately 500 m south west of the Site. No further European Designated Sites are located

within proximity to the Scheme proposal; this includes there being no Special Protection Areas

(SPA), Sites of Community Importance (SCI’s) or RAMSAR sites located within 2 km of the

Scheme. No SACs are located within 30 km of the Scheme where bats are one of the qualifying

site features.

SITES OF SPECIAL SCIENTIFIC INTEREST (SSSI)

5.5.2. There is one Site of Special Scientific Interest (SSSI), Stryt Las A’R Hafod, within 2km of the

proposals, located approximately 500 m south west from the Site.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 17 of 32

NON-STATUTORY DESIGNATIONS

5.5.3. There are two Country Parks within 1 km of the scheme, comprising Bonc yr Hafod situated

500m south west and Erddig Park situated 500m north east from the Site. Erddig Estate Local

Wildlife Site LWS is located 911m from the Site. There are no other designations within 1 km

of the Scheme proposals.

PRIORITY HABITATS

5.5.4. Two Ancient Woodland Sites AWS were present within 500 m and 850 m of the Site. No priority

habitats were identified on site.

PROTECTED SPECIES AND HABITATS

A Phase 1 habitat survey has identified that the Site is largely made up of grassland, scrub,

woodland, scattered patches of bare ground and hard standing habitats with varying

topography. Some of these habitats, namely the grassland and scrub habitats comprise a

diverse array of botanical species. that could support a range of protected and/or notable

species specifically invertebrates, reptiles and breeding birds.

As no phase two surveys have been carried out, it cannot be determined if protected and/or

notable species are present or absent, however, a range of biological records has been

returned from COFNOD.

5.6 GEOLOGY AND SOILS

GEOLOGY

5.6.1. The geology of the area according to the British Geological Survey (BGS) GeoIndex is

summarised in the Table 5.7 below.

Table 5-7 - Geology

Geology Location and Description Aquifer Designation

Made Ground Entire site

Likely comprising colliery spoil.

-

Superficial Deposits - Till

The majority of the Site excluding the northern boundary:

Devensian – diamicton.

Secondary A

Superficial Deposits - Glaciofluvial Deposits

Along the northern boundary of the Site:

Devensian - sand and gravel.

Secondary A

Bedrock - Etruria Formation

Entire site:

Mudstone, with lenticular sandstones and conglomerates. Common pedogenic horizons, but coal seams are rare. Subordinate, lenticular sandstones and conglomerates commonly consist mostly of volcanic and lithic clasts.

Secondary A

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 18 of 32

5.6.2. There are no geological SSSI’s or Regionally Important Geological Sites (RIGS) within 2km

of the Scheme proposals.

CONTAMINATED LAND

5.6.3. The Site was previously associated with a colliery and the current surrounding land use is

mainly industrial. Therefore, there is potential for the soils and groundwater to have been

impacted by associated contamination. The extent and nature of any potential contamination

will be required to be established in order to assess risks to identified receptors. The first

stage in addressing potential risks is to complete a phase 1 desk study which will assess

potential pollutant linkages and discuss suitability of the land for the proposed use.

AGRICULTURAL LAND

5.6.4. The land associated with the Scheme does not comprise agricultural land.

5.7 PEDESTRIANS, CYCLISTS AND COMMUNITY EFFECTS

5.7.1. The land surrounding the Scheme is sparsely populated towards the south west, south and

south east and is predominately surrounded by woodland and agricultural fields with the A483

bordering the Site to the west. The land towards the north east is built up of predominately

residential areas and community resources. Land immediately north and east comprises

industrial commercial units. Table 5-8 lists the receptors which are within 0.5km of the scheme:

Table 5-8 - Sensitive Receptors within 0.5km from the scheme proposals

Receptor / Resource Distance & Direction

Industrial and Commercial Buildings

Macron Store Wrexham Adjacent to Site (east)

Rascals Retreat Art and Craft Café Adjacent to Site (east)

NV cakes Adjacent to Site (east)

Evans Halshaw Ford Wrexham Adjacent to Site (east)

Wrexham Recycled Adjacent to Site (north east)

Starbucks Coffee 167m north west

Dicksn Vauxhall Wrexham 200m north

Dee Valley Water 530m south west

Residential and Community

Residential dwellings on Tudor Avenue Adjacent to Site (north)

Residential dwellings north of A5152 230m north

School 500m north

PRoW Adjacent to A483 and railway line within the Site

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 19 of 32

Receptor / Resource Distance & Direction

Railway line Adjacent to the Site (south)

Farm Stead 150m north west

5.8 WATER ENVIRONMENT

5.8.1. There is one main river within 1km to the Site, comprising Afon Brook located 1km to the south

of the Site.

5.8.2. The Glan yr Afon Brook is flows through the woodland area to the north of the Site and

continues flowing east, before heading south east and converging with the Black Brook 1km

south from the Site.

5.8.3. The Site is partially located within both flood zone B & C2, due to its proximity to the Glan yr

Afon Brook, as shown below. Flood Zone C2 are areas of floodplain without significant flood

defence infrastructure and Flood Zone B are Areas known to have flooded in the past, as

described in TAN15.

5.9 TRAFFIC AND TRANSPORT

BASELINE ASSESSMENT

5.9.1. The Site, which is currently allocated as derelict land, is bound to the north by the A5152, to

the west by the A483, to the east by access roads connecting to Bersham Enterprise Centre,

and to the south by vacant land. The Site is considered to be well connected to the Major

Road Network, with the A483 trunk road providing connections from Swansea to Chester. It

is assumed that vehicular access will be taken from the existing local highway network,

namely the Church Street / Wrexham Road / A5152 junction which connects to Bersham

Enterprise Centre.

5.9.2. The Site is well connected by public transport, with several bus stops being located along the

A5152 which connect to Wrexham and further afield. The bus stops are served by Arriva and

a summary of their services is provided in Table 5-9 below.

Table 5-9 – Bus Services

Service Number Origin / Destination Service Frequencies

2 Oswestry Hourly

2A Oswestry Hourly

2C Cefn-Bychan Every 30 mins

3 Penycae Every 30 mins

4A Afon Eitha Hourly

5 Llangollen Every 30 mins

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 20 of 32

Service Number Origin / Destination Service Frequencies

5C Wrexham Every 30 mins

5.9.3. The nearest rail station is Wrexham Central which provides services to Bidston, Holyhead,

Cardiff Central and Birmingham International. The rail station can be accessed by bus from

the Site.

5.9.4. The Site is well connected to the local highway network, with pedestrian footways provided

on the western side of the carriageway into and out of Bersham Enterprise Centre, which it is

assumed would be the main access route used for vehicles and employees accessing the

Site. There is a public right of way (PRoW) which runs through the proposed site location

(ESC/15) as shown in Figure 5-1 below. This is a footpath which could be impacted on given

its route through the Site.

Figure 5-1 - Public Right of Way though the Site

Source: http://www.wrexham.gov.uk/english/leisure_tourism/prow/definitive_map.htm

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 21 of 32

Figure 5-2 - Environmental Constraints Map

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 22 of 32

5.10 POSSIBLE MITIGATION

5.10.1. Environmental impacts on the environment should be managed by:

Providing effective mitigation where necessary;

Ensuring best practise measures and pollution prevention measures are in place during the

construction phase; and

Carrying out work under method statements and under supervision by a licenced ecologist where

necessary and/or appropriate.

5.10.2. At this stage of the project, the exact design life of the project during operation is not known, and it is

expected that the infrastructure will remain in situ for its design life (approximately 27 years). It is

anticipated that maintenance will be required periodically throughout the life of the scheme, but

activities will be temporary and minimal. When the scheme is decommissioned, the prior land use and

form would be reinstated, where possible – notwithstanding any planning applications which may

follow.

5.11 SCOPING OPINION

5.11.1. The Proposed Development do not lie within any designated or protected areas and the Site is not a

“sensitive area” as defined in regulation 2 (1), but the Scheme covers an area over the threshold of

0.5ha.

5.11.2. From the baseline assessment undertaken and noted above, environmental impacts could arise due

to: an increase in noise and vibration during construction; a decrease in air quality during construction

and operation; increase in traffic associated journey times during construction; adverse visual impacts

caused by construction activities and the loss of land and vegetation; impacts on the setting of

scheduled monuments, and an increase in HGVs in the area and additional vehicles travelling to the

Site adding to an increase in general disruption to the local highway network and nearby receptors.

Many of these impacts however will be temporary and will last as long as the construction works. With

appropriate mitigation measures in place it is envisaged that these effects will be non-significant.

5.11.3. Consequently, we conclude that the Proposed Development project is therefore be ‘EIA Development’

and that an application for planning permission does need to be accompanied by an Environmental

Impact Assessment, albeit this position will be formally reached and confirmed by the Welsh Ministers.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 23 of 32

6 CHARACTERISTICS OF POTENTIAL IMPACTS

6.1 POTENTIAL ENVIRONMENTAL IMPACT SUMMARY TABLE

6.1.1. This section assesses the scheme’s potential impacts during both the construction and operational

phases, and provides the basis for determining whether an EIA is required or not. In order to

characterise the likely change and impact, it is necessary to take into account all the following

parameters, as per article 3 of Schedule 3 of the 2017 Regulations:

The magnitude and spatial extent of the impact;

The nature of the impact;

The transboundary nature of the impact;

The intensity and complexity of the impact;

The probability of the impact;

The expected onset, duration, frequency and reversibility of the impact;

The cumulation of the impact with the impact of other existing and/or approved development; and

The possibility of effectively reducing the impact.

6.1.2. As per Section 5 of this Report, the following topics have been assessed:

Air Quality;

Cultural Heritage;

Landscape;

Ecology;

Geology and Soils;

Materials;

Noise and Vibration;

Pedestrian, Cyclists and Community Effects; and

Road Drainage and the Water Environment.

6.1.3. See Table 6-1 below for an environmental appraisal assessment and summary of the Proposed

Development.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 24 of 32

Table 6-1 – Potential Environmental Impact Summary Table

Environmental Receptors

Assessment Magnitude and Spatial Extent of Impact

Nature of The Impact Transboundary Nature of The Impact

Intensity and Complexity of The Impact

Probability of The Impact

Duration of Impact Frequency of Impact

Reversibility of Impact

Cumulative Impacts

Reducing and Mitigating Impacts

Conclusion

Air Quality Construction

During construction, the Proposed Scheme has the potential to create temporary adverse nuisance impacts due to dust (arising due to construction activities) and impacts on human health from particulate matter and exhaust emissions associated with construction plant and machinery.

As stated by the Institute of Air Quality Management (IAQM), ‘with the implementation of effective site-specific mitigation measures the environmental effect will not be significant in most cases’. As such, the residual effect of the construction phase on nearby receptors is likely to be negligible providing that best practice site-specific mitigation measures are implemented.

Operational

HGV trips associated with the operation of the Proposed Scheme are anticipated to be significantly less than the extant planning permission given that material will be sourced from the colliery spoil tip and therefore remain on internal haul roads. On this basis, air quality emissions associated with HGV movements are likely to have a negligible impact on offsite sensitive receptors located close to the road network.

Dust and particulate emissions arising from reclamation activities, the operation of the shale energy facility and/or movement of materials within the Application Site are also likely to be negligible provided that appropriate mitigation measures, such as those agreed for the Extant Permission (as outlined above), are implemented.

Construction

Local impact on sensitive receptors within proximity to the Scheme.

Operational

Potential impact on air quality for sensitive receptors to the access road, and potential dispersal impacts (further modelling required).

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and with best practise measures in place are unlikely to have a significant environmental effect.

Detailed dispersion modelling will be required to determine potential operational impacts.

The impacts of the scheme will be temporary and are likely to be localised.

No transboundary impacts are anticipated. However, detailed dispersion modelling will be required to determine potential operational impacts.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised by ensuring that all best practise measures are in place throughout the works to avoid any potential environmental pollution events. Wherever possible, abatement technologies will be applied to reduce emissions to air/odour associated with the operation of the Proposed Scheme.

It is not likely that the construction and operation of the Plant will increase in air quality impacts will be detrimental to the environment and local receptors, there are no AQMAs within 2km and therefore the air quality in this area is assumed to be relatively good. However, detailed dispersion modelling will be required to determine potential operational impacts.

Construction

The impacts will be temporary and localised and will only last for a short duration.

Operational

There may be an impact in air quality overtime if the number of vehicles using the access road increases over time. Detailed dispersion modelling will be required to determine potential operational impacts.

Construction

The local air quality is assumed to be good as there are no AQMAs within 2km. Therefore, the increase in vehicles during the construction phase is only likely to have a temporary impact on air quality. Traffic management will remain in place only when required.

Operational

There may be an impact in air quality overtime due to the operation of the plant. Detailed dispersion modelling will be required to determine potential operational impacts.

Construction

The air quality in the area is relatively good, therefore the area may be able to absorb low levels of pollution. Impacts from the proposed Scheme during construction will be temporary and can be mitigated with appropriate best measures in place throughout the construction period.

Operational

The air quality in the area is relatively good, therefore the area may be able to absorb low levels of pollution, however there may be a decrease in air quality in this area if due to the emissions from the plant. Detailed dispersion modelling will be required to determine potential operational impacts

No cumulative impacts are anticipated.

Construction

Best practise measures will be in place to ensure dust and vehicle emissions are kept to a minimum and traffic management is only in place for as long as is required.

Operational

There is the potential for odorous releases during the operation of the Proposed Scheme. Due to its size (30MW), emissions to air from the proposed energy plant may also result in perceptible increases in pollutant concentrations at nearby sensitive receptors (human and ecological). Therefore, further assessment (i.e. detailed dispersion modelling) will be required. Wherever possible, abatement technologies will be applied to reduce emissions to air/odour associated with the operation of the Proposed Scheme.

Construction

During construction, the Proposed Scheme has the potential to create temporary adverse nuisance impacts due to dust (arising due to construction activities) and impacts on human health from particulate matter and exhaust emissions associated with construction plant and machinery. The residual effect of the construction phase on nearby receptors is likely to be negligible providing that best practice site-specific mitigation measures are implemented.

Operational

Air quality emissions associated with HGV movements are likely to have a negligible impact on offsite sensitive receptors located close to the road network.

Dust and particulate emissions arising from reclamation activities, the operation of the shale energy facility and/or movement of materials within the Application Site are also likely to be negligible provided that appropriate mitigation measures, such as those agreed for the Extant Permission (as outlined above), are implemented.

There is the potential for odorous releases during the operation of the Proposed Scheme. Due to its size (30MW), emissions to air

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 25 of 32

There is the potential for odorous releases during the operation of the Proposed Scheme. Due to its size (30MW), emissions to air from the proposed energy plant may also result in perceptible increases in pollutant concentrations at nearby sensitive receptors (human and ecological). Therefore, further assessment (i.e. detailed dispersion modelling) will be required. Wherever possible, abatement technologies will be applied to reduce emissions to air/odour associated with the operation of the Proposed Scheme.

from the proposed energy plant may also result in perceptible increases in pollutant concentrations at nearby sensitive receptors (human and ecological). Therefore, further assessment (i.e. detailed dispersion modelling) will be required. Wherever possible, abatement technologies will be applied to reduce emissions to air/odour associated with the operation of the Proposed Scheme.

Cultural Heritage

Construction

Construction related activities that could result in likely adverse significant effects will include, but are not limited to:

Vehicle movement; The siting of large

plant; the exportation of

material into and out of site;

the construction of the energy facility; and

the siting of temporary structures.

Significant effects caused during the construction phase related activities listed above are likely to impact upon buried archaeological remains and the setting of designated and non-designated heritage assets.

Archaeological remains: It is possible that construction works will permanently remove or disturb archaeological assets. In particular, there are likely to be unknown below-ground archaeological remains associated with Bersham Colliery on site.

Setting of heritage assets: Construction related works are likely to temporarily impact upon the setting of designated and non-designated heritage assets. There are likely to be significance adverse effects upon assets associated with Bersham Colliery, due to

Construction

Potential local impact on buried archaeological remains in undisturbed ground.

Operational

No impacts are anticipated.

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and with best practise measures in place are unlikely to have a significant environmental effect.

The impacts of the Scheme will be temporary and will be localised. No transboundary impacts are anticipated during the construction or operation of the scheme.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised quite simply by ensuring that all best practise measures are in place throughout the works to avoid any potential impacts to important archaeological

artefacts events.

It is not likely that the construction and operation of the road will have a detrimental impact on cultural heritage.

Construction

Impacts during construction will be temporary and will only last a short duration.

Operational

No impacts are anticipated.

Construction

During the construction period the presence of plant and construction compounds and activities are expected to have an impact on the setting of the area. However, these will only last a short duration.

Operational

No impacts are anticipated.

Construction

Any impacts will be mitigated with best practise measures and mitigation in place throughout the construction phase.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

Construction

Mitigation measures will include best practise measures and ensuring the works stop if in the unlikely event that buried archaeology is recovered.

Operational

No mitigation measures are required.

Construction

Should there be any unrecorded assets discovered during construction these may be significantly impacts, and appropriate mitigation will be proposed.

Operational

During the operational phase there is likely to be a significant adverse effect on the setting of Scheduled Monument DE199 Bersham Colliery Winding Gear.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 26 of 32

their proximity to the Proposed Development.

Operational

Operation related activities will include, but are not limited to:

the reclamation of the colliery spoil tip; and

the siting of the energy facility

It is possible that operational works will permanently affect the setting of designated and non-designated heritage assets associated with Bersham Colliery. In particular, there is likely to be a significant adverse effect on the setting of Scheduled Monument DE199 Bersham Colliery Winding Gear.

Landscape Construction

The scheme is not within any designated landscape areas. There may be some temporary adverse visual impacts during the construction phase due to the presence of plant and machinery. However, these will be temporary and only last for a short duration. The proposed development building will sit within the south western corner of the Site. It will be an industrial element within an existing industrial area and as such will not be an incongruous feature. A substantial tree belt along the south and south east boundary is proposed as part of the proposed development. As such, the key landscape characteristic of woodland will be retained (and enhanced).

Potential impacts on the wider landscape including the Clwydian Range and Dee Valley AONB are not anticipated to be significant given the retention of the boundary vegetation, and that the proposed development will be largely screened. Any potential views from these landscapes of the taller elements of the proposed development would be seen within the context of the industrial and urban edge character around the Site and edge of Wrexham.

Operational

Construction

Local impact on landscape during construction due to the presence of plant and machinery.

Operational

It is not anticipated the scheme will have a significant impact on the setting of the area during the operational phase if mitigation measures such as screening are incorporated into the final design.

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and, with best practise measures in place, they are unlikely to have a significant environmental effect.

The impacts of the scheme will be temporary and will be localised. No transboundary impacts are anticipated during the construction or operation of the scheme.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised quite simply by ensuring that all best practise measures are in place throughout the works to avoid any potential environmental pollution events.

It is not likely that the construction and operation of the road will have a long term detrimental impact on the surrounding landscape.

Construction

The impacts during the construction period will be temporary and will only last for a short duration.

Operational

Once screening has established and the development blends into the landscape, no impacts are anticipated long term.

Construction

The construction impacts will be temporary and will only last for a short duration.

Operational

No impacts are anticipated.

Construction

During the construction of the scheme the presence of plant and machinery may have an impact, but this will be temporary and impacts negligible.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

Construction

Mitigation measures will include best practise measures and where possible minimal vegetation will be removed to reduce the impact on the landscape.

Operational

During the operation of the scheme screening may be required to help the road blend into the landscape and reduce its visual impact to sensitive receptors.

Construction

It is not considered there would be any permanent significant adverse impact upon residential amenity and visual impact by way of visual disturbance of the proposed road. Some vegetation will need to be cleared to accommodate the associated foundations. Where possible, vegetation will be retained.

Operational

It is anticipated that there will be no significant visual impacts during the operation of the scheme.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 27 of 32

In summary, the proposed development is considered consistent with the existing industrial character of the Site, and as the characteristic woodland around the Site will be retained and enhanced, providing a substantial screen, there is limited potential for any significant effects on the landscape character of the Site or wider area.

The visual envelope of the proposed development is limited due to the screening by boundary woodland within the Site and across the surrounding landscape. The slag-bank (although consented to be removed) will also provide additional initial screening to the north.

There is more potential for visibility of the proposed development, particularly the stack and silo, from visual receptors to the south and west. However, given the industrial and urban edge context, intervening A483, and the treed nature of the wider landscape, it is not anticipated that views of the proposed development would result in significant impacts on visual receptors in this area.

Ecology Construction

The scheme is taking place approximately 500m from Johnstown Newt Sites SAC and Stryt Las a’r Hafod SSSI. However, due to the distance of the SAC and that they are separated by a large dual carriageway, and lack of breeding habitats for great crested newts within the Site, it is considered that construction related activities are unlikely to have an impact upon these sites.

An ecological walkover and Phase 1 habitat survey of the Site was undertaken in August 2019.

It is anticipated that clearance of mature and high-quality vegetation will be minimal. However, some land take is required to accommodate the development footprint and therefore vegetation,

Construction

The proposed works have the potential to impact the local ecology and habitats in situ.

Operational

Potential impacts on Johnstown Newt Sites SAC from emissions to air.

The nature of the impacts is associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and, with best practise measures in place, they are unlikely to have a significant environmental effect.

The scale of operational impact on Johnston Newt Sites is unknown at present until dispersion modelling data is available.

The impacts of the scheme will be temporary and will be localised. No transboundary impacts are anticipated during the construction or operation of the scheme.

Dispersion modelling data will be required to determine the potential of transboundary operational impacts

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised by ensuring that all best practise measures are in place throughout the works to avoid potential environmental pollution events and any impacts such as killing, injuring, or disturbing protected species.

Dispersion modelling data will be required to determine the intensity and complexity of air emission impacts on Johnston Newt Sites SAC.

It is not likely that the construction and operation of the proposed energy plant development will have a detrimental impact on local ecology.

Construction

The impacts during the construction period will be temporary and will only last for a short duration.

Operational

No impacts are anticipated.

Construction

The construction impacts will be temporary and will be undertaken outside of sensitive periods (bird nesting, reptile hibernation periods etc.).

Operational

Changes in water quality from nitrogen deposition could affect the breeding success of GCN and therefore impact Johnstown Newt Site SAC which could last the entire duration of the scheme

Construction

Providing all construction works are carried out under a Method Statement (MS) which details best practise and pollution prevention measures, and ensuring the works are undertaken outside of sensitive periods it is not anticipated that the proposed Scheme will have a significant impact on the surrounding habitat and species.

Operational

Changes in water quality through nitrogen deposition could have an irreversible impact on breeding success of great crested newts designated as a

No cumulative impacts are anticipated.

Construction

Specific species mitigation measures should be informed by further Phase 2 ecology surveys and should include best practise measures. General mitigation will include spill kits and pollution prevention measures in place. The works are also likely to be carried out under a Method Statement and under supervision of an ecologist.

In addition, where possible, minimal vegetation clearance should be factored into construction and timing of construction to fall outside sensitive ecological periods.

Operational

Construction

The impact from construction works is likely to be localised, temporary and will only last for

a short duration.

It is anticipated that clearance of mature and high-quality vegetation will be minimal. However, it is likely that some land take is required to accommodate the development footprint and therefore vegetation, scrub, grassland and trees will need to be removed.

Effects from construction will be mitigated through design and best practice construction and

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 28 of 32

scrub, grassland and trees will need to be removed. Grasslands and scrub on site provide suitable habitat for invertebrate species, reptiles, and for breeding birds. In addition, there is a low suitability for badgers and dormouse to be present within the Site.

The woodlands and tree lines on site could provide suitable commuting and foraging grounds for bats

Operational

Emissions to air from the proposed energy plant could result in perceptible increases in pollutant concentrations at nearby Johnston Newt Sites SAC and as a result cause an impact on the Site’s qualifying features.

qualifying features of Johnstown Newt Sites SAC.

Mitigation to reduce the impact on Johnstown Newt Sites during operation of the development will be informed by data and results produced by air quality assessments.

other suitable methods where required.

It is unlikely that the Proposed Development will have significant adverse impacts on habitats and species within the development footprint, however to fully conclude this, phase 2 protected species surveys should be carried out.

Operational

The operational period of the Proposed Development could have significant adverse impacts on Johnston Newt Sites SAC as a result of emissions to air. At present the impact is unknown and would need further air quality assessment and dispersion modelling to understand the level of impact.

It is not yet known if the proposed scheme will be artificially lit during operation, and therefore the impacts on surrounding ecology is not yet known.

Geology and Soils (Contaminated Land)

Construction

No assessments have been undertaken to date. Earthworks associated with the construction phase will be taking place although the cut/fill balance and requirement for import and export of materials has not yet been established. Issues associated with potential land contamination cannot be discounted at this stage.

Operational

Land take will be minimal and no further impacts are anticipated.

It is assumed best practise will be maintained associated with any

Construction

Whilst some impacts are anticipated, there are unlikely to be any significant impacts to soils and geology.

Operational

Negligible impacts are anticipated.

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and with best practise measures in place are unlikely to have a significant environmental effect.

The impacts of the scheme will be temporary and unlikely to be significant. No transboundary impacts are anticipated during the construction or operation of the scheme.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can potentially be mitigated by ensuring that all best practise measures are in place throughout the works to avoid any potential environmental pollution events.

It is likely that the construction and operation of the proposed energy plant will not result in significant detrimental impacts on local geology and soils.

Construction

The impacts during the construction period will be temporary and will last for a short duration.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

Once the construction activities are completed, the ground will be reinstated before any landscaping takes place.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

No mitigation measures are required during the construction or operation of the scheme.

Construction

It is not thought that there will be a significant impact on the sand and gravel resources present, and land take will be minimal.

Operational

No impacts are anticipated.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 29 of 32

chemical storage of the energy plant.

Materials Construction

Materials used for the Scheme will be transported to site. At this stage, it is not known what materials will be used.

Any waste created during construction is likely to be removed from site and disposed of at a suitable facility.

Operational

No impacts are anticipated.

Construction

The impacts of deliveries of materials may have some impacts locally due to the increased movements of lorries on the road; however, given the scale of the development it is not anticipated to have significant disruption on the road network.

Operational

No impacts are anticipated.

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and with best practise measures in place are unlikely to have a significant environmental effect.

The impacts of the scheme will be temporary and will be localised. No transboundary impacts are anticipated during the construction or operation of the scheme.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised quite simply by ensuring that all best practise measures are in place throughout the works to avoid any potential environmental pollution events.

It is not likely that the construction and operation of the road will have a detrimental impact on materials.

Construction

The impacts during the construction period will be temporary and will last for a short duration.

Operational

No impacts are anticipated.

Construction

All materials should aim to be sustainably and locally sourced, and the lifespan and maintenance of the road should be designed so it is minimal and low cost.

Operational

No impacts are anticipated.

Construction

During the construction phase, access areas and deliveries of materials to and from site should be managed through a Construction Environmental Management Plan (CEMP). However, given the scale of the development it is not anticipated there will be as significant disruption to the road network provided construction is managed efficiently.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

No mitigation measures are required during the construction or operation of the scheme.

Construction

Materials used to surface the proposed Scheme will need to be transported to site. At this stage, it is not known what materials will be used.

Any waste generated during the construction phase is likely to be removed from site and disposed of at a suitable facility.

Operational

No impacts are anticipated.

Noise and Vibration

Construction

There may be some noise and vibration impacts due to the activities associated with the construction of the scheme. The nearest receptors are within 300m and will therefore be subject to some noise disturbance.

Operational

During the operation of the scheme, some residential properties within proximity to the alignment may experience an increase in noise disturbance due to increased number of vehicles which were not present before.

Construction

The impacts on noise and vibration are considered to be local and limited to sensitive receptors situated further from the scheme.

Operational

During the operation of the scheme, some residential properties within proximity to the alignment may experience an increase in noise disturbance due to increased number of vehicles which were not present before.

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated, and with best practise measures in place, are unlikely to have a significant environmental effect.

The impacts of the scheme will be temporary and will be localised. No transboundary impacts are anticipated during the construction or operation of the scheme.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised by ensuring that all best practise measures are in place throughout the works to avoid any potential environmental impacts.

It is not likely that the construction and operation of the road and the potential increase in noise will not be detrimental to the environment.

The proximity of the road may increase noise and vibration levels for sensitive receptors.

Construction

The construction impacts on noise and vibration will be temporary and will only last for a short duration.

Operational

No impacts are anticipated.

Construction

The area surrounding the scheme is semi-rural, with a built-up area of Rhostyllen to the north east. With best practise measures in place, it is not anticipated noise impacts will be significant.

Operational

No impacts are anticipated.

Construction

It is anticipated that any significant noise impacts during the construction of the Scheme will be temporary and will only last for a short duration. The impacts can be managed through best practise measures and implemented through the CEMP.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

Construction

Best practise mitigation measures will be in place during the construction phase to ensure noise levels are kept to a minimum.

Operational

No mitigation measures are required.

Construction

Providing all significant noise impacts are suitable managed through best practise measures and a CEMP no significant impacts are anticipated.

Operational

No impacts are anticipated.

Pedestrian, Cyclists and Community Effects

Construction

There is one PRoW which will require diversion during the construction phase. There may be some traffic management required on the A5152 and the road through the Enterprise Centre, which may affect driver frustration by increasing journey times.

Operational

There will be no change to the operation or layout of

Construction

The impacts on the community and people are considered to be local and limited to those who use the B4489, Pant Lasau Road and Rhydypandy Road frequently.

Operational

No impacts are anticipated.

The nature of the impacts are associated with the construction works, and are therefore likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and with best practise measures in place are unlikely to have a significant environmental effect.

The impacts of the scheme will be temporary and will be localised. No transboundary impacts are anticipated during the construction or operation of the scheme.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised quite simply by ensuring that all best practise measures are in place throughout the works to avoid any potential

During the construction and operation of the scheme, the impacts caused by traffic management and a slight change in junction layout is unlikely to have a detrimental impact on local community.

Construction

The construction impacts on the community will be temporary and will only last for a short duration.

Operational

No impacts are anticipated.

Construction

The construction impacts on the community will be temporary and will only last for a short duration.

Operational

No impacts are anticipated.

Construction

The construction impacts on the community will be temporary and will only last for a short duration.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

Construction

It is anticipated that there will be road closures/diversions/traffic management required during the works. The impacts on the community will be minimised by ensuring residents are notified of the works prior to construction commencing, and traffic management will only be in place

Construction

Temporary traffic management will be required may be required during construction.

Operational

There will be no change to the operation or layout of the roads surrounding Enterprise Centre. Therefore, no

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 30 of 32

the roads surrounding Enterprise Centre. Therefore, no impacts are anticipated.

environmental pollution events.

for as long as required.

Operation

No mitigation is required.

impacts are anticipated.

Road Drainage and the Water Environment

Construction

The scheme is situated within proximity to a flood zone and one water course comprising the Glan yr Afon Brook. However, given the distance from the Site no pollution events are anticipated.

Operational

Providing mitigation measures and best practise measures are in place no impacts are anticipated.

The potential impact of flooding is considered to be localised affecting the land surrounding the Glan yr Afon Brook, during both the construction and operational phase.

The nature of the impacts are associated with the construction works, and are, therefore, likely to be localised, temporary and will only last for a short duration. As the nature of the impacts are associated with the construction activities, these can be mitigated and, with best practise measures in place, they are unlikely to have a significant environmental effect.

Construction

There is the potential that pollution could enter the watercourse during construction and therefore have a detrimental impact further downstream. However, given the distance from the Site this is unlikely. These potential impacts will be minimised by ensuring best practise and pollution prevention measures are in place throughout the works.

Operational

No impacts are anticipated.

As the potential impacts are associated with the construction activities, they are temporary and only last for a short duration. These impacts can be minimised by ensuring that all best practise measures are in place throughout the works to avoid any potential environmental pollution events.

During the construction and operation of the scheme it is unlikely there will be any detrimental impacts to the road drainage, and water environment.

Construction

The potential impact of flooding caused by the construction activities will be temporary and last for a short duration.

Potential pollution events will be temporary during the construction phase.

Operational

The potential impacts of flooding caused by the proposed Scheme will be in place throughout the duration of the lifespan of the road.

Potential pollution events will be temporary during the construction phase.

No flood modelling has been undertaken to date. However, with migration measures in place during both construction and operational phase it is anticipated that the presence of the road will not impact the surround flood risk level.

With best practise and mitigation measures and pollution prevention measures in place throughout the construction phase, no impacts are anticipated.

Where the depth of potential flooding is above the threshold level in the operational phase, protection at this area could be a suitable mitigation measure which will minimise the risk of flooding on the road and associated access track during both the construction and operational phase.

Pollution prevention measures and spill kits will ensure no pollution enters the watercourse which could also have an impact downstream if any pollution enters the water stream.

No cumulative impacts are anticipated.

Construction

Best practise mitigation measures will be in place throughout the works to ensure no pollution enters the watercourse. Spill kits will also be available in case of a potential pollution event.

It is recommended that a Flood Risk Assessment (FRA) is carried out to inform the design and assess the impacts upon the surrounding area.

With suitable mitigation in place, pollution prevention measures and best practise it is considered the scheme will have no significant impact during both the construction and operational phase.

Traffic and Transport

Construction

A Transport Assessment / Transport Statement will need to be produced which will measure the impact of the development on the surrounding transport network, and may propose mitigation measures where these are necessary to avoid unacceptable or severe impacts in line with National Planning Policy Framework (NPPF).

At this stage it is considered that the key areas that would need to be assessed include:

Access and servicing arrangements of the Site;

Traffic flows and impact on the local highway network;

Parking supply and demand;

Public transport accessibility; and

Pedestrian and cycle journeys, accessibility and facilities.

It is envisaged that a Travel Plan will not be required, but this will depend on the estimated

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

No cumulative impacts are anticipated.

Construction

No impacts are anticipated.

Operational

No impacts are anticipated.

A Transport Assessment / Transport Statement will need to be produced which will measure the impact of the development on the surrounding transport network, and may propose mitigation measures where these are necessary to avoid unacceptable or severe impacts in line with National Planning Policy Framework (NPPF).

At this stage it is considered that the key areas that would need to be assessed include:

Access and servicing arrangements of the Site;

Traffic flows and impact on the local highway network;

Parking supply and demand;

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 31 of 32

number of employees on site. Given the sustainable location of the Site, it is anticipated that vehicular trips associated with the development proposals would be reduced.

It is envisaged that details relating to construction traffic and impacts would be dealt with via the provision of a Construction Traffic Management Plan (CTMP), which would be prepared in conjunction with the application.

Operation

The potential increase in vehicle and HGV trips and resultant impacts on the operation and safety of the local highway network. This would further need to be considered in light of any planned / committed developments in the local area.

Public transport accessibility; and

Pedestrian and cycle journeys, accessibility and facilities.

It is considered that the key areas of assessment identified could be addressed through the provision of a Transport Assessment / Statement. On this basis, it is not considered that an Environmental Statement (ES) Transport Chapter would be appropriate or useful.

ENERGY PLANT & RECLAMATION SCHEME CONFIDENTIAL | WSP Project No.: 70054016 SEPT 2019 Bersham (Glenside) Ltd Page 32 of 32

7 CONCLUSION

7.1.1. The scheme proposes the development of a circa 30MW energy plant to be located on the

existing disused colliery site in Bersham.

7.1.2. The Proposed Development is not located within any statutory designated areas, but has the

potential for likely significant adverse environmental impacts during the construction phase

of the development, and potentially during the operational phase.

7.1.3. Initially, the environmental impacts from the Proposed Development are largely expected to

be associated with the material reclamation of the former colliery spoil tip and the

construction and operation of the shale recovery / energy facility. These effects include

noise, dust, lighting, transport, ecology and heritage.

7.1.4. Likely significant adverse impacts to environmental receptors from the Proposed

Development have been identified as:

Ecological receptors in and around the woodland;

Impacts on the setting of Scheduled Monuments;

Potential of odorous releases during the operation of the scheme (further detailed

dispersion modelling and further assessment will be required);

Potential increase in noise due to operation of plant and increase in vehicles and HGV

trips; and

Potential increase in vehicle and HGV trips and resultant impacts on the safety of the

local highway network.

7.1.5. It is considered that any likely significant adverse impacts on the environment could be

managed with best practise measures and specific design mitigation to reduce the

construction and operational impacts.

7.1.6. Notwithstanding this, given the above and the size of the proposals, it is considered that the

Proposed Development constitutes EIA development and, accordingly, requires an

Environmental Statement to support the planning application, albeit this position will be

formally reached and confirmed by the Welsh Ministers.

7.1.7. Should the Proposed Development be considered to be EIA development by the Ministers we

will look to submit an EIA screening opinion request to them as soon as reasonably possible

thereafter.

CONFIDENTIAL

1 Capital Quarter

Tyndall Street

Cardiff

CF10 4BZ

wsp.com