millerhill recycling and energy recovery centre (rerc)€¦ · 1488-01 / es main report millerhill...

MILLERHILL RECYCLING AND ENERGY RECOVERY CENTRE (RERC)

PROPOSED DEVELOPMENT OF AN INTEGRATED WASTE RECOVERY FACILITY ON LAND OFF AT THE

FORMER MILLERHILL MARSHALLING YARDS, WHITEHALL ROAD, MILLERHILL, DALKEITH

ENVIRONMENTAL STATEMENT VOLUME 1 - MAIN REPORT

MARCH 2015

This report is submitted in support of a detailed planning application for the above

project. The application has been co-ordinated by AXIS with technical inputs from:

AXIS – Project Management / Co-ordination, Planning Policy & Need, Traffic &

Transportation, Landscape & Visual Effects, Surface Water & Flood Risk and

General Environmental Matters

Environmental Compliance – Air Quality, Human Health

GSDA – Architectural Design

NVC – Noise

Argus – Ecology and Nature Conservation

AOC – Archaeology and Heritage

TerraConsult – geology, Hydrogeology and Ground Conditions

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CONTENTS

FOREWORD

LIST OF ACRONYMS

1.0 INTRODUCTION ............................................................................................... 1

1.1 Introduction ........................................................................................................ 1

1.2 The Proposal ..................................................................................................... 1

1.3 The Site and Its Context ..................................................................................... 4

1.4 Background to the Scheme and Compliance with the extant PPiP ..................... 7

1.5 The Applicant ................................................................................................... 12

1.6 This Document ................................................................................................. 12

2.0 SCOPE OF THE ENVIRONMENTAL ASSESSMENT ..................................... 14

2.1 Scope .............................................................................................................. 14

2.2 Baseline for the Environmental Impact Assessment ......................................... 20

2.3 Assessment of Environmental Effects .............................................................. 23

2.4 Cumulative Effects ........................................................................................... 24

2.5 Structure of the Environmental Statement ........................................................ 25

3.0 NEED AND ALTERNATIVES .......................................................................... 27

3.1 The Need for the Scheme ................................................................................ 27

3.2 Alternatives Considered ................................................................................... 31

4.0 SCHEME DESCRIPTION ................................................................................ 43

4.1 Introduction and Scheme Overview ................................................................. 43

4.2 Permanent Development ................................................................................. 45

4.3 Proposed Site Operations ................................................................................ 60

4.4 Energy Recovery ............................................................................................. 72

4.5 Operational Environmental Management ......................................................... 77

4.6 Proposed Contingency Plans ........................................................................... 81

4.7 Waste Inputs .................................................................................................... 81

4.8 Energy (Heat and Power) Connectivity ............................................................ 84

4.9 Construction Methods ...................................................................................... 85

5.0 PLANNING POLICY CONTEXT ...................................................................... 94

5.1 Introduction ...................................................................................................... 94

5.2 Policy Context .................................................................................................. 94

6.0 TRAFFIC AND TRANSPORTATION ............................................................... 97

6.1 Introduction ...................................................................................................... 97

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6.2 Assessment Modelling ................................................................................... 100

6.3 Baseline Highway Network Conditions ........................................................... 104

6.4 Assessment of RERC Operational Traffic Issues ........................................... 109

6.5 Assessment of Development Construction Traffic Issues ............................... 116

6.6 Additional Mitigation Measures ...................................................................... 120

6.7 Impact Summary ............................................................................................ 121

7.0 LANDSCAPE AND VISUAL EFFECTS ......................................................... 123

7.1 Introduction .................................................................................................... 123

7.2 Methodology .................................................................................................. 129

7.3 Baseline ......................................................................................................... 131

7.4 Assessment of Effects ................................................................................... 138

7.5 Additional Mitigation ....................................................................................... 156

7.6 Residual Effects ............................................................................................. 156

7.7 Conclusions ................................................................................................... 156

7.8 References .................................................................................................... 157

8.0 ECOLOGY AND NATURE CONSERVATION ............................................... 159

8.1 Introduction .................................................................................................... 159

8.2 Methodology .................................................................................................. 166

8.3 Baseline ......................................................................................................... 171


8.5 Mitigation and Enhancement Measures ......................................................... 199

8.6 Residual Impacts ........................................................................................... 201

8.7 Conclusions ................................................................................................... 202

8.8 References .................................................................................................... 203

9.0 GEOLOGY AND GROUND CONDITIONS .................................................... 204

9.1 Introduction .................................................................................................... 204

9.2 Methodology .................................................................................................. 206

9.3 Baseline ......................................................................................................... 210



9.6 Residual Effects and Conclusions .................................................................. 242

9.7 Conclusions ................................................................................................... 243

9.8 References .................................................................................................... 246

10.0 SURFACE WATERS AND FLOOD RISK ...................................................... 247

10.1 Introduction .................................................................................................... 247

10.2 Methodology .................................................................................................. 247

10.3 Baseline ......................................................................................................... 250

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10.6 Conclusions ................................................................................................... 256

11.0 NOISE AND VIBRATION .............................................................................. 258

11.1 Introduction .................................................................................................... 258

11.2 Legislation, Policy and Guidance ................................................................... 261

11.3 Assessment Methodology .............................................................................. 270

11.4 Baseline ......................................................................................................... 282




11.8 Summary and Conclusions ............................................................................ 305

11.9 References .................................................................................................... 309

12.0 AIR QUALITY ................................................................................................ 311

12.1 Introduction .................................................................................................... 311

12.2 Methodology .................................................................................................. 318

12.3 Baseline ......................................................................................................... 327




12.7 Conclusions ................................................................................................... 340

12.8 References .................................................................................................... 341

13.0 ARCHAEOLOGY AND CULTURAL HERITAGE ........................................... 343

13.1 Introduction .................................................................................................... 343

13.2 Methodology .................................................................................................. 347

13.3 Baseline ......................................................................................................... 357




13.7 References .................................................................................................... 398

14.0 SOCIO-ECONOMIC EFFECTS ..................................................................... 400

14.1 Introduction .................................................................................................... 400

14.2 Methodology .................................................................................................. 401

14.3 Baseline ......................................................................................................... 405




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14.7 Conclusions ................................................................................................... 427

15.0 CUMULATIVE EFFECTS .............................................................................. 430

15.1 Introduction .................................................................................................... 430

15.2 Methodology .................................................................................................. 431

15.3 Baseline ......................................................................................................... 434


15.5 Mitigation Measures ....................................................................................... 443


15.7 Conclusions ................................................................................................... 443

16.0 ENERGY EXPORT CONNECTIONS ............................................................. 445

16.1 Introduction .................................................................................................... 445

16.2 Description of Development ........................................................................... 447

16.3 Approach to Assessment ............................................................................... 451

16.4 Residual Effects and Conclusion .................................................................... 456

17.0 HUMAN HEALTH .......................................................................................... 457

17.1 Introduction .................................................................................................... 457

17.2 Methodology .................................................................................................. 463

17.3 Baseline ......................................................................................................... 467




17.7 Conclusions ................................................................................................... 479

17.8 References .................................................................................................... 480

18.0 SUMMARY OF EFFECTS ............................................................................. 481

18.1 Introduction .................................................................................................... 481

18.2 Traffic and Transportation .............................................................................. 481

18.3 Landscape and Visual Impact ........................................................................ 483

18.4 Ecology and Nature Conservation .................................................................. 486

18.5 Geology and Hydrogeology ............................................................................ 487

18.6 Surface Waters and Flood Risk ...................................................................... 489

18.7 Noise and Vibration ........................................................................................ 490

18.8 Air Quality and Human Health ........................................................................ 492

18.9 Cultural Heritage ............................................................................................ 493

18.10 Socio-Economic Effects ................................................................................. 494

18.11 Cumulative Effects ......................................................................................... 496

18.12 Energy Export Connection ............................................................................. 496

18.13 Human Health ................................................................................................ 497

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18.14 Summary ....................................................................................................... 498

FIGURES

Figure 1.1 Site Location

Figure 1.2 Approved Shawfair Masterplan

Figure 2.1 Zero Waste Parc Layout (Option A)

Figure 2.2 Baseline Developments

Figure 2.3 Surrounding Development Proposals

Figure 2.4 Overlay of PPiP and Millerhill RERC Development

Figure 4.1 Site Layout

Figure 4.2 Roof Plan

Figure 4.3 Existing Site Sections

Figure 4.4 Proposed Site Sections

Figure 4.5 South Elevation

Figure 4.6 West Elevation

Figure 4.7 North Elevation

Figure 4.8 East Elevation

Figure 4.9 Section C - C

Figure 4.10 Section D - D

Figure 4.11 Visitor Centre and Staff Accommodation Elevations and Plans

Figure 4.12 Gatehouse Elevations and Plans

Figure 4.13 Crew Welfare Elevations and Plans

Figure 4.14 Bale Storage Elevations

Figure 4.15 Cycle Store, Bin Store and Smoking Shelter Elevations and Plans

Figure 4.16 Fencing and Gating Plan

Figure 4.17 Schematic Flow Diagram

Figure 7.1aL Landscape Character and Designations (5km radius)

Figure 7.1b Landscape Character and Designations (2.5km radius)

Figure 7.2 Zone of Theoretical Visibility

Figure 7.3a Viewpoint Sheet 1

Figure 7.3b Viewpoint Sheet 2

Figure 7.3c Viewpoint Sheet 3

Figure 7.3d Viewpoint Sheet 4

Figure 7.3e Viewpoint Sheet 5

Figure 7.3f Viewpoint Sheet 6

Figure 7.3g Viewpoint Sheet 7

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Figure 7.3h Viewpoint Sheet 8

Figure 7.3i Viewpoint Sheet 9

Figure 7.3j Viewpoint Sheet 10

Figure 7.3k Viewpoint Sheet 11

Figure 7.3l Viewpoint Sheet 12

Figure 7.3m Viewpoint Sheet 13

Figure 7.4 Indicative Landscape Masterplan

Figure 8.1 Statutory Designated Sites and Ancient Woodlands

Figure 10.1 Schematic Drainage Layout

Figure 11.1 Baseline Noise Monitoring Positions (2014 and 2015 Surveys)

Figure 13.1 Heritage Assets within 2km of Proposed Development

Figure 13.2 Heritage Assets within 5km of Proposed Development

Figure 14.1 Midlothian Wards 1999 to 2007

Figure 14.2 Midlothian Wards 2007 onwards

Figure 15.1 5km Area of Search

Figure 16.1 Heat Connection Route

Figure 16.2 Electricity Connection Route

TECHNICAL APPENDICES (BOUND SEPARATELY AS VOLUME 2)

Appendix 1-1 Planning Permission in Principle (reference: 11/00174/PPP)

Appendix 2-1 EIA Scoping Report

Appendix 2-2 Historic Scotland Consultation Response

Appendix 2-3 Minutes of Meetings

Appendix 6-1 Transport Assessment

Appendix 7-1 Landscape and Visual Impact Assessment Methodology

Appendix 7-2 Viewpoint Selection

Appendix 7-3 Effects on Landscape Character

Appendix 7-4 Effects on Viewpoints

Appendix 8-1 Extended Phase 1 Habitat Survey

Appendix 10-1 Greenfield Run-off Information

Appendix 10-2 Surface Water Attenuation Calculations

Appendix 11-1 Basic Acoustic Terminology

Appendix 11-2 Noise Survey Details

Appendix 11-3 Background Noise Survey Results

Appendix 11-4 Construction Plant Inventory

Appendix 11-5 Assumed Noise Levels for Site

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Appendix 11-6 Noise Mapping

Appendix 11-7 Vibration Terminology

Appendix 11-8 Vibration Monitoring Details

Appendix 12-1 Air Quality Assessment

Appendix 13-1 Site Gazetteer

Appendix 13-2 Guide for Contextualised Aesthetic Appreciation of Monuments

Appendix 13-3 Cultural Heritage Plates

Appendix 14-1 Socio-Economic GVA Estimates

Appendix 15-1 Local Authority Baseline Data

Appendix 17-1 Human Health Risk Assessment

1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 viii

FOREWORD

This Environmental Statement (ES) supports and accompanies the planning application

for the construction and operation of the Millerhill Recycling and Energy Recovery

Centre; an integrated waste recovery facility, located on land at the former Millerhill

Marshalling Yards, Whitehill Road, Millerhill, Dalkeith. The ES comprises the following

documents.

The Environmental Statement (ES) Main Report (Volume 1), which contains the

detailed project description; an evaluation of the current environment in the area

of the proposed development; the predicted environmental impacts of the

scheme; and details of the proposed mitigation measures which would alleviate,

compensate for, or remove those impacts identified in the study. Volume 1 also

includes a summary of the overall environmental impacts of the proposed

development and all relevant schematics, diagrams and illustrative figures;

Technical Appendices (Volume 2), which include details of the methodology and

information used in the assessment, detailed technical schedules and, where

appropriate, raw data; and

Non-Technical Summary (Volume 3), containing a brief description of the

proposed development and a summary of the ES, expressed in non-technical

language.

Copies of the documents, as a three volume set, are available at a cost of £250 from

FCC Environment’s planning agent by writing to the following address: AXIS, Camellia

House, 76 Water Lane, Wilmslow, Cheshire, SK9 5BB. Cheques should be made

payable to AXIS P.E.D. Ltd. Alternatively, the Non-Technical Summary can be

purchased on its own from the same point of contact for £20. An electronic copy of the

Non-Technical Summary is also available free of charge via email:

[email protected] In addition, all of the planning application

documentation, including the ES can be downloaded from:

http://www.fccenvironment.co.uk/edinburgh-mid-lothian-efw.html

mailto:[email protected]

http://www.fccenvironment.co.uk/edinburgh-mid-lothian-efw.html

1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 ix

LIST OF ACRONYMS

ACC Air Cooled Condensers AD Anaerobic Digestion ADD Average Daily Dose AGLV Area of Great Landscape Value AOD Above Ordinance Datum APC Air Pollution Control APIS Air Pollution Information Service AQ Air Quality AQA Air Quality Assessment AQDD Air Quality Daughter Document AQMA Air Quality Management Area As Arsenic BAT Best Available Technique BCT Bat Conservation Trust Bgl Below Ground Level BOCC Birds of Conservation Concern BTO British Trust for Ornithologists CAA Civil Aviation Authority CAR Control of Asbestos Regulations CCTV Close Circuit Television Camera Cd Cadmium CEMP Construction Environment Management Plan CERE Cambridge Environmental Research Consultants CHP Combined Heat and Power C&I Commercial and Industrial Waste CIBSE Chartered Institution of Building Services Engineers CIEEM Chartered Institute of Ecology and Environmental Management CIfA Chartered Institute of Archaeologists CL Critical Loads CLO Compost like Product CMLI Chartered Member of the Landscape Institute Co Cobalt CO Carbon Monoxide CO2 Carbon Dioxide COPCs Compounds of Potential Concern COT Committee of Toxicity Cr Chromium Cu Copper DEFRA Department for Food and Rural Affairs DNO District Network Operator DTM Digital Terrain Model EA Environment Agency EAL Environmental Assessment Level EC European Commission ECC Edinburgh City Council EcIA Ecological Impact Assessment EfW Energy from Waste ELC European Landscape Convention ELSP Edinburgh and Lothian’s Structure Plan ELVs Emission Limit Values EMP Environmental Management Plan EMS Environmental Management System

1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 x

EPAQs Expert Panel on Air Quality Standards EPS European Protect Species EQS Environmental Quality Standards ERC Energy Recovery Centre ERF Energy Recovery Facility ES Environmental Statement EU European Union EUNIS European Nature Information System FCS Forestry Commission Scotland FGT Flue Gas Treatment GLC Ground Level Concentrations GSDA Gary Stewart Design Associates HCI Hydrogen Chloride HF Hydrogen Fluoride Hg Mercury HGV Heavy Goods Vehicle HHRA Human Health Risk Assessment HHRAP Human Health Risk Assessment Protocol HMIP Her Majesty’s Inspectorate of Pollution HPR Heat Plan Report HQ Hazard Quotient hr Hour HS Historic Scotland HSE Health and Safety Executive IED Industrial Emissions Directive IGCB Interdepartmental Croup of Costs and Benefits IGDL Inventory of Historic Gardens and Designated Landscapes ILE Institute of Lighting Engineers IMS Integrated Management System Km Kilometre Kv Kilo voltage LBAP Local Biodiversity Action Plan LBS Local Biodiversity Site LCA Landscape Character Assessment LCL Local Critical Load LEMP Landscape Environmental Management Plan LVIA Landscape and Visual Assessment MAFF Ministry of Forest and Fisheries MBAP Midlothian Biodiversity Action Plan MBT Mechanical Biological Treatment MDR Metal Deposition Rates MLC Midlothian Council Mn Manganese MSW Municipal Solid Waste MT Mechanical Treatment MW Mega Watt MWe Mega Watt electrical MWh Mega Watt hour NH3 Ammonia Ni Nickel NMRS National Monuments Record for Scotland NOx, Nitrogen Oxides NO2 Nitrogen Dioxide NPF National Planning Framework NTS Non-Technical Summary

1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 xi

NVC National Vegetation Classification PAD Planning Application Document PAH Polyaromatic Hydrocarbons PAN Planning Advice Note PAS Publically Available Specification Pb Lead PC Process Contribution PPC Pollution Prevention Control PCBs Polychlorinated Biphenyls PEC Predicated Environmental Concentration Pm Particulate Matter PPiP Planning Permission in Principle RDF Refused Derived Product RHI Renewable Heat Incentive RIGs Regional Geological Site SAC Special Area of Conservation Sb Antimony SBL Scottish Biodiversity List SEI Supplementary Environmental Information SEPA Scottish Environmental Protection Agency SESplan South East Scotland Plan SHEP Scottish Historic Environment Policy SLA Special Landscape Area SM Scheduled Monument SNCD Shawfair New Community Development SNCR Selected Non-Catalytic Reduction SNIFFER Scotland and Northern Ireland Forum for Environmental Research SNH Scottish Natural Heritage SO2 Sulphur Dioxide SPA Special Protection Area SPP Scottish Planning Policy SRF Solid Recovered Fuel SSSI Site of Special Scientific Interest TA Transport Assessment TDI Tolerable Daily Intake TEQ Toxicity Equivalent TI Thallium TOC Total Organic Carbon tpa Tonnes Per Annum TWIC The Wildlife Information Centre USEPA United States Environmental Protection Agency UK United Kingdom UWS Urban Wildlife Site V Vanadium VOCs Gaseous and Vaporous Organic Substances WFD Waste Framework Directive WHO World Health Organisation WPA Waste Planning Authority ZTV Zone of Theoretical Visibility ZWF Zero Waste Facility ZWP Zero Waste Plan

1488-01 / ES MAIN REPORT MILLERHILL RERC MARCH 2015 1

1.0 INTRODUCTION

1.1 Introduction

1.1.1 This Environmental Statement (ES) has been submitted in support of the

planning application for the construction and operation of the Millerhill

Recycling and Energy Recovery Centre (hereafter referred to as the Millerhill

RERC or Proposed Development); an integrated waste recovery facility,

located on land at the former Millerhill Marshalling Yards, Whitehill Road,

Millerhill, Dalkeith.

1.1.2 The ES describes the proposal and provides an assessment of the likely

significant environmental effects that may arise from the construction and

operation of the Proposed Development.

1.1.3 This introductory chapter describes the background to the Proposed

Development, provides an outline description of the proposal, a description of

the development site and its surrounding context, details of the applicant and

defines the structure of the ES.

1.2 The Proposal

1.2.1 The Proposed Development would comprise four principal elements, all of

which would be contained within a main building, they are:

A waste reception hall;

Primary Treatment: a Mechanical Treatment (MT) process to recover

recyclables, remove reject material and produce a Solid Recovered Fuel

(SRF);

Secondary Treatment: a Energy from Waste (EfW) process (Energy

Recovery Centre – ERC) to recover energy and heat from the SRF. The

SRF would either be sourced from the on-site MT facility or other

suitably licensed pre-treatment or recycling facilities; and

Management of products and outputs from the primary and secondary

treatment processes.


1.2.2 The Proposed Development would receive up to 195,000 tonnes per annum

(tpa) of residual waste. The waste material that would be processed at the

facility would comprise non-hazardous municipal solid waste (MSW) and

similar commercial and industrial (C&I) wastes sourced primarily from within

Edinburgh, Midlothian and adjoining administrative areas.

1.2.3 Of the 195,00tpa of residual waste material received at the facility 135,000tpa

would be waste received through the Edinburgh and Midlothian residual waste

contract (contract waste), with the remaining 60,000tpa comprising SRF

received from either commercial and industrial sources or municipal sources

from neighbouring local authority areas.

1.2.4 The 135,000tpa of contract waste received at the site would be transferred to

the MT process which would recover ferrous and non-ferrous metals (circa

2,740tpa) and other ‘reject’ materials that are unsuitable for thermal treatment

(circa 2,798tpa). The remaining material would comprise an SRF which would

be directed, by conveyor, to the ERC for thermal treatment. The circa

60,000tpa of non-contract SRF received from third parties or other local

authorities would be transferred directly to the ERC for thermal treatment, it

would not need to be the subject of MT, having already undergone such a

process in advance of being delivered to the site.

1.2.5 The Proposed Development would be a combined heat and power (CHP)

station. Through the combustion of SRF it would generate heat energy in the

form of steam. A proportion of this steam would be used to generate electricity

with the balance exported as heat in the form or either steam or, more likely,

hot water. The maximum electricity generation capacity would be 13.45MW of

electricity (MWe). A small portion (circa 2.36MWe) of this would be used to

power the RERC itself, with the majority circa 11.09MWe exported to the local

electricity grid. Based upon maximum electricity output, the Proposed

Development would export circa 87,012MWe hours per annum. This is

sufficient to meet the domestic electricity needs of over 26,000 homes.

1.2.6 Heat generated by the Proposed Development would be exported by

underground insulated pipes direct to local users which could include nearby

institutional, commercial and residential developments.


1.2.7 Several existing sites offer clear potential to form part of a district heating

network including the Royal Infirmary of Edinburgh, the new Anaerobic

Digestion (AD) Facility to the north and Queen Margaret University. In

addition, there is a number of other developments (existing, proposed or

under construction) in the surrounding area and of these, the Shawfair New

Community Development (SNCD) (comprising over 3,500 new houses, shops,

leisure, community and commercial outlets) offers considerable potential. FCC

Environment has consulted the Shawfair developers regarding the proposed

development and they have expressed a strong interest in the use of heat

generated by the Proposed Development. Further details are provided the

Heat and Power Plan contained within Part 6 of the Planning Application

Document (PAD) and within Chapter 16.0 of this ES.

1.2.8 The biogenic content of waste, circa 50 – 55% of the total waste, is

recognised as a renewable source of energy. Thus, around 50 - 55% of the

energy, whether it is heat or electricity, produced by the Proposed

Development would be classed as renewable energy.

1.2.9 The Proposed Development would be based around a main building which

would contain both the waste reception area and the primary and secondary

treatment process, described above, together with the following elements:

A building containing administration offices, staff welfare and visitor

facilities;

A baled waste storage hall (for the storage of baled waste during

planned mechanical shut down);

Air cooled condensers; and

A 75m high emissions stack (which would be integrated within the main

building).

1.2.10 It would also include a range of ancillary infrastructure including:

A weighbridge office and weighbridges;

Transformer and Emergency Generator buildings;

Ammonia Store;

Rain Water Harvesting / Fire Water Tanks and Pump House;

Vehicle Crew Building and WC;

Vehicle access and internal site circulation roads;


Car parking and cycle stores;

Various silos and storage tanks for fire water, consumables and process

residues;

Utilities and services;

Lighting and CCTV;

SUDS Drainage Balancing Pond; and

Security fencing, gates and landscaping.

1.2.11 The operation of the proposed facility would comply fully with relevant

European Union (EU), Scottish and United Kingdom (UK) Government

legislation.

1.2.12 On the basis that the planning application is approved in mid-2015, the

planned opening date for the Proposed Development is early 2018. It would

have a design life of approximately 25 years although, in reality, many

elements of the plant would last beyond this period. For the avoidance of

doubt planning permission is being sought for a permanent development and

therefore as elements of the facility require repair / refurbishment /

replacement this would be carried out.

1.2.13 A more detailed description of the Proposed Development is provided within

Chapter 4.0 of this ES.

1.3 The Site and Its Context

1.3.1 The Application Site is located on part of the former Millerhill Marshalling

Yards, which were developed by British Rail during the 1950s. It is located

circa 6km south east of Edinburgh City Centre and circa 900m to the north of

Millerhill village (see Figure 1.1). It is located entirely in the administrative area

of Midlothian Council, but is also in close proximity to the administrative

boundaries of the City of Edinburgh Council and East Lothian Council.

1.3.2 The application site itself covers an area of circa 5.7 hectares (ha), it is

broadly rectangular in shape and generally flat, lying generally between 42.5m

Above Ordnance Datum (AOD) and 43.5m AOD. It is predominantly covered

by vegetation comprising self-seeded trees (primarily Silver Birch) and shrubs.

Those areas of the site which remain bare comprise packed soil consistent


with its historic use as a marshalling yard and railway sidings. It is understood

that the site has not been subject to remediation work which reflects its

disused and partly-derelict state. The site is not the subject of any specific

ecological or other environmental designations. However, it has been

classified as a Native Woodland in the Forestry Commission Scotland’s Native

Woodlands Scotland Survey 2013.

1.3.3 In terms of its immediate context, the site is located to the west of the live

railway lines, train maintenance and stabling yard which forms its eastern

boundary. To the west, the site is bounded by derelict land formerly occupied

by Monktonhall Colliery. To the south is more land associated with the former

Millerhill Marshalling Yard and rail sidings which also comprises a continuation

of the low‐level tree vegetation which subsists within the site itself. To the

immediate north is the site of Alauna Renewable Energy’s AD facility, which is

in the process of being constructed, together with an access road and bridge.

1.3.4 To the immediate west of the site is the land associated with the former

Monktonhall Colliery, which has for some time been earmarked as the location

for the development of a new community, known as Shawfair. The

development is proposed to comprise over 3,500 homes with associated

infrastructure, some industrial / commercial, community (new school and

leisure centre) and amenity uses. The SNCD is a ‘committed development’

within the 2008 adopted Midlothian Local Plan and in August 2014 Midlothian

Council formally granted PPiP for the development. The approved masterplan

for the Shawfair development is shown on Figure 1.2.

1.3.5 In addition to the Shawfair development, and also to the immediate west of the

site, is a section of the new Borders Railway line (former Waverley line), it

intersects with the Zero Waste site north of the AD Facility and then passes in

a north – south direction through the site of the SNCD, within which a new

station has already been constructed. The new Borders Railway will re-

establish passenger railway services between Edinburgh and Tweedbank and

is due to be completed in the autumn of 2015. The route of the new railway

line and the location of the new station are also illustrated on Figure 1.2.


1.3.6 In terms of the wider context:

To the east of the site, beyond the train maintenance, cleaning and

stabling depot, is a series of fields which presently appear to be within

an agricultural use. The fields are allocated for industrial and residential

development in the emerging East Midlothian Local Plan. Further to the

east (circa 1km from the nearest site boundary) is the minor settlement

of Old Craighall, beyond this is the roundabout junction of the A1 and

A720;

To the south, beyond the site of the former Millerhill marshalling yard

and rail sidings and circa 850m from the site boundary is the settlement

of Millerhill, beyond which (circa 1.7km from the site boundary) is the

A720 City of Edinburgh By-pass and Dalkieth Country Park;

To the west is the site of the former Monktonhall Colliery / Sharwfair new

community development and the route of the new Borders Railway,

which is presently under construction. Beyond these and circa 1.6km

from the nearest site boundary is the settlement of Danderhall; and

To the north of the aforementioned Alauna AD Facility is Whitehill Road,

beyond which is a narrow belt of plantation woodland and the A1 dual-

carriageway. To the immediate north of the A1 and circa 750m from the

nearest site boundary, is the settlement of Newgraighall. The Fort

Kinnard retail park and commercial centre is located Circa 1km to the

north west and the Queen Margaret University campus is circa 750m to

the north east (albeit on the opposite side of the A1).

1.3.7 The Application Site would be accessed using the new access and bridge that

has been constructed to the north. This comprises a new priority junction off

Whitehill Road and a bridge crossing of the new Borders Railway Line.

Whitehill Road connects to Newcraighall Road in the Fort Kinnard commercial

area, circa 1.2km to the northwest. This, in turn, provides a direct connection

to the north and southbound carriageways of the A1.

1.3.8 The nearest existing residential properties to the site are Shawfair Farm and

cottages (circa 350m to the west) and Whitehall Mains Farm (located circa

450m to the north‐west of the site boundary and immediately adjacent to the

site access and AD facility). In addition, the approved masterplan for the

SNCD proposes new residential development immediately adjacent to the


site’s western boundary. For the purposes of preparing the ES, it has been

assumed that the SNCD has been completed and is therefore included in the

baseline for the assessment (although the reality is that the totality of the

scheme will take in excess of 10 years to deliver). As such, the properties that

are proposed to the west would comprise the nearest residential properties to

the Application Site. More detailed discussion regarding the proposed

baseline and the approach to the EIA is provided in Chapter 2.0 of this ES.

1.3.9 It must be noted that this sub-section is only intended to provide an overview

of the Application Site and its context and any specific receptors and other

important considerations are taken into account, where relevant, within the

individual Chapters of this ES.

1.4 Background to the Scheme and Compliance with the extant PPiP

1.4.1 In December 2014 FCC Environmental was awarded appointed ‘Preferred

Bidder’ status on a 25 year residual waste management contract with

Edinburgh City Council (ECC) and Midlothian Council (MLC). The main

element of infrastructure the Company is proposing in order to meet the

contract requirements is the development of the Millerhill RERC on land at the

former Millerhill Marshalling Yards.

1.4.2 The site of the proposed Millerhill RERC already benefits from Planning

Permission in Principle (PPiP) for the development of an integrated waste

recycling and treatment facility which was granted on 19th January 2012

(reference: 11/00174/PPP – Appendix 1-1). The application was submitted by

Zero Waste, which is a joint enterprise between MLC and ECC, to procure

facilities for the treatment of residual waste in response to the Scottish

Government’s aim to make Scotland a zero waste society.

1.4.3 The extant PPiP is for a facility capable of processing 230,000tpar annum of

predominantly, but not exclusively, household residual waste, comprising the

following waste management facilities:

Mechanical Biological Treatment (MBT);

EfW including CHP Plant; and

An AD Facility.


1.4.4 The approved development is collectively referred to as the ‘Zero Waste

Facility’ and the development proposals for the site as a whole the ‘Zero

Waste Parc’.

1.4.5 Following approval of the Zero Waste Facility, MLC subsequently submitted a

detailed planning application (reference: 12/00060/DPP) for the formation of a

road from Whitehill Road and the erection of a road bridge over the Borders

Railway line, with the express purpose of providing access to the Zero Waste

Parc site. This application was approved on 6th March 2012 and the access

road and bridge have subsequently been constructed. The planning consent

for the access road and bridge also partly addressed some of the matters

specified in Condition 5 of the PPiP.

1.4.6 In addition to the above, Alauna Renewable Energy has progressed with the

development of the proposed AD Facility and submitted a planning application

for the Approval of Matters Specified in Conditions (AMSC) in the PPiP on 25th

January 2013. The application for the AMSC was subsequently granted

consent with an additional condition relating to landscaping on 12th June 2013

(reference: 13/00077/MSC). At the time of writing Alauna Renewable Energy

is in the process of constructing the AD Facility.

1.4.7 FCC is proposing the development of the Millerhill RERC on the Zero Waste

Parc to the immediate south of the site of the Alauna AD Facility. The location

of the development and the AD Facility is provided on Figure 2.1.

1.4.8 Whilst the Millerhill RERC development would have a number of important

similarities with the PPIP proposal, including mechanical treatment and energy

recovery by way of a CHP Plant, the technology proposed by FCC differs in

other regards. The main differences arising from the technology change are

the scale of the development, specifically::

The maximum height of the tallest building (the boiler house) would be

41.60m compared to 20m on the facility benefitting from PPiP;

The height of the stack would be 75m which is 10m taller than that

proposed as part of the facility benefitting from PPiP;


The development footprint would be 5.70ha this is circa 6.87 (circa 55%)

less than the MBT and EfW elements of Option A of the Zero Waste

Facility. An overlay of the two proposals is provided on Figure 2.2;

Tonnage throughput of the facility would be 195,000tpa which in

combination with the AD Facility to the north (30,000tpa) would be

225,000tpa. This would be 5,000tpa less than the facility benefitting from

PPiP, that being for facilities with a combined capacity of 230,000tpa;

This application proposes a combined facility, comprising a MT facility

and ERC using a moving grate technology, rather than the MBT and

EfW using Gasification technology that is proposed in respect of the

facility benefitting from PPiP.

1.4.9 The reasons for the change in technology can be summarised as follows:

Energy recovery from mixed non-hazardous waste is a complex

engineering process requiring substantial financial investment and

expertise. Consequently, technology choice is critical to securing project

funding, securing an award of contract and ultimately delivering a

successful scheme that functions in accordance with the requirements

of the particular project.

Conventional combustion plants, as proposed by FCC, are a fully

proven technology with circa 30 operating plants within the UK and

something in the order of 500 plants across Europe.

Conversely, gasification technology has seldom been used for the

thermal treatment of mixed non-hazardous waste in the UK. At the time

of writing, there are only two commercial scale, fully operating

gasification facilities in the UK, although other proposals are under

construction. There is very limited application of gasification for the

thermal treatment of non-hazardous waste across Europe.

Gasification technologies are theoretically available in a wide range of

scales and sizes, although typically gasification proposals are smaller

than combustion plants and are proposed in the 35,000tpa to

135,000tpa range.

Whilst there is great variety in the physical scale of gasification plant

technologies (noting that most technologies are only theoretical / non-

proven at a commercial scale anyway), as a general rule, and based on

like for like capacity, a gasification plant will have a larger footprint, but


lower maximum height when compared to a combustion plant. However,

the majority (if not all) of the gasification plants that have and are being

developed are relatively tall and well in excess of the 20m that was

consented for the gasification proposals consented under the PPIP for

the Zero Waste facilities.

Most of the gasification facilities that have been built to date have not

operated in a reliable and consistent manner. The only gasification

facility that was fully built out and Permitted in Scotland was the Scotgen

gasification scheme at Dumfries. Despite a number of years of

attempting to operate the plant, this was never successfully achieved in

terms of prolonged operation with energy recovery. The facility

ultimately had its PPC permit withdrawn and the operating company

went into liquidation.

At this point in time, Viridor is in the process of building a gasification

plant in Scotland at Polmadie in Glasgow. This is using a proven

Energos technology which operates in a very similar manner to

conventional combustion and only has a capacity of 130,000tpa.

Based on the foregoing, and in order to provide Edinburgh and

Midlothian with a proven, robust long term waste management solution,

FCC has elected to use a conventional grate combustion technology for

the Zero Waste contract. FCC believes that this is the optimum technical

solution for the waste tonnages that are proposed to be treated. This

proposal has been accepted by the authorities following extensive

evaluation and appropriate due diligence checks. The authorities’

decision to choose such a technology is entirely consistent with that

made by the majority of other UK authorities who have commissioned a

residual waste thermal treatment facility. It is also notable that the

second place bidder for the Edinburgh and Midlothian residual waste

contract was also proposing an identical grate thermal treatment

technology.

1.4.10 Having selected conventional combustion technology as the only proven form

of thermal treatment, at the scale proposed and for the treatment of mixed

non-hazardous waste, it is important to understand why the RERC boiler

house is as high as it is i.e. 41.6m.


1.4.11 In order to meet Part 4 of the Industrial Emissions Directive (formerly the

Waste Incineration Directive) it is a mandatory requirement that non-

hazardous waste material (the combustion gas) is fully combusted within the

boiler at a temperature of 8500C for a duration of two seconds. As the

combustion gases rise during the combustion process, to ensure the two

second residency time, the boiler needs to be a defined height. The boiler

itself then needs to be housed with sufficient maintenance space to allow

access to the top of the boiler, where, amongst other things, the superheater

bundles are located. These require regular access. In combination, these

factors determine the overall boiler house height.

1.4.12 As a 190,000tpa thermal treatment plant with a single stream (or processing

line), the ERC component of the RERC is typical in height when compared to

other similar facilities. In fact it is slightly lower than most, with, for example,

FCC’s recently completed North Hykeham EfW facility (Lincolnshire) having a

throughput capacity of 150,000tpa and a maximum height of 47m and Viridor’s

Dunbar proposal having a process line capacity of 150,000tpa (noting it has

two lines at this capacity) and also having a maximum height of 47m.

1.4.13 Accordingly, FCC believes it is demonstrably the case that the technology

proposed for the RERC is the most proven, robust and reliable technology for

the waste types that would be treated and the throughput capacity proposed.

Furthermore, that the height and scale of the building, particularly the boiler

house, is essential for this type of technology and is no taller than needs to be

the case from an operational perspective.

1.4.14 Following consultation with MLC, FCC has concluded that the RERC, whilst

conforming to the approved description of the development and the use of

land, would fall outside the ambit of what was approved for the Zero Waste

Facility. Consequently, it has been agreed that FCC submit a new detailed

planning application for the Proposed Development, rather than pursuing the

development through an application for the AMSC.

1.4.15 Notwithstanding, the planning permission for the Zero Waste Facility remains

extant and establishes the general acceptability of this site for a development

of the type proposed. It is therefore a material consideration in the

determination of the planning application and an important consideration when


assessing the environmental effects of the proposed development. Further

discussion on this is provided within Chapter 2.0 below.

1.5 The Applicant

1.5.1 The applicant FCC Environment (FCC) is one of the largest waste

management companies within the United Kingdom and provides treatment,

recycling, energy recovery and waste disposal services to a wide range of

local authorities and private commercial customers.

1.5.2 FCC Environment operates facilities for the reception, recycling and disposal

of waste, including a network of waste transfer and recycling centres, energy

recovery facilities and strategically-situated landfill sites. It is also one of the

largest operators of civic amenity sites on behalf of local authorities for use by

the general public.

1.5.3 In December 2014 FCC was appointed Preferred Bidder by Zero Waste:

Edinburgh and Midlothian to design, build, finance, and operate a new

recycling and energy recovery facility (the Millerhill RERC). The award of the

contract by the joint authorities is part of their continued commitment to

increasing recycling and reducing the amount of waste set to landfill in their

administrative areas.

1.5.4 Further information on FCC Environment can be found on their website at

www.fccenvironment.co.uk.

1.6 This Document

1.6.1 This document is the ES, which has been prepared to accompany the

planning application. It describes the potential environmental effects of the

proposed development, both during its construction and operation. It has been

prepared in accordance with European Community (EC) Directives on the

assessment of the effects of certain projects upon the environment

(85/337/EEC updated by 97/11/EEC). This legislation is now manifest in

Scotland through the Town and Country Planning (Environmental Impact

Assessment) (Scotland) Regulations 2011, with which this report is fully

compliant.


1.6.2 Following on from this introduction the remainder of the ES is structured as

follows:

Chapter 2.0 of the ES outlines the approach to the assessment

describing the scope and structure of the ES;

Chapter 3.0 summarises the need for the proposed Millerhill RERC

development and the alternatives considered;

Chapter 4.0 provides a detailed scheme description and provides an

outline of the construction methods;

Chapter 5.0 provides an outline description of the planning policy

context relevant to the determination of the planning application.

Chapters 6.0 to 15.0 and 17.0 assess the potential environmental

impacts of the proposal during its construction and operation, including

proposed mitigation measures;

Chapter 16.0 provides an assessment of the impacts of potential options

to connect the proposed Millerhill RERC development to the local

electricity grid network, which is a discrete element of the scheme and

does not form part of the planning application which this ES supports;

and

Chapter 18.0 summarises the assessment findings.


2.0 SCOPE OF THE ENVIRONMENTAL ASSESSMENT

2.1 Scope

2.1.1 EIA is the process culminating in the production of this report, the ES. The

objective of the process is to identify and evaluate all significant, direct and

indirect environmental effects of the proposed development, during both

construction and operation, on the environment.

2.1.2 In the context of the Town and Country Planning (Environmental Impact

Assessment) (Scotland) Regulations 2011 (EIA Regulations) the proposed

development constitutes development requiring an EIA, being classified under

Schedule 1: “(10) Waste disposal installations for the incineration or chemical

treatment (as defined in Annex I to Directive 2008/98/EC under heading D9) of

non-hazardous waste with a capacity exceeding 100 tonnes per day.”

2.1.3 As such, the proposed development is deemed to be a Schedule 1

development and therefore an EIA is mandatory for this project.

2.1.4 The scope, or requirements, of an ES are set out in Schedule 4 of the EIA

Regulations. Part 1 of the Schedule details the information that the applicant is

reasonably required to provide, whilst Part 2 identifies the information that the

applicant must provide, these are set out below. References to Chapters in

the ES where information relevant to these requirements can be found are

also listed below.

PART I

1. Description of the development, including in particular:

a) A description of the physical characteristics of the

whole development and the land-use requirements

during the construction and operational phases;

Chapter 4

b) A description of the main characteristics of the

production processes, for instance, nature and

quantity of the materials used;

Chapter 4

c) An estimate, by type and quantity, of expected

residues and emissions (water, air and soil pollution,

Chapters

4, 10, 11,


noise, vibration, light, heat, radiation, etc.) resulting

from the operation of the proposed development.

12 and 17

2. An outline of the main alternatives studied by the

applicant or appellant and an indication of the main

reasons for his choice, taking into account the

environmental effects.

Chapter 4

3. A description of the aspects of the environment likely to

be significantly affected by the development, including,

in particular, population, fauna, flora, soil, water, air,

climatic factors, material assets, including the

architectural and archaeological heritage, landscape and

the inter-relationship between the above factors.

Chapters 6

to 17

4. A description of the likely significant effects of the

development on the environment, which should cover

the direct effects and any indirect, secondary,

cumulative, short, medium and long-term, permanent

and temporary, positive and negative effects of the

development, resulting from:

Chapters 6

to 17

(a) The existence of the development;

(b) The use of natural resources;

(c) The emission of pollutants, the creation of

nuisances and the elimination of waste, and the

description by the applicant of the forecasting

methods used to assess the effects on the

environment.

5. A description of the measures envisaged to prevent,

reduce and where possible offset any significant

adverse effects on the environment.

Chapters 6

to 17

6. A non-technical summary of the information provided

under paragraphs 1 to 5 of this Part.

Volume 3

7. An indication of any difficulties (technical deficiencies or

lack of know-how) encountered by the applicant in

compiling the required information.

Chapters 6

to 17

PART II

1. A description of the development comprising information Chapter 4


on the site, design and size of the development.

2. A description of the measures envisaged in order to

avoid, reduce and, if possible, remedy significant

adverse effects.

Chapters 6

to 17

3. The data required to identify and assess the main effects

which the development is likely to have on the

environment.

Chapters 6

to 17

4. An outline of the main alternatives studied by the

applicant or appellant and an indication of the main

reasons for his choice, taking into account the

environmental effects.

Chapter 3

5. A non-technical summary of the information provided

under paragraphs 1 to 4 of this Part.

Volume 3

2.1.5 This ES is fully compliant with these requirements.

Consultation

2.1.6 Under Regulation 14 of the EIA (Scotland) Regulations, potential applicants

may request a Scoping Opinion from the local planning authority, in this case

MLC. This is a written confirmation as to the information that would need to be

provided in the ES. On 23th January 2014 FCC submitted an informal request

for a Scoping Opinion from MLC. The request was made on an informal basis

given FCC’s on-going involvement in the bidding process for the Edinburgh

and Midlothian Residual Waste Contract, and a desire for the consultation to

be carried out a commercially confidential basis. The request was

accompanied by an Environmental Scoping Report which provided

confirmation of the issues that FCC considered would need to be covered in

the ES. The Scoping Report submitted to MLC is contained within Appendix 2-

1.

2.1.7 Following the aforementioned screening request, MLC failed to adopt an

informal Scoping Opinion and only one response was received from technical

consultees and specifically Historic Scotland. A copy of their consultation

response is provided within Appendix 2-2 and a summary is provided in Table

2.1 over the page.


Table 2.1: Summary of Scoping Consultations

Consultee Key Comments

Historic Scotland

Confirmed that they were content with the principle of the proposed development. They confirmed that there are no assets in their remit within the development site and that it is unlikely (based upon the information contained within the informal Scoping Report) that the development would result in significant adverse impact on the setting of other assets within their remit.

2.1.8 Notwithstanding the lack of formal responses from MLC and other technical

consultees to the informal Scoping Request, the extent of potential

environmental matters to be included within the ES is already well understood

by the project team, by virtue of the information that was required in connection

with the PPiP application prepared for the Zero Waste Facility development.

This existing knowledge has been supplemented by extensive scoping with a

variety of technical officers from MLC and other regulatory consultees,

including the Scottish Environmental Protection Agency (SEPA), Scottish

Natural Heritage (SNH), Transport Scotland and Architecture + Design

Scotland (A+DS). This has included several meetings with MLC and other

regulatory consultees that were held on 29th January 2014, 27th February 2014

and the 28th October 2014. Minutes from these meetings are provided in

Appendix 2-3.

2.1.9 There have also been a number of subsequent consultations with the Planning

Officer at MLC which were held on the 8th January 2015, 6th February 2015 and

6th March 2015 to discuss various aspects of the Proposed Development.

2.1.10 The aforementioned process, along with experience from similar projects, has

informed the scope of the subjects to be addressed within the EIA and the

methods and assumptions used to undertake assessments. A summary of the

consultations held is provided within Table 2.2 over the page.


Table 2.2: Summary of Key Scoping Consultations


MLC Highways Initial e-mail contact was made with the highways officer on the 30th

October 2014 and a subsequent telephone discussion immediately thereafter. During these discussions the Officer specifically suggested that, based on the results of the comparative development trip generation exercise, there would be no requirement for any updated baseline traffic surveys to be undertaken; no off-site network safety or capacity assessment would be required; and that there is no requirement for detailed environmental assessment.

The highways officer was provided with a TA scoping note on 19th

November 2014 and the officer confirmed that he was satisfied with the proposed scope of work.

Following this initial agreement the proposed throughput of the facility was changed from 170,000tpa to 195,000tpa and an updated TA scoping note was issued to reflect this. The Officer had no further comments on this and the Transportation Assessment and the ES chapter have been prepared in line with the updated scoping note.

Transport Scotland Transport Scotland (via their agents JMP) was provided with a copy of the updated TA scoping note (195,000tpa) on the 10

th February 2015,

following initial telephone discussions.

They confirmed in an e-mail of the 26th February 2015 that: “We agree

with the conclusions of your scoping note that these new proposals should not have any greater impact on the trunk road network compared to the previous consented proposals (ref: 11/00174/PPP), and as such, your proposal for a simple Transport Statement would be sufficient from Transport Scotland’s perspective.”

MLC, East Midlothian Council and ECC

Landscape Officers

Given the Millerhill RERC site is located close to the administrative boundaries of MLC, East Midlothian Council and ECC, it has been necessary to consult with the landscape officers at each of the authorities to agree viewpoint locations for the Visual assessment.

All of the Officers were e-mailed a plan on the 3rd

December 2014 which suggested viewpoint locations. All of the officers responded and each suggested alternative or additional view that should be considered. Following this a revised viewpoint plan was issued to the landscape officer at MLC (the determining authority) for formal agreement. It was also submitted to officers at the other authorities for information.

The updated viewpoint plan was subsequently agreed by all parties and it is those viewpoints which have formed the basis for assessment in this ES.

The Scottish Environmental

Protection Agency (SEPA)

The SEPA was consulted with regard to all aspects of the air quality modelling study. This includes the stack height assessment, receptor locations, modelling inputs and sensitive habitats.



MLC EHO – Noise

Following consultation with the EHO at MLC and their appointed noise consultant, the areas surrounding the site were examined and the following suitable locations for noise monitoring

The Local Authority advised that the noise assessment should be designed to achieve a design criteria similar to that imposed on the AD Facility being developed north of the Application Site. The condition relates to the following limits:

Daytime: Fixed and mobile plant (including site vehicles): 0800-2100 hours 40dB LAeq1hr (free field).

Evening: Fixed plant: 2100-2300 hours 39dB LAeq1hr (free field)

Night-time: Fixed plant: 2300-0800 hours 39dB LAeq5mins (free field) and internal level with windows open of NR25.

All reversing alarms to be of the broadband type (restricted between 0800-2000 hours).

Construction noise (all site operations): 70dB LAeq12hr (1m façade) `best practicable means’ applied at all times in accordance with BS5228 guidance.

Construction (piling): 75dB LAeq1hr (1m façade), 80dB LA01(1hr) `best practicable means’ applied at all times in accordance with BS5228 guidance.

Construction (Community Relations): A community liaison representative will be appointed to: ensure (a) availability of information and (b) complaints are dealt with expeditiously.

Architecture and Design Scotland and

Scottish Natural Heritage (SNH)

Two workshops have been held with A+DS / SNH which have informed the design and layout of the proposed development. Further details of the specific discussions held are contained within the Design and Access Statement Contained within Part 2 of the Planning Application Document.

MLC / The Wildlife Information Centre

(TWIC)

Were consulted regarding the need to carry out further reptile surveys art the site. TWIC, on behalf of MLC, confirmed that further reptile surveys were not necessary to inform the Millerhill RERC application.

MLC, Edinburgh Council and East Lothian Council

Provided information on developments that should be considered in the assessment of cumulative effects.

2.1.11 All of the aforementioned points raised during the EIA Scoping and

subsequent scoping carried out on individual topic areas have been taken into

consideration in the EIA and the preparation of this ES.

2.1.12 The information and knowledge required to produce this ES was acquired

from a number of varied sources to ensure that all impacts, whether explicit


from the outset, or coming to light during the projects development, were

assessed. These sources included:

a) Discussions with technical consultees;

b) Review of public files and records;

c) Review of historical mapping and aerial photography;

d) Site surveys undertaken by the applicant;

e) Specialist studies, such as computer modelling of potential noise

impacts; and

f) Expert knowledge from the consultancy team.

2.2 Baseline for the Environmental Impact Assessment

2.2.1 As discussed within Chapter 1.0 the Application Site benefits from PPiP for a

large scale waste treatment facility (the Zero Waste Facility) and numerous

developments are either in the process of coming forward, or are about to be

developed in the surrounding area. The most significant of which are the new

Borders Railway, Alauna Renewable Energy’s AD Facility (both of which are

presently under construction) and the SNCD, which has recently obtained

PPiP and is actively being cleared and promoted for new development. The

Shawfair development is very large and complex and there is considerable

uncertainty as to which elements of the scheme will come forward and when.

2.2.2 Given the planning status of the development site and the presence of the

existing and proposed developments, it has been necessary to give careful

consideration to the baseline for the preparation of the EIA. This matter was

discussed in a pre-application meeting with MLC on the 28th October 2014

and the following approach has been agreed.

The Baseline for the Application Site

2.2.3 The EIA for the Millerhill RERC has been undertaken with reference to the

current baseline conditions at the Application Site (i.e. an undeveloped

brownfield site). However, as the site also benefits from an extant PPiP for a

similar type of development (a combined AD, MBT and EfW Facility) (see

Figure 2.4 for an overlay of the PPiP and Proposed Development), in

considering factors that mitigate the effects of the proposed Millerhill RERC


developed or, to be more precise, the ‘likely future baseline’ / ‘do nothing’

position at the site, reference will be made to the PPiP development.

2.2.4 Whilst the proposed development must be considered in relation to its impact

on existing environmental conditions, it is also entirely appropriate to note

within the assessment that a major development has been granted consent at

the site. The approach to this is discussed within Paragraph C8.4 of the

Scottish Natural Heritage (SNH) Handbook on Environmental Impact

Assessment (4th Edition – 2013), it states (our emphasis):

“The significance of the effects of a proposed development should be

considered in the context of changes that will occur regardless of

whether the project goes ahead or not, the ‘do nothing alternative’. The

‘do-nothing’ comparison, or in some cases, such as road improvements, the

‘do-minimum’ comparison, is a projection of the existing data to provide a

baseline for comparison to show how the site would change if the

project did not go ahead. The ‘do nothing’ comparison examines trends

currently occurring at the site, including likely management, land use

changes, effects of climate change (e.g. species migration) or other

interventions, and assesses the significance of these changing

conditions. The ‘do-nothing’ comparison, however, should be used in a

reasonable way. It should genuinely predict likely change, on a realistic

basis, for example by including the effects of projects which already have

consent but are not yet implemented. It should not take the best possible

comparison for the purpose of the Environmental Statement, in order to

try to demonstrate that the project proposed would have less adverse, or even

beneficial, effects over a ‘do nothing’ prediction that is not likely to materialise.

2.2.5 With regard to the SNH guidance:

1. There is a reasonable prospect that in the event the Millerhill RERC

development is not progressed the extant PPiP development could be

developed. Indeed, the AD element of the PPiP scheme is already in the

process of being constructed to the north of the Application Site; and

2. The information contained within the ES prepared in relation to the PPiP

development will provide a reasonable basis for comparison within the

ES for the Millerhill RERC development.


2.2.6 In light of the foregoing, each Chapter of this ES will assess the potentially

significant environmental effects of the Proposed Development on the existing

site baseline and include a ‘sensitivity test’ which compares the proposed

development against the Zero Waste Facility (i.e. the ‘do nothing’ / ‘future

baseline scenario’).

2.2.7 For example, if the ES prepared in support of the application for the Zero

Waste Facility identifies that the site contains archaeological remains, and

assesses the impact of the development on the remains as being moderate /

major etc. The sensitivity test would note that as the Proposed Development

would have a smaller footprint the Zero Waste Facility development and will

be developed entirely within the proposed built footprint for that development,

the impact on buried archaeology would either be ‘beneficial’ or, at worst,

‘neutral’ when compared against the future baseline.

2.2.8 It must be noted that whilst it is the intention to carry out this ‘sensitivity test’

within the ES, it is not possible to adopt this approach in connection with all of

the ES chapters. The chapters where this approach has not, or cannot be

applied and why, is set out in Table 2.4 below.

Table 2.4: ES Chapters where there is no Comparison with Future Baseline

Scenario

ES Topic Commentary

Traffic and Transportation

In pre-application discussions and during the scoping of the Transport Assessment and ES Chapter, it was agreed that it would only be necessary

Cumulative Effects

Whilst the ES prepared in support of the PPiP application included an assessment of potential cumulative effects, the development proposals considered in the assessment of cumulative effects differ to those which will be the subject of assessment for the Proposed Development. This is on the basis that many of the schemes considered have now either been built (and form part of the baseline) or, in the case of the SNCD, are being considered differently in the assessment of environmental effects. In light of this, there is no reasonable basis for comparison with the PPiP development.

Energy Export Connections

Assessment of the potential environmental effects of the Energy Export Connections was not carried out in the ES prepared in support of the application for PPiP. As a consequence, there is no basis for comparison with the Millerhill RERC development.


The Baseline Relating to Other Development Proposals

2.2.9 With regard to the existing baseline, it was agreed at the pre-application

meeting with Midlothian Council on the 28th October 2014 that, for the purpose

of the EIA, the following should be assumed:

The AD Facility, site access and bridge over the Borders Railway, which

are being constructed to the north of the site, are finished and

operational;

The Borders Railway, which is being constructed to the north and west

of the site, is completed and operational; and

The SNCD is built in accordance with the approved masterplan.

2.2.10 The reason that this approach has been agreed in relation to the SNCD is that

there is too much uncertainty as to which elements of the scheme will come

forward and when, to accurately consider them in any assessment cumulative

effects. It was agreed that a more appropriate proxy for assessment would be

to assume that SNCD is built in accordance with the site masterplan. Of

particular significance in reaching this decision is the fact that the masterplan

envisages that there will be residential development up to the western

boundary of the Millerhill RERC site, thereby representing a worst case

scenario for the assessment of environmental effects upon sensitive

residential receptors.

2.2.11 In order to carry out the assessment on this basis, where necessary,

reference has been made to the environmental assessments submitted in

relation to the aforementioned schemes, along with other published

information (i.e. the timetable for the operation of the railway).

2.3 Assessment of Environmental Effects

2.3.1 The approach to environmental impact assessment is not standardised but

there are established and recognised approaches set out by professional

institutions regarding the methods that are to be used in the assessment of

environmental effects. Where appropriate the environmental effects of the

proposed development have been assessed quantitatively using definitive

standards, legislation and guidance applicable to each of the technical areas


covered within this ES. Where quantitative assessment has not been possible,

qualitative evaluation of significance based on professional judgement has

been applied. In general terms the significance of environmental effects have

been judged by comparing the sensitivity of a particular receptor with the

magnitude of effect, taking into account the nature of the impact being

assessed.

2.3.2 Methodologies for defining the significance of environmental effects are not

prescribed by law. However, when assessing the significance of impacts each

discipline has taken into account relevant legislative requirements, standards

and best practice.

2.3.3 Where available and appropriate the impact assessments have followed

impact assessment criteria and methodology set out by the relevant

professional institution (i.e. Institute of Ecology and Environmental

Management (IEEM), Landscape Institute etc.). Where such guidance is not

available or prescriptive methods are not set out by the relevant professional

body, then assessment criteria have been developed by the technical

specialists to enable a clear and structured approach to the assessment to be

undertaken. In order to understand and clearly communicate likely significant

effects of the project each technical discipline has set out the threshold above

which the effects of the project are considered to be ‘significant’ in EIA terms.

2.4 Cumulative Effects

2.4.1 The EIA regulations require that a description of the likely significant effects of

the development on the environment should be included in the Environmental

Statement, including cumulative effects. The EIA regulations do not define

cumulative effects, however, a commonly accepted definition is: “Impacts that

result from incremental changes caused by other past, present or reasonably

foreseeable actions together with the project.” (EC, 1999)

2.4.2 Chapter 15.0 of this ES provides an assessment of the potential cumulative

effects of the proposed development with other developments in the wider

vicinity. The other developments that have been considered to have the

potential to give rise to cumulative impacts with the proposed development

are:


The Millerhill Marshalling Yard, Whilthill Road, Dalkeith; and

The Edinburgh Royal Infirmary, 51 Little France Crescent, EH16 4SA.

2.4.3 The location of the aforementioned sites is provided on Figure 15.1 contained

within this ES. Further detail of the methodology used and the findings of the

assessment are provided in Chapter 15.0 of this ES.

2.5 Structure of the Environmental Statement

2.5.1 The format of this ES is described below.

2.5.2 Volume 1 (Main Report) provides an introduction to the project and details the

technical assessments that have been undertaken to determine the likely

impacts of the project. The Chapters of the Main Report are as follows:

Chapter 1.0: Introduction.

Chapter 2.0: Scope of the Environmental Assessment.

Chapter 3.0: Need

Chapter 4.0: Scheme Description.

Chapter 5.0: Planning Policy Context.

Chapter 6.0: Traffic and Transportation.

Chapter 7.0: Landscape and Visual Effects.

Chapter 8.0: Ecology and Nature Conservation.

Chapter 9.0: Geology, Hydrogeology and Ground Conditions.

Chapter 10.0: Surface Waters and Flood Risk.

Chapter 11.0: Noise and Vibration.

Chapter 12.0: Air Quality and Human Health.

Chapter 13.0: Cultural Heritage.

Chapter 14.0: Socio Economic Effects.

Chapter 15.0: Cumulative Effects.

Chapter 16.0: Energy Export Connections.

Chapter 17.0: Human Health.

Chapter 18.0: Summary of Effects.

2.5.3 Bound separately to this volume is a series of Technical Appendices (Volume

2). These include details of the methodology and information used in the

assessment, detailed technical schedules and, where appropriate, raw data.


2.5.4 The ES covers a large number of issues and, in doing so, uses a significant

quantity of technical terms. Consequently, all the Chapters are summarised in

a Non-Technical Summary (NTS) (bound separately as Volume 3) to provide

a review of the development proposals and the possible environmental

implications, in concise lay terms.


3.0 NEED AND ALTERNATIVES

3.1 The Need for the Scheme

3.1.1 The need for the Millerhill RERC is described in detail within Section 4.0 of the

Planning Statement (PS) (that forms Part 3 of the PAD). The conclusions from

section are provided in the following paragraphs.

3.1.2 The need for the Millerhill RERC (and the benefits arising from the scheme)

has been considered in the context of a number of strategic waste policy

documents and the current waste management position within the South East

Scotland Strategic Development Plan (SESplan) area and Edinburgh and

Midlothian administrative area. In addition, it has also been evaluated in

terms of national, regional and sub-regional renewable energy policy and

need. The assessment has established the following:

The Need for Waste Management Infrastructure from a European and

National Perspective

i) The ZWP sets a number of challenging targets to reduce the quantities

of biodegradable waste sent to landfill which are focussed on recovering

value from waste through higher levels of recycling and composting. It is

accepted within the national guidance that the balance of waste that

cannot offer greater environmental and economic benefits through reuse

or recycling will need to be managed further down the waste hierarchy

with a preference for energy recovery over landfill disposal.

ii) From a national (and indeed regional) perspective, all relevant extant

and emerging policy and strategy documents support the thermal

treatment of waste with energy recovery.

iii) The ZWP and SPP and the NPF3 identify a need for additional facilities

for the treatment and recycling of municipal and commercial and

industrial waste if the targets set out within the ZWP are to be met. In

this regard the ZWP specifically states that: “moving to zero waste

means more facilities will be required to collect, sort, reuse, recycle and


process waste” and that: “there will also be opportunities to harness

heat and power generated from the energy recovery process.”

iv) It is clear given published waste figures for MSW and C&I waste within

Scotland and the number of EfW facilities that are either built and

operational or in the process of being built, there is a very significant

shortfall in energy recovery infrastructure within Scotland. In this context

the Proposed Development would deliver clear benefits in terms of

conserving valuable resources by way of recycling, the generation of

renewable energy and the diversion of waste from landfill. All of these

benefits would contribute, to a greater or lesser degree to the Scottish

Government’s objectives for managing and combating climate change.

Regional Waste Management Need

v) The PPIP for the ‘Zero Waste Facility’ was granted for facilities with the

treatment capacity of 230,000tpa. On the basis that the AD plant

presently under construction has a capacity of 30,000tpa, the balance of

the ‘approved’ capacity is 200,000tpa (which could all constitute thermal

treatment capacity). The Proposed Development has an overall capacity

of 195,000tpa (and circa 190,000tpa for the ERC element) and is

therefore less than the capacity for which PPIP has already been

granted and a need established.

vi) In terms of the SES Region, it has been established, using conservative

assumptions on the amount of waste available for waste treatment, it

has been established that circa 563,000 tonnes of residual waste would

be available for treatment at the Proposed Development.

vii) Only one other EfW facility is being developed in the Region which is the

Dunbar facility in East Lothian. This has a capacity of 300,000tpa,

leaving in excess of 260,000tpa of suitable waste requiring thermal

treatment in the region. This requirement materially exceeds the

maximum capacity that the Proposed Development would provide.

Accordingly, there is a demonstrable quantitative case of need for the

Proposed Development from a regional and local waste management

perspective.


viii) It is clear that the Proposed Development would contribute to

addressing the shortfall of waste management facilities that are needed

to meet the ZWP targets.

The Need for Energy / Renewable Energy Infrastructure

ix) Energy generation is identified as one of the main sources of

greenhouse gas emissions, the reduction of which is a key challenge in

addressing climate change. Accordingly, national policy seeks for

making the most of renewable energy potential and encouraging power

and heat generation from clean, low carbon sources; it is acknowledged

that biomass from waste can make a positive contribution to renewable

energy targets and the mitigation of climate change.

x) Extant strategy, policy and legislation documentation contains numerous

and very challenging renewable energy and climate change targets that

are either applicable to the UK as a whole or Scotland.

xi) The ERC facility would (taking into account a proportion of energy need

in the operation of the facility) export 11.09 MWe to the local grid of

which 55% would be considered renewable. In addition, the combustion

process would produce heat, which could be exported to a local district

heating network, in the form of stream hot water. Accordingly the ERC

element of the Proposed Development would contribute towards

meeting the challenging renewable energy targets and thus a

demonstrable need for new renewable energy (heat and power)

generation capacity.

Climate Change

xii) The development proposal has been found to accord with the

Government’s key planning objectives for combating climate change.

Including:

a. contributing towards the Scottish Governments target of a 42%

reduction in greenhouse gas emissions by 2020 and a 80%

reduction by 2050;


b. Diverting waste from landfill;

c. Off-setting the consumption of fossil fuels; and

d. Contributing to recycling.

Socio-Economic Benefits

xiii) The economic benefits of the scheme include

a. The proposed development would be consistent with and

supportive of the Government Economic Strategy through its

employment generation within a low carbon setting.

b. It would also contribute towards the achievement of the targets set

out in the NPF / SPP and ZWP aimed at reducing the amount of

waste sent to landfill and increasing the amount of electricity

generated from renewable sources.

c. A range of community benefits would be delivered by the proposal

including direct and indirect employment creation, skills

development, supplier contracts, social enterprise contracts and

education benefits.

d. The creation of approximately 39 permanent jobs together with a

maximum of 300 temporary jobs during the construction phase

(180-200 on average) of the development;

e. Creating new local apprenticeships, FCC Environment operate its

own apprenticeship programme and the Proposed Development

will create up to 3 apprenticeships on an on-going basis;

f. Opportunities to deliver annual fiscal benefits in the order of £0.4m

to Midlothian Council, through the retention of business rates;

g. Opportunities to ensure that local residents and businesses have

access to the employment and business supply chain

opportunities which may emerge;

h. Opportunities to create further value in the waste processing chain

through the sorting of recyclable materials and the utilisation of

process by-products which can be used in other sectors (i.e.

bottom ash in the construction sector); and

i. The potential creation of 50 FTE direct, indirect (local supply

chain) and induced jobs in the impact area. These jobs could

support around £3.8m of GVA per annum.


3.1.3 In conclusion, there is a clear, demonstrable and overriding need for the

Proposed Development and the benefits it would bring relate to both its

contribution towards delivering sustainable waste management and combating

climate change through renewable energy production. Given that both

Scotland and the SES Region have a paucity of sustainable waste

management and renewable energy infrastructure, the opportunity presented

by the proposal must not be missed. The scheme offers very significant

benefits of regional significance and, in accordance with the identified policy

framework these should be afforded very significant positive weight (in

planning terms).

3.2 Alternatives Considered

3.2.1 The requirement to consider alternatives stems from the Town and Country

Planning (Environmental Impact Assessment) (Scotland) Regulations 2011.

Schedule 4 of the Regulations identifies the information for inclusion in

Environmental Statements. Parts 1 (2) and 2 (4) include: “An outline of the

main alternatives studied…and an indication of the main reasons for this

choice, taking into account the environmental effects.”

3.2.2 Paragraph 95 of Circular 3/2011 which accompanies the Environmental

Impact Assessment (Scotland) Regulations 2011, notes that: “Where

alternative approaches to development have been considered, paragraph 4 of

Part II of Schedule 4 requires the applicant to include in the ES an outline of

the main alternatives, and the main reasons for his choice. Although the

Directive and the Regulations do not expressly require the applicant to study

alternatives, the nature of certain developments and their location may make

the consideration of alternative sites a material consideration. In such cases,

the ES must record this consideration of alternative sites. More generally,

consideration of alternatives (including alternative sites, choice of process,

and the phasing of construction) is widely regarded as good practice, and

resulting in a more robust application for planning permission. Ideally, EIA

should start at the stage of site and process selection, so that the

environmental merits of practicable alternatives can be properly considered.

Where this is undertaken, the main alternatives considered must be outlined in

the ES.”


3.2.3 As is evident from the above, there is no formal requirement for applicants to

consider alternatives, rather the imperative is to outline any main alternatives

where (i.e. if) they have been considered. In the case of this planning

application, and specifically the work undertaken leading up to the application,

only a limited number of alternatives have been considered as there is

particularly strong justification for the site that has been selected, the

technologies that have been adopted and the approach to scheme design.

This justification, together with the environmental reasons why key decisions

have been made, is set out below under the following headings:

Site Selection;

Waste Management Technology; and

Design Philosophy.

Site Selection

3.2.4 Scottish waste management policy and guidance, most notably Scottish

Planning Policy (SPP) (June 2014), the Zero Waste Plan (ZWP)1 and the

SEPA Guidance Note 62 provide criteria for consideration on locating waste

management facilities. At a local level, the extant and emerging development

plan provides policy and guidance on site-specific considerations. Accordingly,

the proposed development site has been critically appraised for its suitability

for the proposed use against these criteria and from an operational

perspective, from which it was determined that:

The site already benefits from PPiP for the development of the Zero

Waste Facility which is a large scale waste management facility

including mechanical treatment and an Energy from Waste facility;

Strategic Development Plan for Edinburgh and South East Scotland

(July 2013) specifically allocates and safeguards the site for the

development of a waste management facility.

o Figure 2 of the Plan identifies key strategic infrastructure

improvements required to facilitate existing and future

development across the SDP area. The Millerhill Waste Facility is

identified under the Regional Core sub-area as one of the key

strategic infrastructure improvements required; and

1 Scotland’s Zero Waste Plan, published June 2010, by The Scottish Government 2 SEPA Guidance Note 6: Land Use Planning System, published 22 March 2012 by SEPA (Version 3)


o Figure 3 relates to the Regional Core sub-area and specifically

identifies the ‘Millerhill Marshalling Yards’ for the development of a

waste management facility. The associated supporting text

identifies that the site will be safeguarded for waste treatment. In

addition paragraph 46 states: “Land will be safeguarded within the

LDP (Midlothian) for the development of a waste treatment facility

at Millerhill which is likely to include energy from waste technology,

and potentially an eco-park with complementary waste recycling /

renewable industries.”

The site is also safeguarded within the emerging Midlothian Local

Development Plan. Policy WAST2 ‘Millerhill’ states: “The site indicated

on the Proposals Map [the Application Site] is safeguarded for waste

processing uses. The Council supports the formation of further waste-

related or economic uses on the economic land adjacent to the waste

treatment facility (but without prejudice to the formation of other

employment uses on this site).

The proposed development would deliver the redevelopment of a

redundant / derelict previously-developed (brownfield) site. The Millerhill

Marshalling Yards were created in 1962 and formally opened in 1963.

They were primarily used for freight such as new cars and trucks from

Bathgate and for cement and chemical trucks. At the same time, two

sidings were also laid to service Monktonhall Colliery. When the

Waverley line to the South was closed in 1969, the use of the ‘down

yard’ declined and it was eventually closed in 1983. All the tracks were

lifted apart from the two siding lines into the colliery. The colliery itself

closed in 1997. The redevelopment of degraded, derelict and redundant

land is a key principle of sustainable development supported within

national waste and planning policy, as well as the extant and emerging

development plan.

One of the most significant factors affecting site selection relates to the

fact that the Millerhill RERC development would generate energy in the

form of heat and electricity and in order to maximise the energy

efficiency of any such plant, it is important that it be co-located with

potential, viable heat users. As identified previously, a separate Heat

Plan Report (HPR) has been prepared in support of the application (see

Part 6 of the PAD). This sets out the latest identified proposals for heat


export together with the steps required to maximise benefits in this

regard. The HPR has identified four potential heating zones within close

proximity of the Millerhill RERC site. Paragraph 183 of SPP required

that: “Any sites identified specifically for energy from waste facilities

should enable links to be made to potential users of renewable heat and

energy. Such schemes are particularly suitable in locations where there

are premises nearby with a long-term demand for heat.” Furthermore,

Section 8 of the emerging Midlothian LDP states under sub-heading 8.1

‘Edinburgh (Shawfair) Committed Development includes Development

Considerations’ that (our emphasis): “Millerhill is the site of the Zero

Waste Project – a joint scheme between Midlothian and the City of

Edinburgh Council. The project will occupy two plots across 8 ha. The

first phase (an anaerobic digester, which will turn food waste into

biogas) is under construction. The partners are considering bids for the

2nd stage which will handle unsorted waste and might include an energy

from waste plant (incineration). This project could provide a waste

heat opportunity for use in Shawfair, or further afield. As such, the

Millerhill RERC development, in its proposed location, offers a major

opportunity to deliver a highly efficient energy recovery scheme.

The site has a good standard of access to the strategic highway network

with access via Whitehill Road to the A1. A TA has been undertaken to

accompany the planning application (see Appendix 6-1 of the ES) which

concludes that that: “…the day-to-day operation of the Millerhill RERC

scheme would be acceptable and not give rise to material traffic related

operational or environmental effects” (paragraph 7.55) and “there would

be no requirement for local highway network operational or

environmental improvements over and above existing / committed

provision to accommodate the predicted levels of temporary

construction traffic demand.”

The site is appropriately located (almost centrally) within the identified

waste arisings catchment. This is consistent with the principles set out

within the ZWP which states that: “… proximity for waste management

facilities should be considered strategically as the achievement of a

sustainable strategy may involve waste crossing planning boundaries

within Scotland”;


The site is relatively remote from sensitive receptors and significant

environmental constraints, such that measures can be integrated into

the scheme that would satisfactorily mitigate potential for nuisance or

harm;

The site is of suitable shape, size and topography to accommodate the

proposed development, operational requirements and landscaping

proposals; and

The site is being brought forward by FCC to provide a facility for the

management of Edinburgh and Midlothian’s residual waste. The site

owned by the Council’s and as such, does not represent a constraint to

the development.

3.2.5 Accordingly, it was concluded that the Application Site is both available and

suitable for the Proposed Development.

Waste Management Technology

3.2.6 The main driver for the selected waste management technology was meeting

the requirements of the Scottish Government’s Zero Waste Policy.

3.2.7 The process began with evaluating a ‘long-list’ of potential waste technology

solutions that included permutations of the following:

Landfill;

Autoclave;

Advanced thermal treatment (e.g. pyrolysis, gasification);

Mechanical biological treatment;

In-vessel composting;

Open windrow composting;

Modern thermal treatment (also referred to as energy from waste - EfW);

Anaerobic digestion; and

Plasma arc.

3.2.8 These technologies were the subject of a two-stage appraisal. First they were

considered against the following high level criteria and the most feasible

options were then taken forward for further appraisal:

National policy / legislation;


Product marketability;

Efficacy: proven technology; and

Economic viability.

3.2.9 Those technologies surviving the stage-one appraisal were subject to a second

evaluation examining the planning, environmental and deliverability risks

associated with each of the technology options. The criteria used in this second

options appraisal exercise were:

Planning risks associated with technology;

Track record of the technology;

Flexibility and adaptability of the technology to changes in waste

composition / volume;

Climate change implications of the technology option;

Health effects of emissions from technology;

Contribution of the technology to recycling / composting and demand the

technology makes on primary materials extraction; and

Net energy generation / use of the technology.

3.2.10 The outcome of this analysis produced a shortlist of technology options as

follows:

Modern Thermal Treatment (EfW) with combined heat and power

(CHP);

Mechanical Treatment (MT) producing a fuel to power dedicated CHP

plant(s);

Mechanical Biological Treatment (MBT) producing a fuel to power

dedicated CHP plant(s);

MBT producing a biologically stabilised material that is sent to landfill;

Autoclave producing an active fibre fuel that is sent to power dedicated

CHP plant(s); and

Advanced thermal treatment with syngas used for electricity production

and recovery of heat energy.

3.2.11 A more detailed review was undertaken on the suitability of the short-listed

technologies. The technologies reviewed are discussed in the following

sections.


Modern Thermal Treatment (EfW) with combined heat and power (CHP)

3.2.12 Direct waste combustion in a modern thermal treatment (EfW) facility with CHP

is a proven technology capable of delivering a flexible and sustainable waste

management solution. EfW facilities are used throughout the UK and Europe

for the management of MSW and C&I waste, and are established as an

efficient way to recover energy, especially where CHP can also be delivered

from the plant. The technology also demonstrates consistently high reliability

and is, by a very significant margin, the most widely deployed waste recovery

solution in Europe (with circa 500 operating plants). Such a facility would be

capable of managing the predicted waste volumes and effectively treat the

likely composition of the waste predicted to remain after achieving recycling

and composting targets. Given, the technology is well proven, it is also

significantly less complex to fund. On this basis, the use of a modern EfW

facility was considered to be an appropriate waste management option for the

treatment of residual waste which cannot practically be recycled.

Mechanical Treatment (MT)

3.2.13 MT plants are often used where there is likely to be materials in the waste

which could be extracted as recyclables prior to the residual stream being sent

for further treatment. MT plants rely on several well proven and reliable

mechanical operations such as over-band magnets, eddy current separators,

trommels and windsifters. MT plants can separate the feed waste stream into

individual streams including recyclables such as paper, plastics grades, metals

and glass. An MT plant ensures that the processing of waste follows the waste

hierarchy, allowing recycling to occur before recovery or disposal. ECC and

MLC already have effective kerbside recycling and a number of other recycling

facilities. However, treatment of the waste in a MT plant prior to sending it to

the ERF would ensure that the level of recycling from their residual waste

would be maximised. This arrangement is therefore consistent with the goals of

the ZWP. A MT plant is considered an integral part of the Millerhill RERC

development.


Mechanical Biological Treatment (MBT)

3.2.14 Mechanical Biological Treatment (MBT) technology is usually adopted instead

of an MT facility where there is a large proportion of organic material in the

mixed municipal waste, which could be removed as an organics stream (in the

MT part of the process) and then treated and stabilised in a biological process

such as composting or AD. This would produce a stabilised Compost-Like

Output (CLO) product. Biological processes applied to organics removed from

mixed municipal waste are often unreliable due to the poor quality of the

organics stream compared with a source-segregated organic stream.

Contamination of the organics stream from small plastic pieces and fine inert

material often leads to a build-up of inorganic materials in biological process

vessels, decreasing the digestion efficiency and reducing plant availability

because the contamination needs to be cleaned out periodically. The intention

of the ZWP is to move towards increased source-segregation of organics. This

means that the organic content of the municipal waste would decrease, which

in turn makes the contamination issue more pronounced. Furthermore,

because the organic stream is derived from mixed municipal waste as opposed

to source-segregated, the CLO produced would not meet the industry standard

PAS110 specification, meaning there is a higher possibility that it would be un-

marketable and would need to be landfilled. The SEPA has stringent rules on it

being spread to land.

3.2.15 ECC and MLC have separate organic / food waste collections and have

successfully tendered a contract for the management of this waste. The

proposed solution for the management of organic waste is the AD Facility that

is in the process of being constructed on land to the immediate north of the

Milerhill RERC site. In light of this, given the small amount of organics that

would be contained within the mixed municipal waste it would be more cost

effective for it to be retained within the residual stream produced by the MT

facility, in order that that its energy can be recovered as heat and electricity in

the ERF.

Autoclave

3.2.16 Autoclaves are not in themselves a residual waste treatment solution and only

offer an interim process which results in the production of a fuel (generally


referred to as a SRF or refuse derived fuel (RDF)), or a CLO. The SRF / RDF

then require a separate facility / process, such as the ERF proposed, in order

for energy to be recovered. Furthermore, an autoclave facility on its own is a

significant net user of energy. The CLO produced by autoclaves from mixed

residual waste has very little application and the SEPA has complex and

stringent rules on it being dispersed on land. At best it can be mixed with soils

and used in landfill (or occasionally contaminated land) restoration. However,

in reality the demand for CLO is extremely limited and it often ends up being

landfilled. Accordingly, it was considered that there were insufficient benefits in

autoclaving as a technology when compared to other options and therefore it

was dismissed.

Advanced Thermal Treatment

3.2.17 With regard to Advanced Thermal Treatment (e.g. pyrolysis and gasification)

there is very limited experience of successfully using these technologies for the

processing of MSW and C&I waste at the scale proposed at the Millerhill

RERC. Pyrolysis and gasification processes are more complex than other more

widely deployed technologies and more prone to operational problems. As a

consequence, they are more difficult to fund and were therefore rejected.

Alternative Thermal Treatment Technologies

3.2.18 Direct waste thermal treatment facilities can be delivered through a variety of

sub-technologies. Consideration was given to these technologies and a

synopsis of this assessment is set out below.

Fixed Hearth

3.2.19 This type of furnace is generally not considered to be suitable for the

management of large volumes of mixed waste and is best suited to low

volumes of consistent waste. As a consequence, they have not been used for

the combustion of municipal waste in the UK.


Pulsed Hearth

3.2.20 Pulsed hearth technology has been used for municipal waste in the past, as

well as other solid wastes. However, there have been difficulties in achieving

reliable and effective burnout of waste and it is considered that the burnout

criteria required by the European WID would be difficult to achieve.

Rotary Kiln

3.2.21 Rotary Kilns have achieved good results with clinical waste, but they are not

commonly used in the UK for MSW (or similar wastes). There is a rotary kiln in

use on municipal waste at Grimsby, which has a design throughput of 56,000

tonnes per annum. In general this technology is suitable only in the throughput

range of 40,000 to 80,000tpa and thus would not be appropriate for the

proposed waste throughput at this facility. Furthermore, the energy conversion

efficiency of a rotary kiln is lower than that of a moving grate (see below) due

to the large areas of refractory lined combustion chamber.

Fluidised Bed

3.2.22 Fluidised bed technology has been used for municipal waste at a very few

sites in Europe. In the UK, there are only two operating facilities which are

located in Dundee and at Allington in Kent. The former has a history of

significant operational difficulties.

3.2.23 Fluidised bed technology has a number of advantages over moving grate

technology, including lower nitrogen oxide (NOx) formation, slightly higher

thermal efficiency and the lack of moving parts within the combustion

chamber. However, there are also a number of disadvantages:

The waste stream needs to be homogenised to provide consistent

fluidisation and therefore would need to be pre-treated (beyond the pre-

treatment achieved in an MT plant) before feeding to the fluidised bed.

This would lead to additional energy consumption and a larger building.

The additional energy consumption tends to outweigh the combustion

efficiency advantage;

High fluidisation velocities can lead to the carryover of fine particulate

material. This can lead to a higher particulate loading in the flue gases,


so leading to higher quantities of flue gas treatment residues, which

need to be disposed of as waste. However, the bottom ash tends to be

of better quality;

Although less NOx would be formed, additional NOx abatement

equipment would still be required to meet the limits imposed by the WID.

Therefore, there would be very little difference in NOx levels overall;

The operational and capital costs of a fluidised bed are higher than the

equivalent costs for a moving grate incinerator; and

Reliability in UK fluidised bed plants is lower than for other thermal

treatment options.

Moving Grate

3.2.24 This is the leading technology in the UK and Europe for the combustion of

municipal and similar wastes, being installed on virtually all UK incinerators

and some 98% of European incinerators. It is a proven and developed design,

with a number of suppliers available. The various designs are proven to

achieve the burnout requirements for Industrial Emissions Directive (IED)

compliance.

Conclusion

3.2.25 In summary, the selected technology scheme for the Proposed Development

is a MT plant removing more recyclable material and producing a residual

stream (SRF) which is fed to an ERF employing moving grate technology to

recover the residual energy as electricity and heat. This technology is readily

available and well-proven for the treatment and combustion of municipal and

similar wastes.

Design Philosophy

3.2.26 The applicant has appointed Gary Stewart Design Associates (GSDA), an

architectural practice with specific experience in the design of waste

management facilities. Their experience covers the design and construction of

a wide range of energy and waste related projects and they are noted for the


design quality of their work which stems from their contextual and sustainable

approach.

3.2.27 The rationale behind the chosen design / architectural solution is described in

detail within the Design and Access Statement (DAS) which is contained

within Part 2 of the PAD.


4.0 SCHEME DESCRIPTION

4.1 Introduction and Scheme Overview

4.1.1 This Chapter provides a description of the layout and design of the proposed

development, together with details regarding its construction and operation.

4.1.2 As described briefly in Chapter 1.0, the Millerhill RERC development would

comprise a combination of a MT process to recover recyclable materials and

an ERC to recover energy from SRF. The SRF would be sourced from the on-

site MT facility and other suitably licensed pre-treatment or recycling facilities.

4.1.3 The Proposed Development would receive up to 195,000 tonnes per annum

(tpa) of residual waste. The waste material that would be processed at the

facility would comprise non-hazardous municipal solid waste (MSW) and

similar commercial and industrial (C&I) wastes sourced primarily from within

Edinburgh, Midlothian and adjoining administrative areas.

4.1.4 Of the 195,00tpa of residual waste material received at the facility 135,000tpa

would be waste received through the Edinburgh and Midlothian residual waste

contract (contract waste), with the remaining 60,000tpa comprising either SRF

received from either commercial and industrial sources or municipal sources

from neighbouring local authority areas.

4.1.5 The 135,000tpa of contract waste received at the site would be transferred to

the MT process which would recover ferrous and non-ferrous metals (circa

2,740tpa) and other ‘reject’ materials that are unsuitable for thermal treatment

(circa 2,798tpa). The remaining material would comprise an SRF which would

be directed, by conveyor, to the ERC for thermal treatment. The circa

60,000tpa of non-contract SRF received from third parties would be

transferred directly to the ERC for thermal treatment, it would not need to be

the subject of MT, having already undergone such a process in advance of

being delivered to the site.

4.1.6 The ERC would generate energy in the form of heat and electricity. The

biodegradable (or biomass) content of the waste is recognised as a renewable


source of energy. Thus around 50-55% of the energy produced by the ERC,

whether it be heat or electricity, would be classed as renewable energy.

4.1.7 The Proposed Development would be a combined heat and power (CHP)

station. Through the combustion of SRF it would generate heat energy in the

form of steam. A proportion of this steam would be used to generate electricity

with the balance exported as heat in the form or either steam or, more likely,

hot water. The maximum electricity generation capacity would be 13.45MW of

electricity (MWe). A small portion (circa 2.36MWe) of this would be used to

power the RERC itself, with the majority circa 11.09MWe exported to the local

electricity grid. Based upon maximum electricity output, the Proposed


sufficient to meet the domestic electricity needs of over 26,000 homes.

4.1.8 Heat generated by the Proposed Development would be exported by

underground insulated pipes direct to local users which could include nearby

institutional, commercial and residential developments.

4.1.9 The need for the proposed facility is described in detail within Section 4.0 of

the PS, which forms Part 3 of the PAD. This sets the proposed Millerhill RERC

and the benefits arising from the scheme in the context of national (Scottish

and UK Government) strategic waste and renewable energy policy documents

and the current waste management position within Edinburgh & Midlothian

and the wider SESplan area.

4.1.10 In addition, the proposals represent a £144 million investment in the

Edinburgh and Midlothian area. The economic benefits of the scheme include

the creation of approximately 40 permanent jobs together with up to 300 - 350

temporary jobs during the construction phase of the development, providing

local employment and apprenticeship opportunities. Furthermore, social and

community benefits would arise from the new education and visitor centre

facilities which would enable the community and schools to learn about waste

management and how they can take more responsibility for their own waste.

4.1.11 The need assessment contained within the PAD concludes that there is a

clear and demonstrable need for the proposed Millerhill RERC development.

The benefits arising from the scheme relate to contributing towards delivering


sustainable waste management (in accordance with the ZWP), combating

climate change through low carbon and renewable energy production and

economic investment with job creation.

4.2 Permanent Development

Main Building

4.2.1 The proposed development would be based around a main building located

centrally within the site on a broadly north to south axis with ancillary

structures, e.g. air cooled condensers, ammonia store and water tanks to the

to the east, an emergency generator, transformer and baled waste store to the

west, an internal access road to the south of the main building and ancillary

vehicle access to / from the building on both the east and west elevations, and

the main vehicular access, manoeuvring area, gatehouse and car parking to

the north of the site near the new site entrance. Provision is also made for the

construction of surface water attenuation ponds to the south and west of the

site. The development is illustrated in plan and elevation form on Figures 4.1 –

4.16.

4.2.2 The main building would contain the following areas:

Waste Reception Hall;

Waste Bunker;

Mechanical Pre-treatment Hall;

Boiler Hall;

Flue Gas Treatment (FGT) facility;

Flue stack;

Turbine Hall;

District Heating Centre; and

Bottom Ash (Storage and Loading) Hall.

4.2.3 The building would have a total length of circa 136.04m and range in width

from circa 55m wide, through the main body of the building, to circa 72.65m

wide where the Boiler Hall / Bottom Ash facility extends out of the main body

of the building to the east.


4.2.4 The height of the main building would also vary reflecting the operational

heights required for the various elements of process equipment housed

therein. The highest part of the main building would house the Boiler Hall /

FGT facility to the south where the roof (to the top of the parapet) would

measure circa 41.6m above ground level down to circa 18.2m for the roof of

the tipping hall and 12.3m for the bottom ash storage and collection hall.

4.2.5 The principle material finishes for the building are as follows:

Metal composite horizontally spanning wall cladding with integral louvres

(colour – Anthracite);

Metal composite roof cladding (colour – Anthracite & Light Grey);

Polycarbonate translucent cladding system (colour – crystal/opal);

Windows in PPC aluminium frames with double glazing (colour – Merlin

Grey)

4.2.6 A full tabulated schedule of all of the materials and finished that are to be

included on the Proposed development are provided in the Design and

Access Statement contained within Part 2 of the Planning Application

Document (PAD).

4.2.7 The flue stack would extend from within the main building envelope and would

measure 75m in height.

4.2.8 Prior to the submission of this planning application FCC entered into

consultation with both the Civil Aviation Authority (CAA) and Edinburgh Airport

Ltd to establish whether any specific airfield safeguarding measures need to

be adopted in connection with the facility and specifically aircraft warning

lights on the stack. They have confirmed that no safeguarding measures

would be required in connection with the facility and as such, no airfield

safegurading light is proposed on the stack.

Other Buildings and Ancillary Structures

4.2.9 In addition to the main building, the facility would also include a number of

ancillary buildings these would comprise a baled waste store, site office /


visitor centre building, gatehouse and driver welfare facility. Each is described

below.

Baled Waste Store

4.2.10 When the ERC is undergoing planning maintenance there is a requirement for

incoming waste to be baled within the MT facility and stored until operations

resume, with the baled waste thereafter being re-introduced to the process.

4.2.11 The proposed baled waste store would comprise a portal framed structure

located to the west of the main building and directly opposite the entrance to

the MT facility. The building would have a single roller shutter door on its

eastern elevation, and personnel doors on its northern and southern

elevations. There would also be a series of louvers on all elevations. The

building would measure circa 52.5m long by circa 20.5m wide by circa 9m

high. It would be constructed of the same composite metal wall cladding as

the main building and in the same anthracite grey colour (RAL7016).

Site Office and Visitor Centre

4.2.12 The main site office, staff welfare and visitor facilities would be located within

a self-contained structure which would be located to the immediate west of the

main building opposite the main stairwell and lift shaft. The building would

include the office reception, conference room, administration and staff welfare

facilities, visitor reception and education and visitor centre facilities. The

building would measure circa 38.2m long by circa 15.7m wide by circa 4.725m

high (to the top of the parapet). It would be constructed of the same composite

metal roof and wall cladding as the main building, including polycarbonate

translucent wall cladding on the northern and southern elevations.

Gatehouse

4.2.13 The Gatehouse would be located near the site’s entrance to the south of the

site. The building would measure circa 14m long by circa 3m wide by circa

3.10m high (to the top of parapet) and would include office and welfare

facilities. The Gatehouse would include a painted metal door on its western

elevation and aluminium framed windows on all other elevations. It would be


finished with the same composite metal wall cladding as the main building and

in the same anthracite grey colour (RAL7016).

Driver Welfare Building

4.2.14 The Driver Welfare Building would be located within the northern part of the

site, near the site entrance and to the immediate east of the out-going

weighbridge. The building would measure circa 16m long by circa 4m wide by

circa 4m high (to the top of parapet) and would include a waiting room and

welfare facilities. The building would include a painted metal personnel door

on its southern elevation and aluminium framed windows on the same

elevation. It would also be finished with the same composite metal wall

cladding as the main building and in the same anthracite grey colour

(RAL7016).

4.2.15 In addition to the aforementioned buildings there would also be a number

ancillary structures and plant associated with the facility, these comprise:

Air Cooled Condensers (ACC) - typically comprising a steel frame

structure measuring approximately circa 36.3m long x circa 14.7m wide

x circa 16m high (18m to the top of the pipe), housing the ACC units.

The frame would accommodate 3 No ACC units;

Step up transformer and emergency generator;

Ammonia store;

Electrical sub-station;

Bin-store / smoking shelter and cycle store (see Figure 4.15)

Fuel oil tanks.

4.2.16 The development would also include the following ancillary infrastructure, the

layout and design of which is described more fully under the following

headings below:

Vehicle Access and Site Circulation;

Parking Provision;

Drainage;

Utilities and Service Connections;

Fire Break Water Tank and Pumping Facilities;

Lighting and CCTV;


Security Fencing and Gates; and

Landscaping.

4.2.17 The Millerhill RERC would have a design life of approximately 25 years,

although, in reality, many elements of the plant would last beyond this period.

Planning permission is being sought for a permanent development and

therefore as elements of the facility require repair / refurbishment /

replacement this would be carried out as necessary.

Vehicle Access and Circulation

4.2.18 The Millerhill RERC development would be served via two new dedicated

vehicle access points to the internal site access road. The first would allow for

public vehicle access to the staff / visitor car and coach parking area. The

second would provide the main HGV access to the weighbridge and

operational areas of the plant. The layout and arrangement of the junctions is

illustrated on Figure 4.1.

4.2.19 Staff / visitors entering the site would proceed along a dedicated access road

to a turning area to the immediate north of the main site office and visitor

centre. A coach parking bay would be provided to the east of the turning area

and car parking to the west and within a central reserve.

4.2.20 Under site operating procedures, all operational HGV vehicles would ‘weigh in’

at a dedicated site entry weighbridge before proceeding to the relevant

delivery / reception areas within the main building. The layout of the proposed

operational access road is such that queuing vehicles approaching the site

entry weighbridge would be accommodated within a widened on-site queuing

area capable of catering for at least 6 full size articulated HGV units. A parallel

‘bypass lane’ would be available for emergency vehicles to avoid any delay /

conflicts with queuing operational HGV traffic.

4.2.21 From the weighbridge HGV’s and other service vehicles would be directed

around the main building in a clockwise direction. A service yard would be

constructed at the northern end of the site, outside the waste reception /

tipping hall to provide for HGV manoeuvring associated with the disposal of

waste and SRF. A series of other service areas would be provided along the


eastern elevation of the main building providing access to the bottom ash

collection building, silos for the delivery and collection of reagents and

residues respectively.

4.2.22 All main service vehicles lanes within the site would be suitable to

accommodate a maximum size articulated HGV unit.

4.2.23 All operational HGV service vehicles exiting the site would be required to

‘weigh-out’ at the dedicated exit weighbridge. This exit area also includes for a

parallel bypass lane. Vehicles exiting the site would proceed onto the internal

access road to the junction with Whitebridge Road to the north.

4.2.24 A series of internal pedestrian footpaths would enable safe movement within

the site.

4.2.25 All heavily-trafficked internal access roads would be surfaced in asphalt with

associated lay-bys and car parking area surfaced in either tarmac or a semi-

permeable treatment. The service yards would be constructed and surfaced

with concrete. Pedestrian footpaths would be surfaced in concrete block

paving.

Parking Provision

4.2.26 Provision would be made for 32 car parking spaces (including 3 disabled

spaces) adjacent to the entrance to the site office and visitor facility. This

level of car parking has been provided to accommodate the proposed staffing

level, taking into account shift change requirements.

4.2.27 In addition, a coach drop-off / parking bay would be provided to accommodate

one coach within the visitor car park and a shelter would be provided for both

bicycles and motorcycles adjacent to the entrance to the site office and visitor

centre.

Drainage

4.2.28 The site is located in an area where the risk of flooding from all sources is low.

However, the proposed development would give rise to a significant increase


in surface water runoff from roads, vehicle parking areas, building roofs and

hardstandings, when compared to the undeveloped state.

4.2.29 The RERC development plot is served by foul and surface water drainage

infrastructure, approved and installed pursuant to the Zero Waste PPiP

scheme, via satellite manholes on or within the boundaries of the site.

4.2.30 The off-site surface water network has been designed to accommodate

regulated flows from the RERC, equivalent to ‘greenfield’ rates (i.e. 3.6/l/s/Ha

or 19.8l/s for the developable area of the plot).

4.2.31 This necessitates an on-site Sustainable Urban Drainage Scheme (SUDS)

which serves to regulate runoff to the prescribed rates, removes pollutants,

and demonstrates that surface water flows can be satisfactorily

accommodated. The scheme would drain surface water via drainage

channels, trapped gullies and a network of pipework, with oil / petrol

interceptors provided in areas susceptible to pollution (e.g. roads and parking

areas), to two interconnected attenuation ponds located in the southern

portion of the development plot. A schematic layout of the proposed drainage

arrangements is provided in Figure 10.1).

4.2.32 Designed to accommodate a design storm with a statistical frequency of 1%

occurrence each year (often referred to as the 1 in 100 year event), together

with a 20% allowance for the effects of climate change, these ponds will

provide in excess of 1,250m3 of storage and act as part of the ‘treatment train’,

in terms of surface water quality.

4.2.33 Domestic foul flows attributable to the proposed development would be

collected by a separate arterial system of below-ground pipework (as

illustrated in Figure 10.1), which would discharge into the existing proprietary

treatment facility, located to the north of the development plot, via an on-site

satellite manhole.

4.2.34 Effluent attributable to the RERC plant itself would include water from the de-

mineralisation plant, condensate and residues from the ash quenching

process. This effluent would be collected in a separate drainage network and

recycled for use in the ash quenching process. As such, there would be no


requirement for the disposal of these wastewaters to the off-site treatment

system.

4.2.35 It is proposed that the detailed design of the drainage scheme be developed in

accordance with the principles set out in the schematic layout subject to

agreement with the SEPA’s and Midlothian Council’s drainage services team.

It is proposed that the detailed drainage design be controlled by a suitably-

worded planning condition.

Utilities and Service Connections

4.2.36 The proposed development would require connection into a number of utilities.

Connections include sewer, water, telecommunications, gas and electricity.

Services are to be provided by Midlothian Council in the new access road that

is being constructed along the eastern boundary of the Application Site.

Fire Break Water Tank and Pumping Facilities

4.2.37 Provision would be made for the storage and pumping of water for emergency

use in the event of fire at the facility. Water would be stored within two Fire

Break Water Tanks (Sprinkler Tank) which would also collect rainwater from

the roof of the main building. Each would comprise a vertical cylinder of circa

5m diameter and 5m high located to the east of the main building, adjacent to

the Waste Reception Hall.

4.2.38 The pumping equipment would be housed within a building and located

immediately adjacent to the water tanks.

Internal and External Lighting and CCTV

4.2.39 Once commissioned, the Millerhill RERC facility would operate on a

continuous (24 hour / 7-day per week) basis. During hours of darkness / low-

level natural illumination there would be a need for lighting commensurate with

health and safety requirements to ensure a safe working environment for

operatives on site.


4.2.40 There are a number of relevant documents and guidance which should be

followed when developing internal and external lighting systems, which

comprise:

Guidance Notes for the Reduction of Obtrusive Light’, Institute of

Lighting Engineers (ILE) 2000;

Application Guide to Lighting in Hostile & Hazardous Environments,

CIBSE 1983;

Guidance Note 4: Lighting Requirements of Building Regulations Part L,

CIBSE 1996

Lighting Guide 6: Lighting The Outside Environment , CIBSE 1992

Lighting Guide 12: Emergency Lighting Design Guide, CIBSE 2004

Lighting Guide to the Industrial Environment, CIBSE 1999

4.2.41 These documents and guidance have been used in determining the principles

of the internal and external lighting arrangements for the Millerhill RERC

development.

Internal Lighting

4.2.42 During night time operations there will be a degree of lighting inside the ERC

which would be necessary to support the 24 hour processing of waste. The

internal lighting will offer an overall low lux level, with directional task lighting

of areas where improved illumination is required for activities such as reading

of gauges and inspecting equipment.

4.2.43 General and specific lighting would also be provided within the Waste

Reception Area and MT building, to supplement the natural lighting that would

be afforded by roof lights.

4.2.44 Manually switched, fixed position high bay induction lighting, would be

installed in the Waste Reception Hall, ERC and MT building. The lighting

would be centrally controlled from a point near to the staff entry / exit door.

4.2.45 The High Bay internal lighting would also be controlled by daylight sensors

and presence sensors located within the building with features allowing for

isolation, testing and manual override functions. The control system shall


offer, without exception, a two channel control, presence and daylight sensors,

with manual over-ride.

4.2.46 Internal lighting would be designed and installed to provide lighting levels that

comply with the CIBSE Code for Interior Lighting and relevant lighting guides

and British Standards to illuminate all internal areas.

4.2.47 Lighting within the Switch Room in the ERC and all common areas / office

areas within the process building would be IP65 rated and controlled from a

point near to the staff entry / exit door. The internal lighting to the above areas

would also be controlled by daylight and presence sensors.

External Lighting

4.2.48 Lighting during operations is required to ensure a safe working environment

for traffic (including manoeuvring HGVs), pedestrians and staff on site. The

facility would have consent to operate on a 24/7 basis and whilst the bulk of

deliveries and visits will be made during daylight hours, operations may

continue outside of these hours, particularly at times of year when daylight

hours are reduced. At all times of the year, the external lighting would be

adequate for safe operations.

4.2.49 This requirement for safe working conditions would be balanced against the

requirement to reduce any unwanted visual prominence of the development at

night. Further, any ecological constraints, such as bat flight paths, would be

considered in the lighting design.

4.2.50 An initial lighting strategy has been developed for the site, based on the

following core principles:

Illumination for safety, particularly along roads, at weighbridges, and

pedestrian areas, when dark during operational hours;

design / architectural lighting of the building;

The application of mitigation measures as part of the lighting design to

avoid unnecessary and unwanted light spillage.


Principals of the External Lighting Strategy

4.2.51 The guidance contained in CIBSE Lighting Guide 6: Lighting The Outside

Environment, suggest appropriate lux levels for various components of

developments, those of relevance to the Proposed development are

summarised in Table 4.1 below.

Table 4.1: Recommended lux levels

Area Recommended lux level

Entrance Signage 100

Feature Lighting 100

Vehicle Routes 10-30

Staff/ Visitor Car Park 5-20

Building exits/ entrances 50-100

Loading areas/ Weighbridge Area 50

4.2.52 It is proposed that the lighting scheme for the Proposed Development is within

the levels recommended within the CIBSE Lighting Guide 6: Lighting the

outside Environment. Whilst detailed assessment is yet to be carried out, it is

considered that the following levels could be realistically achieved:

General roadways / car parking, low lux level (circa 10-30 lux);

Footpaths / pedestrian routes, very low lux level (circa 5-20 lux);

Building entrance / focal points, medium lux levels (circa 20 lux); and

Process / specialist areas, high lux level (circa 50-100 lux).

Architectural / Feature Lighting

4.2.53 As discussed in more detail in the DAS (Part 2 of the PAD) and Chapter 7.0 of

this ES the upper elevations of the Proposed Development would be

constructed of a translucent polycarbonate material. This would allow internal

lighting to be partially visible to create a low intensity ‘glow’ from the building

during hours of darkness. This is purely a design feature and would not be of

such a level that it could cause disturbance to surrounding properties or

ecological impacts (bats etc.).


Mitigation Measures associated with External Lighting

4.2.54 The lighting design would incorporate the following mitigation measures:

The use of low level lights as far as possible (maximum 14m high

columns) to reduce the visibility of site lighting;

The use of carefully sited directional lighting incorporating light shields to

avoid unwanted light spray / upward light and possible glare effects;

Digital programmable switches including timers and / or movement

sensors;

Avoid unnecessary or unplanned lighting of the building façade;

Site lighting to be concentrated in locations essential to night operations;

and

Low level lighting bollards with low energy fittings to reduce the scale

around the offices, visitor centre and pedestrian routes.

4.2.55 Other measures associated with the reduction of intrusive light spillage on site

could also include the use of a surface finish to the road with very low

reflectivity; the use of kerbs with inbuilt reflectors to assist night time

navigation of the roads, and thereby reducing the overhead illumination

requirement.

4.2.56 FCC has carried out pre-application consultation with the CAA and Edinburgh

Airport Ltd which has confirmed that there is no need for the stack to be

illuminated for the purposes of airfield safeguarding.

4.2.57 It is suggested that the detailed lighting design is the subject of a planning

condition.

CCTV

4.2.58 A CCTV system will be installed then maintained and operated in accordance

with British Standard 7958:2005 - Closed Circuit Television {CCTV}

Management and Operation [Code of Practice] and CCTV cameras will be

positioned to give clear surveillance around the perimeter of the development.


4.2.59 This will be monitored 24/7 to ensure the security of the site and management

of the site is not compromised.

4.2.60 CCTV cameras will be mounted on lighting columns, canopies and to the

building where appropriate to ensure that comprehensive coverage is

achieved.

Security Fencing and Gates

4.2.61 The site layout has been designed with the following considerations:

A 2.4m anti-climb welded mesh security fence will provide a secure

barrier preventing access into the operational site beyond the

designated access control point in front of the gatehouse which will also

have gated control for securing the site during out of hours;

A secondary 2.4m high anti climb welded mesh security fence will

secure the staff/visitor access road and car park from the perimeter

multi-use path but will be open during daytime operations adjacent to

the front entrance to the Visitor Centre and via gates opening over the

Visitor Centre terrace and ornamental pond;

With a large part of the site being made accessible as public amenity

area the main security fence is set some way back from the sites part-

west/south/part-eastern boundaries and an additional 1.2m high timber

post and rail fence will be located along the sites perimeter in that

instance;

A further 1.2m high metal estate railing fence will separate the 3m wide

multi-use path and the publically accessible landscaped area and run

from the sites south west corner up to the Visitor Centre.

4.2.62 Details of the fencing and gating proposed on the site are provided on Figure

4.16.

Landscaping

4.2.63 The development includes a comprehensive landscape scheme the indicative

layout of which is illustrated on Figure 7.4.


4.2.64 The landscape scheme has been developed with the aim of achieving a

number of objectives including:

To provide an appropriate setting for the operational development

including security measures and drainage infrastructure;

To create accessible public space which assists in integrating the facility

into the surrounding landscape, provides an amenity for the community

and a resource for staff and visitors;

To maintain and where possible enhance levels of biodiversity across

the site.

4.2.65 Much of the site is currently covered with native semi-natural woodland and is

indeed listed by the Forestry Commission Scotland as an area of lowland

broadleaved deciduous woodland, a priority habitat. In reality, the woodland is

of poor quality, consisting of mainly silver birch with frequent goat willow and

occasional Scots pine. The age of the trees ranges from saplings to

approximately 20 to 25 years. The trees are growing on impoverished soils

(largely railway ballast) and range from fair to predominantly poor condition

showing signs of the effects of growing in a derelict industrial and disturbed

environment.

4.2.66 The majority of the site would be cleared in advance of construction (as was

proposed for the PPiP scheme). In order to preserve as much of the existing

biodiversity as possible, it is proposed that following felling of trees, the upper

soil layers (not topsoil as such, but rather remnant post-industrial substrates

with whatever organic matter has built up over time) would be ‘scraped’ to a

depth of around 200mm and the arising’s deposited in mounds for later re-

use. The aim of this process would be to safeguard the organic matter,

existing seedbank and existing soil fauna etc. There is no existing topsoil

resource on site and it is not anticipated that any would be imported. Instead,

existing site material will be site blended with imported organic matter (green

waste compost or similar) to create manufactured soils suitable for vegetation

establishment. Such material would be loose tipped to the required depths

over prepared (free draining and de-compacted) ground in order to ensure

that a functional rooting zone is created. It is anticipated that the stockpiled

surface material would be used for loose spreading at the surface and that it

would be used preferentially within areas proposed for woodland and


grassland. Specific measures would be incorporated to accommodate

particular ecological interest. For example building wood and stone habitat

piles to encourage common lizard, which is known to occur in the wider area.

4.2.67 An important element of the landscape scheme proposals is the manner in

which security has been delineated in order to allow a greater degree of public

access. Achieving a secure site is a requirement of waste management site

licensing. On this basis, the operational area is enclosed by a 2.4m high

weldmesh fence. The applicant has worked to ensure that this secure area is

drawn as tightly as possible around the operational components of the

Proposed Development in order to allow as much as possible of the site to be

fully accessible to the public. Consequently, an area of approximately two

hectares of new public open space would be created alongside the Proposed

Development. A key component of the new public space would be its

connectivity. A new pedestrian link around the west and north site boundaries

would provide access to and from the Proposed Development for staff and

visitors, but would also provide a new physical link between the existing and

emerging Shawfair communities to the west of the site (including the recently

constructed Borders Railway station) and destinations to the east and north of

the site, including the settlement of Musselborough and emerging employment

land allocations. This connectivity and the resultant increase in use of the site

throughout the day and night will improve the natural safety and security of the

new facility through active use and the attendant passive surveillance.

4.2.68 The Visitor Centre is described in more detail above. The building has been

positioned with a south facing terrace looking along an ornamental water

body. The landscape to the south of the visitor centre would host further

ponds that would function as the sites sustainable drainage system and

provide attenuation during storm events. A network of footpaths would provide

recreational routes through a variety of woodland, grassland and wetland

habitats, with planting of trees, hedgerows and woodland around the periphery

of the open space partially screening the security measures whilst still

allowing some intervisibility with the operational site. There is potential for the

new open space to become part of the visitor centre offer, with an interpreted

nature trail laid out along the path network to provide an additional activity for

school parties. There is good potential for this new open space to be part of a

larger open space utilising land to the west and south. Development proposals


for these off-site areas are not yet finalised but the applicant is open to

discussion regarding the final treatment of the south and west boundaries of

the Proposed Development in order to accommodate a joined up solution.

4.2.69 North of the Visitor centre there would be a car park for use by staff and

visitors with provision for groups arriving by bus or coach. The car park would

be reached using a tree lined driveway linked to the site entrance at the north

east corner of the Proposed Development site. The boundary between the

arrival zone and the operational site, whilst secured by a 2.4m fence, is

deliberately left open to allow clear views of the vehicle movements that are

fundamental to the sites operation.

4.2.70 There would be a substantial area of woodland habitat (approximately half a

hectare), within the security line to the east of the facility. This would consist of

a mix of retained existing tree cover and new planting and would be actively

managed for the duration of the operation of the Proposed Development

alongside the public habitat areas. New planting would replicate the existing

species mix in order to perpetuate habitat suitable for the existing bird

populations. The secure nature of this part of the site is likely to be beneficial

to wildlife in providing a refuge, with considerably less disturbance than would

occur in the publically accessible areas.

4.2.71 It is suggested that the detailed design of the landscape scheme be controlled

through a suitably worded planning condition.

4.3 Proposed Site Operations

4.3.1 The following text describes the operations and processes that would be

undertaken at the Millerhill RERC and should be read in conjunction with the

schematic process flow diagram shown on Figure 4.17.

Waste Reception and Handling

4.3.2 Incoming refuse collection and bulk transport vehicles would enter the site

from the internal access road which provides access from Whitehill Road.

Having entered the site vehicles would proceed to the weighbridge, where the

quantity of incoming waste would be checked and recorded. Vehicle loads


would be inspected periodically at the weighbridge to confirm the nature of the

incoming wastes.

4.3.3 A dedicated quarantine area would be provided at the site entrance

(immediately after the inbound weighbridge) for any unacceptable or rejected

waste material. This material would be loaded into open-top containers,

covered and transported to a suitable disposal facility.

4.3.4 After weighing, the vehicles would continue along the internal site road that

leads to the northern side of the main building. Vehicles delivering waste

would proceed to the northern elevation of the main building to the enclosed

waste reception / tipping hall. When ready to tip, the lorries would be directed

to reverse into a vacant tipping bay to discharge their load into the waste

bunker. On completion of the tipping operation, the vehicles would leave the

waste reception / tipping hall. The vehicles would then proceed on the internal

site road, in the opposite direction to their arrival, to the outbound weighbridge

to record the weight of the vehicle prior to leaving the site.

4.3.5 The tipping hall would be approximately 44.9m wide and 19.8m in depth and

incorporate 6 tipping bays, each about 4m wide. The entry and exit doors

would be equipped with manually operated ‘rapid closing’ vertical folding

doors, which would be kept closed when delivery of waste is not taking place.

4.3.6 The refuse bunker would be of a concrete construction and housed within the

bunker hall in the main building. The refuse bunker would measure

approximately 14m by 30.10m and extend approximately 8m below ground

level. The bunker would be capable of accommodating 3,371m3 or

approximately 1,264 tonnes of waste.

4.3.7 The bunker would be split into two distinct areas, one area for the receipt of

contract waste and another for the receipt of direct delivered SRF. Upon

delivery to the site the contract waste would be directed to the MT facility

where further recyclable and reject material would be removed and the waste

formed into an SRF. Once formed into an SRF, the waste material would be

returned to the bunker with the direct-delivered SRF material for thermal

treatment. The MT process is described in more detail later in this sub-section.


4.3.8 Above the storage bunkers would be two overhead travelling cranes equipped

with petal grabs, each with a capacity of approximately 6 tonnes (including the

weight of the hoist and grab). One of the cranes would be used for the transfer

of material into the hopper for the MT facility, the other would be used to mix,

stack and load the SRF into the feed chutes for the furnaces. The cranes

would be operated by dedicated crane operators, located in an operations

room overlooking the bunkers. CCTV cameras would be installed above the

furnace charging chute to ensure maximum visibility.

4.3.9 Odour and dust in the tipping hall would be controlled by forced draught fans

located above the bunker. These would draw air from the bunker hall and

boiler hall into the furnace to feed the combustion process creating a slight

negative pressure which would prevent odours, dust or litter from escaping

from the building. Anaerobic conditions within the refuse bunkers, which could

cause odour, would be prevented by regular mixing of the waste by the crane

operators.

4.3.10 Following loading into the feeding chute by the petal grabs, the SRF would be

transferred onto the grate by hydraulically powered feeding units. The

backward flow of combustion gases or the premature ignition of the SRF

would be prevented by keeping the chute full of waste and by keeping the

furnace under negative pressure. A level detector would monitor the amount

of SRF in the feed chute and an alarm sounded if the level of SRF falls below

the safe minimum level. Secondary air would be injected from nozzles in the

walls of the furnace to control flame height and the directions of air and flame

flow. The feed rate to the furnace would be controlled by a combustion control

system.

Mechanical Treatment Process

4.3.11 The MT facility would have a dual function by recovering recyclable materials

(specifically ferrous and non-ferrous metals) from the incoming waste and the

preparation of the waste as a SRF for use in the ERC.

4.3.12 The MT process has been specifically designed to recover ferrous and non-

ferrous metals from the incoming residual waste material, sort them into their

separate fractions and remove any reject materials that are unsuitable for


either recycling or the thermal treatment process. Following the MT process

the recyclable elements would be sent for onward transhipment to appropriate

reprocessing facilities, the reject materials sent to a suitable disposal facility

and the remaining material forming an SRF which would be conveyed back

into the waste bunker prior to transfer into the ERC.

4.3.13 The process would comprise a series of conveyors with mechanical sorting

equipment, such as screens and automatic sorters. A description of the typical

components of the MT facility and likely process line is provided below.

The contract waste would be deposited in the waste bunker where any

prohibited material or material unsuitable for processing through the MT

or thermal treatment processes would be removed. Any materials that

could not be re-used, recycled or recovered would be disposed of at

landfill (in accordance with the waste hierarchy);

The waste would then be fed from the waste bunker into a hopper and

coarse shredder;

The shredded material would be passed through a trommel screen to

remove undersized (<120mm) and oversized (>120mm) material for

metal extraction;

The undersized material would pass underneath an over-band magnet

to recover ferrous metals which would then be conveyed to the ferrous

metal collection container;

The remaining undersized material would pass through an Eddy Current

Separator to remove aluminium particles which would then be conveyed

to the non-ferrous (aluminium) collection container;

The oversized material would also pass underneath an over-band

magnet to recover ferrous metals, which would then be conveyed to the

ferrous metal collection container;

After the metals have been removed the remaining, treated, material

would be conveyed (as an SRF) to the SRF bunker; and

The MT facility would also include a Baler which would allow for the

treated SRF material to be wrapped and baled for storage (in the on-site

bale store) during periods of planned maintenance.


4.3.14 The precise internal arrangement of the equipment would be determined by

the contractor at the detailed design stage to optimise the use of space and to

give adequate access to the equipment for repair and maintenance.

Shredders

4.3.15 The shredder at the start of the MT process would reduce input waste to a

particle size of less than 300mm in order to make it a more manageable for

other process equipment. Components of the shredders requiring frequent

maintenance would be easily accessible, easily removable and replaceable.

Conveyors

4.3.16 The conveyor system would be designed so that material flow is uniform

across and along the conveyors and there is minimal spillage or accumulation

of debris in / or around the equipment. The number and types of conveyor

would be kept to a minimum. Access under conveyors with clearance heights

of greater than 2.7m would be designated unrestricted access ways. Access

under conveyors with a clearance height less than 2.7m would be designated

restricted access ways and guards would be put in place. Debris dropout

points would be designed such that material cannot fall onto operational staff.

The dropout points would be positioned such that debris can be removed

easily and safely without staff accessing moving parts.

Trommel

4.3.17 A Trommel would be installed with variable speed control. Safe access would

be provided to the internal parts of the Trommel to enable maintenance and

cleaning. This would screen the material according to size and in this case

into material that is greater or less than 120mm.

Overband Magnet

4.3.18 The overband magnet would remove ferrous metal from the waste stream and

eject it into a container for recovery. All areas before and after the overband

magnet, including all guards, shoots and fixings would be constructed from

non-magnetic material. The overband magnets would be designed to remove


circa 90% by weight of ferrous metal entrained within the input material

stream.

Eddy Current Separator

4.3.19 The Eddy Current Separator uses a powerful magnetic field to induce a

change in magnetic flux into cans / other aluminium material when they fall off

the end of the conveyor. Powerful magnets contained within the discharge

head roll of the conveyor move against each other and affect the Eddy current

force causing the change in Magnetic Flux. The ‘swirling currents’ created

then act to oppose the change in magnetic field being applied which causes

the aluminium material to be thrown to the far end of the discharge chute and

deposited onto a conveyor and the aluminium collection container. The other

material passing through the eddy current would be conveyed to the SRF

Bunker.

Baler

4.3.20 The baler will allow for SRF to be wrapped and stored, whilst the ERC is

undergoing maintenance. The baler would be capable of processing up to 30

tonnes of waste each hour. Finished bales would be ejected onto a bale

conveyor that holds up to 3 finished bales before being transferred to the Bale

Store.

Combustion Process

4.3.21 The proposed facility would use a moving grate which comprises inclined fixed

and moving bars that move the waste from the feed inlet to the residue

discharge. The grate movement turns and mixes the waste along the surface

of the grate to ensure that all waste is exposed to the combustion process.

The start-up burners (which typically operate for up to 16 hours during a start-

up event) would be gas fuelled using low sulphur gas oil. There should be only

two start-ups per year following planned maintenance activities.

4.3.22 Primary air for combustion is fed to the underside of the grate by a single

inverter-driven fan. Secondary air is also admitted above the grate to create

turbulence and ensure complete combustion with minimum levels of oxides of


nitrogen (NOx). The volume of both primary and secondary air is regulated by

a combustion control system.

4.3.23 The combustion control system regulates combustion conditions (and thereby

minimises the levels of pollutants and particulates in the flue gas before flue

treatment) and controls the boiler. The furnace is also fitted with auxiliary

burners, fuelled by low sulphur gas oil, which would automatically maintain the

temperature above 850oC, should temperatures start to fall below this level.

However, this rarely occurs. Combustion chambers, casings and ducts, and

ancillary equipment are maintained under slight negative pressure to prevent

the release of gases. The plant would meet the requirements of the Industrial

Emissions Directive (IED), which would be reflected in the PPC Permit for the

facility.

4.3.24 During operation the temperature in the combustion chamber would be

continuously monitored and recorded to demonstrate compliance with the

requirements of the IED. The combustion control system would be an

automated system, including the monitoring of combustion and temperature

conditions of the grate, modification of the waste feed rates, and the control of

primary and secondary air.

Boiler Water Treatment

4.3.25 A demineralisation plant would be provided as part of the facility, this would be

located under the boiler within the building basement. Various chemicals,

including hydrochloric acid and caustic soda would be required for the

demineralisation process and for boiler water dosing to prevent corrosion.

4.3.26 The chemicals for demineralisation would be stored within a bunded area

within the demineralisation plant. Caustic soda would be delivered by bulk

tanker and offloaded into a 5m³ tank in a bund. Hydrochloric acid would also

be delivered by tanker and stored in a 5m³ bunded tank after it is vented

through a scrubber.


Flue Gas Treatment

4.3.27 Gases generated during the combustion process would be cleaned before

being released into the atmosphere. The ERC would be served by a flue gas

treatment system and associated reagent storage silos. The treatment plant

comprises a dry absorption system that includes activated carbon injection,

dry lime scrubbing, and fabric filters. This would be designed to ensure that

the plant operates within the emission limits set out in the IED.

4.3.28 Vehicles would be required to access the FGT plant in order to deliver Air

Pollution Control (APC) reagents and export APC residues. The silos

containing the APC reagents and residues would be housed in the southern

end of the main building adjacent to the FGT plant. Vehicles would access the

silo storage area via the roadway that runs to the east of the main building.

Vehicles would drive in a clockwise direction around the northern elevation

and would access silo storage area via a door on the eastern elevation. APC

reagents and residues would be transferred by sealed pumps into and out of

the storage silos within the building. Vehicles would then exit via a door on the

western elevation of the building and proceed to the exit via the weighbridge.

NOx Reduction

4.3.29 NOx3 levels would be managed through careful control of combustion air and

selective non-catalytic reduction. This involves the injection of ammonium

hydroxide solution into the combustion chamber of the boiler. The ammonium

hydroxide reacts with both nitrogen oxide (NO) and nitrogen dioxide (NO2) to

form nitrogen and water.

Gas Scrubbing

4.3.30 Acid gases produced during the combustion process would be removed by a

dry scrubbing system, using hydrated lime as a reagent. Neutralisation of the

acid gases would take place as they react with the lime. The residual material

would be recovered at the outlet of the flue gas scrubbing system.

3 NOx is the generic term which refers to NO and NO2 gases formed during the combustion process.


4.3.31 Activated carbon would also be injected into the flue gas duct to minimise the

flue gas emissions of dioxins, mercury and other heavy metals.

Fabric Filtering

4.3.32 After flowing through the gas scrubber, the gases would be drawn through a

fabric bag filter to remove particulates, including lime and activated carbon

particles. The fabric filter would be divided into at least four separate

compartments allowing for maintenance as described below. The treated flue

gas passes through an induced draught fan into the stack for release to the

atmosphere.

4.3.33 Regular bag filter cleaning would be performed on-line by pulsing compressed

air through the filter bags. The residues are known as APC residues and

would be collected in fully enclosed hoppers beneath the filters.

4.3.34 Bag failure, albeit it an infrequent occurrence, would be identified by a sudden

increase in particulate concentration at particulate meters installed

immediately downstream of the bag filter. The compartment containing the

failed bag would be isolated and then replaced. The plant would be capable of

operating at full capacity with one compartment off-line whilst maintenance

was being undertaken. Spare bags would be held on site and installed

immediately after a failure occurs.

Stack

4.3.35 Following cleaning, the combustion gases would be released into the

atmosphere via the stack. Emission from the stack would be monitored

continuously by an automatic computerised system and reported in

accordance with the SEPA’s requirements for the operation of the facility. The

proposed stack would be integrated within the structure of the main building. It

would be 75m high from ground level. Details of the stack height and air

quality modelling are provided in the Air Quality Assessment contained within

Appendix 12-1.


By-Product Handling and Disposal

4.3.36 Two types of solid by-products would be produced from the operation of the

EfW facility, bottom ash and APC residues, each of which would have

separate handling and disposal arrangements as described below.

Bottom Ash

4.3.37 Bottom ash is the inert burnt-out residue from the combustion process and

approximately 6 tonnes per hour of bottom ash would be produced at full load.

The volume of bottom ash generated equates to approximately 25% of the

overall volume of the waste managed at the site. Bottom ash typically

comprises a mixture of glass, brick, rubble, sand, grit and metal as well as ash

from combusted waste.

4.3.38 Bottom ash would be quenched as it leaves the combustion chamber to both

cool the ash and also reduce potential for emissions of ash (dust) into the air.

Any water not vaporised in the quenching process would be collected and

recycled for continued use in the quenching process. The bottom ash would

be fed onto a conveyor that would transport it to the bottom ash hall within the

eastern elevation of the building. The bottom ash would then be collected from

the floor of the bottom ash hall using a front end loading shovel and

transferred to a container for collection and transfer off-site.

4.3.39 The ash material would be processed off-site at a dedicated ash processing

facility where it would be processed into a recycled aggregate which would act

as a direct replacement for virgin aggregate.

Air Pollution Control (APC) Residues

4.3.40 APC residues comprise fine particles of ash and residue from the flue gas

treatment process, which are collected in the bag filters. It is estimated that

the operations would generate approximately 0.5 tonnes of APC residues per

hour which equates to approximately 2.8% of the overall volume of the waste

managed at the site. APC residues would be stored in a silo within the flue

gas treatment facility.


4.3.41 Due to the alkaline nature of the APC residues, they are classified as

hazardous waste (in much the same way as cement). The APC residues

would be transported off-site to a Permitted Hazardous disposal facility or,

alternatively, the residues may be taken to an appropriate treatment facility

where, for example, they could be re-used in the stabilisation of acid wastes or

in cement manufacture.

Raw Materials Handling and Storage

4.3.42 Apart from treating non-hazardous waste, the plant would use various raw

materials during processing. Primarily, these would include hydrated lime,

ammonium hydroxide solution, activated carbon and gas oil. Table 4.2

indicates the processes in which they would be used, the table also provides

estimates of the rates of use. The materials would be stored within

appropriately designed silos either within or adjacent to the facility.

Table 4.2: Proposed Raw Material Usage and Storage

Raw material (if required) Process Typical Rate of Use

Hydrated Lime CA(OH)2 FGT – acid gas scrubbing Approx 1,933 tonnes / annum

Ammonium Hydroxide NH4OH FGT – NOx reduction Approx 635 tonnes / annum

Activated Carbon FGT – dioxins / heavy metal Approx 66 tonnes / annum

Low Sulphur Gas Oil System firing Approx 180 tonnes /annum

4.3.43 In addition, various other materials would be used for the operation and

maintenance of the plant including:

Hydraulic oils and silicone based oils;

Electrical switchgear;

Gas emptying and filling equipment;

Refrigerant gases for air conditioning plant;

Glycol / anti-freeze for cooling;

Oxyacetylene, TIG, MIG welding gases; and

CO2 / fire-fighting foam agents.

4.3.44 In order to minimise the risks of contamination to process and surface water,

all liquid chemicals stored on site would be kept in bunded controlled areas

with a volume of 110% of stored capacity.


4.3.45 In addition to the raw materials described above, the facility would require

materials necessary to maintain the boiler water demineralisation plant, these

include:

Hydrochloric acid (35% solution);

Caustic soda (30% solution); and

Boiler water dosing chemicals.

4.3.46 These materials would be used both in the demineralisation process and for

boiler water dosing to prevent boiler tube corrosion and would be stored in an

appropriately bunded area within the demineralisation plant, in the main

building.

Employment

4.3.47 The plant would provide permanent employment for up to 39 people, working

in shifts to maintain 24-hour / 7-day per week cover. The majority of

employees would be skilled operatives (electricians / fitters / crane operatives)

or technical engineers (control and plant).

4.3.48 It is anticipated that the proposal scheme would be operated by a total daily

staffing level of the order of 30 staff, broken down into a number of shifts.

Peak day time staffing levels on site are predicted to occur during the early

afternoon shift change period (13:00-14:00) when up to 22 staff could be

present on site. The EfW facility could be expected to operate a three shift

system (5 staff per shift) to support 24 hour operation of the plant, with the MT

facility operating a two shift system (1 staff), reflecting the 05:00 – 23:00

operating hours of this element of the Proposed Development. Up to five office

/ management staff could be expected to work a more traditional 08:00-17:00

weekday pattern.

Hours of Operation

4.3.49 It is proposed that the proposed ERC element of the Proposed Development

would operate on a 24 hour, 7 days a week basis. However, the plant would,

be expected to shut down for occasional short term periods to allow the

carrying out of essential programmed maintenance work – albeit that waste


deliveries would likely continue to the site during these times, with waste

stored within the on-site bunker / baled waste storage facility.

4.3.50 Waste input & ash export vehicle movements to / from the site could take

place on a 7 day per week basis, with deliveries of municipal waste to the site

extending to 363 days per year (i.e. not including Christmas Day or New

Year’s Day). However, in practice, commercial & industrial waste,

consumables and process exports / recycling would likely be transported to /

from the site on a Monday – Saturday basis, representing a 300 delivery days

per year.

4.3.51 It is anticipated that the mechanical treatment facility would operate between

05:00 and 23:00.

4.3.52 Typically the majority of waste input movements could be expected to take

place during weekday daytime hours 08:00 – 20:00.

Vehicle Numbers

4.3.53 On the basis of the predicted tonnage figures for the Millerhill RERC (set out

previously in this ES Chapter), it is anticipated that the proposed development

would generate in total 128 daily HGV two-way movements (i.e. 64 in plus 64

out). This includes all HGV movements associated with the delivery of waste,

consumables and the removal of residues and recyclables from the site.

4.3.54 A detailed breakdown of the anticipated vehicle numbers associated with the

proposed development, including staff vehicle demand is provided within the

TA) which is provided within Appendix 6-1.

4.4 Energy Recovery

4.4.1 One of the major benefits of the ERC would be the ability to recover energy

from the combustion of the SRF by way of electricity and heat production. For

the avoidance of doubt, the development proposal includes for electricity

generation and export to the grid, but the connection to the local electricity

distribution network is not included within the formal application itself. This

would be delivered through a separate consenting process as described


subsequently. However, this ES does consider the potential environmental

effects of implementing a grid connection.

4.4.2 Similarly the planning application includes for the generation of heat. As with

electricity connectivity above, the distribution of heat to potential users is not

included within the development proposals. A detailed HPR has been

prepared in support of the planning application (see Part 6 of the PAD) and in

accordance with the guidelines set out within Annex B of the SEPA’s Thermal

Treatment of Waste Guidelines. The HPR provides details of the heat

recovery process, how the heat may be supplied and used by customers, an

estimate of the amount of heat that may be generated and a summary of

discussions held to-date with potential heat users. However, until such time as

the Proposed Development attains both the necessary planning consent and

permit, heat users are unable to make a firm commitment.

4.4.3 The energy generation process is founded upon hot gases from the

combustion chamber passing to a boiler which converts the energy from the

gases into steam. The boiler would be located above the grate and the plant

would generate approximately 76 tonnes of steam per hour.

4.4.4 The ERC would include a steam turbine that would have a generation capacity

of up to 13.45MW of electricity 11.09MW of which would be available for

exported to the local supply grid (the grid connection is discussed

subsequently) with the remainder (2.36MW) used in the operation of the

facility. The turbine would be able to generate an estimated 103,590 megawatt

hours per year (MWh/yr) of electricity (based upon 90% availability i.e.

operating for 7,900 hours in a year). Approximately 87,012 MWh/yr would be

exported to the local grid and the balance would be used to provide power

within the facility itself.

4.4.5 The ERC would also have the capability to export heat to local heat users. To

facilitate this, the turbine would be equipped with steam extraction points to

allow low pressure steam to be supplied directly to consumers, or to be

condensed in heat exchangers in order to provide hot water.

4.4.6 The facility would be able to generate up to 20MW of heat in the form of steam

which would be available for export to a heat network. This would provide an


estimated 158,000 MWh/yr of heat (based upon 90% availability i.e. operating

for 7,900 hours in a year) for export to a district heating network.

Renewable Energy Generation

4.4.7 It is important to note that a proportion of the energy (both electricity and heat)

created from the combustion of municipal and commercial and industrial

waste is classed as renewable. This is manifest in a number of key legislative

and policy documents including the EU Renewable Energy Directive ‘on the

promotion of the use of energy from renewable sources’ (ref: 2009/28/EC).

This defines energy from renewable sources as meaning: “… energy from

renewable non-fossil sources, namely wind, solar, aerothermal, geothermal,

hydrothermal and ocean energy, hydropower, biomass [our emphasis],

landfill gas, sewage treatment plant gas and biogases.” Furthermore, this

directive defines ‘Biomass’ as meaning “… the biodegradable fraction of

products, waste and residues from biological origin from agriculture (including

vegetal and animal substances), forestry and related industries including

fisheries and aquaculture, as well as the biodegradable fraction of

industrial and municipal waste [our emphasis].”

4.4.8 At a national level, the use of waste to generate renewable energy is

recognised in Scotland’s ZWP4 which sets out an overarching mission and a

strategic objective to: “Recover and utilise the electricity and / or heat from

resources which cannot be reused or recycled for greater environmental or

economic benefit, in line with Scotland’s renewable energy goals.”

4.4.9 With regard to the fraction of waste that represents a renewable energy

source, the Renewable Heat Incentive (RHI)5 states: “Energy from waste

combustion (the biomass proportion of municipal waste) rather than being

sent to landfill the waste we produce can be reused, recycled or burned to

produce heat. More than half of the rubbish households throw away is organic,

renewable matter, such as food or paper products. Although it is usually better

from an environmental perspective to reuse, recycle or produce biogas from

these materials, this is not always possible and combustion can offer a better

4 Scotland’s Zero Waste Plan, published June 2010, by The Scottish Government

5http://www.decc.gov.uk/assets/decc/What%20we%20do/UK%20energy%20supply/Energy%20mix/Renewable%20energ

y/policy/renewableheat/1387-renewable-heat-incentive.pdf (page 35)


option than disposal to landfill, which generates harmful greenhouse gas

emissions. Due to its renewable biomass proportion, currently around half the

heat produced by burning municipal waste is renewable heat.”

4.4.10 The RHI goes on to state: “Participants who burn MSW will receive the

biomass tariff, adjusted pro-rata for the solid biomass content of their waste.

Unless participants prove a higher percentage of biomass content, the pro-

rata content will be deemed at 50 per cent.” This indicates that 50% is

considered to be the minimum proportion of the waste which is considered

biomass, and therefore the minimum proportion that is a renewable energy

source (i.e. at least 50% of the electricity and the heat generated from the

combustion of municipal and commercial and industrial waste is classed as

renewable).

4.4.11 In reality, the 50% figure would be exceeded, but the actual figure would

depend upon the precise composition of the waste to be treated. For the

purposes of this scheme, based upon predicted waste compositional analysis,

a conservative figure of 55% renewable energy has been adopted.

4.4.12 On the basis that it is estimated that circa 55% of this would be renewable, up

to 7.4MW (56,974MWh/yr) of renewable electricity and 11MW

(56,974MWh/yr) or renewable heat would be generated by the facility

Recovery Operations

4.4.13 Whilst the ERC would recover energy from waste, waste combustion facilities

(i.e. incinerators) are only classed as ‘recovery’ operations (as opposed to

‘disposal’ operations) if they meet a specified energy efficiency as set out in

the revised Waste Framework Directive (ref: 2008/98/EC), enacted in

Scotland through: The Waste Management Licensing (Scotland) Regulations

2011. The Directive includes specific definitions of ‘disposal operations’ and

‘recovery operations’, whereby:

Disposal: “… means any of the operations listed in Part II of Schedule 4,

and any other operation relating to waste which is not recovery even

where it has as a secondary consequence the reclamation of

substances or energy, and any reference to waste being disposed of is

a reference to its being submitted to any such operations;”


Recovery: “…means any of the operations listed in Part III of Schedule

4, and any other operation the principal result of which is waste serving

a useful purpose by replacing other materials which would otherwise

have been used to fulfil a particular function, or waste being prepared to

fulfil that function, in a plant or in the wider economy, and any reference

to waste being recovered is a reference to its being submitted to any

such operations”

4.4.14 Part III of Schedule 4 of the Directive includes R1, which is defined as: “use

principally as a fuel or other means to generate energy.” A footnote to this

definition states that: “This includes incineration facilities dedicated to the

processing of municipal waste only where their energy efficiency is equal to or

greater than … (ii) 0.65 for other installations” [that is other than those under

part (i) being permitted before 1st January 2009], and defines energy efficiency

using a formula, set out in Annex II of the Waste Framework Directive (WFD),

which takes into account the differing benefits of electricity generation and

heat generation.

4.4.15 Applying this formula gives an energy efficiency factor of 0.70 for the

proposed ERC when only exporting electricity (as opposed to heat, or heat

and electricity in combination). Export of heat would significantly increase the

energy efficiency factor (it would be 0.99 with the export of 20MW of heat and

circa 6.75MW of electricity). This confirms that the operation of the plant would

be defined as a recovery operation.

4.4.16 As alluded to above, Annex II of the WFD restricts the scope of the formula to:

“facilities dedicated to the processing of Municipal Solid Waste” so it does not

effectively apply to plants that are dedicated to incineration or co-incineration

of hazardous waste, hospital waste, sewage sludge or C&I waste. Whilst it is

anticipated that the Millerhill RERC development would receive some C&I

waste, the main purpose of the facility would be for the processing of mixed

municipal solid waste for energy recovery, thus the R1 calculation is relevant.


Summary

4.4.17 In summary the Proposed Development:

would generate electricity, more than half of which would be classed as

renewable;

would be designed with the potential to generate heat for export and use by

local heat users;

would be defined as a ‘recovery’ operation in the revised EU Waste

Framework Directive; and

has the opportunity to provide heat off-take to a number of sources locally.

4.5 Operational Environmental Management

4.5.1 The potential effects of waste management developments can be the subject

of public concern (i.e. nuisance caused by litter and odour), or through the

attraction of vermin or other pests. However, a modern, well run facility, such

as the Millerhill RERC, should not give rise to such issues.

4.5.2 The site would be operated under a Planning and Pollution Control Permit

(PPC Permit), issued and monitored by the SEPA. The Permit would identify

the potential for effects upon public amenity and ensure that management

measures are adopted to minimise these effects and that the Millerhill RERC

does not give rise to unacceptable environmental harm.

4.5.3 The potential impacts of the Millerhill RERC development and associated

mitigation are described in detail within Chapters 6.0 to 17.0 of this ES.

Notwithstanding, the identified additional mitigation measures identified within

these Chapters, this section considers the standard measures that would be

employed to manage and monitor the following potential public amenity issues

at the site:

Vermin and Pests;

Dust and Odour;

Fire; and

Litter.


Vermin and Pests

4.5.4 All waste would be delivered to the enclosed Reception Hall and deposited

within the appropriate storage areas (described in Sub-section 4.3 above).

Regular inspections of the site would ensure litter within and adjacent to the

site that could attract vermin would be collected and disposed of. In addition,

the Reception Hall would be cleaned daily to ensure that material that could

attract rodents or other pests does not accumulate.

4.5.5 A vermin control programme would be put in place and inspections of the site

by pest control specialists would be undertaken if any rodent or other pest

issues were identified.

Dust and Odour

4.5.6 Whilst odour sources do occur at EfW facilities, odour complaints and escape

of odours at EfW facilities beyond the site boundary are unlikely on the basis

that all operations occur within an enclosed building. Odours would be

prevented from escaping the tipping hall and waste bunker, which is where

most odour issues are likely to arise, as the air within the building is retained

under negative pressure. This is achieved through the extraction of air from

the tipping hall by forced draught fans which feed the combustion process.

4.5.7 The handling operators would be trained to operate a FIFO (first in first out)

system, so that waste is not routinely kept in the waste bunker for longer than

two to three days. In addition, anaerobic conditions within the refuse bunkers,

which could cause odour, would be prevented by regular mixing of the waste

by the crane operators. An activated carbon filter unit would also be installed

to prevent odour issues during any shutdown period. A separate odour filter

would also be installed in the MT facility, which would operate during a

shutdown period, to ensure that odour is not released during the baling of

waste.

4.5.8 No odours would be emitted from the stack as all odorous compounds would

be destroyed due to the high temperatures achieved (850oC) within the

furnace. Deliveries of biogenic waste, which could give rise to odour, would be

within enclosed or sheeted delivery vehicles. All delivery vehicles entering the


site would be inspected by the gatehouse operator to ensure that they are

appropriately enclosed. Any drivers failing to comply with site regulations

would be warned and breaches reported in the Environmental Management

Plan (EMP) for the site (required as part of the PPC Permit). If repeated

offences occur then drivers would be banned from accessing the site.

4.5.9 Odour surveys would be undertaken if any complaint from neighbours in

relation to odours is received. If necessary, operating procedures would be

amended to deal with any issues identified at the site.

4.5.10 Dust emissions from the site are unlikely to occur as all process operations

are undertaken within enclosed buildings. Dust arising from vehicle movement

is unlikely as all trafficked areas would be hard surfaced. During prolonged

periods of dry weather the site roads would be washed, if the potential for

fugitive dust impacts resulting from traffic movements are identified by the

facility’s general manager.

4.5.11 Bottom ash storage, handling and loading would occur within an enclosed

building. The doors of the bottom ash processing facility would remain closed

other than for access to vehicles collecting material for transport off-site. Air

vented from the bottom ash processing building would be filtered before being

released to the atmosphere by means of a bag filter system (or any other

system with at least same performance levels, such as air cyclones, jet

system or multi-venturi), again further mitigating the potential for dust release

from the facility.

Fire

4.5.12 Whist extremely unlikely, it is possible that waste loads being received at the

site may comprise elements of smouldering waste. The site management plan

would have procedures in place to deal with such events and records of any

smouldering load incidents would be made within the EMP and monthly facility

service reports. A dedicated area would be provided within the facility that

would be equipped to receive and extinguish smouldering loads delivered to

the facility.


4.5.13 Once deposited in the waste bunker the waste would be inspected by the

crane operator and as described above the waste would be mixed regularly to

avoid anaerobic conditions developing within the waste mass. Inspections and

regular mixing of the waste would help identify and prevent hot spots forming

within the waste mass which could cause a fire.

4.5.14 Fire prevention and suppression systems would operate at the facility. This

may include the use of a specific water deluge system within the waste bunker

and a fire water sprinkler system.

Litter

4.5.15 FCC would maintain the site in a clean and tidy condition and measures would

be defined within the EMP to prevent the release of litter from the facility

buildings and from the site boundary.

4.5.16 All vehicles carrying waste to the site would be required to be adequately

covered, thus avoiding problems associated with litter escaping onto the

public highway, or other areas outside the boundary of the site. Drivers would

only be allowed to un-sheet vehicles upon entering the waste hall. As

described above any drivers failing to comply with site regulations would be

warned and breaches reported in the site EMP. If repeated offences occur

then drivers would be banned from accessing the site.

4.5.17 All unloading of waste would be undertaken within the enclosed waste

reception hall, which, as described above would be controlled under negative

air pressure. This would assist in preventing any litter from escaping the

building.

4.5.18 The boundary of the operational areas would be secured by a 2.4m high

fence. This would help prevent litter from being blown beyond the site

boundary. The internal and external boundaries of the site would be inspected

daily and any litter would be collected and disposed of.


Conclusions

4.5.19 The site would be operated under a PPC Permit, which would ensure that any

potential effects upon public amenity are minimised. Management measures

adopted at the facility would help to prevent unacceptable environmental

effects in respect of rodents and other pests, odour, dust, fires and litter.

4.6 Proposed Contingency Plans

4.6.1 Extensive operating procedures and contingency plans would be put in place

to ensure the safe and efficient running of the Millerhill RERC. These would

cover situations such as plant failure, receipt of unacceptable waste and traffic

problems.

4.6.2 Procedures would be put in place in the event that waste cannot be delivered

to the facility for processing. For example, the plant would require essential

annual planned maintenance over a period of 2-3 weeks. Waste which cannot

be processed at the plant during this period would be baled within the MT

plant and transferred to the bale storage building until the facility is

operational. In the event of unexpected shut-down, similar procedures would

apply.

4.7 Waste Inputs

Waste Types, Sources and Quantities

4.7.1 The proposed ERC has been developed for the thermal treatment of circa

190,000tpa of residual non-hazardous waste arising within Edinburgh and

Midlothian. As set out in Chapter 3.0 of this ES (and Section 4.0 of the

Planning Statement) there is a demonstrable need for such treatment capacity

within the joint authority area.

4.7.2 The proposed ERC would cater primarily for residual MSW delivered under

contract by Zero Waste: Edinburgh and Midlothian, but capacity has also been

allowed for the treatment of residual non-hazardous waste received from

either commercial and industrial sources or municipal sources from

neighbouring local authority areas.


4.7.3 Regardless of what the precise residual MSW / C&I waste split transpires to

be, the aforementioned need assessment demonstrates that there is far more

residual waste requiring treatment within the SES Region than could be

accommodated at the plant.

Understanding Waste Throughput

4.7.4 The ERC has been designed with the capacity to thermally treat circa

190,000tpa of residual waste. However, it is important to understand thermal

treatment plants, such as the ERC, are actually sized on thermal capacity, not

mass throughput, and that once a plant has been constructed its thermal

capacity is fixed for life. The relationship between mass throughput and

thermal size is dictated by the Calorific Value (CV) of the Waste. The CV

depends upon the mix of materials that is in the waste and when this is

applied to residual waste this is also related to the materials removed from the

waste by recycling. The higher the CV of the waste, the lower the tonnage

throughput of any given thermal treatment plant and vice versa (this

relationship is independent of the thermal treatment technology selected).

4.7.5 Plant availability is the number of hours per year the plant is running and

processing waste; this affects annual tonnage throughputs. Over the life of the

ERC there will be years of high availability and years of low availability.

Typically a well-run and reliable plant would average circa 90% availability.

There are 8,760 hours available in a year, for a plant averaging circa 90%

availability over a 25 year life this means that on average it would operate for

7,900 hours in a year. However, some years may have more hours and some

less. For example: a plant processing 25 tonnes per hour for 8,000 hours has

an annual throughput of 200,000 tonnes, but if the same plant only operates

for 7,500 hours (maybe due to increased maintenance needs that year) then

the throughput would reduce to 187,500 tonnes.

4.7.6 In light of the above, it should be understood that the plant throughput in any

year is a combination of three factors:

Thermal capacity;

Waste CV; and


Plant availability.

4.7.7 Given that once a plant has been constructed its thermal capacity is fixed, it is

the other two variables that determine the waste throughput profile over the

life of the plant, albeit the likely change in throughput would be very modest

even if the variables shift.

4.7.8 This is a common issue faced in planning applications for thermal treatment

plants, like the ERC, where the applicant must use the best available

information to fix a throughput figure which accurately reflects current waste

data and is supported by a need argument. It is inappropriate to assess the

effects of the scheme based upon theoretical outcomes (not reflecting the best

available data) which could modestly either reduce or increase the actual

throughput capacity.

4.7.9 As stated throughout, the overall capacity of the Proposed Development is

nominally 195,000tpa, which after removing recyclable material and rejects (at

just over 5,000tpa) gives a required thermal treatment (ERC) capacity of just

under 190,000tpa. The ERC has been designed, in terms of the thermal

capacity of its boiler, to thermally treat 190,000tpa of waste subject to the

following variables:

7,900 operating hours per year (circa 90% of the year); and

A waste net CV of 7.51 MJ/kg.

4.7.10 This is considered to comprise a realistic maximum number of operational

hours per year and towards the minimum CV for the input waste material.

Accordingly, 190,000tpa is the realistic maximum tonnage throughput that the

ERC could deliver. In reality, it is judged that the waste CV will be slightly

higher than 7.51 MJ/kg and thus the operational throughput slightly lower. For

example if the CV were actually 8.37 MJ/kg, then, based on the same 7,900

operating hours, the actual ERC capacity would be reduced to 170,000tpa.

4.7.11 The Proposed Development assessed within this planning application,

therefore represents the highest realistic throughput. Accordingly it is

considered to represent a robust, scenario in terms of vehicle movements etc.

and in terms of demonstrating the need for the facility.


4.7.12 However, for the reasons identified above, whilst the Millerhill RERC facility

capacity is designed to have circa 190,000tpa capacity, the volume of waste

treated at the facility could, dependent upon the aforementioned variables, be

slightly different. For this reason, an absolute tonnage throughput restriction

should not be placed on the facility and it is suggested, as is commonly the

case, that if a tonnage restriction is placed on the permission, it provides for

the planning authority to control and agree minor variations in throughput

depending upon the prevailing circumstances.

4.8 Energy (Heat and Power) Connectivity

4.8.1 As outlined above, the ERC would recover energy from the combustion of SRF

by way of heat and electricity production. A separate HPR has been prepared

in support of the application (see Part 6 of the PAD). This sets out the currently

defined proposals for heat and power export, together with the steps required

to maximise benefits in this regard.

Heat Connectivity

4.8.2 The HPR has identifies 4 potential district heating zones within close proximity

to the Application Site. The location of the identified heat off-take opportunities

and potential routeing of a heat pipe network is illustrated on Figure 16.1. The

heat pipe network does not form part of the planning application for the

Millerhill RERC and would be authorised by either a separate planning

application or through permitted development rights. However, on the basis

that export of heat is an integral part of the scheme, it is considered

appropriate that the potential environmental impacts associated with the

delivery of the heat pipe network are assessed within the ES (refer to Chapter

16.0).

Electricity Connectivity

4.8.3 Similar to the heat pipe network, the grid connection works required to export

electricity from the ERC do not form part of the planning application and would

be authorised either under a separate formal consenting process, or under

permitted development rights, depending on the nature of the connection.


However, on the basis that export of electricity is an integral part of the

scheme, it is considered appropriate that the potential environmental impacts

associated with the connection to the local electricity grid are assessed within

the ES.

4.8.4 The applicant has undertaken a Grid Connection Feasibility Study and has

consulted with the local District Network Operator (DNO) (Scottish Power

Networks) to identify potential grid connection options. The DNO has confirmed

that a connection is feasible.

4.8.5 The most likely connection would be to the 33 / 11kV Niddrie sub-station

located off the A6106 (The Wisp) to the Rear of the Jack Kane Sports Centre in

Niddrie. This would be an underground cabling connection below the existing

highway network (see Figure 16.2).

4.8.6 An assessment of the potential environmental impacts of these connection

options is presented in Chapter 16.0 of this ES.

4.9 Construction Methods

4.9.1 The following section provides a summary of the key elements of the

construction. It is not intended to be prescriptive and the exact construction

methods, phasing and programme would be determined by the appointed

contractor. However, the following description enables the key environmental

effects of the development to be assessed.

Programme

4.9.2 The timing of the construction period would be dependent on the grant of

planning permission for the proposed development and subsequent contract

negotiations. The current programme of works is based on the assumption of

a construction start date in mid-2015.

4.9.3 The construction period is anticipated to take approximately 28 months, this

includes internal fit-out and commissioning of mechanical and electrical plant.

The programmed date for the opening of the plant is early 2018.


4.9.4 The core ground works including site clearance, earthworks, foundations,

drainage are likely to occur within the first five months. The erection of building

frames and the main structural works would be staggered throughout the

construction period. The first major structure to be erected would be the boiler

hall and FGT building, this would begin immediately following the main ground

works. The final building structure to be completed would be the air cooled

condensers. These structures would be erected between months 17 and 22,

towards the end of the construction period. Following completion of the

structural building works, external hardstandings including roads and car

parks would be completed along with lighting, signage and landscaping. All of

the construction works would be managed within the site.

Construction Hours

4.9.5 Construction operations would generally be limited to 07:00 – 19:00hrs

Monday to Friday and 07:00 – 12:00hrs Saturday. It is possible that some

construction activities would be undertaken outside these hours e.g. during

the internal fit out of buildings, delivery of abnormal loads. HGV movements

would not be permitted outside the hours outlined above without prior

agreement from the Waste Planning Authority (WPA) and operations would

not exceed any noise limits imposed as part of the permission.

Site Access

4.9.6 Site access would be from the new access off Whitehill Road. This access has

proved suitable for the construction of the Alauna AD plant to the north.

Main Construction Activities

4.9.7 The key construction phases of the project are described below. The

construction activities are set out in the likely construction sequence.

However, it is expected that a number of the operations would overlap and as

described above the construction of various elements of the main building

would be staged throughout the construction period.


Site Preparation

4.9.8 The perimeter of the site would be secured for the duration of the construction

works by either timber hoardings or Heras (or similar) fencing.

4.9.9 A one way traffic system would be set up on site with a separate entrance and

exit providing access to/from the internal site access road. The site entrance

and exit would be gated and 24 hour manned security would operate

throughout the construction period.

4.9.10 Vegetation clearance on the site would involve the removal of a number of

immature trees and areas of scrubby grassland. Vegetation clearance would

be undertaken outside the bird breeding period (April – September) and would

take into account any other ecological constraints identified at the site.

Earthworks, Foundations and Piling

4.9.11 The construction would involve the excavation of materials at the site. The

excavations would include creation of the void for the waste bunker, turbine

condenser room and bottom ash bunker. Other excavated material would be

generated from the piling and foundation works, development of external hard

standing areas and utilities and drainage runs.

4.9.12 As described previously the landscaping scheme / noise mitigation measures

include the creation of an earth bund. The creation of these bunds, along with

the use of the arisings in road construction and development of building

platforms, would utilise the excavated material on site.

4.9.13 Provisional site investigations indicate that the excavated material would be

suitable for reuse as engineering fill or for landscaping operations.

Building Foundations

4.9.14 Foundations for the frame of the main building are likely to be founded using a

piled solution. Piling methods would be determined by the piling contractor but

could be hammer driven or rotary auger. Noise impacts from the hammer


driven option has been assessed in Chapter 11.0 as this is likely to result in

the most significant noise impacts.

4.9.15 Foundations for the ancillary buildings including the weighbridge, ACC, water

pump house and substation are likely to be strip or pad footings.

4.9.16 Building slabs would be cast in-situ and concrete would either be delivered

directly to the site via concrete mix lorry or concrete would be made from an

on-site concrete batching plant with aggregates being supplied to site by HGV.

Erection and Cladding of Building Frames

4.9.17 The buildings are likely to be of steel frame construction with the external

envelope formed from a combination of masonry blocks, cold rolled sheeting

rails, metal cladding and polycarbonate cladding. The roofs of the buildings

would be constructed of composite cladding panel.

4.9.18 Steel work would be delivered to the site by HGV. The construction is likely to

be undertaken using a series of mobile truck mounted cranes and a fixed

tower crane. Typically a tower crane with a 55 metre boom and a span of 65

meters to the hook would be used in such a construction. The height of the

tower crane would typically be 40m. The greatest lifting capacity is likely to be

provided by a large crawler (500 tonne capacity) for boiler erection.

Installation of Plant and Equipment

4.9.19 The installation of the main plant and equipment would be undertaken

following the completion of the boiler hall and FGT facility. The installation

would begin approximately 12 months after the start of construction and would

take approximately 12 months.

4.9.20 Commissioning of the plant would take a period of 7 months and would

commence following installation of the main plant. The initial commissioning

referred to as ‘cold testing’ would involve a series of tests prior to the burning

of any waste at the site. The cold testing would ensure that all systems are in

full working order prior to the thermal treatment of waste. Waste would then

begin to be imported to the site to allow ‘hot testing’ of the plant to commence.


Hot testing, optimisation of the plant and performance testing would take a

period of 4 months after which the plant would be fully operational.

External Civil Engineering and Infrastructure (Roads, Car Parking Areas,

Drainage and Utilities)

4.9.21 Much of the external civil engineering works are likely to be undertaken

towards the end of the main construction works in parallel with the installation

of plant and the commissioning period. The works would comprise the laying

of access roads, the car park, external hard standing areas to the buildings

and earthworks associated with the final landscape scheme. The laying and

installation of drainage and utilities would be phased with much of the work

being undertaken in the early phases of the project. Connections and finishing

of service runs are likely to be undertaken towards the end of the construction

phase. It is likely that the external grid connection works i.e. the construction

of the cable route, cabling and any ancillary works e.g. reinforcement of

substations would be undertaken by the DNO. This work would be undertaken

in parallel with the plant installation and commissioning operations.

Site Compound and Operative Facilities

4.9.22 The site compound would be located in the northern area of the site close to

the site entrance. Parking would be provided within the northwest corner of

the site. The main storage and pre-assembly area would be within the north

east corner of the site, the area would be used for the temporary storage and

laydown of materials and plant. Further material storage and laydown areas

would be provided along the southern boundary of the site.

4.9.23 The proposed car parking would be located within two areas of the site and

would cover an area of approximately 5,500m2 in total. The car parking area

would be formed by laying stone either directly on the current ground surface,

to provide a suitable parking surface. In order to minimise the requirement for

operative car parking, buses would be provided and a car sharing scheme

would form part of the Construction Travel Management Plan (CTMP). In

addition, a new rail station has also just been constructed within the SNCD

immediately to the west of the site which could also be used by operatives.


4.9.24 Appropriate bunding and environmental protection measures would be

implemented within the fuel and material storage areas situated within the

construction site. The protection measures would be defined in the

Construction Environmental Management Plan (CEMP) described in further

detail below and would be in line with the SEPA’s Pollution Prevention

Guidelines.

4.9.25 A wheel wash facility would be located at the site exit. It would be self-

contained with an integral pump house and internal settlement collection tank

and would comprise high-pressure water hoses and a power washer hand

lance.

Plant

4.9.26 The following items would be the principal elements used during the

construction period:

Tracked excavators (excavation and loading);

Articulated dump trucks;

Wheeled backhoe loaders;

HVG wagons;

Piling rigs;

Mobile cranes and telescopic handlers;

Tower cranes;

Rollers and vibratory compactors;

Generators and water pumps;

Concrete batching plant and pump; and

Cement mixer trucks.

Construction Environmental Management Plan (CEMP)

4.9.27 A CEMP would be developed for the construction period, the purpose of which

would be to manage and report environmental effects of the project during

construction. The CEMP would set out how environmental issues would be

managed in accordance with relevant legislation, regulations and best practice

guidance. It would be the responsibility of the main contractor to develop and

enforce the CEMP.


4.9.28 The objectives of the CEMP would be to:

Highlight environmental impacts resulting from the development and

identify sensitive receptors within the development site to the

construction team;

Reduce and manage environmental impacts through appropriate

construction methods;

Reduce and manage environmental impacts through the implementation

of environmental best practice during the construction period;

Undertake on-going monitoring and assessment during construction to

ensure environmental objectives are achieved;

Provide emergency procedures to protect against environmental

damage;

Provide an environmental management structure for the construction

stage;

Recommend mechanisms to reduce risks of environmental damage

occurring; and

Consult and liaise with the SEPA, SNH, Local Authority Officers and

other stakeholders throughout the works if necessary.

4.9.29 A CEMP for a project of this nature would typically cover the following key

elements:

Drainage, water quality and hydrology;

Dust, emissions and odours;

Noise and vibration;

Health and safety / site management;

Site waste management;

Construction traffic management;

Wildlife and natural features;

Cultural heritage;

Contaminated material; and

Pollution control and emergency / contingency procedures.

4.9.30 Prior to the commencement of construction an environmental walkover

ecological survey would be undertaken to establish any changes in the


environmental baseline since the surveys undertaken as part of the EIA and

update any of the defined construction procedures as necessary.

4.9.31 Detailed construction method statements would be developed for the key

construction phases e.g. site preparation and development of site compound,

site excavation and foundations and piling activities. The method statements

would outline the key construction processes, identify potential environmental

and health and safety risks and define appropriate mitigation measures.

4.9.32 The main contractor would have regard to the following guidelines in the

preparation of the CEMP and during the operation of the site:

Pollution Prevention Guidelines 1: General Guide to the Prevention of

Pollution (PPG1), SEPA;

Pollution Prevention Guidelines 2: Above Ground Oil Storage Tanks

(PPG2), SPEA;

Pollution Prevention Guidelines 3: Use and Design of Oil Separators in

Surface Water Drainage Systems (PPG3), SPEA;

Pollution Prevention Guidelines 4: Disposal of Sewage where no Mains

Drainage is Available (PPG4), SPEA;

Pollution Prevention Guidelines 5: Works and Maintenance in or near

water (PPG5), SEPA;

Pollution Prevention Guidelines 6: Working at Construction and

Demolition Sites (PPG6), SEPA;

Pollution Prevention Guidelines 7: Safe Storage – The Safe Operation of

Refuelling Facilities (PPG7), SEPA;

Pollution Prevention Guidelines 8: Storage and Disposal of Used Oils

(PPG8), SEPA;

Pollution Prevention Guidelines 13: Vehicle Washing and Cleaning

(PPG13), SEPA;

Pollution Prevention Guidelines 21: Pollution Incident Response

Planning (PPG21), SEPA

Pollution Prevention Guidelines 22: Incident Response – Dealing with

Spills (PPG22), SEPA;

CIRIA. Culvert design and operation guide (C689) (2010);

CIRIA. Control of water pollution from linear construction projects.

Technical guidance (C648) (2006);


CIRIA. Environmental Good Practice on Site (fourth edition) (C741)

(2015);

CAA – Civil Aviation Publication CAP738 – Safeguarding of

Aerodromes;

AOA – Advice note AN/01 – Safeguarding of Aerodromes – Overview;

AOA – Advice note AN/02 – Safeguarding of Aerodromes – Lighting;

AOA – Advice note AN/03 – Safeguarding of Aerodromes – Birds

(Landscaping);

AOA – Advice note AN/04 – Safeguarding of Aerodrome – Cranes; and

AOA – Advice Note AN/06 – Safeguarding of Aerodromes – SUDS

(potential Bird Hazard from Sustainable Urban Drainage Schemes).


5.0 PLANNING POLICY CONTEXT

5.1 Introduction

5.1.1 This section briefly identifies the planning policy context for the Millerhill RERC

development. The full planning policy assessment is not included in the ES

but provided by way of a separate PS included as Part 3 of the PAD. Only the

relevant policy context is summarised below.

5.2 Policy Context

The Development Plan

5.2.1 In the case of the Proposed Development, the relevant statutory Development

Plan comprises:

The Strategic Development Plan for Edinburgh and South East Scotland

(SESplan) (2013); and

The Midlothian Local Plan (1998).

Material Considerations

5.2.2 Many of the policies contained within statutory Development Plan were

adopted some time ago. As a consequence, whilst they carry statutory weight,

many have been superseded or are supplemented, in part, by elements of

subsequent national policy, guidance and other new evidence. This

information is contained within a number of documents which are considered

to be material planning considerations in the determination of this planning

application. The key documents are judged to comprise the following:

European (EU) Waste, Energy and Climate Change Policy and Legislation:

Revised Waste Framework Directive (2008/98/EC), December 2008;

Renewable Energy Directive (2009/28/EC), June 2009;

Industrial Emissions Directive (2010/75/EU), January 2011;


Waste, Energy and Climate Change Policy and Legislation:

UK Government Policy, as relevant within Scotland:

Energy White Paper ‘Meeting the Energy Challenge’, May 2007;

The Renewable Energy Strategy, July 2009;

The Low Carbon Transition Plan, July 2009;

The Renewable Heat Incentive, March 2011;

The Renewable Energy Roadmap Update, July 2011 (including

updates);

The Carbon Plan: Delivering our Low Carbon Future, December 2011;

Planning our Electric Future: A White Paper for Secure, Affordable and

Low-Carbon Electricity, July 2011;

Scottish Government Policy:

Zero Waste Plan, June 2010;

Policy Statement: Zero Waste Regulations, October 2011;

Waste (Scotland) Regulations 2012, May 2012;

SEPA Thermal Treatment of Waste Guidelines, May 2014;

SEPA Guidance Note 6 Land Use Planning System, February 2013;

Planning Advice Note 63: Waste Management Planning, February 2002;

Specific Advice Document / Sheet ‘Energy from Waste’, February 2011;

The Climate Change (Scotland) Act 2009, August 2009;

The Climate Change Delivery Plan: Meeting Scotland’s Statutory

Climate Change Targets, June 2009;

2020 Routemap for Renewable Energy on Scotland, July 2009

(including 2013 update);

The Renewables Action Plan, June 2009 (including updates);

Electricity Generation Policy Statement, June 2013;

Scottish National Planning Policy:

National Planning Framework 3, June 2014;

Scottish Planning Policy, June 2014;


Emerging Development Plan Documents:

Emerging Second Strategic Development Plan for Edinburgh and South

East Scotland - the latest e-bulletin update regarding the preparation of

the Plan indicates that: “The team are finalising the Main Issues Report

(MIR) and supporting documents. All statutory documents will be

considered for approval and subsequent ratification at the SESplan Joint

Committee meeting on the 18th May 2015.” It goes on to state that: “The

MIR and all supporting documents will be available on the SESplan

website form the 11 May 2015. The official consultation via the SESplan

consultation portal will run for 8 weeks from 21 July 2015 until 15

September 2015.”

Emerging Midlothian Local Development Plan - from an informal

discussion with Officers in the Council’s planning policy team, they have

confirmed that a consultation exercise will take place between 14th May

and 26th June 2015.

5.2.3 A further material planning consideration is the overriding and demonstrable

‘need’ for the development which is set out in Chapter 4.0 of Planning

Statement (Contained within Part 3 of the Planning Application Document)

and summarised in Chapter 3.0 of this ES.

5.2.4 In combination, the statutory Development Plan and the identified material

considerations contain policies and guidance which seek to:

Control the use of land;

Protect the environment;

Give locational guidance for new development;

Facilitate sustainable development including sustainable waste

management; and

Encourage renewable energy development.

5.2.5 As such, they provide a framework against which development proposals

should be considered. In addition, in many instances, they provide the

planning basis for the scope of this EIA. Accordingly, the EIA findings have

been used to inform the assessment of the Proposed Development against

the identified planning context as set out in the PS.


6.0 TRAFFIC AND TRANSPORTATION

6.1 Introduction

6.1.1 This Chapter of the ES has been prepared to consider the traffic and transport

related environmental effects of the construction and operation of the

proposed Millerhill RERC development.

6.1.2 Detailed traffic and transport operational analysis work, including the

identification of development trip generation, a review of network safety

records and an audit of general site accessibility has been considered in a

supporting formal Transport Assessment (TA) document. The TA report has

been submitted separately as part of the Planning Application and has been

prepared in accordance with 2012 Transport Scotland (TS) document

“Transport Assessment Guidance” for the preparation of Transport

Assessment reports. The TA also makes reference to environmental

assessment criteria set out in Institution for Environmental Management &

Assessment (IEMA) document “Guidelines for the Environmental Assessment

of Road Traffic”, which represents the industry standard guidance that

underlies the traffic and transport analysis set out within this ES chapter.

6.1.3 The TA report also includes a Travel Plan Framework (Appendix TA6 to the

TA). This Travel Plan would act as an inherent mitigation measure in support

of the Millerhill RERC development to manage development traffic related

operational and environmental effects. The Travel Plan also identifies a range

of measures to maximise sustainable staff and visitor travel to the Millerhill

RERC development and the control and management of large goods vehicle

routing over the immediate local highway network to the proposal site.

Potential Impacts

6.1.4 Traffic and transport related environmental impacts for new road based

employment developments are typically associated with changes in traffic

demand, both in terms of the total number of development vehicles and the

type of vehicles generated (i.e. the proportion of larger HGV service vehicles).

Key impact types to be considered in traffic related environmental assessment

are as follows:


Changes in development traffic demand impacting on prevailing

highway safety conditions, accident risk and network congestion and

delay on key links in the immediate vicinity of the proposal site and

further a-field;

Changes in development traffic demand impacting on other local road

network users and the immediate community, resulting in a reduced

amenity (e.g. community severance, pedestrian delay / intimidation,

etc.);

Changes in development traffic demand resulting in noise and vibration

effects at surrounding / frontage properties to key access road corridors;

and,

Changes in development traffic demand and congestion resulting in

local air quality effects at key local network links and junctions.

6.1.5 Traffic and transport related environmental impacts also vary over the different

stages of the development lifetime. Typically a full assessment of transport

environmental impact considers the following:

Construction Traffic Impact – i.e. the extent of vehicle movements that

would take place to / from the main application site during the

construction phase. It should be noted that any environmental impacts

associated with construction related traffic demand are generally only

temporary in nature (occurring for the extent of the project build period

only) and are rarely constant over the full construction period. Typically

construction traffic impact can vary greatly in scale depending on the

main activities taking place on site on any particular day.

Operational Traffic Impact – i.e. the day to day transport impact of the

operation of the proposal site – associated with typical staff, visitor and

operational HGV demand.

Assessment Scope and Consultation

6.1.6 The scope and nature of the assessment considered with the TA and this ES

chapter reflect the extent of the highways and transport issues identified as

being of interest to Midlothian Council (Local Highway Authority) and officers

of Transport Scotland (Strategic Highway Network) – see Appendix TA1 to the

formal Transport Assessment report. Scoping consultation with officers


identified that the assessment of key highways and transport issues should be

concentrated on understanding future predicted development HGV and car

traffic demand levels over the immediate highway network and a comparison

to those traffic levels previously identified as being acceptable in relation to

similar recent waste management proposals at the site.

Relevant Planning History

6.1.7 The Millerhill RERC proposal site forms part of the Edinburgh and Midlothian

Zero Waste Contract ‘reference site’ and therefore already benefits from

Planning Permission in Principle (PPiP) for an integrated waste management

facility, including Mechanical Biological Treatment (MBT) and Energy from

Waste (EfW) processes - known as the Zero Waste Facility (ZWF). The site is

also identified for waste management land use within the strategic plan for the

Edinburgh and South East Scotland region.

6.1.8 The extant ZWF PPiP consent is considered to represent a material planning

consideration when reviewing highways and transport issues associated with

the Millerhill RERC proposals, as it establishes the principle of waste

management activities at the proposal site and a ‘fall-back’ threshold of

acceptable development related traffic demand. Formal highways and

transport submissions prepared to support the consented 230,000tpa ZWF

scheme (Feb 2011 Transport Assessment Report by Colin Buchanan &

Partners Ltd and parallel Traffic & Transport Chapter to the Environmental

Statement) identified the ZWF development traffic demand to be circa 400

vehicle movements per day (in + out), including of the order of 350 HGV

movements.

6.1.9 The supporting TA & ES reports for the ZWF scheme ultimately concluded

that such development traffic levels would result in only insignificant or

negligible impact on the operation of the surrounding road network and related

environmental conditions, as set out in paragraphs 13.12.3 and 13.12.4 of the

ZWF ES:

“The traffic assessments concluded that there would be short term

increases in traffic levels during the construction of the Proposed


Development. In accordance with the IEMA significance criteria, these

increases are judged to be insignificant.

The traffic generated during the operational phase of the development

would be minimal and would have a negligible effect on the traffic flows

associated with the strategic and local road network.”

6.1.10 These conclusions were reviewed and accepted by statutory highway

consultees, who raised no objections to the ZWF scheme on highways and

transport capacity or traffic related environmental grounds.

6.1.11 The above traffic estimates for the ZWF development and the related

assessment conclusions are therefore considered highly relevant to the

assessment of the impact of the Millerhill RERC proposals, as they effectively

establish a traffic generation ‘fall-back’ position for the Millerhill RERC

proposal site. In simple terms, the ZWF traffic estimates represent a threshold

level of traffic demand associated with waste management development at the

proposal site that has been tested and demonstrated as having no material

impact both in terms of network operational capacity issues and traffic related

environmental effects. Scoping discussions with representatives of the

relevant highway authorities have validated this position, with officers

confirming that future development traffic volumes below this previously

identified threshold level would be acceptable - as they would ultimately

represent a reduced level of traffic impact when compared to the current

consent, which itself has already been demonstrated as resulting in only

negligible traffic and transport related operational and environmental effects.

6.2 Assessment Modelling

6.2.1 In accordance with best practice, the assessment of traffic and transport

impacts has been undertaken in line with advice set out in the following

documents:

Guidelines for the Environmental Assessment of Road Traffic produced

by the Institute of Environmental Assessment (March 1993) (now

Institute of Environmental Management & Assessment (IEMA).

The Design Manual for Roads & Bridges, produced by the Department

for Transport (DfT);


Transport Assessment Guidance produced by Transport Scotland

(2012).

6.2.2 This guidance identifies that traffic and transport impact assessment can

generally be categorised as follows:

Operational Issues – i.e. does the network offer sufficient capacity to

accommodate development traffic movements and what improvements

might be required to ensure suitable future year operating conditions?

Environmental Issues – i.e. what are the environmental effects of

additional development related traffic movements and what mitigation

measures might be required in order to manage impacts to ensure that

they fall below appropriate thresholds?

6.2.3 This ES Chapter concentrates on the potential environmental effects of

transport movements, in terms of the impact of additional development related

traffic movements on local amenity and sensitive users / receptors, and the

extent of effects on key environmental criteria such as noise, air quality and

vibration.

6.2.4 IEMA guidelines have been used as the core reference document to inform

the environmental appraisal of development road traffic effects. This is the

same approach as adopted for the assessment of the consented ZWF

scheme - which as noted above, forms a key reference text for the

environmental analysis of the proposal site and identifies existing thresholds

for acceptable site related traffic demand.

6.2.5 The IEMA guidelines suggest the following general rules when considering the

initial ‘screening’ of traffic and transport related environmental impact and the

identification of when more detailed analysis of specific environmental effects

might be required:

“Rule 1: Include highway links where traffic flows will increase by more

than 30% (or the number of heavy goods vehicles will increase by more

than 30%).

Rule 2: Include any other specifically sensitive areas where traffic flows

have increased by 10% or more”


6.2.6 IEMA guidance notes that traffic forecasting is not an exact science and that it

is generally accepted that accuracies of greater than 10% are not achievable.

Day to day variation of traffic on a route corridor is frequently at least some +

or – 10% of data recorded on a single survey date. The IEMA guidelines

therefore suggest that, at a basic level, projected changes in total traffic of

less than 10% would create no discernible environmental impact.

6.2.7 With respect to Rule 1 (30% threshold), IEMA guidance notes that the most

discernible environmental impacts of road traffic are considered to be noise /

vibration, severance and pedestrian delay & intimidation. In terms of these

potential impacts, IEMA guidance states the following:

In general, people are unable to perceive a change in noise nuisance for

changes in noise levels of less than 3dB(A), such changes require a

“doubling or halving in the level of traffic”.

At low flows, increases in traffic of around 30% can double the delay

experienced by pedestrians attempting to cross a road.

Severance (community disruption) and intimidation are much more

sensitive to traffic flow and DfT suggest 30%, 60% and 90% changes in

traffic levels should be considered as ‘sight’, ‘moderate’ and ‘substantial’

impacts respectively.

6.2.8 Other environmental impacts (e.g. pollution, ecology, etc.) are considered to

be less sensitive to traffic flow changes. IEMA guidelines therefore

recommended that as a starting point a 30% change in traffic would represent

a reasonable threshold for identifying a potential need to undertake a more

detailed assessment of environmental conditions.

6.2.9 Where there are major changes in the composition of the traffic flow, the IEMA

guidance suggests that a lower percentage change threshold might be

appropriate and that the assessor should use their professional judgement as

to whether additional detailed assessment is required.

6.2.10 Guidance with respect to Rule 2 (10% threshold) IEMA guidance identifies

that the assessor should consider the inclusion of any other locations or

network links where a 10% change in traffic demand is predicted in specific

environmentally ‘sensitive’ areas. The IEMA guidelines suggest a ‘sensitive’


receptor could include accident blackspot locations, conservation areas,

hospitals, links with high pedestrian flows, etc.

6.2.11 IEMA guidance notes that it would not normally be appropriate to consider

links where total traffic flows have changed by less than 10%, unless there are

significant changes in the composition of traffic, e.g. an usually large increase

in the number of heavy goods vehicles. Ultimately the assessor is charged

with utilising professional judgement to determine whether further assessment

is necessary in such cases. This will also include the need to reflect the

‘cumulative’ effects of a combination of new development schemes against

background conditions.

6.2.12 In the case of the immediate study network to the Millerhill RERC site

(typically characterised by routes with only strictly limited levels of frontage

residential development or other potentially sensitive land uses) it is not

anticipated that the Rule 2 threshold would typically apply.

6.2.13 For clarity this ES Chapter has been prepared on the basis of the suggested

IEMA approach that a projected change in total traffic or HGV traffic levels of

less than the relevant IEMA screening thresholds (30% and 10%) on each

study link would not create a discernible traffic related environmental impact

and in such cases no further detailed assessment would be required.

Significance Criteria

6.2.14 The significance level attributed to traffic and transport related effects is based

on the magnitude of change expected to take place as a result of development

traffic levels, and the sensitivity of the affected receptor / receiving

environment to any changes.

6.2.15 The approach to the assessment of the significance of effects has been based

on the following definitions, which have been adapted from relevant guidance

notes and correspond to the significance criteria utilised in the reference ZWF

assessment.

Major / Substantial impact: where the proposed development could be

expected to have a substantive impact (either positive or negative),


resulting in a loss of resource and / or the quality and integrity of a resource

or location via a major impact on key characteristics, features or elements.

Moderate impact: where the proposed development could be expected to

have a noticeable impact (either positive or negative), resulting in a loss of

resource, but not adversely affecting the integrity (partial impact on key

characteristics, features or elements).

Slight impact: where the proposed development could be expected to

result in a small, barely noticeable impact (either positive or negative),

resulting in some measurable changes in attributes or one or more key

characteristics, features or elements

Negligible: where no discernible impact is expected as a result of the

proposed development.

6.2.16 Impacts classified as Major and / or Moderate are considered as being

potentially ‘significant’ in EIA terms. Typically changes in baseline traffic

demand of less than 30% as a result of development are not anticipated to

result in readily discernible traffic related environmental effects (i.e. they are

‘negligible’ in scale) and therefore, as noted above, a 30% change forms the

basis for the IEMA ‘screening threshold’ for the identification of potential more

significant effects.

6.3 Baseline Highway Network Conditions

Wider Network Connections

6.3.1 Wider network connections to the Millerhill RERC proposal site are provided

by Whitehill Road, which runs to the north of the site. This route is of circa

7.0m width at the currently under construction connection point to the Zero

Waste Parc but narrows to 5.5m in places and on the approach to the junction

at Redcroft Cottage. The route currently accommodates HGV traffic

associated with the Network Rail marshalling yard, which is accessed further

to the east along Whitehill Road, to the eastern side of the existing rail bridge.

6.3.2 Whilst Whitehill Road has historically served HGV traffic, the planning

application in support of the ZWF scheme proposed a range of local highway


improvements for the Whitehill Road corridor to support increased HGV

operation including:

Widening of Whitehill Road to 7.3m between the priority junction at

Redcroft Cottage and the junction of Whitehill Road / unnamed road to

The Wisp.

Widening of Whitehill Road to a minimum of 6.5m between the junction

of Whitehill Road / unnamed road to The Wisp and the access to the

Millerhill development area.

Alterations to the minor arm of the priority junction at Redcroft Cottage.

6.3.3 It is understood that these improvements are programmed to be delivered by

the Partner Councils prior to the opening of the Millerhill RERC.

6.3.4 Whitehill Road provides onward connections to the wider highway network via

the junction connection at Redcroft Cottage, which links to the looped

commercial estate road of Whitehill Road / Newcraighall Road, which in turn

eventually terminates to the north east at a roundabout with the A6095

Newcraighall Road (approximately 1200m travel distance from the Zero Waste

Parc access road connection to Whitehill Road). The A6095 Newcraighall

Road provides access to the Strategic Road Network via the nearby grade-

separated junction with the A1 Musselburgh Bypass and local connections to

Musselburgh to the east and Niddrie, Craigmillar and Cameron Toll to the

west.

Local Network Background Traffic Flows

6.3.5 2014 background traffic flow information for the immediate local highway

network to the Millerhill RERC proposal site was presented in support of the

ZWF planning application. Review of this background data demonstrates that

traffic flows on the immediate access road to the Zero Waste Parc (Whitehill

Road) are typically low, with total traffic demand at the Redcroft Cottage

junction (the connection to the main looped section of route) being of the order

of just 5,000 vehicles per day. Traffic flows on the main local distributor route

of the A6095 are at much busier levels, with daily flows at the key Whitehill

Road connections to Newcraighall Road at Fort Kinnaird being in excess of

25,000 vehicle movements per day.


Road Safety

6.3.6 An appraisal of the operational safety of the immediate local network to the

Millerhill RERC proposal site has been carried out through reference to

Personal Injury Accident (PIA) data for the most recently available standard

five year search period (January 2009 – December 2013 (inclusive)), with the

extent of the search area including the full length of Whitehill Road and

connections to the A1.

6.3.7 Review of the historical accident information for this five year period identifies

that only 12 accident incidents have been recorded within the search area,

with all of these accident events being of a slight severity classification. Only

three of the recorded accidents are noted to have taken place on the

immediate Whitehill Road / Newcraighall Road section of route that is

anticipated would accommodate all predicted development HGV movements.

None of these incidents involved HGV movements or pedestrian / cycle users.

6.3.8 The remaining recorded accident incidents within the study area took place at

the A6095 Fort Kinnaird Eastern Roundabout (2 accidents), A6095 / A1

western slip road junction (3 accidents), A6095 / A1 eastern slip road junction

(3 accidents). Given the significant traffic volumes experienced at these

junctions and the fact that the accident incidents recorded at the connections

to the A1 slip roads all took place either prior to or during recent local highway

improvement works, it is not considered that this review of accident issues

indicates any material highway safety / design concerns that would require

specific improvements to support the proposed Millerhill RERC development

over and above the committed package of local works. Indeed, it is worth

noting that highway safety issues were not previously raised as an issue of

concern by local highway stakeholders with regard to the consented ZWF

project, which was predicted to generate higher levels of operational HGV

levels when compared to the current Millerhill RERC scheme.

Sustainable Transport Connections and Site Accessibility

6.3.9 It is envisaged that the majority of regular staff / visitor movements to / from

the proposed Millerhill RERC development would likely access the site using

the private car. The site is located in an area which is generally quite remote


from large local centres of population and therefore provides only relatively

limited access by cycling and public transport. Given the generally low levels

of staff numbers anticipated to be based at the site, however, it is not

expected that the proposals would give rise to a significant demand for staff /

visitor private vehicle travel that could not be easily accommodated by the

local highway network.

Local Committed Development

6.3.10 For the purposes of the assessment of the network operational and traffic

related environmental effects of the Millerhill RERC development, it is

assumed that the following consented developments will have been

completed and are operational.

The AD Facility being constructed to the immediate north of the

Application Site.

The Borders Railway to the immediate north and west of the RERC site.

The Millerhill Development Area site access road and bridge over the

Borders Railway.

The consented Rail Rolling Stock Maintenance Depot to the north &

east of the RERC site.

The SNCD to the south and west of the RERC site (NB – this represents

a long term project which could take of the order of 20 years to

complete)

6.3.11 Further details of the highways and transport implications of these schemes is

summarised below.

6.3.12 Following approval of the ZWF scheme, Alauna Renewable Energy has

progressed a 30,000tpa capacity AD Facility at the Zero Waste Parc on the

site to the immediate north of the RERC proposal site, with this AD Facility

designed to serve the food waste portion of the Edinburgh & Midlothian Zero

Waste contract. Robust estimates of traffic demand associated with maximum

30,000tpa operation of the AD Facility have been calculated by Axis via a ‘first

principles’ trip generation exercise, based on experience of the operation of

similar AD facilities at other locations across the UK. This suggests daily traffic


estimates at circa 66 vehicle movements per day (in + out), including 46 HGV

movements.

6.3.13 It should be noted that this AD Facility is entirely separate from the Millerhill

RERC proposal (the RERC scheme seeks to expand on the principles of the

MBT and EfW elements of the ZWF scheme originally approved as part of the

January 2012 ZWF PPiP), however, cognisance of the traffic generation

implications of the consented AD Facility is important in understanding future

combined traffic levels predicted to be generated to the proposed waste

management facilities at Zero Waste Parc and any comparison to previously

consented ZWF traffic levels.

6.3.14 As part of the enabling works for the ZWF, planning consent (Ref:

12/00060/DPD) has also been granted for the formation of a new access road,

new bridge structure over the proposed ‘Borders Railway’ rail route and

junction connection to Whitehill Road. The access road is currently under

construction and will be fully delivered by Autumn 2015 to support the

commencement of operations at the consented AD Facility and will therefore

be available to serve future operations over the remainder of the Zero Waste

Parc, including the Millerhill RERC development. The road itself is not

predicted to generate any specific traffic movements or result in any diversion

/ re-assignment of existing traffic, but is to be delivered simply to support

future development at the Zero Waste Parc.

6.3.15 The adjacent rail freight yard site to the north east of the Millerhill RERC

proposal site, enjoys planning consent for the development of a rail depot for

the maintenance and cleaning of new trains associated with the electrification

of the Edinburgh rail network. The proposals have yet to be constructed. The

Transport Statement prepared to support this depot facility identified that

traffic flows for the proposed development would generally be related to staff

movements, with 80% of staff working an overnight (19:00-07:00) shift. The

majority of movements associated with the scheme can therefore be expected

to take place outside of the core weekday day-time periods and traditional AM

& PM network peak hours. In total the submitted TS report identified that the

consented Rolling Stock Depot development could generate of the order of

172 additional movements per day (in + out).


6.3.16 The SNCD is predicted to generate additional levels of traffic of up to 500

vehicle movements per hour at junctions on the A6095 through Fort Kinnaird

and onward towards the A1. In practice, such levels of traffic will take many

years to build up as a consequence of the phased nature of the Shawfair

development and its long-term development timetable, with traffic

programmed to be accommodated by a package of off-site highway

improvements. The short term network impacts of the initial phases of the

Shawfair scheme, (for example during the construction of the Millerhill RERC

and the it’s initial operating years), are anticipated to be negligible.

6.4 Assessment of RERC Operational Traffic Issues

Predicted RERC Operational Traffic Generation

6.4.1 Anticipated demand estimates for vehicle trip movements to / from the

proposed Millerhill RERC under maximum operation have been calculated

using a ‘first principles’ approach, based upon main plant operating

assumptions such as anticipated site waste input capacity, site operating /

delivery hours and anticipated vehicle input / export payloads. Core

information and operating assumptions have been provided by the site

operator, FCC Environment and the Edinburgh & Midlothian Zero Waste

Team based on relevant operational experience.

6.4.2 The Millerhill RERC proposals envisage delivery to the site of up to

195,000tpa waste / SRF inputs (including for circa 5,500tpa of rejects and

recyclables which will be subsequently extracted from the waste supply) and

additional process consumables such as lime, activated carbon, ammonia and

oil. The site would be road served in terms of both waste / consumables inputs

and the export of process (ash / pollution control) residues (estimated at circa

51,858tpa).

Table 6.1: Input and Export Materials

Input materials

Municipal Waste Contract Delivery 135,000tpa

Bulk Third Party SRF / Residual Waste Delivery 60,000tpa

Total Consumables (lime / ammonia / oil / carbon) 2,874tpa

Export materials


Recyclables from treated waste inputs 2,740tpa

Rejects from treated waste inputs 2,789tpa

Ash output 46,553tpa

Air Pollution Control Residues 5,305tpa

6.4.3 On the basis that no ‘backloading’ would be undertaken at the Millerhill RERC

development (i.e. HGV vehicles would operate full in one direction only, i.e.

arriving full and leaving empty, or vice versa), the maximum operation of the

RERC could be anticipated to generate of the order of 128 HGV movements

on an average day (64 arrivals / 64 departures), as illustrated in Table 6.2

below.

Table 6.2: Input and Export Material Arrivals and Departures

Arrivals Departures

Waste Inputs / Consumables: 53 53

Recyclables / Process Exports 11 11

6.4.4 Typically waste management plants do not experience substantive levels of

operational HGV demand during the traditional weekday AM & PM ‘rush hour’

periods – reflecting standard waste collection patterns operated by waste

authorities and commercial clients. Waste delivery demand would be spread

across the core weekday day-time delivery window (08:00-20:00).

6.4.5 In order to provide an indication of the likely HGV demand profile associated

with the Millerhill RERC development, reference has been taken to the waste

trip generation profile information submitted in support of the previous ZWF

consent, which was based on operational information supplied at that time by

the local waste collection authorities and operational experience of the export

of process waste materials. Application of the predicted average Millerhill

RERC total daily HGV demand to the trip profile information demonstrates that

site related HGV demand could be expected to be of the order of 18 vehicles

(9 in / 9 out) over the AM peak hour (08:00-09:00) & PM peak period (16:00-

18:00) traditional busy network periods. Such traffic demand is not considered

to represent a level that would typically be expected to result in a material

impact on local network operation.


Table 6.3: Predicted Millerhill RERC Operational HGV Traffic Demand

WCA Arr

WCA Dep

SRF Arr

SRF Dep

Export Arr

Export Dep

Total Arr

Total Dep

07:00-08:00 0 0 0 0 0 0 0 0

08:00-09:00 8 8 1 1 0 0 9 9

09:00-10:00 4 4 1 1 1 1 6 6

10:00-12:00 1 1 2 2 3 3 6 6

12:00-14:00 12 12 2 2 3 3 16 16

14:00-16:00 6 6 2 2 3 3 10 10

16:00-18:00 7 7 1 1 1 1 9 9

18:00-19:00 0 0 1 1 0 0 1 1

19:00-20:00 7 7 1 1 0 0 7 7

07:00-19:00 37 37 9 9 11 11 57 57

08:00-20:00 44 44 10 10 11 11 64 64

24hrs 44 44 10 10 11 11 64 64

HGVs - (Values rounded for presentation)

6.4.6 The proposed Millerhill RERC development is anticipated to require input from

up to 30 staff members over a typical weekday 24 hour period. Given the 24 /

7 nature of the Proposed Development. However, it is anticipated that the site

would be operated on a shift system, with a maximum of 22 staff members

being on site at any one time (during shift change periods). In addition, the site

will also generate some technical visitor trips as well as occasional organised

group educational visits. It is predicted that the Millerhil RERC could ultimately

result in staff / visitor car trip demand of the order of 60 vehicles (27in + 33out)

across the core weekday day-time period 07:00-19:00. Typically trip demand

during traditional AM & PM network peak periods is not anticipated to be

significant (less than 13 car trip movements over 2 hours) with maximum staff

/ visitor demand anticipated to take place for early afternoon period of 12:00-

14:00, when of the order of 25 vehicle trips are predicted (13in + 12out) –

associated with the early afternoon main shift changes.


Table 6.4: Predicted Millerhill RERC Staff & Visitor Traffic Demand

Time Arrivals Departures

07:00-08:00 6 -

08:00-09:00 2 -

09:00-10:00 2 2

10:00-12:00 4 4

12:00-14:00 13 12

14:00-16:00 4 5

16:00-18:00 2 10

18:00-19:00 - -

19:00-20:00 - -

07:00-19:00 33 33

08:00-20:00 27 33

24hr 50 50

All vehicles (Values rounded for presentation)

6.4.7 Summation of the staff / visitor car trip demand levels to the predicted

operational HGV traffic levels suggests a total daily Millerhill RERC vehicular

demand to the Millerhill site of 214 vehicle movements (in + out).

Table 6.5: HGV Deliveries and Staff / Visitor Movements

Arrivals Departures

HGV Deliveries (Imports / Exports) 64 64

Staff / Visitor Movements 50 50

6.4.8 Maximum weekday vehicular demand to / from the proposal site is proposed

to take place for the hour of 12:00-14:00 - when a total of 56 / 58 vehicle

movements (in + out) could be expected to be generated by the Millerhill

RERC on an average operational day. Such demand levels represent

significantly less than 1 development vehicle movement per minute.


Table 6.6: Predicted Total Millerhill RERC Operational Traffic Demand

Time (Hour Start) Staff / Visitor

Demand HGV

Demand

Total

Vehicles

07:00-08:00 6 0 6

08:00-09:00 2 18 20

09:00-10:00 4 11 15

10:00-12:00 8 12 20

12:00-14:00 25 32 57

14:00-16:00 9 20 29

16:00-18:00 12 19 31

18:00-19:00 0 1 1

19:00-20:00 0 15 15

07:00-19:00 66 114 180

08:00-20:00 60 128 188

24hr 100 128 228

Vehicle trips: in + out (Values rounded for presentation)

Millerhill RERC Operational Traffic Impact Assessment: Comparison to

the Extant PPiP Development Consent

6.4.9 As set out in Chapter 1.0, the proposal site already benefits from planning

consent for integrated waste management development (the ZWF project),

which was anticipated to generate of the order of 400 vehicle movements per

day (in + out), including 352 HGV movements. The formal TA & ES

assessments prepared to support the ZWF scheme established that such

levels of traffic would only give rise to negligible network operational or traffic

and transport related environmental effects. It therefore follows that

development traffic levels below these established thresholds would represent

a further reduced level of traffic impact.

6.4.10 A comparison of the difference in total traffic generation levels between the

delivery of the extant ZWF consent and the predicted combined total traffic

demand associated with the Millerhill RERC proposals and the adjacent

under-construction AD Facility (effectively the replacement facilities to the

consented ZWF project) demonstrates that that the current proposals would

give rise to a reduced level of daily traffic volume. Over the course of a typical

day, for example, the combined Millerhill RERC & AD projects would result in


some 106 less vehicle movements (in + out) than the consented ZWF scheme

(see Table 6.4 below).

Table 6.7: Comparison of Predicted Total Daily Millerhill RERC & AD

Traffic to Consented ZWF PPiP Demand Levels

Trip Demand Arrivals Departures Total

Current Proposals

AD Scheme 33 33 66

RERC 114 114 228

Total Traffic 147 147 294

Consented Facility

ZWF Scheme 200 200 400

Net Change -53 -53 -106

All vehicles (Values rounded for presentation)

6.4.11 A similar comparison exercise for HGV traffic levels demonstrates that

anticipated combined daily HGV traffic levels for the Millerhill RERC proposals

and consented AD scheme would be significantly lower than those associated

with the permitted ZWF development. Over the course of an average day, it is

anticipated that the delivery of the Millerhill RERC scheme in combination with

the consented AD Facility would result in of the order of 178 fewer HGV

movements over the local network when compared to the currently permitted

ZWF scheme.

Table 6.8: Comparison of Predicted Total Millerhill RERC & AD HGV

Demand to Consented ZWF HGV Estimates

Trip Demand Arrivals Departures Total

Current Proposals

AD Scheme 23 23 46

RERC 64 64 108

Total Traffic 87 87 174

Consented Facility

ZWF Scheme 176 176 352

Net Change -89 -89 -178

HGVs (Values rounded for presentation)

6.4.12 It is therefore clear that the combined operation of the Millerhill RERC and the

currently under-construction AD Facility would result in substantially less


development related traffic demand (both in terms of overall vehicle numbers

and, importantly, HGV trips), when compared to the consented ZWF scheme.

Given that ZWF predicted traffic levels have already been demonstrated as

being expected to result in only a negligible level of traffic and transport

related impact, there can be a high degree of confidence that the day-to-day

operation of the Millerhill RERC scheme would also not give rise to material

traffic related operational or environmental effects. Indeed delivery of the

current proposals would result in an overall ‘net benefit’ in traffic and transport

impact terms when compared against the current reference planning position.

6.4.13 Given the above analysis it is therefore concluded that the traffic and transport

related environmental effects of the day to day operation of the Millerhill

RERC development would be negligible.

RERC Operational Traffic Management & Mitigation

6.4.14 Whilst operation of the Millerhill RERC development is anticipated to result in

only negligible traffic and transport related effects, it is still proposed that a

number of traffic related management / mitigation measures are adopted. For

example, it is proposed that operational (HGV) traffic movements to / from the

site would be encouraged to observe appropriate local route corridors. This

routing strategy would seek to restrict operational HGV traffic to those roads

suitable to accommodate regular large service vehicle movements and would

ensure that no operational vehicle trips take place on immediate local rural

routes to the west of Whitehill Road through Shawfair. Such inappropriate

local rural routes are already signed as being unsuitable for HGV access.

6.4.15 In practice it is anticipated that the majority of Millerhill RERC related HGV

delivery traffic would seek to access the site via the A6095 Newcraighall Road

and onward strategic road network connections to / from the A1. Some local

RCV collection traffic may, however, use Newcraighall Road further to the

east to serve Musselburgh or Niddrie Mains Road to the west to give access

to Niddrie, Craigmillar & Duddingston.

6.4.16 Local route enforcement of waste delivery / export vehicles serving the

Millerhill RERC would be delivered via the following measures:


All delivery drivers to be provided with suitable route plan mapping

before beginning a delivery run to the Millerhill RERC site;

Suitable signing strategy on immediate links and key junctions;

A clear disciplinary procedure for drivers to discourage the use of

inappropriate local routes.

6.4.17 Such arrangements would be controlled and managed as part of the Site

Travel Plan. A copy of an Interim Travel Plan document is included as

Appendix TA6 to the formal Transport Assessment report.

6.5 Assessment of Development Construction Traffic Issues

Predicted Millerhill RERC Construction Traffic Demand

6.5.1 Development construction would be phased in order to minimise development

construction traffic demand on the local highway network. This will ensure

that, even during peak construction periods, construction HGV traffic demand

will not exceed those levels associated with the ultimate operation of the

Millerhill RERC site post opening of the facility.

6.5.2 Maximum construction related HGV demand is anticipated to take place

during the initial earthworks / delivery of building structural supplied phase of

construction, with a secondary peak in demand occurring during final ‘hot

testing’ / commissioning of the Millerhill RERC immediately prior to formal

opening.

6.5.3 Construction staffing levels are anticipated to be at their highest levels during

the core building fit out & installation period, involving a high number of

technical staff required for the delivery of specialist equipment. Fit out and

process installation could be expected to take place over an approximate 13

month period, with staffing levels of over 100 workers undertaking E&I tasks

for over 9 months of that period, in parallel to other building structural and

building service workers.

6.5.4 Ultimately maximum combined construction staff traffic demand is anticipated

to take place at the peak of the fit out & installation phase (288 staff based on


site in Month 17). Such staffing levels could be expected to generate circa 145

– 190 staff vehicle movements per day based on typical construction staff

vehicle occupancy rates of 1.5 – 2 staff per vehicle. Such staff travel demand

would be accommodated by the proposed on-site parking arrangements and

supporting travel management initiatives. Construction HGV demand during

such peak construction staff periods are likely to be at generally lower levels

(circa 25 HGV deliveries per day (50 movements (in + out)).

Assessment of Millerhill RERC Construction Traffic Impact

6.5.5 The peak construction traffic levels identified for the Millerhill RERC scheme

are noted to be slightly higher than the preliminary estimates previously

considered in relation to the delivery of the consented ZWF project. Given this

potential for a higher level of short term trip movements, an appraisal of the

effects of the predicted Millerhill RERC peak construction traffic volumes has

been undertaken via reference to IEMA Rule 1 (30% increase in traffic) and

Rule 2 (10% increase in traffic) thresholds.

6.5.6 Table 6.6 over the page sets out anticipated ‘worst case’ peak construction

traffic volumes (Month 17: 288 staff and 24 HGV arrivals) on key local routes

to the proposal site when compared to 2016 baseline traffic estimates. These

2016 baseline estimates have been calculated by:

Growthing of the 2014 background network traffic estimates set out in

the ZWF traffic submissions, to a 2016 assessment year using

estimates for the Midlothian area as taken from STEP (3.8%).

The addition of the predicted additional operational traffic movements

associated with the adjacent Rail Rolling Stock Depot (172 movements

per day, in+out), assigned to the highway network on a similar basis to

the general routing proportions set out in para 6.5.7 below.

The addition of traffic flows associated with the operation of the adjacent

AD Facility (20 staff movements, 46 HGV movements per day (in + out))

- due to begin operations in late 2015. HGV deliveries have been

assigned 80% east / 20% west along A6095 Newcraighall Road, with

staff traffic movements on the basis of the routing proportions set out in

para 6.5.7.

NB - No additional traffic flows have been included in the 2016 baseline estimates in relation to the adjacent Shawfair development area, as it has been assumed that this scheme would only


be at a very preliminary stage of development for the 2016 assessment year and therefore any local network traffic effects to the Millerhill RERC site would be of a strictly limited nature.

6.5.7 Millerhill RERC construction traffic estimates have been calculated on the

robust staff vehicle occupancy rate 1.5 staff per car and via reference to the

following construction traffic route assignment proportions:

Construction Staff Traffic (ZWF construction staff local route assignment):

30% west on A6095 to Niddrie and West Edinburgh

10% east on A6095 and then north via the A1

60% east on A6095 and then south via the A1 to A720 Edinburgh

Bypass.

Construction HGV Traffic:

100% via A6095 east to the A1.

Table 6.9: Assessment of Peak Millerhill RERC Construction Traffic Impact over

the Immediate Highway Network to the Zero Waste Parc

Junction

2016

24hr AADT

2016 AADT +

Rail Depot

2016 AADT

+ AD Facility

BASELINE

RERC Constructi

on

%’tage Change

vs Baseline

A6095 Newcraighall Rd / The Wisp

42240

(1745)

42291

(1745)

42306

(1754)

115

(0)

0.27%

(-)

Fort Kinnaird Main Western R’bout

27814

(590)

27865

(590)

27880

(599)

115

(0)

0.41%

(-)

Fort Kinnaird Main Eastern R’bout

29070

(650)

29191

(652)

29253

(698)

317

(48)

1.08% (6.88%)

Whitehill Road / Redcroft Cottage Jnt

5144

(104)

5316

(106)

5382

(152)

432

(48)

8.03%

(31.6%)

A1 Interchange Western Jnt

32940

(2337)

33061

(2339)

33123

(2385)

317

(48)

0.96%

(2.01%)

All Traffic (HGVs)

6.5.8 This assessment of construction traffic effects demonstrates that anticipated

‘worst case’ peak Millerhill RERC construction traffic volumes on key local

routes to the proposal site would not result in an increase in 24hr baseline

total traffic volumes in excess of critical 10% thresholds, with impact on the

main A6095 Newcraighall Road being predicted to be circa 1% or less.


6.5.9 A similar conclusion can also be drawn for predicted changes in local HGV

volumes, with all local links bar the immediate site access road of Whitehill

Road demonstrating changes in HGV demand of less than 7% of baseline

levels. As identified in sub-section 6.2 above, IEMA guidelines state that, at a

basic level, changes in traffic of less than 10% create no discernible impact.

6.5.10 Given that predicted construction traffic volumes over the network would

typically be less than appropriate assessment thresholds and that HGV

volumes on Whitehall Road would be less than predicted operational HGV

levels associated with average day-to-day operation of the Millerhill RERC site

– levels which have already been established as only likely to give rise to a

negligible traffic effects (see sub-section 6.4 above) - it can only be concluded

that Millerhill RERC construction traffic volumes would not give rise to any

material network operational or traffic related environmental impacts.

6.5.11 Based on the above review, it is ultimately concluded that the traffic related

environmental effects of construction of the Millerhill RERC development

would be negligible.

Millerhill RERC Construction Traffic Management & Mitigation

6.5.12 FCC Environment recognise that the delivery of the Millerhill RERC

development would represent a major construction project in the local area

and that it is therefore important that that any disturbance to the local

community be minimised during the construction period. To this end it is

proposed that a Construction Traffic Management Plan (CTMP) would be

prepared, to ensure that the best available techniques necessary to manage /

mitigate adverse effects would be adopted. It is anticipated that the CTMP

would encompass issues such as construction operating hours & vehicle

delivery hours, on-site construction vehicle parking & manoeuvring, staff travel

management initiatives, off-site construction vehicle routing, management of

abnormal load access, local signage strategy and construction noise & dust

management.

6.5.13 The CTMP would seek to ensure that all construction HGV related traffic on

the local network is routed to / from the site via Whitehill Road and

Newcraighall Road to the east to connect to the A1 and onward links to the


A720 Edinburgh City Bypass. This proposed haulage route is considered

suitable to accommodate construction HGV movements and is consistent with

the routing strategy currently used by HGV traffic travelling to / from the

adjacent Network Rail facility, the consented AD Facility and ultimately

proposed to serve the operation of the Millerhill RERC. The use of such a

haulage route would minimise impact on key local residential areas such as

Niddrie, Craigmillar, Danderhall & Duddingston.

6.5.14 Construction traffic routing would be supported by a suitable temporary

construction traffic / HGV signage strategy to / from the A1 which would be

implemented in parallel to driver education and enforcement practices. The

CTMP would further manage local conditions on the immediate haulage route

through the implementation of supporting dust suppression and road / vehicle

cleansing arrangements.

6.6 Additional Mitigation Measures

6.6.1 Given the review of anticipated future operational highway conditions and

reference to appropriate guideline standards, it is concluded that the Millerhill

RERC development would not result in a material impact on operational or

environmental conditions over the local highway network. There is therefore

no requirement for additional off-site highway improvement / mitigation works

over and above those already programmed to be delivered by the Partner

Councils in relation to the Zero Waste Parc.

6.6.2 As noted above, a number of operational measures are proposed to assist in

managing development traffic demand and restricting the time periods and

haulage routes associated with key operational HGV movements. Ultimately it

is anticipated that such management measures would be secured and

controlled by planning condition / legal agreement in line with good practice.

Should such controls be implemented and enforced appropriately, it is not

anticipated that the proposal scheme would operate with any material residual

traffic related environmental effects.


6.7 Impact Summary

6.7.1 The assessment of the transport related environmental effects of the Millerhill

RERC development has established that the proposal scheme would not give

rise to unacceptable network operational or traffic related environmental

effects. The proposed development is to be located on a site that has been

identified as being suitable for waste management use within the strategic

plan for the Edinburgh and South East Scotland region and already benefits

from an existing consent for an integrated waste management facility.

Millerhill RERC Operational Traffic Effects

6.7.2 The traffic levels associated with the extant waste management consent

(ZWF) have established an acceptable threshold for traffic volumes

associated with development at the proposal site, below which traffic demand

has been demonstrated via formal environmental assessment as not likely to

give rise to discernible network operational or traffic related environmental

concerns.

6.7.3 The combined operation of the Millerhill RERC and the currently under-

construction AD Facility would result in substantially less development related

traffic demand (both in terms of overall vehicle numbers and, importantly,

HGV trips), when compared to the consented ZWF scheme. There can

therefore be a high degree of confidence that the day-to-day operation of the

Millerhill RERC development would also not give rise to material traffic related

operational or environmental effects. Indeed delivery of the current Millerhill

RERC proposals would result in an overall ‘net benefit’ in traffic and transport

effects when compared against the current reference planning position. Given

the above analysis it is concluded that the traffic related environmental effects

of the day to day operation of the Millerhill RERC development would be

negligible.

Millerhill RERC Construction Traffic Effects

6.7.4 Construction of the Millerhill RERC would not generate a material level of

HGV demand. None of the construction phases are anticipated to generate

HGV levels in excess of those associated with the day to day operation of the


Millerhill RERC or indeed, those HGV thresholds already established as being

acceptable with respect to previously consented development.

6.7.5 Maximum construction periods could result in the requirement for up to 288

staff to be based at the site, to be accommodated by appropriate on site

parking areas and supporting travel management initiatives. Such peak staff

demand levels would not be experienced across the full extent of the

construction programme, being typically related to the building fit out /

installation phases. Indeed, construction staffing levels of over 200 workers

are only anticipated to occur for approximately a quarter of the construction

programme. Furthermore, during intensive staff demand periods, HGV

construction traffic would be at typically low levels (circa 20-30 HGV arrivals

per day).

6.7.6 Such combined peak daily construction traffic demand including for maximum

predicted staffing levels has been demonstrated as falling well within industry

standard screening thresholds for the assessment of operational and traffic

related environmental effects. It can therefore only be concluded that the

traffic and transport related environmental effects of construction of the

Millerhill RERC development would be negligible.


7.0 LANDSCAPE AND VISUAL EFFECTS

7.1 Introduction

7.1.1 This Landscape and Visual Impact Assessment (LVIA) has been prepared in

relation to the Proposed Development. The assessment was undertaken by a

Chartered Member of the Landscape Institute (CMLI). The LVIA follows best

practice guidance set out in Guidelines for Landscape and Visual Impact

Assessment (3rd edition 2013, Landscape Institute and Institute of

Environmental Management and Assessment).

7.1.2 Landscape and visual effects are separate, although closely related and

interlinked issues. As such, the assessments of the effects of the Proposed

Development upon the landscape and upon visual amenity have been carried

out separately and are described under separate headings below.

7.1.3 The assessment of landscape effects considers the potential effects of a

development on the landscape as an environmental resource. Landscape

effects are caused by physical changes to the landscape, which may result in

changes to the distinctive character of that landscape and how it is perceived.

7.1.4 A visual assessment is concerned with the potential effects that may occur

resulting from a development, upon the population likely to be affected. It

assesses the change in visual amenity undergone by specific receptors that

would arise from any change in the nature of views experienced.

7.1.5 The LVIA aims to establish the following:

A clear understanding of the Application Site and its context, in respect

of the physical and perceived landscape and in respect of views and

visual amenity;

An understanding of the Proposed Development in terms of how this

would relate to the existing landscape and views;

An identification of the likely significant effects of the Proposed

Development upon the landscape and upon views, throughout the life-

cycle of the development;


Potential for mitigation to reduce/eliminate any potential adverse effect

on the landscape or views arising as a result of the Proposed

Development; and

A conclusion as to the residual likely significant effects of the Proposed

Development.

7.1.6 The process follows a standard approach, namely:

The establishment of the baseline conditions, against which the effects

of the Proposed Development will be assessed;

The determination of the nature of the receptor likely to be affected, i.e.

its sensitivity;

The prediction of the nature of the effect likely to occur, i.e. the

magnitude of change; and

An assessment of whether a likely significant effect would occur upon

any receptor, by considering the predicted magnitude of change

together with the sensitivity of the receptor, taking into account any

proposed mitigation measures

7.1.7 Further details on the specific methodologies of assessment and

determination of significance are included in Appendix 7-1. The LVIA has

been informed by both desk and field-based studies.

7.1.8 It should be noted that the landscape (including the context in which views are

experienced) is dynamic, i.e. it is affected by social, economic, technological

and climatic changes, all of which can influence patterns of land use, land

cover and land management. As such, the baseline context for the LVIA is not

static.

7.1.9 Cumulative effects are addressed in Chapter 15.0 of the ES. The landscape

and visual effects of the proposed grid connection are set out in Chapter 16.0

of the ES. The assessment of effects upon the setting of cultural heritage

assets is set out in Chapter 13.0 of the ES.


Previous Assessment

7.1.10 As discussed in Chapter 1.0 of the ES, the Application Site benefits from PPiP

(granted in 2012) for the Zero Waste Facility, comprising:

An Energy from Waste (EfW) facility;

An Anaerobic Digestion (AD) facility; and

A Mechanical and Biological Treatment (MBT) facility.

7.1.11 A LVIA was carried out for the Zero Waste Facility at the Application Site. In

order to address AMSC associated with the Zero Waste Facility, a further

LVIA was prepared in respect of the AD Facility, located immediately north of

the Proposed Development site. Planning permission for the AD Facility was

granted in June 2013, and construction was on-going at the time of writing.

7.1.12 The Proposed Development would be implemented instead of the consented

EfW and MBT facilities. Given the greater height of some of the proposed

elements, landscape and visual effects are likely to be different to those

assessed for the Zero Waste Facility and hence the current LVIA is required.

As stated in Chapter 1.0, it is for these reasons that a detailed planning

application will be submitted to MLC, rather than an application for AMSC.

Description of the Proposed Development

7.1.13 A detailed description of the Proposed Development is set out Chapter 4.0 of

the ES. Key aspects of the development that are of relevance to this LVIA

include:

EfW facility with maximum roof height (boiler house) 41.6m;

Exhaust stack of height 75m;

Associated ancillary infrastructure;

Lighting; and

Landscape proposals.

7.1.14 Table 7.1 summarises the key differences in height between the Proposed

Development and the consented Zero Waste Facility and also, for

completeness, includes details of the AD Facility (currently under

construction).


Table 7.1: Comparison of Developments

Zero Waste EfW / MBT facility (consented)

AD Facility (under construction)

Proposed Development

Stack Height 65m 20m 75m

Roof Height (tallest building 20m 17.3m 41.6m

Legislative and Policy Context

7.1.15 Full details of the planning and policy background for the proposal, including

an appraisal of effects on relevant landscape-related policies, as set out in the

adopted statutory Development Plan, are included in the PS which forms Part

3 of the PAD. Key legislation and policies relevant to the LVIA are

summarised below.

European Landscape Convention

7.1.16 The UK Government is a signatory of the European Landscape Convention

(ELC), which became binding in March 2007. The ELC is aimed at the

protection, management and planning of all landscapes and raising

awareness of the value of a living landscape. It relates chiefly to public bodies

and to the policies, plans and programmes produced by these.

7.1.17 Article 6C of the ELC sets the following requirement:

“Identification and assessment

1. With the active participation of the interested parties, as stipulated in

Article 5.c, and with a view to improving knowledge of its landscapes,

each Party undertakes:

(a) To identify its own landscapes throughout its territory;

(b) To analyse their characteristics and the forces and pressures

transforming them;

(c) To take note of changes; and

(d) To assess the landscapes thus identified, taking into account the

particular values assigned to them by the interested parties and

the population concerned.

2. These identification and assessment procedures shall be guided by the

exchanges of experience and methodology, organised between the

Parties at European level pursuant to Article 8.”


7.1.18 Article 8 of the ELC requires that:

“The Parties undertake to co-operate in order to enhance the effectiveness of

measures taken under other articles of this Convention, and in particular:

a. To render each other technical and scientific assistance in landscape

matters through the pooling and exchange of experience, and the

results of research projects;

b. To promote the exchange of landscape specialists in particular for

training and information purposes;

c. To exchange information on all matters covered by the provisions of the

Convention.”

7.1.19 The LVIA is a development specific process which accords with Article 6C.

The LVIA is informed by extant Landscape Character Assessment (LCA)

studies (described in sub-section 7.3 below), which more directly relate to the

provisions of Article 6C.

Planning Policy

National

7.1.20 National planning policy applicable across the whole of Scotland is set out in

SPP (2014). Policies of direct relevance to this LVIA include:

“The planning system should: Facilitate positive change, while

maintaining and enhancing distinctive landscape character…”

(Paragraph 194)

“The siting and design of development should take account of local

landscape character. Development management decisions should take

account of potential effects on landscapes and the natural and water

environment, including cumulative effects. Developers should also seek

to minimise adverse impacts through careful planning and design,

considering the services that the natural environment is providing and

maximising the potential for enhancement.” (Paragraph 202)


Strategic Development Plan

7.1.21 The adopted Strategic Development Plan (2013) sets out strategic policies for

south-east Scotland. Whilst there are a range of policies set out in the

document, none of them have direct relevance to this LVIA.

Midlothian Local Plan

7.1.22 The adopted Midlothian Local Plan (2008) includes policies that are of direct

relevance to this LVIA, as follows:

Policy RP5: Woodland, Trees and Hedges, states: “Development will not

be permitted where it could lead directly or indirectly to the loss of, or

damage to, woodland, groups of trees, individual trees (including areas

covered by a Tree Preservation Order, areas defined as ancient and

semi-natural woodland, or areas forming part of any designated

landscape) and hedges which have particular amenity, nature

conservation, biodiversity, recreation, landscape character, shelter or

other importance…Where an exception to this policy is agreed, any

trees lost will be replaced with equivalent.”

Policy RP7: Landscape Character, states: “Development will not be

permitted where it may adversely affect the quality of the local

landscape. Where development is acceptable, it will respect the local

landscape character and contribute towards its maintenance and

enhancement. New development will incorporate proposals to:

o Maintain the local diversity and distinctiveness of landscape

character including natural and built heritage features of landscape

value such as woodland, hedges, ponds, stone walls and historical

sites; and

o Enhance landscape characteristics where they have been

weakened and need improvement and create new landscapes

where there are few existing features.”

Policy IMP1 New Development’ states: “Planning conditions will be

applied and, where appropriate, legal agreements sought to ensure that,

where new development gives rise to a need, appropriate provision is

made for: (D) landscaping, including its management for the longer


term, and the retention of open spaces and amenity spaces.”

7.1.23 Additionally, Policy DP2 Development Guidelines sets out detailed guidance in

respect of landscape proposals.

7.2 Methodology

7.2.1 This Section outlines the methodology used for the LVIA. It provides details of

the professional guidance that has been considered when undertaking the

LVIA. The full methodology can be found in Appendix 7-1.

Current Guidance

7.2.2 This LVIA has been based on the published best practice guidelines set out in

Guidelines for Landscape and Visual Impact Assessment (3rd edition 2013,

Landscape Institute and IEMA).

7.2.3 Reference has also been made to the following additional guidance

documents when carrying out the LVIA:

Swanwick C (2002) Landscape Character Assessment - Guidelines for

England and Scotland Countryside Agency / Scottish Natural Heritage;

The Countryside Agency / SNH (2004) Topic Paper 6: Techniques and

Criteria for Judging Capacity and Sensitivity; and

Landscape Institute (2011) Photography and photomontage in

landscape and visual impact assessment. Landscape Institute Advice

Note 01/11.

The Study Area

7.2.4 It is considered that, based upon previous experience of similar

developments, if any significant landscape and visual effects are to be

experienced, they would arise at relatively closer distances to the Proposed

Development, most likely within approximately 2.5km. Whilst elements of the

Proposed Development would potentially be visible at longer-range, it is

considered highly unlikely that this would give rise to significant effects upon

either the landscape or upon views. An additional 2.5km radius has been


included to act as a buffer which captures potential longer-range effects from

sensitive receptors, giving an overall study area of approximately 5km radius.

Significance of Effect

7.2.5 The purpose of EIA is to determine the likely significant effects of a

development proposal. Not all landscape and visual effects arising as a result

of a particular proposal will be significant. Furthermore, where likely significant

effects are predicted, this does not automatically mean that such effects are

unacceptable. The acceptability of landscape and visual effects is a matter to

be weighed in the planning balance alongside other factors. What is important

is that the likely effects of any proposal are transparently assessed and

described in order that the relevant determining authority can bring a balanced

and well-informed judgement to bear as part of the decision-making process.

Refer to Appendix 7-1 for further details.

Consultation

7.2.6 As part of the iterative design process, FCC (including the project architect

and project landscape architect) attended a series of Architecture and Design

Scotland (A&DS) Design Forum Workshops. As a result of this process, there

has been an increase in the area of the Application Site that would be open for

permanent public access. This has been achieved through alteration of the

secure boundary treatment (a requirement of the waste management licence)

such that it is located closer to the operational area. A public access through

the site has also been introduced.

7.2.7 Provisional viewpoint locations for inclusion in the LVIA were forwarded to

MLC, SNH, East Lothian Council and ECC for comment. Further locations

were suggested by consultees. Following the consultation process, final

viewpoint locations were agreed with MLC’s Landscape Officer (refer to

Appendix 7-2 for details of the viewpoint selection process).


7.3 Baseline

Baseline Data Collection

7.3.1 Baseline data for the LVIA has been gathered using both desk and field based

surveys. These have included review of extant landscape character

assessment studies (see below) and site visits to gain an understanding of the

landscape and visual context of the Application Site.

Baseline Conditions

Development under Construction

7.3.2 As mentioned in Chapters 1.0 and 2.0, a series of developments are currently

under construction in the vicinity of the Application Site. These principally

comprise:

AD Facility (as discussed earlier in this Chapter):

o Maximum roof height 17.3m; and

o Exhaust stack of height 20m.

Borders Railway:

o A new railway line to the west of the Application Site (and

associated over bridges); and

o A new station.

SNCD:

o Residential neighbourhoods;

o Town centre;

o Industrial estate;

o Business park / biomedical hub; and

o Structural landscaping, including public parks.

7.3.3 As construction work is underway, the presence of these three developments

in their completed state forms part of the baseline for the LVIA. This approach

has been agreed, for the ES as a whole, with MLC (refer to Chapter 2.0 for

further details).


The Application Site and its Surroundings

7.3.4 The Application Site is located within the former Millerhill Marshalling Yards,

between an operational Marshalling Yard to the east and land associated with

the former Monktonhall Colliery to the west. Woodland cover has developed

across much of the Application Site via natural regeneration over the period

since the active use of the Application Site as part of the railway network

ceased, approximately 20 – 25 years ago. A strip of this woodland located

towards the western boundary of the Application Site has been removed to

accommodate construction access to the adjacent AD Facility (immediately to

the north) and to accommodate construction compounds for the new Borders

Railway (to the west).

7.3.5 The Application Site is set within the Edinburgh urban fringe, where a mix of

different land uses is present, including agriculture, industry, residential and

major transport corridors. Much of the undeveloped area lies within the Green

Belt, although the Application Site lies outside this planning designation.

Significant change is underway in the surrounding area, with the AD Facility

immediately to the north, and the SNCD and Borders Railway to the west,

which are under construction at the time of writing and are included in the

baseline for this assessment. Additionally, other nearby areas of land are

allocated for development in the new Local Plan. Refer to Figure 2.3 for

indicative locations of development sites.

7.3.6 Established settlements are present in the vicinity of the Application Site at

Newcraighall (circa 970m to the north), Old Craighall (circa 960m to the east),

Easter Millerhill (circa 960m to the south), Newton Village (circa 950m to the

south-west) and Harelaw (circa 670m to the south). Farm properties at

Shawfair (circa 350m to the west) and Whitehill Mains (circa 470m to the

north) are located closer to the Application Site.

7.3.7 Larger residential communities are located at Danderhall (circa 1.5km to the

south-west), Niddrie (circa 1.6km to the north-west), Brunstane (circa 1.3km to

the north) and Musselburgh (circa 1.2km to the north-east). Dalkeith is

located circa 2.7km to the south. The centre of Edinburgh is circa 6.75km to

the west.


7.3.8 The A1 dual carriageway runs east-west approximately 575m north of the

Application Site. National Cycle Route 1 is located north of the A1, linking

Edinburgh with Musselburgh. The A720 Edinburgh bypass runs north-south

(joining the A1) approximately 1.2km east of the Application Site. A large retail

development is located south of the A1 at Fort Kinnaird, approximately 1km

north-west of the Application Site.

7.3.9 The landform of the area surrounding the Application Site is undulating and

subject to local variations, including changes associated with former mining

activity, but elevation generally decreases to the north, towards the Firth of

Forth. As such, views are often available along the coast and across the Firth

to Fife, with a range of urban and industrial development visible in a broad

panorama. Views are also available westwards towards Edinburgh, with the

distinctive hills within the city being prominent features (particularly Arthur’s

Seat). The Pentland Hills are also obvious features to the south-west.

Landscape Designations

7.3.10 There are no statutorily protected landscape designations (National Parks and

/ or National Scenic Areas) located within the study area for the LVIA. The

nearest such designation is the Upper Tweeddale National Scenic Area,

located approximately 30km to the south.

7.3.11 Additionally, the Application Site is not covered by the non-statutory Areas of

Great Landscape Value (AGLV) designation currently maintained by

Midlothian Council. Refer to Figure 7.1a-b for AGLV boundaries. The closest

AGLV is the North Esk Valley, approximately 1.75km to the south, towards

Dalkeith.

7.3.12 As part of the background to the emergent local plan, MLC undertook a review

of AGLV boundaries (Midlothian AGLV Review Final Evaluation Report Carol

Anderson Associates 2013), with a view to replacing the AGLVs with a similar

Special Landscape Area (SLA) designation. Following the review process, no

proposed SLA boundary would be located any closer to the Application Site

than any of the current AGLV boundaries. The closest boundary of the North

Esk Valley AGLV is not proposed to be changed following the review.


Landscape Character Assessment and Related Studies

Lothians LCA

7.3.13 At a regional level, the Application Site is located within a sliver of urban land

surrounded to east and west by the Musselburgh/ Prestonpans Fringe

landscape character area (The Lothians landscape character assessment,

Ash Consulting 1998). The dominant urban/ industrial character of this area is

identified in the regional character assessment as a negative attribute of the

landscape.

7.3.14 Regional landscape character areas located within the 5km study area for this

LVIA include (refer to Figure 7.1a for location):

13: North Esk;

15: Mayfield/ Tranent Ridge; and

25: Musselburgh/ Prestonpans Fringe Coastal Margins

7.3.15 Urban areas are excluded from the Lothians LCA.

Edinburgh Green Belt LCA

7.3.16 At a more local level, the Edinburgh Green Belt Landscape Character

Assessment (Land Use Consultants 2008) identifies that the Application Site

is located within an urban area that is excluded from the study. The area

occupied by the adjacent SNCD is also largely excluded from the study for the

same reason. The Application Site borders landscape character areas 46:

Danderhall Settled Farmland and 95: Old Craighall.

7.3.17 There are a large number of Green Belt Character Areas located within the

Study Area, as illustrated on Figure 7.1b. Green Belt Character Areas within

approximately 2.5km of the Proposed Development are considered within this

LVIA, these being:

45: Brunstane Farmland;

46: Danderhall Settled Farmland;

47: Craigmillar Farmland;

49: Drum Estate Landscape;


55: Edmonstone Policies;

87: Dalkeith Palace;

93: Musselburgh Golf Course;

94: Newhailes;

95: Old Craighall.

7.3.18 Two Green Belt Character Areas, 44: Burdiehouse Farmland and 91:

Wallyford Farmland have been excluded from the LVIA as only a very small

proportion of either area falls within 2.5km of the Proposed Development.

Future Landscape Change

7.3.19 As mentioned earlier in this Section, there is considerable development

pressure in the area, which is evidenced by a number of allocations for

housing, mixed-use and employment development and a series of

developments that were under construction in the vicinity of the Application

Site at the time of writing (AD Facility, Borders Railway and SNCD). These

three developments under construction are included as part of the baseline for

the LVIA, and it should be noted that their presence results in considerable

landscape and visual change, regardless of the presence of the Proposed

Development. The underlying context for the LVIA is that the landscape

surrounding the Application Site is far from static and is experiencing dynamic

change.

Visual Baseline

ZTVs

7.3.20 Zone of Theoretical Visibility (ZTV) mapping has been utilised to determine

the overall extent of theoretical visibility of the project. The ZTVs are displayed

on Figure 7.2, which also shows the locations of agreed Viewpoints (see

below).

7.3.21 The ZTVs enable an understanding of the visual context of the Proposed

Development and allow the identification of the areas of the surrounding

landscape from which people may experience views of it.


7.3.22 The ZTVs are based upon the Ordnance Survey Terrain 50 bare earth digital

terrain model (DTM) which takes no account of other elements in the

landscape such as vegetation, buildings or built up areas. As such, they

represent a maximum and worst-case scenario of potential visibility.

7.3.23 A clear limitation of this technique is that actual zones of visibility are not

determined by topography alone. Other elements in the landscape act as

screens, such as buildings, or filters, such as hedgerows and woodlands.

Screening and filtering of views by these elements can often be very

significant.

7.3.24 In addition, a simple ZTV takes no account of the scale of the visible

components of the Proposed Development within the view, or whether the

entirety of the development would be visible or just a small part; it simply

illustrates that a part of the facility would be visible.

7.3.25 In order to provide a more detailed understanding of the extent of visibility of

the Proposed Development, Figure 7.2 combines four separate ZTVs, namely:

The theoretical visibility of the consented Zero Waste facility buildings

(maximum roof height 20m);

The theoretical visibility of the proposed buildings (maximum roof height

41.6m);

The theoretical visibility of the consented Zero Waste facility exhaust

stack (height 65m); and

The theoretical visibility of the proposed exhaust stack (height 75m).

Viewpoints

7.3.26 Following the consultation process outlined in sub-section 7.2 above, sixteen

viewpoints have been included in the LVIA. Refer to Appendix 7-2 for details

of the process by which these viewpoints were selected.

7.3.27 Viewpoints fall into three categories, as set out in the GLVIA:

Representative viewpoints (which represent the experience of different

types of receptors in the vicinity);


Specific viewpoints (a particular view, for example a well-known beauty

spot);

Illustrative viewpoints (which illustrate a particular effect/issue, which

may include limited/lack of visibility).

7.3.28 It should be noted that the viewpoint itself is not the receptor; rather the

receptor is the person that would be experiencing the view from the viewpoint.

7.3.29 The viewpoints are set out in the Table below (refer to Figure 7.2 for viewpoint

locations).

Table 7.2: Viewpoint Locations

Viewpoint British National Grid Co-ordinates

Viewpoint Type

1: Battle Memorial, Salter’s Road

336300, 671283 Specific viewpoint from battle memorial. Also, broadly representative of views from the adjacent stretch of the A1.

2: Old Craighall 333373, 670415 Representative of views from residential properties within a small village.

3: Danderhall Medical Centre

331069, 669410 Representative of views from the village.

4: Danderhall 330410, 670001 Representative of views from the village.

5: The Wisp 330517, 670584 Representative of views from minor road linking Danderhall and Niddrie

6: Minor road east of Cauldcoats

331473, 671104 Representative of views from minor road west of Application Site

7: A1 (Queen Margaret’s University)

332726, 671353 Representative of views from the A1 north-east of the Application Site.

8: B6415, A1 underpass 333547, 670799 Representative of views from the A1 to the east of the Application Site. Note the viewpoint is at a lower elevation than the carriageway of the A1.

9: Falside Hill 338110, 671263 Specific viewpoint from lay-by on minor road in an elevated location.

10: A720 (footpath) 333215, 669108 Representative of views from the A720 east of the Application Site and from the adjacent footpath.

11: Craigmillar Castle 328810, 670870 Specific viewpoint from publicly accessible castle

12: Queen’s Drive 328132, 672840

Specific viewpoint from lay-by on minor road affording views eastwards across Mid and East Lothian. Also, more generally representative of views from Arthur’s Seat/ Holyrood Park.

13: Fort Kinnaird 331344, 671742 Representative of views from out of town retail park.

14: Newcraighall 332237, 671909 Representative of views from residential area.


Viewpoint British National Grid Co-ordinates

Viewpoint Type

15: Borders Railway overbridge

332002, 670044 Representative viewpoint from within the SNCD.

16: A68 (A6106 overbridge)

337344, 667192 Specific viewpoint from hillside south-east of the Application Site.

PPiP Future Baseline Scenario

7.3.30 The PPIP future baseline scenario (refer to Chapter 2.0 for full details) reflects

the fact that a major development located at the Application Site has been

granted planning consent. The assessment of effects in this Scenario seeks

to set out in brief any additional landscape and visual effects that would derive

from the Proposed Development, over and above those deriving from the

consented PPiP development which it would effectively replace. (The principal

differences between the consented PPiP Development and the Proposed

Development, in so far as they relate to the assessment of landscape and

visual effects, were set out in Table 7.1 earlier in this Chapter.)

7.4 Assessment of Effects

Incorporated Mitigation

7.4.1 A detailed description of the Proposed Development is set out in Chapter 4.0

and is summarised in sub-section 7.1 above. A series of measures have been

incorporated into the design of the Proposed Development and into

construction and operational procedures, which are intended to provide

mitigation against potentially adverse landscape and visual effects and other

environmental effects. These measures include:

Form of buildings: The buildings have been designed using the principal

that the process equipment should be enclosed in a volumetrically

efficient manner so as to minimise the overall building height and

volume.

Colour of buildings: The built form has been designed with a dark ‘plinth’

below a paler upper structure. This has the effects of ‘grounding’ the

building and reducing the apparent overall scale.

Cladding materials: Whilst the building plinth would be clad in a

composite sheet material, the upper part of the structure would be clad


in a translucent polycarbonate material. The polycarbonate would reflect

the tones of the sky and would assist in assimilating the structure and

providing the building with a dynamic, ever-changing element. After

dark, the material would allow a low level glow of process lighting to

permeate into the landscape introducing a further dynamic aspect.

Landscape design: Whilst a comprehensive landscape design has been

developed, in most views considered as part of the LVIA, this will have

little mitigating effect. The landscape scheme would however be very

effective in the immediate vicinity in providing an attractive and

functional setting for the development.

Lighting design: The lighting design would incorporate the following

mitigation measures:

o The use of low level lights as far as possible to reduce the visibility

of site lighting;

o The use of carefully sited directional lighting incorporating light

shields to avoid unwanted light spill and possible glare effects;

o Digital programmable switches including timers and / or movement

sensors;

o Avoidance of any unnecessary or unplanned lighting of building

façades;

o Concentrated of lighting in locations essential to night operations;

and

o Low level lighting bollards with low energy fittings utilised around

the offices, visitor centre and pedestrian routes;

o Possible use of a surface finish to the road with very low

reflectivity; and

o Possible use of kerbs with inbuilt reflectors to assist night time

navigation of the roads (reducing the overhead illumination

requirement).

7.4.2 As such, the landscape and visual effects of the Proposed Development (as

assessed below) relate to a project that has benefited from considerable

mitigation through design.


Construction Phase

Assessment of Effects against Existing Baseline

7.4.3 An overview of the key elements of the construction process for the Proposed

Development is set out in Chapter 4.0 of this ES. It is anticipated that

construction would last for a period of approximately 28 months. Initial works

would include site clearance, foundations and drainage, and these would be

likely to take place early, within the first 5 months. Erection of building frames,

plant and equipment, and then cladding would follow. Landscaping and other

external works would generally be amongst the last tasks to be completed.

7.4.4 Construction activity is already evident, both within the boundary of the

Application Site, and in the surrounding area, associated with the Borders

Railway, AD Facility and SNCD. The baseline for the LVIA assumes that this

construction activity is complete. The construction of Proposed Development

would introduce visible construction activity from approximately mid-2015 until

spring 2018. There would be adverse effects of short-term duration deriving

from this construction activity.

7.4.5 The construction process would be managed in accordance with a project-

specific CEMP which would set out how construction would comply with any

specific environmental limitations imposed by the planning consent, as well as

relevant legislation, regulations and best practice guidance. The CEMP would

include detailed method statements for specific tasks where necessary, as

described in Chapter 4.0 of the ES. The CEMP would include details of

measures required to protect any retained tree/ woodland cover from harm

during construction, with outline measures set out in the Tree Survey (refer to

Part 7 of the PAD).

7.4.6 A temporary compound would be required during the construction process to

accommodate contractor’s personnel, welfare facilities, storage of plant and

materials etc. A temporary parking area would also be required. Both would

be located within the Application Site boundary. Some vegetation clearance

would be required to accommodate these temporary facilities, which would be

additional to that required to accommodate the operational facility. As such,


there would be some limited specific construction phase effects resulting from

this aspect of the works.

7.4.7 The construction of the Proposed Development would require the use of

cranes, which by their nature would be visible for some distance. Both fixed

tower cranes and mobile cranes would be used. Typically, a tower crane with

a 55m boom and a span of 65m to the hook would be used. The height of the

tower crane would typically be 40m (see Chapter 4 for further details). The

cranes would be tall structures and hence potentially visible over a wide area.

It is anticipated that cranes would be present on site for approximately

fourteen months (between months 10 and 23), i.e. for approximately one-half

of the construction phase. Whilst short term and adverse visual effects would

result from the presence of cranes, these would be temporary in nature and

would not be significant.

7.4.8 Lighting during construction would be required during the winter months to

ensure the health, safety and welfare of those on-site during poor light

conditions and in particular at the beginning and end of the working day. This

may require both fixed lighting columns and mobile task lighting. In some

instances lighting may be required for work on elevated structures, including

crane mounted lighting. Lighting would be at the minimum levels necessary as

far as practicable. The CEMP would include measures to monitor and control

lighting levels and light spillage throughout the construction process.

7.4.9 Construction operations would generally be limited to 07:00 – 19:00hrs

Monday to Friday and 07:00 – 12:00hrs Saturday and as such, the main

construction lighting would be limited to this period. Low level lighting of

security compounds may be required throughout the night, but the effects of

this would be very limited in their extent. Night-time effects would not be

significant.

Assessment of Effects against PPiP Future Baseline Scenario

7.4.10 The construction period for the PPiP development was proposed to occur

between 2013 / 2014 and 2015 / 2016 for a period of approximately 24

months. The details regarding construction in the PPiP ES are limited, and as

such, it seems reasonable to assume construction would involve similar


activities to those required for the Proposed Development. The PPiP LVIA

simply states that temporary construction phase effects would be equal to or

no greater than the residual operational effects of the PPiP development, with

no further consideration of construction phase effects.

7.4.11 The difference between the construction phase for the Proposed

Development, as compared with that for the PPiP development, would be the

increased duration of construction activity and the increased height of the

structure, which is likely to result in taller cranes and a more widespread

visibility of activities. As such, the adverse effects of the Proposed

Development would be incrementally greater due to this. It is not considered

that other aspects of the construction process would result in any effect that is

appreciably different from that would could be anticipated from the PPiP

development.

Landscape Effects: Operational


Effects on Landscape Fabric

7.4.12 The landscape fabric of the Application Site chiefly comprises young

deciduous woodland that has regenerated on the compacted substrates of a

former marshalling yard. The predominant tree species is birch. The woodland

is generally of poor quality and vigour due to poor growing conditions, and has

in places been disturbed due to adjacent construction activity and on-site

ground investigation works. There are also areas within the Application Site

where no tree cover has developed; these areas are composed of grassland

or bare earth. A temporary construction access track for the adjacent AD

Facility runs north-south through the western part of the Application Site.

7.4.13 A Tree Survey of the Application Site has been undertaken and is included as

part of the planning application documentation (refer to Part 7 of the PAD).

This confirms that the tree cover is of low quality and value.

7.4.14 The vegetation cover within the Application Site has a low to medium

susceptibility to change. Both the young woodland and the grassland could be


recreated with little difficulty in a relatively short period of time. Value is

low/medium; the woodland is not mature and is of low quality (as identified as

part of the Tree Survey), and there is no public access. Overall, sensitivity is

low / medium.

7.4.15 The Proposed Development would result in the loss of most of the woodland

cover within the Application Site, although where possible, pockets of existing

woodland would be retained. Additionally, areas of grassland, bare earth and

hard surfacing would also be lost to accommodate the Proposed

Development. Again, it is considered beneficial to retain some of these areas

where possible, as they provide habitat niches and would contribute to the

diversity of external areas.

7.4.16 The Proposed Development would introduce new built structures and

associated external hard surfacing (roads, footways and parking). The

proposed indicative landscape scheme is illustrated on Figure 7.4 and would

include areas of new native woodland, specimen tree planting and areas of

species-rich grassland. New waterbodies with associated planting would also

be provided.

7.4.17 Changes to the landscape fabric would occur within the Application Site.

There would be a loss of tree cover, but there would be replanting of new,

more sustainable woodland (planted into better substrate), and also a greater

diversity of vegetation types would be created. Overall, the Application Site

would change from a vacant site with young poor quality woodland, to an

operational industrial facility with only a proportion of the site covered in

vegetation. Change would be long-term (for the life of the Proposed

Development). The magnitude of change would be medium.

7.4.18 A moderate level of effect upon the landscape fabric of the Application Site

would occur as a result of the Proposed Development. The existing fabric

comprises young woodland that has regenerated on poor substrates within a

vacant industrial site. The re-introduction of industrial development at the

Application Site would result in the loss of much of the existing vegetation

cover to accommodate the Proposed Development. New and more diverse

vegetation cover would be introduced and both this, and retained existing

vegetation would be actively managed by the Applicant to promote


biodiversity. The reduced amount of vegetation cover within the site would be

adverse, but the greater diversity of vegetation and the enhanced

management of the landscape fabric would be beneficial.


7.4.19 The PPiP LVIA did not make any specific conclusion as to the significance of

effects upon the landscape fabric. Two layout options were considered in the

PPiP LVIA; a landscape scheme was not produced for either option.

7.4.20 In the absence of any details regarding landscape proposals for the PPiP

scheme, it is not possible to assess the effects of the Proposed Development

against these. It seems reasonable to assume that the PPiP landscape works

would be similar in type to those outlined for the Proposed Development, i.e.

loss of the majority of existing woodland, introduction of replacement

woodland and other vegetation types, and management of this. As such, it

also seems reasonable to state that there would be little/ no additional effects

upon the landscape fabric resulting from the Proposed Development, i.e.

effects would at worst be negligible.

Effects on Landscape Character

7.4.21 The effects of the Proposed Development upon each of the Lothians LCAs

located within the 5km study area, and upon each of the Edinburgh Green Belt

landscape character areas located within approximately 2.5km of the

Application Site are assessed in detail in Appendix 7-3.

7.4.22 To summarise this, none of the character areas assessed in the LVIA would

experience significant effects upon their character. The Proposed

Development would be introduced into an urban fringe landscape where the

presence of built development, including electricity pylons and road corridors

is already strong, and will be even more so with the addition of the new

Borders railway, AD Facility and SNCD (all of which form part of the LVIA

baseline).

7.4.23 In this context, the presence of the Proposed Development would be visually

apparent due to the size and scale of the structures proposed and would be


larger than any other single existing feature. However, the influence of the

development upon the wider character would nonetheless be limited, due to

the very strong influence of built features in the baseline landscape, as

identified above.

7.4.24 There would be an incremental increase in the influence of built development

in some locations closer to the Application Site (Lothians character area 25:

Musselburgh / Prestonpans Margins; Green Belt character areas 46:

Danderhall Settled Farmland and 95: Old Craighall). Effects would be minor to

moderate adverse and not significant.

7.4.25 Elsewhere, change would be limited to changes in the visual context of the

landscape, with underlying characteristics wholly or largely unaffected, given

the widespread existing visibility of other urban / industrial and infrastructure

development. Effects, whilst adverse, would be minor at worst.


7.4.26 The PPiP LVIA identified localised significant effects upon landscape

character, which it considered would occur in the Green Belt character area

46: Danderhall Settled Farmland, with all other character areas experiencing

effects that would not be significant. SEI submitted in relation to the PPiP LVIA

did not address effects on landscape character.

7.4.27 It should be noted that the PPiP LVIA did not reflect the presence of the

Borders Railway and the SNCD as part of the baseline receiving landscape,

and therefore did not recognise the changes in character that will inevitably

result from the presence of these two developments (and which indeed are

already being felt). The AD Facility which also forms part of the baseline for

the current LVIA, was a component element of the PPiP development. As

such, the baseline for the PPiP LVIA and the current LVIA are not the same

and it is understandable that differences between the two assessments have

resulted.

7.4.28 Whilst the Proposed Development would be more visible than the PPiP

development due to the greater height and bulk of the buildings, its influence

upon the surrounding landscape would be no greater from most character


areas, and would be less from the Danderhall Settled Farmland, where the

presence of the SNCD will exert a strong influence.

Visual Effects: Operational


Viewpoints

7.4.29 The visual effects of the Proposed Development from each of the sixteen

viewpoints included in the LVIA are assessed in detail in Appendix 7-4, and

are summarised below. The view from each viewpoint looking towards the

Application Site is displayed on Figures 7.3a to 7.3m. (NB. It must be

recognised that the Figures reflect the view available at the date of

photography, and hence do not show the full assessment baseline which

includes a fully built AD Facility, Borders railway and SNCD).

7.4.30 Photomontages from selected viewpoints are displayed on the same set of

Figures. The photomontages superimpose a computer-generated model of the

Proposed Development onto the photograph of the existing view. It should be

noted that the photomontages are merely a tool in the assessment process,

representing a static image of how the Proposed Development would appear

the particular weather and light conditions and at the particular time of day

when photography was taken.

7.4.31 Of the sixteen viewpoints, significant visual effects would be experienced from

a single viewpoint, namely Viewpoint 2: Old Craighall. At this viewpoint, the

Proposed Development would be introduced into a view where similar

features are not presently visible. Partial screening would be provided by the

intervening railway embankment, but the taller elements of the Proposed

Development would nevertheless form conspicuous new skyline features.

There would be an obvious contrast with the distinctive skyline landforms of

Arthur’s Seat and the Pentland Hills, and with other features in the view.

7.4.32 At each of the other sixteen viewpoints, visual effects would not be significant.

The viewpoints are located at a range of distances from the Application Site

and reflect views toward the Application Site from different directions. The


views available are defined by the presence of built development, including

large-scale urban areas, industrial / commercial buildings (such as Fort

Kinnaird), and major trunk roads and other transport routes, often with

prominent embankments (particularly the A1 embankment). Whilst not visible

in the viewpoint photography, or shown on the photomontages, the presence

of the SNCD (which forms part of the assessment baseline) in particular

means that visual influence of built development is already extensive, and this

restricts the visibility of the Proposed Development from some nearby

locations. In this context, the Proposed Development, whilst generally visible

over a wide area, would have only a limited influence upon the views

available, which would be characterised by the presence of built development

and road traffic. It is again stressed that the presence of the AD Facility,

Borders Railway and SNCD form part of the assessment baseline. Therefore,

in reality, in the baseline scenario that is being assessed, many views would in

reality be blocked or heavily influenced by built development.

Pattern of Visual Effects

7.4.33 The Proposed Development would theoretically be visible from much of the

surrounding area by virtue of its height (refer to Figure 7.2 for the ZTV). The

nature of existing views is that they are strongly influenced by the presence of

built development (despite the rural character conveyed in some viewpoint

figures), and the Proposed Development would always be experienced in this

context.

7.4.34 From the north, the Proposed Development would in general be clearly visible

to traffic along the A1, which is elevated on an embankment (see Viewpoint

8). Views would be screened by vegetation from some short stretches of the

road. Typically, the Proposed Development would be conspicuous as a new

large structure visible at short-range, but change would be in the context of a

view where highway traffic and infrastructure is very prominent and with other

built development, such as the AD Facility and Queen Margaret’s University,

often also prominent. It should also be noted that some of the land east and

north-east of the Application Site (south of the A1) is allocated in the emerging

East Lothian Local Development Plan for mixed-use development and, as

such, the context of the views available from the road is likely to change

further.


7.4.35 Further north, beyond the A1, the wooded road embankment would screen the

lower elevations of the Proposed Development from view. The tallest

proposed structures, including the exhaust stack, would in general be visible

above this existing feature, alongside the existing very tall lighting columns at

the Millerhill Marshalling Yards. Views would be in the context of other built

development (primarily urban/ suburban) located north of the A1, and the

obvious visual separation provided by the A1 embankment would result in the

Proposed Development appearing as a background feature with little influence

of note upon the type of views available (see Viewpoint 14).

7.4.36 From National Cycle Route 1, the Proposed Development would be partially

screened by the A1 embankment and associated tree cover, and by further

woodland to the south of the road. Again, the tallest elements of the Proposed

Development would be visible above this, but would be background features

visually subordinate to the far more prominent Queen Margaret’s University

buildings and the A1. In this context, visual effects would not be significant.

7.4.37 From the east, the Proposed Development would be visible from properties at

Old Craighall (see Viewpoint 2) and from the nearby A1 (see Viewpoint 8) and

A720. The taller elements of the Proposed Development would break the

skyline and offer a clear contrast with the background landforms of Arthur’s

Seat and the Pentland Hills. From more sensitive static receptors, such as

people in residential properties, this would intrude upon the view and may give

rise to significant effects.

7.4.38 At a longer range, views of the Proposed Development would be available

from along the A1 corridor (see Viewpoint 1) and from more exposed,

elevated locations further east, such as Falside Hill (see Viewpoint 9). In these

cases, the Proposed Development would be visible in the middle ground of a

view where a wide range of development types are already visible. In this

context, the Proposed Development would be a minor addition.

7.4.39 In respect of views from the south-east, the Proposed Development would be

visible from the A720 (see Viewpoint 10), in the context of the busy traffic and

prominent highway infrastructure, and perpendicular to the direction of travel.

Longer views would be available from the hillsides further south-east, such as

stretches of the A68 (see Viewpoint 16). Again, the Proposed Development


would be a minor addition to a view where built development is already readily

apparent in the middle and longer ranges.

7.4.40 From Dalkeith Country Park, views would typically be screened by the dense

woodland cover present. From some locations, the taller elements of the

Proposed Development would occasionally be discernible, for example from

the footbridge over the A68 located towards the north-eastern edge of the

Park. Such views would be in the context of the existing development visible.

7.4.41 From the south, all views of the Proposed Development would be in the

context of the SNCD. The built form of development at Shawfair would

obscure short-range views of the Proposed Development, although occasional

clearer views are likely to remain possible from more elevated locations, or

where there are vistas formed through gaps between buildings (see Viewpoint

15). In general, views from this area would inevitably be dominated by urban

built development regardless of the presence of the Proposed Development.

7.4.42 Further to the south, built development at Shawfair will occupy the intervening

ground between the Proposed Development and people living in properties at

Danderhall, Newton Village, Easter Millerhill and Wester Millerhill. The tallest

elements of the Proposed Development would be visible from some properties

(see Viewpoints 3 and 4), but their influence upon the view would be limited by

the existing context of dense built development at Shawfair.

7.4.43 From the west, the Proposed Development would typically be clearly visible at

short-range (see Viewpoints 5 and 6). The landform in this area tends to slope

downhill towards the Firth of Forth (i.e. northwards), which naturally focuses

views toward the developed coast, with Fort Kinnaird particularly conspicuous.

Additionally, the presence of the SNCD immediately south-west of the

Proposed Development would result in built development having a strong

influence upon landward views. In this context, the Proposed Development

would have only a limited influence upon the nature of views available,

whether from the scattered residential properties in the area, from the public

road network, or from footpaths.

7.4.44 From a series of elevated vantage points further west, including Arthur’s Seat

and Queen’s Drive (see Viewpoint 12), the high-rise flats at Niddrie, and


Craigmillar Castle (see Viewpoint 11), the Proposed Development would be

visible in the context of long views eastwards across Mid and East Lothian.

Existing built development is widely visible within Edinburgh, along the coast

and at the urban fringe, with buildings representing a wide range of styles and

periods and at a variety of scales. The further presence of the Proposed

Development would constitute only a minor addition and would not give rise to

any significant visual effects.

Views from SNCD

7.4.45 The SNCD Masterplan indicates that residential development would be built

close to the western boundary of the Application Site. This would comprise a

series of two-storey properties. For the purposes of the LVIA, it has been

assumed that these would have direct views into the Application Site from rear

windows.

7.4.46 Clear views of the Proposed Development would be available from second

storey rear windows. The baled waste building would partially screen views of

vehicle movements and other ground level activities, although these would be

apparent to either side of the building. The main building would be clearly

visible above the baled waste building. Visual effects would be significant and

adverse, as the Proposed Development would be a prominent new feature

added into the view at close range.

7.4.47 It should be noted that the LVIA has assumed that no screening features

would be present within the boundaries of the SNCD. In reality, garden

vegetation, and / or boundary features are likely to feature and would reduce

visibility.

7.4.48 From locations further west and south-west within the SNCD, it is likely that

the juxtaposition of buildings and other structures would restrict clear views of

the Proposed Development, and often would wholly screen views. Clear views

may be available from the windows of some individual properties or other

buildings, or from roads / paths, depending upon the specific orientation of

these once built, but such views would always be in the context of the

extensive surrounding development and the Proposed Development would be

a background feature set within the newly urbanised context of the foreground


view. As such, more general visual effects from Shawfair would not be

significant.

Plume Visibility

7.4.49 The combustion process produces an emissions plume, composed primarily

of water vapour, which is emitted via the exhaust stack. The degree to which

this plume is visible is determined by the flowrate of the exhaust gases in

combination with their temperature and humidity relative to that of the

surrounding air environment.

7.4.50 When visible, emission plumes vary greatly in their visual characteristics in

response to weather conditions. Plumes often have characteristics in common

with the surrounding air environment, (i.e. on a cloudy day they would often

blend in with the background as they comprise primarily of water vapour).

7.4.51 Plume visibility has been modelled as part of air quality assessment for this

Environmental Statement. The modelling was based on weather data

recorded over the five year period 2009 – 2013.

7.4.52 The modelling indicates that a visible plume would be apparent for

approximately 70% of daylight hours. When visible the average plume length

is predicted to be short, with plume length being less than 20m for around

50% of daylight hours. The plume would be longer than the average distance

from the exhaust stack to the site boundary for less than 5% of daylight hours.

7.4.53 The presence of the emissions plume would have potential to accentuate

visibility of the development and its stack in the wider landscape.

7.4.54 Atmospheric conditions that lead to plume formation (low temperature &

humidity) occur more frequently in winter, and consequently both plume length

and visibility greatly decrease in the summer months.

7.4.55 Cloud cover is a significant factor in determining the extent to which visible

plumes are discernible. In clear or blue sky conditions a plume will contrast

strongly with its background. However, in skies with more than one or two

oktas of cloud this contrast become progressively less marked. The periods


when cloud cover is likely to be at its greatest are across the autumn, winter

and early spring seasons which coincide with when the plumes are most likely

to occur.

7.4.56 As such, whilst the modelling indicates that plumes will be present for the

majority of daylight hours, in general it is considered that plumes would not be

prominent. There would be occasional transient adverse visual effects (for

example where long plumes form in clear skies during a temperature

inversion) but is concluded overall that the emissions plume would not lead to

significant adverse visual effects.

Night-time Effects

7.4.57 The lighting proposed as part of the Proposed Development is described in

Chapter 3.0, including an overview of mitigation measures that would be

implemented to reduce the adverse effects of lighting.

7.4.58 The area surrounding the Application Site is one where external lighting is an

established night-time presence. Street lighting is prevalent within urban areas

and around road junctions, including within the SNCD (part of the baseline for

the assessment). The lighting at the Millerhill Marshalling Yards is

conspicuous, set on tall columns. The high volumes of traffic on the A1 and

A720 are also a source of light. Internal lighting within buildings, especially

taller buildings, such as those at Queen Margaret’s University, is also

apparent.

7.4.59 The upper elevations of the Proposed Development would principally

comprise translucent polycarbonate material, which during the day would

appear generally white in colour, with changes in tone in response to ambient

light and the changing sky. At night the translucent nature of the material

would be such that internal lighting would be partially visible through the

cladding and the building would seem to ‘glow’ when viewed from the

surrounding area. This ‘glow’ would be a light source of low intensity, filtered

through the polycarbonate building façade. In the context of the area

surrounding the Application Site, which is already well-lit (including lighting

from the SNCD) and where there is a significant degree of ‘sky glow’ from the


adjoining urban areas, the very limited light generated by the ‘glowing’ building

would not be intrusive.

7.4.60 Some areas of the Proposed Development would be lit at ground level. This is

necessary to ensure safe working in operational areas, and for the health and

safety of people walking to and from proposed buildings to car parking areas.

Additionally, lighting columns would be provided along the publicly accessible

link path around the northern and western boundaries. Such lighting would be

the minimum intensity required and would deploy modern full cut-off

luminaires to minimise light spill. All of the lighting at the site would occur in

the context of established urban lighting in the surrounding area.

7.4.61 Given the widespread sources of existing light and the incorporation into the

lighting design of measures intended to minimise light pollution and the

generation of obtrusive light, it is considered that the night-time effects of the

Proposed Development would be small scale and would not be significant.


7.4.62 The PPiP LVIA identified significant visual effects from locations closer to the

PPiP Site, including Danderhall, Millerhill, Newton Village and Old Craighall.

At all these settlements effects were identified as generally not significant, but

locally significant. Additional significant effects were identified from short

stretches of the A1 and National Cycle Route 1 to the north-east of the PPiP

Site.

7.4.63 SEI submitted in relation to the PPiP LVIA includes consideration of visual

effects from five additional viewpoint locations. Three of these viewpoints are

located in the area west of the Application Site, including one at Harelaw

within the boundaries of the SNCD; the PPiP SEI concludes that visual effects

from these locations would not be significant, but makes no reference to the

future presence of Shawfair within the view.

7.4.64 The PPiP SEI does identify significant visual effects from two viewpoints

located to reflect potential views available to future residents at Shawfair,

namely 9 Former Monktonhall Colliery Site and 10 Monktonhall Bing, and

goes on to identify that these effects are likely to reduce over time due to new


planting both within the PPiP site and within Shawfair. Neither viewpoint is

publicly accessible at present, but both lie within the boundary of the Shawfair

development, close to the eastern boundary with the wider Millerhill

Marshalling Yards. Viewpoint 10 lies due west of the Application Site, close to,

if not directly on the line of the new Borders Railway, which is not recognised

in the PPiP SEI.

7.4.65 The respective ZTVs of the Proposed Development and the PPiP are

displayed on Figure 7.2. The buildings associated with the Proposed

Development would be theoretically visible over a wider area than the PPiP

buildings, due to their greater height. The proposed exhaust stack would be

10m higher than the consented PPiP stack; however, the areas of increased

stack visibility (refer again to Figure 7.2) would be limited. The majority of the

extent of additional theoretical visibility would be concentrated in the urban

areas north and west of the Application Site, from within which significant

screening of views would be provided by other buildings and structures, and

therefore actual additional visibility of the Proposed Development would be

limited

7.4.66 The Proposed Development would generally be more visible than the PPiP

development, due to the greater height of the buildings. However, due to the

subsequent changes to the visual context of the surrounding area, visual

effects would be less. In particular, visual effects from the south and west (i.e.

Danderhall, Millerhill and Newton Village) would not be significant due to the

presence of extensive built development at Shawfair and the transformative

influence of this development upon views. Visual effects from properties at Old

Craighall would remain significant, although it is noted that land between this

settlement and the Application Site is allocated for mixed-use development in

the East Lothian Local Plan and could therefore undergo a similarly profound

change in outlook. Properties within the SNCD located close to or adjacent to

the boundary of the Application Site (PPiP SEI Viewpoints 9 and 10) would

also remain significantly affected

7.4.67 In relation to visual effects for users of the A1, the visual effects of the

Proposed Development would not be significant for the reasons stated earlier

in this Section and set out in more detail in Appendix 7-4. From NCR 1, the

Proposed Development would be a background feature, partially screened by


intervening earthworks and vegetation and less prominent than closer existing

features; again effects would not be significant. It is considered that a similar

statement should apply in relation to the PPiP and that the conclusions of the

PPiP LVIA in relation to these two receptors exaggerate the visual effects that

would occur. The visual effects of the Proposed Development would be

incrementally more adverse than those of the PPiP, but would not be

significant, due to the receiving context.

Effects on Landscape Designations

7.4.68 The presence of the Proposed Development would not affect the integrity of

the North Esk Valley AGLV. The Development would be located in a different

landscape context, separated from the designation by the corridor of the

A720, and there would be few clear views due to the dense and extensive

woodland cover north of Dalkeith. Neither the character of the landscape

within the AGLV, nor the views available, would be significantly affected. It is

concluded that the presence of the Proposed Development would not

materially affect the designation.

Decommissioning Effects

7.4.69 Landscape and visual effects experienced during the decommissioning stage

would, by and large, represent a reversal of those that would occur during

construction. Buildings and other structures, and the majority of above ground

infrastructure, would be removed from the Application Site and tall cranes

would be utilised as part of this process. There would be some adverse

effects, and for some nearby residents these would be likely to be significant.

Effects would however be temporary and of relatively short duration. It is

anticipated that mitigation measures in relation to specific potential effects

would be developed prior to decommissioning taking place.

7.4.70 It should also be noted that the decommissioning stage would represent the

progressive removal of the effects associated with the operation of the

Proposed Development, (i.e. the adverse effects upon landscape character

and upon views would cease following removal).


7.5 Additional Mitigation

7.5.1 No additional measures are proposed to mitigate against potential adverse

landscape and visual effects.

7.6 Residual Effects

Residual Effects against Existing Baseline

7.6.1 In the absence of additional mitigation measures, the residual effects of the

Proposed Development would be as set out in Section 7.4 above.

Residual Effects against PPiP Future Baseline Scenario



7.7 Conclusions

7.7.1 The Proposed Development would be located within a former industrial site,

set within a wider urban fringe landscape. The existing influence of transport

infrastructure and built development, including electricity pylons and road

corridors, is marked. The agreed EIA baseline includes a number of further

developments (the new Borders railway, AD Facility and SNCD) which are

currently under construction in the immediate vicinity of the Application Site.

The LVIA has been undertaken on the basis that these three developments

have been built and are established features in the landscape. The Shawfair

development in particular will have a profound influence upon the surrounding

area. As such, despite its height, the potential for the Proposed Development

to change the landscape of its surroundings would be less than might be

anticipated. A similar but differently configured development (larger footprint,

but lower building height) at the same site benefits from planning consent. In

this context, the influence of the Proposed Development upon character would

be limited due to the already strong existing influence of built features. There

would be no significant effects upon landscape character.


7.7.2 The assessment identified that Significant visual effects would be experienced

from one of the sixteen selected viewpoints, at the western edge of Old

Craighall. This viewpoint would be representative of views from short range to

the west, where there are approximately 30 residential properties and where

the taller elements of the Proposed Development would form a conspicuous

new skyline feature, contrasting with distinctive background landforms and

with other features in the view. The ES for the consented PPiP development

also found that there would be significant effects from this location. Whilst

effects would be significant, views from the majority of the residential

properties would be oblique or obscured by other properties. It must also be

noted that the parcels of land situated between Old Craighall and the

marshalling yard have been allocated for mixed use development in the

emerging East Lothian Local Development Plan. As such whilst it cannot be

guaranteed that development will come forward, there is a strong likelihood

that the view illustrated on Figure 7.3b will change significantly in the short to

medium term, with much of the foreground likely to take on an urbanised

character and with the Proposed Development becoming partially screened

and a such less conspicuous component of the view as a result.

7.7.3 When contrasted with the landscape and visual effects identified for the

consented PPiP development, the significant effects of the Proposed

Development would be less extensive, due to the on-going changes in the

surrounding area and the spread of built development, including the AD

Facility, Borders Railway and SNCD. The presence of these developments

changes the context of the receiving landscape and greatly increases the

influence of buildings and other structures upon it. Hence whilst the Proposed

Development would be a larger structure than the PPiP development, it would

have a lesser effect upon its surroundings.

7.8 References

ASH Consulting Group (1998). The Lothians landscape character assessment.

Scottish Natural Heritage Review No. 91. Scottish Natural Heritage;

Carol Anderson Associates (2013). Midlothian AGLV Review Final Evaluation

Report;

European Landscape Convention (2000) opened for signature 20 Oct 2000;


Land Use Consultants in association with Carol Anderson (2008). Edinburgh Green

Belt Landscape Character Assessment Final Report. Midlothian Council, City of

Edinburgh Council, East Lothian Council, West Lothian Council, Scottish Borders

Council, and Scottish Natural Heritage;

Landscape Institute (2011) Photography and photomontage in landscape and visual

impact assessment. Landscape Institute Advice Note 01/11;

Landscape Institute and Institute of Environmental Management and Assessment

(3rd edition 2013). Guidelines for Landscape and Visual Impact Assessment.

Routledge, Abingdon;

Midlothian Local Plan (2008). Midlothian Council;

Scottish Planning Policy (2014). The Scottish Government;

Shawfair Developments Limited (2002). South East Wedge ‘our vision’ The

Masterplan;

Shawfair Developments Limited (2006). South East Wedge ‘our vision’ The Design

Guide;

Strategic Development Plan (2013). SESPlan; The Strategic Development Planning

Authority for Edinburgh and South East Scotland;

Swanwick C (2002). Landscape Character Assessment - Guidelines for England

and Scotland. Countryside Agency/Scottish Natural Heritage;

The Countryside Agency / Scottish Natural Heritage (2004). Topic Paper 6:

Techniques and Criteria for Judging Capacity and Sensitivity.


8.0 ECOLOGY AND NATURE CONSERVATION

8.1 Introduction

8.1.1 This Chapter considers the potential impacts of the Proposed Development on

flora and fauna. The assessment was undertaken in accordance with the

Chartered Institute of Ecology and Environmental Management (CIEEM)

Guidelines for ecological impact assessment in the UK.

8.1.2 The structure of the assessment follows standard practice; scope and

methodology of the study are first described, including evaluation and

assessment methods. This is followed by a description of the ecological

context of the site and its habitats and fauna, including the occurrence of

legally protected species. The nature conservation interest of the site and its

surroundings is then evaluated; any significant impacts upon interest features

are assessed, including indirect impacts on interest features in the wider

vicinity of the Proposed Development.

8.1.3 Full account is taken of the results of the Air Quality Assessment (Chapter

12.0) in assessing potential ecological impacts in a wider context, including

effects on European and nationally designated conservation sites within a

15km buffer, and ancient woodland sites within 2km. Other environmental

studies reported in this EIA have also been consulted in order to assess

impacts on ecological receptors, including Noise (Chapter 11.0) and Surface

Water and Flood Risk (Chapter 10.0).

8.1.4 Where possible mitigation design measures have been identified to avoid,

reduce or compensate for any potentially significant ecological impacts on

identified interest features on the site and features in the surrounding

landscape. Ecological impacts of the construction and operation phases of the

development are outlined, with an assessment of impact significance based

on the conservation status of identified interest features. Further proposed

mitigation and ecological enhancement measures are outlined, with a

summary of residual impacts following the implementation of these measures.

8.1.5 Cumulative ecological effects are assessed in Chapter 15.0; ecological effects

of the proposed grid connection are assessed in Chapter 16.0 of this ES.



8.1.6 A detailed description of the Proposed Development is set out in Chapter 4.0.

Key aspects of the development of relevance to the ecological assessment

include:

Construction methods and their requirement for land-take;

Stack height and its influence on air quality at ecological receptors;

Lighting design and measures to reduce light spillage; and

Landscape design and its potential to provide ecological mitigation and

enhancement.



an appraisal of effects on relevant nature conservation policies, as set out in

the adopted statutory Development Plan, are included in the PS (Part 3 of the

PAD). Key legislation and policies relevant to the ecological assessment are

summarised below.

European Legislation

8.1.8 The Habitats Directive (92/43/EEC) provides for the establishment of

protected sites (Special Areas of Conservation (SAC)) as part of the Natura

2000 network, to protect habitats and species of Community interest listed on

Annex I and Annex II respectively of the Directive. It also provides for strict

protection of species of Community interest listed in Annex IV(a) of the

Directive – European Protected Species (EPS).

8.1.9 Article 12 of the Habitats Directive sets out the system of strict protection

which Member States are required to adopt for animal species listed on Annex

IV(a). Article 12(1)(b) prohibits: “deliberate disturbance of these species,

particularly during the period of breeding, rearing, hibernation and migration”;

Article 12(1)(d) prohibits: “deterioration or destruction of breeding sites or

resting places.”


8.1.10 The Birds Directive (2009/147/EC) provides a scheme of protection for all wild

birds naturally occurring in the European Union. Article 4(1) of the Directive

provides for the protection of habitats of birds requiring special conservation

measures (listed in Annex I). Article 4(2) provides for the protection of habitats

of regularly occurring migratory species, with particular reference to the

protection of wetlands. This is undertaken through establishment of Special

Protection Areas (SPA), which also form part of the Natura 2000 network.

8.1.11 Article 4(4) of the Birds Directive states that within the SPA network, Member

States should: “take appropriate steps to avoid (significant) pollution or

deterioration of habitats or any disturbances affecting the birds.” Outside the

protected areas network, they should: “also strive to avoid pollution or

deterioration of habitats.”

8.1.12 Article 2 of the Birds Directive states: “Member States shall take the requisite

measures to maintain the population of the species referred to in Article 1 (i.e.

all wild birds within their natural range) at a level which corresponds in

particular to ecological, scientific and cultural requirements, while taking

account of economic and recreational requirements, or to adapt the population

of these species to that level.”

8.1.13 The 1971 Ramsar Convention on Wetlands provides for the protection of

wetlands of international importance. These are frequently, but not

exclusively, sites which qualify under the selection criteria because of their

ornithological interest.

Implementation of European Legislation in Scotland

8.1.14 The Habitats Directive is implemented in Scotland by the Conservation

(Natural Habitats, &c.) Regulations 1994 (as amended). Regulation 39

implements the system of strict protection applied to EPS.

8.1.15 Procedures for designation of SPAs and duties in relation to wild bird habitat

were incorporated into Scottish law by the Conservation (Natural Habitats,

&c.) Amendment (Scotland) Regulations 2011 and 2012 respectively.


8.1.16 Section 38 of the Nature Conservation (Scotland) Act provides for notification

of Ramsar sites. There is no specific legal framework in Scotland for Ramsar

site protection, but they are typically also designated as European protected

sites.

Scottish Legislation

8.1.17 The Wildlife and Countryside Act 1981, as amended by the Nature

Conservation (Scotland) Act 2004 provide the main national nature

conservation legislation for designation of nationally important sites and

protection of species.

8.1.18 Sites of Special Scientific Interest (SSSI) are nationally important conservation

sites, designated and protected under Part 2, Chapter 1 of the Nature

Conservation (Scotland) Act.

8.1.19 Section 1 of the amended Wildlife and Countryside Act provides for protection

against deliberate or reckless killing or injury of wild birds, their nests and

eggs. Birds listed in Schedule 1 receive additional protection from disturbance

while breeding; Schedule 1A species may not be intentionally or recklessly

harassed at all times, while the nests of Schedule A1 species are protected

from intentional or reckless damage, destruction or interference at all times.

8.1.20 Section 9 of the amended Wildlife and Countryside Act provides for protection

of certain animal species which are listed on Schedule 5. The degree of

protection under Schedule 5 varies; the commoner reptile species in Scotland

(adder, slow worm and common lizard) are protected against deliberate or

reckless killing or injuring, but no protection is given to their habitat.

8.1.21 Section 1 of The Nature Conservation (Scotland) Act 2004 addresses the duty

of public bodies to further the conservation of biodiversity (the ‘biodiversity

duty’), implemented in Section 2 through the Scottish Biodiversity Strategy.

Section 2(4) requires the publication of a list of species of principal importance

for the conservation of biodiversity in Scotland (the Scottish Biodiversity List).


Policy Context

8.1.22 National planning policy applicable across the whole of Scotland is set out in

SPP (the Scottish Government 2014). Policies of direct relevance to this

ecological assessment include:

[194] “The planning system should:

...conserve and enhance protected sites and species, taking account of the

need to maintain healthy ecosystems and work with the natural processes

which provide important services to communities….protect and enhance

ancient semi-natural woodland as an important and irreplaceable resource,

together with other native or long-established woods, hedgerows and

individual trees with high nature conservation or landscape value…seek

benefits for biodiversity from new development where possible, including the

restoration of degraded habitats and the avoidance of further fragmentation or

isolation of habitats…”

[195] “Planning authorities, and all public bodies, have a duty under the

Nature Conservation (Scotland) Act 2004 to further the conservation of

biodiversity. This duty must be reflected in development plans and

development management decisions.”

[203] “Planning permission should be refused where the nature or scale of

proposed development would have an unacceptable impact on the natural

environment. Direct or indirect effects on statutorily protected sites will be an

important consideration, but designation does not impose an automatic

prohibition on development.”

[204] “Planning authorities should apply the precautionary principle where the

impacts of a proposed development on nationally or internationally significant

landscape or natural heritage resources are uncertain but there is sound

evidence indicating that significant irreversible damage could occur. The

precautionary principle should not be used to impede development without

justification. If there is any likelihood that significant irreversible damage could

occur, modifications to the proposal to eliminate the risk of such damage

should be considered. If there is uncertainty, the potential for research,


surveys or assessments to remove or reduce uncertainty should be

considered.”

[214] “The presence (or potential presence) of a legally protected species is

an important consideration in decisions on planning applications. If there is

evidence to suggest that a protected species is present on site or may be

affected by a proposed development, steps must be taken to establish their

presence. The level of protection afforded by legislation must be factored into

the planning and design of the development and any impacts must be fully

considered prior to the determination of the application.”

8.1.23 The Midlothian Local Plan (adopted 2008) includes local policies that are of

direct relevance to this ecological impact assessment, including:

[RP10 Internationally Important Nature Conservation Sites] “Development will

not be permitted where it could adversely affect, either directly or indirectly,

the integrity of a nature conservation site of international importance (Natura

2000 areas), or any other site which is proposed or designated as of

international importance during the lifetime of the Plan, unless it can be

demonstrated that there are imperative reasons of overriding public interest

and:

A. The proposed development would have no significant effect on the

habitats or species being safeguarded; or

B. There are no alternative solutions.”

[RP11 Nationally Important Nature Conservation Sites] “Development will not

be permitted where it could adversely affect, either directly or indirectly, the

integrity of a nature conservation site of national importance, or any other site

which is proposed or designated as of national importance during the lifetime

of the Plan, unless it can be demonstrated that:

A. The objectives of designation and the overall integrity of the area will not

be compromised; or

B. Any significant adverse effects on the qualities for which the area has

been designated are clearly outweighed by social or economic benefits

of national importance.”


[RP12 Regionally and Locally Important Nature Conservation Sites]

“Development will not be permitted where it could adversely affect, either

directly or indirectly, the nature conservation interest of any sites, or wildlife

corridors, of regional or local conservation importance unless the applicant

can show that:

A. The development has been sited and designed to minimise damage to

the value of the site and includes measures that will appropriately

compensate for any damage which cannot be avoided; or

B. The public interest to be gained from the proposed development can be

demonstrated to clearly outweigh the nature conservation interest of the

site.”

[RP13 Species Protection] “Development that would affect a species protected

by law will require an appropriate level of environmental and biodiversity

assessment. Where development is permitted, proposals will require:

A. Measures for mitigation; and

B. Measures for enhancement or sustainable habitat replacement, where

appropriate.”

[RP14 Habitat protection outwith Formally Designated Areas] “In the

assessment of planning applications for development that would affect sites

which contain habitat of some significance (although insufficient to justify a

formal natural heritage designation), effects on the habitat, including the

expected results of mitigation measures, will be taken into account.”

[RP15 Biodiversity Action Plan] “Development proposals shall be expected to

demonstrate compatibility with the aims and objectives of the Midlothian Local

Biodiversity Action Plan and related plans, by identifying appropriate

measures to protect, enhance and promote existing habitats and/or the

creation of new habitats, and provide for the effective management of these

habitats.”


8.2 Methodology

Scope of Investigation

8.2.1 The rationale for the scope of ecological survey and assessment works is set

out in the informal Scoping Report submitted to MLC in January 2014. The

scope of the ecological assessment takes into account the availability of

recent survey data commissioned by Zero Waste: Edinburgh and Midlothian in

2013 to inform the Millerhill RERC development, as well as surveys

commissioned the same year to inform the adjacent AD Facility development.

A suite of ecological surveys had also been undertaken in 2009 of the site and

wider surrounding area to inform the application for PPiP. Based on this data,

an ecological impact assessment was carried out for Zero Waste: Edinburgh

and Midlothian and presented as Chapter 9 of the associated Environmental

Statement.

8.2.2 The 2009 ecological assessment to inform the application for PPiP was

supported by the following surveys:

Phase 1 Habitat and Invasive Plants Survey (David Dodds Ecology,

March – April 2009);

Lower Plants Survey (David Dodds Ecology, March – April 2009);

Breeding Bird Survey (April – June 2009);

Bat Roost Survey (Nov – March 2008-09) and activity survey (June –

Sept 2009);

Reptile Survey (April – September 2009); and

Badger Survey (June 2009).

8.2.3 Although these surveys are all now too old to provide valid data to inform the

current application, they provide useful contextual information, covering a

wider area than the current Application Site, highlight potential issues, and

allow an assessment of change in relation to more recent survey data.

8.2.4 AMEC were subsequently commissioned in 2013 by Zero Waste: Edinburgh

and Midlothian to update the ecological surveys undertaken in 2009. These

further surveys included a vegetation survey (updating the previous Phase 1

Survey), an Invasive Species Search, Bat Survey, Breeding Bird Survey and


Badger Survey. The Bat Surveys followed Bat Conservation Trust (BCT)

guidelines for bat activity surveys appropriate to the habitat quality present,

while the breeding bird survey similarly followed standard methodology used

to support ecological impact assessments.

8.2.5 The informal Scoping Report identified the need for an updated habitat survey,

carried out at an optimum season, in order to provide a more detailed

description of woodland habitats and allow for a better evaluation of the site’s

habitat quality; this was undertaken by Argus Ecology in Summer 2014, and

incorporated a further check on use of the site by protected species. In order

to ensure contextual data were up-to-date and to ensure compliance with data

supply copyright restrictions, a data search was commissioned from The

Wildlife Information Centre for Lothian and the Borders (TWIC) for a 2km

buffer around the Application Site. An online data search was also carried out

of the Scottish Natural Heritage (SNH) website, including downloads of digital

boundary data for statutory designated sites and ancient woodlands (see

Figure 8.1).

8.2.6 As well as surveys commissioned to inform the earlier PPiP and the Millerhill

RERC development, ecological surveys carried out to inform the adjacent AD

Facility development were also consulted. These were carried out by Barton

Wilmore and BSG Ecology in 2012, with a wider geographic scope

encompassing the Application Site. They included an updated Phase 1

Habitat Survey, an Emergence Survey of a possible bat roost identified in the

2009 surveys, and an inspection of possible barn owl roost sites.

8.2.7 Following a review of existing data by Argus Ecology, MLC and TWIC (as

agents of the local planning authority) were consulted to confirm that further

reptile surveys were not necessary to inform the Millerhill RERC application.

Desktop Study

8.2.8 The wider ecological context of the development site has been updated from

information provided in the Environmental Statement for the PPiP application.

Digital boundary datasets for European Conservation Sites (Natura 2000

sites, i.e. SAC and SPA), SSSIs and Ancient Woodland Inventory data have

been downloaded from SNH Natural Spaces website


(https://gateway.snh.gov.uk/natural-spaces/, accessed 08/12/2013). The

location and distance from the Application Site boundary have been

determined by measurement using QGIS 2.6.

8.2.9 Data on protected and priority species, and non-statutory designated

conservation sites were obtained from TWIC for a 2km buffer from the

Application Site boundary.

Phase 1 Habitat Survey

8.2.10 Surveys were carried out on the 9th June and 4th July 2014, of habitats within

the planning application boundary, and adjacent vegetated habitats to the

south. The survey area excluded areas within the footprint of the Proposed

Development which were being used as a haul road to the AD Facility

construction site to the north, or were being actively disturbed as part of the

Borders Rail construction works to the west.

8.2.11 An extended Phase 1 Habitat Survey was carried out to verify habitats on site.

Survey methods followed extended Phase 1 methodology (JNCC, 1993; IEA,

1995). Detailed notes were made on vegetation throughout the accessible

parts of the site in order to provide a full update of previous survey data.

These are presented in a series of ‘target notes’ in accordance with Phase 1

standards supplemented by an abundance-weighted species list subdivided

by habitat compartment in the report. Where possible, the relevant National

Vegetation Classification (NVC) communities (Rodwell, 1991 et seq) were

identified. All species were identified in the field where possible, including

bryophytes and terricolous (ground-living) lichens. Where necessary, selected

bryophyte and lichen samples were collected for expert verification.

8.2.12 As the site had changed significantly since the most recent available OS base

plans and aerial photography, most notably in terms of significant felling of

parts of the woodland, habitat boundaries were mapped in the field as

necessary using a Topcon GMS-2Pro differential GNSS receiver. This can

provide sub-metre accuracy, although this was degraded slightly in places due

to the proximity of the tree canopy.

https://gateway.snh.gov.uk/natural-spaces/


8.2.13 In accordance with Extended Phase 1 methodology, faunal habitat quality was

assessed as part of the habitat survey, with particular reference to assessing

the suitability for the site to support protected species. This included in

particular an assessment of whether the site contained features suitable for

bat or barn owl roosts. Signs of use of the site by badger and other protected

mammal species were searched for, and any birds noted in the course of the

habitat survey were recorded.

Other Relevant Survey Data

8.2.14 The results of the Tree Survey (AJT Consultants, 2015) provide further

evidence of habitat quality, including in particular a description of an area of

scrub to the west of the site which was not accessible in Summer 2014,

information on tree health and longevity, and further confirmation of

conclusions relating to suitability of trees to support bat roosts.

Assessment Criteria

8.2.15 In order to assess the impacts of the development on flora and fauna, it is first

necessary to identify the nature and geographical extent of likely impacts and

identify the component ecological interest features of the receiving

environment. The valuation of ecological features utilises current guidance

produced by the CIEEM (2006). This process assesses the geographical

scale of importance of habitats and species that may be impacted by the

development proposals. It also identifies legal issues, including habitats and

species with legal protection, or with a specific requirement for control (e.g.

invasive alien species).

8.2.16 The evaluation first considers species and habitats subject to legal protection,

before considering other ecological features. These include locally designated

sites, species and habitats listed on the Scottish Biodiversity List. The Scottish

Biodiversity List (SBL) is a list of animals, plants and habitats that Scottish

Ministers consider to be of principal importance for biodiversity conservation in

Scotland. The SBL was published in 2005 to satisfy the requirement under

Section 2(4) of the Nature Conservation (Scotland) Act 2004. The SBL has

been updated to take account of changes to the UK BAP priorities list. Finally,

the assessment takes account of local priority habitats and species listed in


the Midlothian Biodiversity Action Plan (MBAP), and other features of local

importance for nature conservation.

8.2.17 The impact assessment methodology also follows current CIEEM guidelines

(2006), as recommended in a handbook on environmental impact assessment

(SNH, 2013). CIEEM guidance is based on:

The identification of valued ecological resources described above;

The characterisation of potential impacts as a consequence of the

development;

An assessment of the likelihood of occurrence, duration, extent,

magnitude, frequency and reversibility; and

An assessment of impact significance.

8.2.18 The findings of the Air Quality Assessment (Chapter 12.0) provide data to

assess the likelihood of effects on off-site nature conservation designations

and inform the requirements for any detailed appraisal of effects on such

features. This includes impacts on European and nationally designated

conservation sites within 15km of the development, and other sites including

ancient woodlands within 2km of the site. The results of the AQA also inform

the determination of likely significant effect on any European Sites in

accordance with the Habitats Regulations.

8.2.19 The results of the noise assessment (Chapter 11.0) have been considered in

terms of near-site ecological impacts in the vicinity of the development, using

the extent of the 55dB(A)eq noise contour to determine the magnitude of

potential impacts on birds, based on territory mapping within the 2013

Breeding Bird Survey.

8.2.20 In the CIEEM guidelines a significant impact in ecological terms is defined as

an impact on the integrity of a defined site or ecosystem and/or the

conservation status of habitats or species within a given geographical area.

The guidelines do not favour a matrix approach to the assessment of

significance, because these can downplay impacts on features of local

importance, and the ecological meaning of the resulting terms is often poorly

defined. Instead, significance is defined at the geographic scale at which it

occurs.


Limitations

8.2.21 All surveys carried out by were carried out within acceptable seasonal and

weather parameters, and conformed to current guidelines with respect to

duration and frequency. There were some restrictions in access for the Phase

1 Habitat Survey due to site investigation works, while an area in the west of

the site was inaccessible at the time of survey for safety reasons due to

Borders Rail construction work.

8.2.22 The assessment relies partly on the survey work carried out by SLR

Consulting on behalf of Zero Waste: Edinburgh and Midlothian in 2013 and

reported in the documents listed in Paragraph 8.2.4.

8.3 Baseline

Ecological Context

European Designated Sites

8.3.1 Table 8.1 illustrated the European designated conservation sites located

within 15km of the Application Site.

Table 8.1: European Conservation Sites within 15km

Site Status European Site Qualifying Features Location of

Nearest Point

Distance and Direction from Site Boundary

Firth of Forth

SPA,

Ramsar

Waterfowl assemblage (>20,000 waterfowl); non-breeding species: curlew, dunlin, goldeneye, great crested grebe, knot, lapwing, mallard, pink-footed goose, red-breasted merganser, ringed plover, Slavonian grebe, turnstone, wigeon, common scoter, golden plover, long-tailed duck, redshank, shelduck, bar-tailed godwit, cormorant, eider, grey plover, oystercatcher, red-throated diver, scaup, velvet scoter; passage species: Sandwich tern.

333050, 673030

2.35km, NE

Imperial Dock Lock

SPA

Breeding species: common tern 327013, 677300

8.32km, NW

Forth Islands

SPA Breeding: seabird assemblage; gannet, kittiwake, lesser black-backed gull, roseate tern, Sandwich tern, guillemot, razorbill, fulmar, common tern, Arctic tern, cormorant, herring gull, puffin, shag

320713, 680517

14.83km, NW


8.3.2 SPA sites are classified under Article 4 of the EU Birds Directive

(2009/147/EC), to protect rare and vulnerable birds and regularly occurring

migratory species.

8.3.3 In addition to being classified as a SPA Firth of Forth is also listed as a

Ramsar site and SSSI. These designations are largely contiguous, and cover

a large area of 6,313.72ha. Ramsar sites are wetlands of international

importance, listed under the Ramsar Convention.

8.3.4 The following nationally designated nature conservation sites are located

within a 15km buffer of the Application Site boundary. The list below includes

sites designated for biological but not earth science (geological) interest.

Table 8.2: Nationally Designated Conservation Sites within 15km

Site Status Interest Features Location of Nearest Point

Distance and direction from site boundary

Dalkeith Oakwoods

SSSI Oak woodland, wood pasture and parkland, lichen assemblages and beetles

333466,668920 1.96km SE

Duddingston Loch

SSSI Transition open fen, eutrophic loch

328340, 672200 4.14km NW

Arthur’s Seat Volcano

SSSI Acid grassland, calcareous grassland, vascular plants

328100, 672590 4.44km NW

Hadfast Valley SSSI Breeding bird assemblage, scrub 338610, 668810 6.57km SE

Bilston Burn SSSI Upland mixed ash woodland 328680, 664935 6.62km SW

Roslin Glen SSSI Upland mixed ash woodland 328580, 664130 7.35km SW

Wester Craiglockhart Hill

SSSI Lowland acid grassland, lowland calcareous grassland

322900, 670260 9.22km W

Crichton Glen SSSI Upland oak woodland, valley fen, lowland neutral grassland

337860, 661730 10.35km SE

Black Burn SSSI Lowland acid grassland, fen meadow

323675, 658550 14.70km SW

8.3.5 SSSIs are nationally important sites, designated under Section 28 of the 1981

Wildlife & Countryside Act, or Section 3 of the 2004 Nature Conservation

(Scotland) Act.


Non-statutory Designated Sites

8.3.6 TWIC provided details of the following locally designated non-statutory

conservation sites within 2km of the Application Site boundary.

Table 8.3: Non-statutory Designated Conservation Sites within 2km

Site Status Interest features Location of nearest point

Distance and

direction from site boundary

Edmonstone UWS LBS

Open parkland and mature woodland. Common pipistrelle roost.

330376, 670045 1.87km WSW

Dalkeith Estate LBS Open parkland and woodland 332845, 668742 1.87km SSE

Disused Railway Network

UWS Areas of mature woodland and scrub that provide habitat for a variety of species and function as a wildlife corridor.

332935, 671760 1.1km NE

Brunstane Burn UWS Riparian corridor with stream, woodland and grassland.

332552, 672649 1.79km NNE

8.3.7 Urban Wildlife Sites (UWS) (City of Edinburgh only), and Local Biodiversity

Sites (LBS) are non-statutory sites of local level importance, and protected

under local authority planning policies.

Ancient Woodland and Other Woodland Sites

8.3.8 Table 8.4 below illustrates Ancient Woodland sites which are located within a

2km buffer of the Application Site boundary.

Table 8.4: Ancient woodlands within 2km

Site* Interest Features Location of Nearest Point

Distance and Direction from Site Boundary

Newhailes Ancient woodland 332600,672283 1.52km NE

Eastfield Wood Ancient woodland 333851, 670393 1.46km ESE

Wood East of Newton Ancient woodland 333788, 669706 1.63km SE

Howland’s Park Ancient woodland 333080, 668893 1.79km SSE

Wood East of Newton Church Ancient woodland 333653, 669180 1.86km SE

* Ancient woodland names not given in SNH database, taken from nearest points of woodland groups on OS 1:25000 map.


8.3.9 Whether or not they have a statutory or non-statutory conservation

designation, ancient woodlands are significant in nature conservation terms as

they represent ‘critical natural capital’, which cannot be readily re-created.

They are frequently protected under local planning policies. They can also be

regarded as sensitive receptors with respect to changes in air quality.

8.3.10 The Forestry Commission Scotland (FCS) website mapping tool

(www.maps.forestry.gov.uk) shows the results of the Native Woodland Survey

of Scotland. The map indicates that the Application Site is located within a

17.5ha area of lowland mixed deciduous woodland (ID 950154828) described

as: ‘young native woodland’, with the dominant structure being immature. The

site is not ancient woodland.

Protected and Priority Species

8.3.11 The following protected species records were received from TWIC. These

include:

EPS listed under Schedule 2 of the Habitats Regulations 1994 (CHS-2)

and Annex 4 of the EU Habitats Directive (HD-4);

Animals protected in Scotland under Schedule 5 of the Wildlife &

Countryside Act 1981 (W5) as amended; and

Birds with special protection under Schedule 1 of the Wildlife &

Countryside Act 1981 as amended (W1) and Protection of Badgers Act

1992 (BA).

8.3.12 All records illustrated in Table 8.5 over the page are within a 2km radius, but

none relate to the Application Site or its immediate environs.

http://www.maps.forestry.gov.uk/


Table 8.5: Protected Species Records

Species Status Grid reference / details Distance and direction from site boundary

Bat Chiroptera CHS-2, HD-4, W5 & SBL

Inveresk Lodge NT 34 71

Edmonstone Terrace NT 309 697

Newhailes Estate NT 326 725

1.65km E

1.55km SW

1.68km NNE

Otter Lutra lutra CHS-2, HD-4, W5 & SBL

River Esk NT 338 717

Water of Leith NT 315 691

1.76km NE

1.57km SW

Badger Meles meles BA SBL SO1 Newhailes Estate NT 326 725 1.70km NNE

Common crossbill Loxia curvirostra

W1 Newhailes Estate NT 327 724 1.64km NNE

Fieldfare Turdus pilaris W1 Musselburgh NT 335 721

Newhailes Estate NT 325 727

1.73km NE

1.84km NNE

Redwing Turdus iliacus W1 Newhailes Estate

NT 326 725

NT 325 727

NT 329 727

NT 330 724

NT 327 724

1.7km NNE

1.88km NNE

1.95km NE

1.69km NE

1.59km NE

8.3.13 TWIC also supplied data on priority species records within a 2km buffer

around the Application Site. A number of priority species including SBL

species, UK Biodiversity Action Plan (UK BAP) (PS) and local BAP species

have been recorded within the search area including City of Edinburgh (C),

East Lothian (E) and Midlothian (M) local BAP priority species. Only one

record relates to the site: woodcock Scolopax rusticola, with a grid reference

given as NT 3226 7071 (332660, 670710). This is a SBL species, listed

because a decline of 25% or more in abundance or range has occurred in

Scotland over a recent 25 year period. Other species that have been recorded

in the wider 2km search area include:

Skylark Alauda arvensis (SBL, E, C);

Grey partridge Perdix perdix (SBL, PS, E, C);

Swift Apus apus (SBL, E, C);

Yellowhammer Emberiza citronella (PS, C);

Linnet Carduelis cannabina (SBL, E, C);

Brown hare Lepus europaeus (SBL, PS, E, C);

European hedgehog Erinaceus europaeus (PS);

Grayling Hipparchia semele (PS); and

Pyramidal orchid Anacamptis pyramidalis (E, very local distribution).


Local Ecological Context

8.3.14 The site is located on a former area of the Millerhill rail marshalling yard which

was abandoned and became colonised with birch woodland, established on

made ground including colliery spoil and ballast. The currently active area of

rail sidings is located to the east of the Application Site. A new access road for

the AD plant and site is in the process of construction between the site and rail

sidings.

8.3.15 An AD Facility is located to the immediate north of the Application Site, and at

the time of writing is in the process of being constructed. The newly

constructed Borders Railway runs in cutting to the north and west of the site.

The remaining area of former rail sidings to the south of the site support birch

woodland, interspersed with areas of open ballast.

8.3.16 To the west of the site, former arable fields and a reclaimed waste tip are

being developed as the new settlement of Shawfair, a large residential

complex with commercial and retail space and a new rail station. The local

ecological context is therefore one of significant recent and on-going

urbanisation and attendant habitat change, particularly to the west and north

of the Application Site.

8.3.17 OS maps and aerial photography show no surface watercourses in the vicinity

of the Application Site. A small drain flows east from the adjacent rail sidings

towards the River Esk, which discharges into the Firth of Forth circa 3.4km

north-west of the Application Site boundary.

Habitats and Vegetation

8.3.18 Habitats within the site are described more fully in Extended Phase 1 Habitat

Survey (Appendix 8-1). This provides a detailed description of species

composition and is described in a series of target notes in accordance with

Phase 1 methodology. The table below is adapted from the habitat survey,

with additional cross-referencing to European Nature Information System

(EUNIS) habitats in accordance with current SNH practice (Strachan, 2015):


Table 8.6: Habitats Present on Site

EUNIS category (level 3/4) Phase 1 category Area (ha)

G1.91 Birch woodland not on marshy terrain

A1.1.1 Broadleaved semi-natural woodland

2.3

F3.13 Atlantic poor-soil thickets A2.1 Dense scrub 0.08

E5.1 Anthropogenic herb stands C.3.1 Tall ruderal 0.1

G5.8 Recently felled areas A.4 Recently felled woodland

(retaining vegetation)

1.09

G5.8 Recently felled areas A.4 Recently felled woodland

(with bare ground)

0.33

E5.22 Thermophile woodland fringes – mesophile fringes

B2.1 Unimproved neutral grassland

0.04

(various – road / construction area, bare ground, small areas of woodland and scrub not accessible for survey)

1.49

Birch Woodland

8.3.19 The largest area of habitat within the site comprised secondary silver birch

(Betula pendula) woodland, covering 2.3ha. Although well-established, this is

of relatively recent origin, with trees mostly less than 12-14m high,

interspersed with areas of younger birch trees. The Tree Survey assessed the

majority of tree groups as having a low value, with limitations to growth

imposed by the nature of the substrate, and some wind-throw. The age of the

trees was assessed as being up to 20 – 25 years.

8.3.20 The field layer vegetation was atypical compared to semi-natural birch

woodland communities, reflecting the mixed nature of the artificial substrate,

and including flora typical of both base-rich and acidic soils. Abundant field

layer species included rosebay willowherb (Chamerion angustifolium), wild

strawberry (Fragaria vesca), Yorkshire fog (Holcus lanatus) and perforate St.

John’s-wort (Hypericum perforatum). The bryophyte layer was luxuriant in

places; both the 2009 lower plant survey and 2014 habitat survey found that

this was composed of common species such as Pseudoscleropodium purum.

Lichens were also locally frequent, including Peltigera and Cladonia species.

8.3.21 Many semi-natural birchwoods in eastern Scotland are examples of the W11

oak (Quercus sp.) – downy birch (Betula pubescens) – wood sorrel (Oxalis

acetosella) NVC community. This is a community of relatively base-poor soils;

reference to the description and floristic tables in British Plant Communities


(Rodwell, 1991) indicates a poor correspondence with this community on the

Application Site, with few characteristic species present, with the exception of

some of the mosses such as Pseudoscleropodium and Rhytidiadelphus

triquetrus. This is likely to be a consequence both of the recent age of the

woodland, and the substrate on which it has established.

8.3.22 Woodland to the south of the Application Site was similar in structure and

species composition, additionally including partially-vegetated clearings in

areas where a greater depth of coarse track ballast remained at the surface.

Other Habitats

8.3.23 Large areas of the woodland had been felled by Summer 2014, creating

clearings and broad access corridors which were bare or sparsely vegetated,

in places retaining remnants of the original woodland field layer vegetation. A

large pile of stumps and brash had been placed in the largest, northern

clearing.

8.3.24 Other habitats included a very small area of neutral grassland with Yorkshire

fog and wild strawberry in the south of the site, close to two small areas of

dense scrub with goat willow (Salix caprea) and broom (Cytisus scoparius). A

small patch of tall ruderal (disturbed-ground) vegetation occupies an area in

the north of the site.

Fauna

Bats

8.3.25 The 2013 Bat Surveys found relatively low levels of activity within the site and

the wider survey area, which took in the whole of the vegetated former rail

sidings, including land well to the south of the Application Site. Soprano

pipistrelle (Pipistrellus pygmaeus) were most frequently recorded, with smaller

numbers of common pipistrelle (Pipistrellus pipistrellus); static detector

surveys also recorded very low levels (1-2 passes) of Nyctalus sp. (in

Midlothian, almost certainly noctule, Nyctalus noctula), and brown long-eared

bat (Plecotus auritus).


8.3.26 A bat roost had previously been located in 2008 in a brick retaining wall

located approximately 300m south of the site boundary. This was investigated

in 2009 and 2012 (in the AD Facility surveys) with emergence surveys, and

was used as a static monitoring location in the 2013 surveys. No further use of

this structure by bats has been confirmed.

8.3.27 Within the Application Site, as none of the trees are fully mature, they are

lacking in crevice and cavity habitats which would make them potentially

suitable as bat roosts. There are no other structures within the proposed

development boundary which would be capable of supporting a bat roost.

8.3.28 Current site conditions differ from earlier surveys in terms of bat foraging

habitat quality. Woodland clearance within the site will have temporarily

improved bat foraging habitat quality by increasing the amount of edge habitat

and sheltered rides, but in the absence of a high bat population in the wider

area are unlikely to result in a significant increase in bat activity, as surveys

inferred the nearest roosts were likely to be some distance from the site.

Badger

8.3.29 TWIC hold records of badger over 1.7km from the site and the 2013 surveys

by AMEC noted that the site provided suitable habitat for badger, with the

woodland areas providing a suitable location for setts.

8.3.30 The 2014 extended Phase 1 Habitat survey checked areas of rabbit holes,

which were frequent near the eastern boundary of the woodland where

adjacent rail tracks had been constructed on different levels, now forming a

‘terraced’ appearance within the woodland. No signs of use by badger were

found, which supported and confirmed the findings of earlier surveys.

Furthermore, badger habitat quality is not particularly high across the

Application Site, largely because of the immature soils likely to support a

limited earthworm population. Even over better-vegetated parts of the

woodland ground flora, soils appear to consist of a relatively thin layer of

surface humus over colliery spoil or railway ballast.


Riparian Mammals

8.3.31 As noted above, TWIC hold records of otter (Lutra lutra) in the wider area on

the River Esk and Water of Leith. There are no suitable habitats on site to

support riparian mammals such as otter or water vole.

Reptiles

8.3.32 A dedicated reptile survey in 2009 found no evidence of reptiles within the

Application Site or wider survey area, but in the 2013 surveys there was an

incidental record of common lizard (Zootoca vivipara) at the northern

boundary, adjacent to land which has now been cleared and is in the process

of being developed as the AD Facility.

8.3.33 Although recent disturbance associated with the AD Facility construction and

tree felling on the Application Site is likely to have displaced lizards, the piles

of tree stumps and brash noted above as present in Summer 2014 are located

only around 50m south of the location of the previous record location, and

provide a suitable hibernation site. Open areas with patches of bare ground

close to areas of denser cover also provide suitable summer basking habitat.

Breeding Birds

8.3.34 The results of breeding bird surveys reported by AMEC in 2013 provide an

assessment of the number of breeding territories within the Application Site.

These comprise common passerines of woodland habitats, with 7 willow

warbler (Phylloscopus trochilus) territories, 3 robin (Erithacus rubecula), 2

chaffinch (Fringilla coelebs), 1 blackcap (Sylvia atricapilla) and 1 wren

(Troglodytes troglodytes).

8.3.35 Birds noted in the course of the 2014 Habitat Survey were consistent with the

results of the 2013 bird survey, although the area of suitable breeding habitat

had declined through woodland clearance. Species such as willow warbler

which were found in relatively high densities in the 2013 survey were

prominent, together with wren, robin, chaffinch, chiffchaff (Phylloscopus

collybita), blackcap and greater spotted woodpecker (Dendrocopos major).


Ecological Interest Features

Designated sites

8.3.36 Tables 8.1 and 8.2 list the statutory designated sites within a 15km buffer;

Table 8.3 lists non-statutory sites within a 2km buffer of the Application Site.

European designated sites such as SPAs can be considered interest features

of international importance; SSSIs can be considered as being of national

importance. Local non-statutory sites and ancient woodlands can be

considered to be of local interest.

8.3.37 There are no statutory or locally designated conservation sites within or

adjacent to the Application Site. The nearest statutory designated site is

Dalkeith Oakwood SSSI, located 1.96km to the south-east of the site

boundary. Firth of Forth SPA, Ramsar site and SSSI is located 2.35km to the

NE, and is hydrologically connected via the River Esk.

Protected Species

8.3.38 In order to assess the level of value of protected species as ecological interest

features, it is important to consider the following aspects separately:

Their scale of importance on site, including the extent to which the site

contributes to the maintenance of their conservation status in the wider

area; and

Their level of legal protection, in order to later assess whether the

proposed development may contravene this protection.

8.3.39 For example, it may be possible that the site could be of negligible value for a

EPS, and any impacts would not be significant in EIA terms. However,

because of strict legislative protection, there may nevertheless be a risk of

committing an offence which would require the implementation of avoidance

measures; if avoidance is not possible, a SNH disturbance licence would be

required.

8.3.40 As noted above, four species of bat have been recorded foraging within the

Application Site and / or the wider area of wooded rail sidings, although only

two species (soprano and common pipistrelle) were frequently recorded. The


absence of a nearby roost site, and relatively low levels of activity detected

indicate that the site is of no more than local value for bats.

8.3.41 All bat species are EPS, listed on Annex IV of the Habitats Directive and

Schedule 2 of the Habitats Regulations 1994 (as amended).

8.3.42 No bird species listed on Annex I of the Birds Directive or having special

protection under Schedule 1 of the Wildlife and Countryside Act 1981 have

been recorded within the Application Site. The 2012 AD Facility survey

recorded a barn owl roost (a Schedule 1 species) to the north of that site,

under a bridge. Habitat quality for barn owl was assessed as low in the 2013

breeding bird surveys, and no further evidence was found. The assessment

baseline conditions of increased urbanisation of farmland to the west of the

site (associated with the Shawfair and Borders Railway developments) are

likely to further reduce habitat quality for barn owl in the wider vicinity of the

Application Site; barn owl require rough grassland habitats with a good small

mammal population, coupled with suitable roost sites in structures such as

farm outbuildings. Although use of the site on occasion cannot be ruled out,

for the above reasons it can be considered as being of at most negligible

interest for barn owl.

8.3.43 Evidence of other breeding birds was found on site, with woodland, scrub and

tall herb habitats providing reasonable cover. The total of fourteen territories

recorded in 2013 all comprised common species, although one species has a

declining population (see below). The breeding bird assemblage can be

regarded as a feature of local interest.

8.3.44 The population size of common lizard in the site and surroundings appears to

be low, with only one record from all surveys, including a dedicated reptile

survey in 2009, before any construction works and disturbance of habitats

took place. However, as common lizard are very difficult to accurately assess,

a precautionary approach would suggest that there could be a population of

local conservation interest utilising the site. Woodland clearance and creation

of a pile of stumps and brash may have recently improved common lizard

hibernation habitat; although there is no evidence of habitat utilisation, a

precautionary approach should be taken which assumes likelihood of

occupancy. Common lizard have partial protection under the Wildlife and


Countryside Act 1981 (as amended) against intentional or reckless killing or

injuring.

Priority Habitats and Species

8.3.45 Section 1 of the Nature Conservation (Scotland) Act 2004 places an obligation

on public bodies to conserve biological diversity in accordance with the 1992

UN Convention on Biological Diversity. A list has been published of habitats

and species considered to be of principal importance for the conservation of

biological diversity in Scotland (the SBL).

8.3.46 SBL habitats and species are classified into four Categories for Action:

Conservation action needed;

Avoid negative impacts;

Watching brief only; and

Communicating with the public (iconic habitats and species of cultural

significance).

8.3.47 The identification of priority habitats is facilitated by reference to descriptions

published by Biodiversity Scotland. The woodland areas can be considered to

fall within the category of lowland mixed deciduous woodland UK BAP / SBL

priority habitat. As noted earlier, it is atypical of woodland communities due to

its origin on an artificial substrate, while the Tree Survey emphasises the poor

tree condition resulting from difficult soil conditions; it does not closely match

the descriptions of the priority habitat either. However, this does not

necessarily endow it with a lower conservation value and its inclusion within

the Forestry Commission Native Woodland Survey of Scotland (Forestry

Commission, 2014) further supports its classification as lowland mixed

deciduous woodland. They identify the site as being located within a 17.5ha

area of lowland mixed deciduous woodland, although felling to accommodate

the AD plant, access road and bridge, and works within the site have reduced

this to around 8ha located to the south of the site.

8.3.48 The importance of the woodland on site also has to be seen in the context of

the wider Regional / County context. Midlothian is noted as having a total of

671ha of lowland mixed deciduous woodland, so the woodland in which the


site is located accounted for 2.6% of this resource prior to the AD Facility and

road construction and partial felling on site. The remaining 2.3ha of woodland

on site is equivalent to 0.34% of the County-wide resource. It can therefore be

regarded as a feature of local importance as part of the wider woodland area

established on the former sidings.

8.3.49 The four bat species recorded within the Application Site are also priority

species; they have been evaluated above as EPS.

8.3.50 No other priority species have been recorded on site, although the breeding

bird survey recorded a number of species within the wider survey area, which

could conceivably utilise the Application Site for foraging on occasion.

Local BAP Priority Habitats

8.3.51 The site falls within the definition of Brownfield Land local priority habitat in the

Local Biodiversity Action Plan (LBAP) for Midlothian. This highlights coal spoil

heaps, shale bings and derelict mill sites as particular features of the

Midlothian area; the site’s vegetation shares some characteristics of colliery

spoil heaps and shale bings, and could be considered to be of local

conservation interest.

Other Ecological Interest Features

8.3.52 Willow warbler is on the British Trust for Ornithology (BTO) Amber List of Birds

of Conservation Concern (BOCC), due to a moderate decline in breeding

population (>25 - <50%) over both longer-term (40 year) and shorter-term (25

year) periods. This is the only species of higher conservation value recorded

breeding within the Application Site is willow warbler. Although it remains a

common and widespread migratory species, because of the favourable habitat

conditions (birch woodland with varied structure) leading to a relatively high

breeding density (7 pairs in 2013), can be considered a feature of local

conservation interest as part of the breeding bird assemblage.


Invasive Species

8.3.53 No plant or animal species listed on Schedule 9 of the Wildlife & Countryside

Act 1981 (as amended) were recorded within the site during any of the

surveys.

Summary of Ecological Interest Features

8.3.54 The table below summarises the ecological interest features identified above

with an indication of their geographical scale of importance. These are the

features which will be considered as sensitive receptors for the purposes of

the EcIA.

Table 8.7: Summary of Ecological Interest Features

Feature Legal and National Policy Status

Scale of Importance

Firth of Forth SPA and Ramsar Site

Imperial Dock Lock SPA

Forth Islands SPA

Article 4 Birds Directive; Habitats Regulations 1994 (as amended in Scotland); Scottish Planning Policy (2014), paras. 194, 195, 196, 203-04, 207-08, 211.

Features of international importance within 15km of site to be considered in terms of air quality or other indirect impacts.

Firth of Forth SSSI

Dalkeith Woodlands SSSI

Arthur’s Seat Volcano SSSI

Duddingston Loch SSSI

Hadfast Valley SSSI

Bilston Burn SSSI

Wester Craiglockhart Hill SSSI

Crichton Glen SSSI

Black Burn SSSI

Section 3-11 Nature Conservation (Scotland) Act 2004; Scottish Planning Policy (2014), paras. 194, 196, 203-04 & 212.

Feature of national importance within 15km of the site to be considered in terms of air quality or other indirect impacts.

Edmonstone UWS / LBS

Dalkeith Estate LBS

Disused Railway Network UWS

Brunstone Burn LWS

Scottish Planning Policy (2014), paras. 196-97.

Feature of local importance within 2km of the site to be considered in terms of any potential indirect impacts.

Newhailes ancient woodland

Eastfield Wood ancient woodland

Wood east of Newton ancient woodland

Howland’s Park ancient woodland

Wood East of Newton Church ancient woodland

Scottish Planning Policy (2014), paras. 194, 201, 216 & 218

Feature of at least local importance within 2km of the site to be considered in terms of air quality impacts.


Feature Legal and National Policy Status

Scale of Importance

Lowland mixed deciduous woodland (G1.91 birch woodland) priority habitat

Scottish Planning Policy (2014), para. 195.

Feature of local importance within site.

Bats Annex Iva Habitats Directive; Schedule 2 1994 Habitats Regulations (as amended in Scotland); Scottish Planning Policy (2014), paras. 194, 195 & 214.

Feature of local importance on site;

EPS to be considered in terms of legislative compliance.

Breeding bird assemblage 1981 Wildlife & Countryside Act (as amended in Scotland); Schedule 6, 2004 Nature Conservation (Scotland) Act; Scottish Planning Policy (2014), para. 194, 214.

Feature of local importance on site;

Legal protection against deliberate or reckless killing or injury, to be considered in terms of legislative compliance.

Common lizard Schedule 5 1981 Wildlife & Countryside Act (as amended in Scotland); Scottish Planning Policy (2014), para. 194, 214

Feature of up to local importance on site;

Legal protection against deliberate or reckless killing or injury, to be considered in terms of legislative compliance.

Brownfield site Scottish Planning Policy (2014), paras. 195, 197, 217 & 218. Midlothian BAP.

Secondary woodland, scrub and grassland habitat; local importance.




granted planning consent. The assessment of effects in this scenario seeks to

set out in brief any additional ecological effects that would derive from the

Proposed Development, over and above those deriving from the consented

PPiP development which it would effectively replace.




8.4.1 A number of mitigation measures have been incorporated into the scheme

design, construction and operational procedures in order to avoid, reduce or

compensate for potential adverse ecological impacts. These include:

Measures incorporated into the combustion and energy generation

processes to avoid or reduce emissions, which are outlined in the

scheme description contained within Chapter 4.0 and the AQA in

Chapter 12.0;

Measures are incorporated into construction methods and operational

procedures in accordance with the SEPA guidelines in order to reduce

the risk of any potential impacts on the water environment, as described

in Chapter 10.0;

Measures incorporated into the site design to reduce the extent of light

and noise pollution, as described in Chapters 3.0 and 11.0; and

Measures incorporated into the site’s landscape design to replace

woodland habitat loss and maintain or enhance the biodiversity interest

of the site, as illustrated in the Indicative Landscape Masterplan (Figure

7.4).

Construction Phase Impacts – Existing Baseline

Direct Impacts on Habitats and Species

8.4.2 Construction works will result in loss of the habitats listed in Table 8.7 above,

although efforts will be made to retain the eastern fringe of birch woodland

during construction, as shown in Figure 7.4 (Indicative Landscape

Masterplan). Based on current construction plans all areas required for offices

/ staff facilities, parking, storage and pre-assembly can be accommodated

within the Application Site boundary, and there will be no requirement for

additional habitat loss outside of this area.

8.4.3 The loss of 2.3ha of lowland mixed deciduous woodland habitat represents a

reduction of 13.1% in the original woodland resource present on the wider


Millerhill sidings site, and could be seen as a moderate magnitude impact in a

local context.

8.4.4 Bat foraging habitat will be degraded over the site due to the loss of sheltered

woodland edge and glade habitats and their associated insect prey species.

No roost sites will be affected, and since the site now lies on the northern

edge of the wooded rail sidings, with the AD Facility to the north, habitat

connectivity will not be adversely affected. The loss of foraging habitat is a low

magnitude impact due to the relatively low bat activity levels recorded in

surveys.

8.4.5 Habitat loss will result in the displacement and loss of nesting habitat for up to

14 territories in total of five woodland breeding bird species, including seven

territories of an Amber List species, willow warbler. There will also be a loss of

potential foraging habitat for species breeding in adjacent habitats, and loss of

foraging habitat for birds outside the breeding season. If further vegetation

clearance works are carried out during the breeding season, there is a risk of

loss of nests and eggs and killing or injuring young birds.

8.4.6 Construction activity on site, with associated noise, vibration and movement of

plant is likely to result in displacement of common lizard from the site and its

surroundings. There is also a risk of killing or injuring lizards during the

removal of piles of tree stumps and brash, particularly if this is carried out

during the hibernation season.

Indirect impacts on habitats and species

8.4.7 Potential adverse indirect ecological impacts during construction include:

Disturbance of wildlife in adjacent habitats due to noise, lighting,

vibration and human activity; and

Pollution of adjacent land as a consequence of leakage of hydrocarbons

from plant or stored fuels, and deposition of waste materials from

construction operations.

8.4.8 The risk of significant indirect ecological impacts is lessened by the lack of

sensitive ecological receptors in close proximity to the Application Site. The

recently constructed AD Facility to the north, Borders Rail line and Shawfair


urban development to the west, and active rail sidings to the east are not

sensitive to disturbance impacts. The birch woodland to the immediate south

of the site does support breeding birds and foraging bats, and is a likely to

support a small population of common lizard, and can be considered a

sensitive receptor to near-site effects.

8.4.9 The magnitude of disturbance impacts would vary according to the time of

day, season of operations and species group concerned. They would tend to

be greater in spring for birds during the breeding season, and in spring and

autumn for bats when activity periods coincide with working hours. Human

activity involved with construction at height, sudden construction noise, and

high intensity lighting are likely to be the most disturbing activities. Movement

of vehicles and plant is generally less disturbing, with some habituation of

birds likely. All of these disturbance effects are likely to be of short duration,

with the likelihood of recovery following completion of the activity.

8.4.10 With respect to lighting impacts, the proposed working hours of 07:00 –

19:00hrs Monday to Friday and 07:00 – 12:00hrs Saturday will have limited

effects on the bat flight activity period, with any overlap limited to small periods

of the spring and autumn. As noted in Chapter 4.0, low-level lighting of

security compounds may be necessary outside these periods, but this is likely

to result in a low level of light spillage and consequently limited disruption to

nocturnal wildlife.

8.4.11 The Surface Water and Flood Risk Chapter (see Chapter 10.0) assesses the

risk of water pollution of downstream habitats during construction as short

duration and minor adverse in significance. Any risks would be minimised by

measures outlined in Chapter 10.0 and summarised in the Incorporated

Mitigation section above, and implemented through a CEMP produced in

accordance with the SEPA guidelines.

8.4.12 The AQA does not predict any adverse impacts on sensitive ecological

receptors as a consequence of the construction phase of the Proposed

Development. With implementation of incorporated mitigation measures, local

scale impacts such as dust deposition to adjacent vegetation would be

minimal and very unlikely to have a measurable ecological effect.


Impacts on Ecological Interest Features

8.4.13 Table 8.8 lists the potential construction phase impacts on ecological interest

features identified in the preceding section.

Table 8.8: Construction Phase Impacts on Interest Features

Interest Feature Potential Impact and Magnitude / Extent

Risk of Occurrence, Duration and Reversibility

Lowland mixed deciduous woodland

Loss of up to 2.3ha, moderate magnitude in local context

Certain to occur. Can be partially reversed by tree and shrub planting in landscape scheme.

Bats Loss of foraging habitat for low numbers of bats, mainly soprano pipistrelle

Certain to occur during the construction phase. Can be partially mitigated by tree and shrub planting in the landscape scheme.

Breeding bird assemblage Displacement of breeding birds on site (14 territories) and disturbance of birds adjacent to site.

Certain to occur, risk of wider impacts depends on nature and timing of operations, medium term (>2-3 years), partly reversible with mitigation.

Common lizard Displacement of probably small population and potential killing / injury of common lizard.

Possible occurrence during site clearance of piles of brash. Can be avoided through method statement.

Brownfield habitat Loss of 5.43ha of habitats within the brownfield site including birch woodland, scrub, tall herbs, grassland and vegetated clearing.

Certain to occur during the construction phase. Can be partially mitigated through compensatory planting and landscape scheme.

Construction Phase – Assessment Against PPiP Future Baseline

8.4.14 The PPiP scheme proposed two options, one of which (option ‘A’, drawing no.

25640-G012-K) would require the greater part of the birch woodland to be

cleared in order to accommodate the development.

8.4.15 The PPiP scheme does not set out construction methods in detail, but it is

reasonable to assume that they would require the use of additional areas to

accommodate site compounds, storage or pre-assembly areas.

8.4.16 It is reasonable to assume that the PPiP scheme would carry out similar

precautions to limit the risk of indirect impacts on the water environment in

accordance with legislative requirements and the SEPA guidance, as well as

measures to limit construction noise and light spillage.


8.4.17 The PPiP development is therefore likely to result in a significantly greater

impact of lowland mixed deciduous woodland priority habitat and brownfield

land local BAP priority habitat, together with all associated fauna including the

breeding bird assemblage. With reference to the 2013 breeding bird survey,

this would involve loss of a further 25 territories from the area to the south of

the current Application Site, including six willow warbler territories. In addition,

the area supports one yellowhammer territory and a song thrush territory; both

are SBL species, albeit not in the highest risk categories (song thrush: ‘avoid

negative action’ category; yellowhammer: ‘watching brief category).

Operational Phase – Existing Baseline

Summary of Potential Ecological Impacts

8.4.18 The operational phase of the Proposed Development would not result in any

additional direct impacts in terms of land-take and consequent habitat loss.

The habitats created in the landscaping scheme and the development of

ponds will start to offset habitat losses during the construction phase, leading

to positive impacts through habitat enhancement for amphibians and other

wildlife.

8.4.19 Potential indirect adverse impacts during the operational phase may arise due

to the ecological effects of lighting, noise, human disturbance and emissions

to air and water. These are considered in further detail below.

Potential Ecological Impacts of Lighting

8.4.20 Light spillage from the site into adjoining wooded habitats to the south and

landscaped areas within the site could potentially disrupt bat foraging

behaviour, and affect nocturnal flying insect behaviour. Published levels with

observed ecological effects range from 1 lux to over 4 lux, depending on

spectral quality. Effects are species-specific, with the pipistrelle species which

have been most frequently recorded on site being less sensitive. Lighting

impacts also have to be assessed in comparison with the current baseline,

which includes tall lighting towers over the Millerhill Marshalling Yards.


8.4.21 Chapter 4.0 describes a number of incorporated mitigation measures to

address external light spillage. Light sources will include the translucent

building façade, low-level lighting in operational areas and along paths, and

lighting columns along the public path which will be constructed around the

northern and western boundaries of the site. These will be unlikely to prevent

utilisation of wooded habitats adjacent to the site, or newly-created wetland

and woodland habitats within the site by common and soprano pipistrelle bats.

Potential Ecological Impacts of Noise

8.4.22 There are no regulatory standards applied to noise impacts for the protection

of ecological receptors. Based on studies carried out by the University of

Hull’s Institute of Estuarine and Coastal Studies, a noise level of 55dB(A) can

be considered as a threshold at which disturbance of sensitive species of

waders may occur. Passerines (perching birds) are generally thought to be

less sensitive, although behavioural effects and in some species a reduction in

breeding success can occur. This is probably a consequence of the masking

effect of certain frequencies (e.g. from road traffic noise). The ‘A’ weighting

used to adjust sound pressure levels to the frequency range of human hearing

can be applied to birds, and is slightly precautionary.

8.4.23 The Noise Assessment predicts day-time and night-time noise levels to be

well below the 55dB(A)eq level at the site boundary (see Appendix 11-6,

Noise Mapping), and noise from the Proposed Development will not therefore

have a discernible ecological effect on adjoining habitats.

Potential Disturbance Impacts

8.4.24 There will be some increase in human disturbance as a consequence of the

Proposed Development, with vehicle movements and activity generated by the

operation of the RERC. There will also be public access to some of the

landscaped areas of the site, including grassland, ponds and some of the

woodland habitats, as illustrated by Figure 7.4.

8.4.25 Disturbance levels may be sufficient to prevent utilisation of the new

landscape by some sensitive species, possibly including reptiles such as

common lizard. However, this has to be seen in the context of the concurrent


urbanisation of the wider environment, with a consequent shift to species

which are adapted to more urban habitats.

8.4.26 As a working facility, the proposed development is unlikely to generate

significant additional human disturbance on habitats outside of the site.

Potential Ecological Impacts of Emissions to Air

8.4.27 In ecological terms, the emissions of greatest potential concern are oxides of

nitrogen, sulphur dioxide and ammonia, because of their fertilising or

acidifying effect on ecosystems. Nitrogen dioxide and ammonia have a

fertilising effect and all three can have an acidifying effect when deposited to

soils and vegetation (the alkaline gas ammonia as a source of hydrogen ions).

Sensitivity varies between habitats and particular components of habitats and

is reflected in a series of Critical loads (CL) for deposition of nitrogen and

acidity. Because of their potential to affect sensitive ecological receptors

remote from the site, including European designated sites, it is important to

give careful consideration to these potential adverse ecological impacts.

8.4.28 The AQA modelled the cumulative air quality impacts of the Proposed

Development (with 75m stack) and the adjacent AD Facility for sensitive

ecological receptors within 15km of the site. The AD Facility was not included

in the ammonia modelling as it does not produce significant emissions.

8.4.29 In accordance with the SEPA guidance, significance thresholds for ecological

effects are set for a process contribution (PC) of 1% of the long-term (annual)

critical level or critical load, and 10% of the short-term (24-hour) critical level. If

the predicted environmental concentration (PEC) resulting from the

background levels and PC is <70% of the relevant critical level or load, then

the process contribution can be screened out as insignificant. Where the PC

exceeds 1% and the PEC 70%, assessment of potential ecological effects has

been carried out.

8.4.30 For oxides of nitrogen, none of the predicted PCs exceeded the short-term

threshold. A number of sites exceeded the 1% long-term threshold, including

five of the modelled receptor locations at Firth of Forth SPA / Ramsar / SSSI,

together with Newhailes and Eastfield Wood ancient woodlands. The


maximum PC (at Newhailes) was 1.5%. However, in every case the PEC is

<70% of the critical level for protection of ecosystems of 30µg/m3, and can be

screened out as insignificant.

8.4.31 For sulphur dioxide, all the process contributions were less than the 1% long-

term threshold of the critical level for protection of ecosystems of 20µg/m3; the

PC was also less than the lower critical level for sites with sensitive lichen

communities of 10µg/m3 applied to Dalkeith Oakwood SSSI. Modelled

background concentrations are also all well below critical levels.

8.4.32 For ammonia, all the process contributions were less than the 1% long-term

threshold of the critical level for protection of ecosystems of 3µg/m3; the PC

was also less than the lower critical level for sites with sensitive lichen

communities of 1µg/m3 applied to Dalkeith Oakwood SSSI. In the case of

ammonia, modelled background concentrations exceed Critical levels at

Dalkeith Oakwood, but as the Proposed Development is only predicted to

make a 0.31% process contribution to this level it cannot be considered to

have an ecological effect.

8.4.33 The process contribution to nitrogen deposition was predicted to exceed the

1% of critical load threshold at three of the modelled locations at Firth of Forth

SPA / Ramsar site / SSSI (E5-E7), and Newhailes ancient woodland, with a

maximum PC of 1.20%. Table 47 of the AQA provides full details.

8.4.34 The Firth of Forth sites are all at Levenhall Links near Musselburgh, and only

exceed the 1% threshold if the lower critical load (LCL) for sand dune habitat

of 8kg N/ha/yr is applied. In fact the habitats within the SPA in the vicinity of

these points are intertidal mud, a coastal ash lagoon and a wetland area, all of

which have significantly higher critical loads. Furthermore, reference to the

SSSI citation indicates that qualifying sand dune habitats in the Firth of Forth

are calcareous dunes. The recommended critical load for environmental

assessment purposes for calcareous dunes (from the Air Pollution Information

Service (APIS) website) is 10kg N/ha/yr; the maximum modelled PC of

0.959kg N/ha/yr does not exceed the 1% threshold of what would in any case

be a very precautionary critical load.


8.4.35 With respect to Newhailes ancient woodland, the correct critical load for

environmental assessment purposes is 10kg N/ha/yr, with the 1% threshold

just exceeded by the modelled PC of 0.1058kg N/ha/yr. Modelled background

levels (from APIS) are 24.22kg N/ha/yr, and therefore exceed the 70%

threshold and cannot be screened out as insignificant. However, the PC is

less than 0.44% of background levels, representing a small incremental

contribution to critical load exceedance. While not understating the potential

detrimental effects of critical load exceedance, such a small magnitude effect

is very unlikely to have a measureable ecological effect.

Potential Ecological Impacts of Emissions to Water

8.4.36 Mitigation measures have been incorporated into the scheme design and

operational procedures which would prevent release of untreated wastewaters

to watercourses, and attenuate surface water drainage from hard surfaces.

Potential ecological impacts on the water environment would therefore be

avoided.

Summary of Operational Phase Impacts

8.4.37 Table 8.9 over the page summarises potential operational phase impacts on

ecological interest features identified in the previous section, with an

assessment of magnitude, risk of occurrence, duration and reversibility.


Table 8.9: Summary of Operational Phase Impacts

Interest feature Potential impact and magnitude/extent

Risk of occurrence, duration and reversibility

Firth of Forth SPA / Ramsar site / SSSI

Habitat changes as a consequence of (a) increased oxides of nitrogen levels and (b) increased nitrogen deposition.

(a) No risk of occurrence as air quality standard not exceeded; (b) No risk of occurrence as process contribution <1% of critical load for relevant habitat.


Habitat changes due to increased nitrogen deposition

Negligible risk of measurable effect as process contribution <1% of background deposition.

Bats Reduction in potential use of bat habitat within and around the site due to lighting

Low risk of occurrence with incorporated mitigation measures.

Breeding bird assemblage Reduction in potential use of bird habitat within and around the site due to noise and human disturbance

Low risk of discernible effects as bird community likely to change in wider vicinity of site; no risk of noise impacts outside site.

Common lizard No colonisation of new habitats within the site due to human disturbance

Moderate risk of occurrence without mitigation to improve habitat quality.

Operational Phase Impacts – Assessment Against PPiP Scheme

8.4.38 It is likely that the operational phase impacts of the PPiP scheme would be

essentially similar to those of the Proposed Development in terms of potential

ecological effects of lighting, noise, human disturbance, air quality and water

quality. These are not specified in the ecological assessment carried out to

inform the PPiP, but it is reasonable to assume they would not be significantly

different.

Impact Significance

Impacts on European Conservation Sites

8.4.39 No likely significant effects are predicted on any of the three European

designated sites within a 15km buffer of the Application Site. When habitat-

specific critical loads for nitrogen deposition are taken into account, air quality

impacts on the Firth of Forth SPA and Ramsar site are not significant.

Incorporated mitigation measures will ensure that any risks to the water

environment are avoided or reduced in accordance with the SEPA pollution

prevention guidance.


Impacts on Ecological Interest Features

8.4.40 Table 8.10 summarises the significance of the impacts outlined in Tables 8.8

and 8.9 above. This combines the scale of importance of the interest feature

with the magnitude of predicted impact, to arrive at an assessment of impact

significance. This utilises the site integrity or conservation status approach

favoured in current guidelines, and arrives at a conclusion based on the

criteria set out in Table 8.1. Note that features of negligible interest, and

features with no impacts predicted are excluded from the assessment.

Table 8.10: Impact Significance

Interest feature Scale of

importance Impacts

Impact significance / effect on site integrity or conservation status

Firth of Forth SPA / Ramsar / SSSI

International Small magnitude increase in oxides of nitrogen & nitrogen deposition likely

No likely significant effect: not significant


Local Small magnitude increase in oxides of nitrogen & nitrogen deposition likely

No measurable effect likely – not significant

Lowland mixed deciduous woodland priority habitat

Local

Certain loss of feature on site, moderate magnitude impact on remaining woodland cover; partial recovery in area following re-establishment

Effect on site integrity certain – significant at local scale of importance.

Bats Local

Certain small loss of foraging habitat for relatively low numbers of bats, mainly soprano pipistrelle; possible ongoing local reduction in local habitat quality due to lighting

No impact predicted on conservation status of bat species in the local area, therefore not significant in ecological terms

Impact Significance – PPiP Scheme

8.4.41 The ecological assessment for the PPiP (Chapter 9 of the Zero Waste ES)

reached broadly similar conclusions on impact significance despite some

differences in assessment methodology. Impacts on woodland habitats and

breeding birds were assessed as slight / moderate adverse significance,

based on a matrix approach which valued the features as having ‘low’ value

and the impact magnitude as ‘moderate’. Given the greater scale of impact on

these features (e.g. loss of 39 breeding bird territories), the impacts of the


PPiP scheme could be regarded as having a higher ecological significance

than the Proposed Development.

8.4.42 Key differences in PPiP ecological impact assessment include the

identification of barn owl as an interest feature subject to slight / moderate

significance impacts in the PPiP scheme, and the identification of possible

impacts on common lizard in the present scheme. The identification of barn

owl as a sensitive receptor in the PPiP scheme is a consequence of the wider

area affected by the scheme, and differing baseline conditions; barn owl have

not been recorded on or near the Application Site, while the more urbanised

nature of the current baseline is likely to displace barn owl further from the

site. Common lizard were not recorded prior to the PPiP, so impacts on

reptiles did not form part of that assessment. Had they been, it is possible that

they would have been identified as a significant ecological impact at least at

the local scale, particularly given the greater extent of habitat loss and

disturbance associated with the PPiP scheme.

Compliance with Protected Species Legislation

8.4.43 It is also necessary to consider the predicted impacts to determine whether

there is any possibility of breaching protected species legislation. Key

questions to consider include:

Would the development comply with EPS legislation, as implemented by

the Conservation (Natural Habitats, &c.) Regulations 1994 (as

amended)?

Would the development comply with European and UK protected

species legislation, including any Schedule 1, Schedule 5 or Schedule 8

Wildlife and Countryside Act 1981 species (as amended) recorded on

site?

Are there any other protected species which may need to be

considered, other than those already recorded?

8.4.44 There are no confirmed bat roosts on site, and the assessment has

demonstrated that habitats present have a negligible risk of supporting a bat

roost. Development of the site would not involve any licensable activities. The

assessment has concluded that the loss of foraging habitat as a consequence


of the development would not affect the conservation status of bats in the local

area; it would not constitute ‘disturbance’ in the sense of Article 12(1)(b) of the

Habitats Directive.

8.4.45 No other EPS are known to occur or likely to occur on site, and there is

therefore no risk of non-compliance with EPS Legislation.

8.4.46 All species of wild bird are under protected against deliberate or reckless

destruction of nests and eggs, or killing and injuring adults and young. It will

be necessary to avoid activities such as scrub clearance and tree felling

during the bird breeding season (April – July for most species) to ensure

legislative compliance with respect to breeding / nesting birds.

8.4.47 Common lizard have partial protection under Schedule 5 of the Wildlife &

Countryside Act 1981 (as amended) against killing and injuring. It will be

necessary to formulate a method statement in the CEMP to implement

measures during site clearance operations which ensure legislative

compliance with respect to common lizards. This may involve ecological

supervision of brash-pile clearance, particularly if this is undertaken during the

winter hibernation season (October – March).

8.4.48 No impacts are expected on any other protected species.

8.5 Mitigation and Enhancement Measures

Need for Additional Mitigation

8.5.1 The incorporated mitigation measures previously described adequately

address the need to avoid, reduce and compensate for many of the potentially

significant adverse impacts on ecological interest features. The landscape

design includes some woodland planting along the eastern boundary of the

site, which will provide partial compensation for habitat loss and impacts on

the breeding bird assemblage. New habitats will not provide direct

compensation, but will contribute to the overall biodiversity of the site and

address policy needs to achieve no net loss of biodiversity interest.


8.5.2 Within the framework of the landscape design, additional ecological mitigation

can best be achieved by formulating a long-term management plan targeted at

key species and habitats. These include not necessarily those displaced from

the site by construction works, but priority species and other key species

which have a reasonable expectation of establishment given appropriate

management. As part of the site is open to the public, it would be appropriate

for some of these to be species of cultural significance in the SBL.

8.5.3 Although it would be difficult to recreate the specific features of the woodland

which will be lost from the site, particularly the soil conditions which have led

to its distinctive post-industrial flora, it should be possible to achieve better

growth rates and future condition of the woodland. In doing so it will minimise

the gap between felling and the new woodland achieving some of the

ecological functions fulfilled by the present habitat, such as providing a

sheltered feeding site for bats, and sufficient cover and structural diversity to

support foraging and nesting birds. It is anticipated that the new planting will

start to fulfil some of these functions within 5 years of planting, when a closed

canopy is achieved and it is able to provide suitable conditions to support a

range of breeding birds.

8.5.4 Features should be incorporated into the site design which provide suitable

habitat for common lizard. It is not certain that common lizard will recolonize

the site, although parts of the active rail sidings and woodland to the south

could potentially support any displaced individuals which would have access

to the restored landscape as it became suitable. Features such as

hibernacula and areas of longer grass adjacent to open basking areas would

be beneficial and will be incorporated into the landscape management plan.

The location of some of these features in areas which are not readily

accessible to the public will help ensure there are no residual impacts caused

by greater levels of disturbance.

Mitigation of Impacts on Protected Species

8.5.5 In order to comply with protected species legislation, measures described

above relating to the avoidance of impacts on breeding birds and common

lizard should be implemented during the construction phase of the

development.


Ecological Enhancement Measures

8.5.6 For the purposes of the ecological assessment, features such as new ponds

and grassland incorporated into the landscape design are best characterised

as enhancement rather than mitigation, since they introduce new habitats

which were not present on site before the development.

8.5.7 Target species and habitat condition standards for new habitats will also be

formulated in the Landscape and Ecological Management Plan (LEMP), with

the aim of maximising biodiversity benefits. These will include the

establishment of aquatic vegetation, the avoidance of introducing invasive

alien species, and the establishment of a diverse grass sward composed of

species native to the south-east Scotland region.

8.5.8 Target fauna will include those native species with a reasonable chance of

colonising, including birds of aquatic and marginal habitats such as moorhen,

and freshwater invertebrates, which are not currently represented on site. The

establishment of aquatic habitats with clean water and good invertebrate

populations will also improve habitat quality for foraging bats. Habitat and

species targets will be selected with reference to the Midlothian LBAP and

SBL.

8.6 Residual Impacts

8.6.1 The development will result in a residual impact of local ecological significance

(minor significance) on lowland mixed deciduous woodland priority habitat and

brownfield land local priority habitat.

8.6.2 Following establishment of new trees and shrubs from around 5 years after

planting, together with new wetland habitats, the residual impacts on the

breeding bird assemblage will differ from the current baseline in terms of

numbers of breeding pairs and species composition. However, these

differences are unlikely to be significant in ecological terms.

8.6.3 No other residual impacts are anticipated; with appropriate management of

the planned landscape design, it is a reasonable expectation that there will be


no significant loss of biodiversity interest in terms of numbers of species

present on site.

8.7 Conclusions

8.7.1 The effects of the Proposed Development on flora and fauna have been

considered in accordance with current guidance for ecological impact

assessment.

8.7.2 The assessment predicts adverse impacts of local significance on lowland

broadleaved woodland priority habitat; brownfield land local priority habitat;

the breeding bird assemblage on site; and common lizard.

8.7.3 No effects are predicted on the conservation status of bats in the local area as

a consequence of the Proposed Development; although there will be a

reduction in habitat quality by loss of woodland edge habitat, this has not been

assessed as ecologically significant. No other effects are predicted on EPS.

8.7.4 These effects occur against a baseline of increasing urbanisation, which

would be likely to change the species composition of the site and surrounding

area in the absence of any development in the site.

8.7.5 Consideration of wider scale effects on sensitive ecological receptors within

15km of the Proposed Development has shown that there will be no significant

ecological effects. In particular, no likely significant effects are predicted on

European conservation sites.

8.7.6 Measures will be required to be incorporated in the CEMP to protect common

lizard and breeding birds in accordance with species protection legislation and

policy.

8.7.7 The establishment of new habitats within the site provides the opportunity to

realise benefits for biodiversity within the site, in accordance with national

planning policy.

8.7.8 When compared to the future baseline represented by the PPiP scheme, the

Proposed Development will reduce the magnitude of impact on features such


as lowland broadleaved woodland habitat and its component breeding bird

assemblage.

8.8 References

IEEM (2006). Guidelines for ecological impact assessment in the United

Kingdom. Approved version, 26 June 2006.

Midlothian Biodiversity Action Plan (2006) (accessed 2nd December

2014).

http://www.midlothian.gov.uk/info/200134/biodiversity/409/biodiversity_inf

ormation/2

Natural Scotland Scottish Government Forestry Commission Scotland

(2014), Native woodland survey of Scotland: Local Authority and regional

native woodland areas by priority woodland type. Summary Leaflet.

Scottish Natural Heritage (2013). A handbook on environmental impact

assessment. 4th edition.

Strachan, I.M. (2015). Manual of terrestrial EUNIS habitats in Scotland.

Scottish Natural Heritage Commissioned Report No. 766.

http://www.midlothian.gov.uk/info/200134/biodiversity/409/biodiversity_information/2

http://www.midlothian.gov.uk/info/200134/biodiversity/409/biodiversity_information/2


9.0 GEOLOGY AND GROUND CONDITIONS

9.1 Introduction

9.1.1 This Chapter provides an assessment of the potential environmental effects

and impacts of the Proposed Development in relation to geology,

hydrogeology and ground conditions (including contamination and

geotechnical stability).

9.1.2 Soils, geology and hydrogeology (i.e. groundwater) play an important role in

determining the environmental character of an area. Development schemes

can have both direct and indirect effects on geology and groundwater.

Existing soil conditions (particularly land contamination), can impose

constraints on development and pipelines can form pathways for the migration

of groundwater, both in the short-term, during construction, and in the long-

term. Ground conditions can also introduce physical constraints on the

construction of structures (e.g. historic mining, foundations, hard standing,

services and excavations).

9.1.3 This section of the ES report will set out how these issues will be assessed in

a systematic manner.

Planning Policy and Guidance

9.1.4 Planning policy and legislation relevant to the consideration of geology and

hydrogeology in the context of the development is as follows:

SPP1 – Development of Contaminated Land (PAN33) and Planning and

Environmental Protection (PAN51);

Environmental Protection Act, 1990 (Part IIA) – Statutory Guidance:

Edition 2

The Groundwater (Scotland) Regulations, 2009;

Contaminated Land (Scotland) Regulations 2005;

Water Environment and Services (Scotland) Act, 2003;

Flood and Water Management Act, 2010;

The Environment Act, 1995;

Town and Country Planning Act (Scotland), 1997; and


Scottish Private Water Supply Regulations 2006.

Previous Planning Application at the Site

9.1.5 The EIA undertaken for a previous PPiP application for a similar but facility to

the proposed Millerhill RERC development, assessed the geological and

hydrogeological impacts of the proposed development. The facilities proposed

within the previous PPiP included an option which was larger than the

currently proposed Millerhill RERC development. This previous ES concluded

that most potential impacts during the construction, operational and

decommissioning phases of the development were assessed as being of

negligible or minor significance. This was with the exception of the potential

for mineral instability to impact site operatives during construction and

decommissioning (assessed as being of moderate/major significance) and for

contamination to impact human health assessed as being of moderate

significance due to construction workers being considered as high sensitivity.

With the proposed mitigation measures and monitoring identified in the ES in

place, the potential impacts of the previously proposed development were

assessed as being negligible and not significant.

9.1.6 The PPiP required that the development shall not begin until a scheme to deal

with any contamination of the site and/or previous mineral workings has been

submitted to, and approved by, the planning authority. The PPiP also required

that proposals should be provided to deal with any contamination and/or

previous mineral workings and include:

A. The nature, extent and types of contamination and/or previous mineral

workings on the site;

B. Measures to treat or remove contamination and/or previous mineral

workings to ensure that the site is fit for the uses hereby approved, and

that there is no risk to the wider environment from contamination and/or

previous mineral workings originating within the site;

C. Measures to deal with contamination and/or previous mineral workings

encountered during construction work; and

D. The condition of the site on completion of the specified decontamination

measures.


9.1.7 The PPiP also required that before any of part of the development is brought

into use, the measures to decontaminate and stabilise the site if required shall

be fully implemented as approved by the planning authority.

9.2 Methodology

9.2.1 The assessment methodology will involve assessing the existing baseline

conditions and assessing the risks to various receptors in order to rank the

significance during all aspects of the project lifetime (e.g. current conditions,

during construction, operation and during decommissioning phases). The

required mitigation measures will then be presented and the revised level of

potential impact will then be assessed.

9.2.2 The sensitive receptors identified as part of this assessment will be

considered in terms of their importance and their sensitivity to change within

the context of the site. The criteria used to define this are presented in Table

9.1 below.

Table 9.1: Evaluation of Sensitive Receptors

Importance

National Nationally designated sites (e.g. Geological SSSI). A nationally important feature that is rare in the region.

Regional A feature that falls short of national designation guidelines but provides a resource that is rare or relied upon at a regional level (e.g. a RIGS).

Local A regularly occurring feature that provides a resource that is relied upon at a local level.

Sensitivity to Change

High Long-term integrity of the receptor may be compromised at a national or regional level

Medium Integrity of the receptor may be compromised at a local level

Low Integrity of the receptor is not at risk

9.2.3 Significance criteria used in this assessment are based on changes (resulting

from the development) to the impact of contamination on the environment in

terms of statutory standards (primarily statutory guidance Contaminated Land

(Scotland) Regulations 2005 under Part IIA of the Environmental Protection

Act 1990).


9.2.4 Significance of impact is based on the change in level of risk from

contamination. The classification of risk is explained in Table 9.2. This follows

DEFRA’s Guidelines for Environmental Risk Assessment and Management

(2000).

Table 9.2: Classification of Risks from Contamination

Probability High Medium Low Negligible

Level of

Severity Consequence of Risk Likely

Reasonably Foreseeable

Unlikely Not

Credible

Sev

ere

Acute risks to human health

Catastrophic damage to buildings/property (e.g. by explosion).

Direct pollution of sensitive water receptors or serious pollution of other controlled water (watercourses or groundwater) bodies.

Very High

High High/

Medium Low

Mo

dera

te

Harm to human health from long-term exposure.

Slight pollution of sensitive controlled waters (surface waters or aquifers) or pollution of other water bodies.

Significant effects on sensitive ecosystems or species.

High Medium Medium/

Low Low

Mild

No significant harm to human health in either short or long term.

No pollution of sensitive controlled waters, no more than slight pollution of non-sensitive waters.

Significant damage to buildings or structures.

Requirement for protective equipment during site works to mitigate health effects.

Medium/ Low

Low Low Low

Neg

lig

ible

Damage to non-sensitive ecosystems or species.

Minor damage to buildings or structures

No harm or pollution of water.

Low Near Zero Near Zero

Near Zero

9.2.5 The risks from all pathways to relevant receptors from contaminant sources

are assessed. Where potential linkages between sources of contamination

and sensitive receptors are identified, predicted effects documented. The

prediction of these effects considers the importance and sensitivity of the

receptor and the assessment also assess whether the predicted effect is

beneficial or adverse, direct or indirect and permanent or temporary.


9.2.6 The predicted effects have been evaluated in terms of their likely significance,

which will then inform any proposed mitigation measures. The criteria used to

determine the significance of predicted effects are provided in Table 9.3

(below). Where the significance of a predicted effect would be influenced by

further intrusive data and quantitative risk assessment, a worst case scenario

was assumed in order to provide a robust assessment.



Major Adverse The effect would adversely affect the integrity of the receptor, and would be difficult to reverse and/or alleviate.

Moderate Adverse The effect would not permanently affect the integrity of the receptor but may result in noticeable damage that would require mitigation.

Slight Adverse No permanent or noticeable damage but requiring mitigation as a preventative measure.

No Significant Effect

No significant adverse or beneficial effects would result.

Beneficial The effect would benefit the quality of the receptor but not such that its importance would be improved.

Major Beneficial The effect would improve the integrity of the receptor such that its overall importance would improve.

Geotechnical Assessment

9.2.7 An assessment will be made of issues associated with ground conditions

present at the site including natural hazards, land instability due to the

presence of low strength and compressible strata and the presence of deep

Made Ground. The risks from shallow mine workings and mine entries

together with former railway structures (e.g. basements) and presence of

shafts has also been assessed. The risk from past mine workings is currently

considered to be a significant risk that requires mitigation.

9.2.8 Areas of uncertainty are indicated and site investigations recommended that

to reduce any uncertainty prior to commencement of construction. Where

piling is proposed for foundations, a preliminary piling risk assessment will be

carried out in accordance with the SEPAs requirements.


Stages of Assessment

9.2.9 The ground-based environmental conditions will change over time given the

different processes that will be carried out at each stage. An evaluation has

been made of each of the following stages:

Current (Baseline) conditions;

Effects of the construction process;

Effects during the operational phase; and

Effects during decommissioning.

Baseline Conditions

9.2.10 The potential effects of the presence of contamination at the Application Site

are identified and evaluated using the contaminant-pathway-receptor risk

assessment approach and from this, potential contaminant linkages will be

identified. The potential for the creation of pathways between contaminant

sources and receptors, as well as consideration of the significance of the

predicted effect, will be considered. As detailed in Chapter 2.0, the baseline

assessment shall assume that the Shawfair development (located adjacent to

the west of the Application Site and comprising residential housing) has been

constructed and completed. Additional developments which are assumed to

have been completed will an AD Facility located to the north and the

completion of the borders railway and site access road.

Mitigation

9.2.11 Mitigation measures, including any further investigation considered necessary

prior to construction, is described in the assessment. This includes any

measures required to mitigate harmful effects on human health, the

environment or built structures that may arise from the proposed development.

If options exist to mitigate the potential risks then these will be compared and

assessed in a rational and economical manner as set out in CLR11 (EA,

2004) for contamination and CIRIA Report SP32 (1984) regarding the

mitigation of risk from abandoned mine workings. Potential mitigation

measures may include:


Remedial Options Appraisal – An appraisal of remedial options for all

plausible contaminant linkages would be assessed and discussed in an

appropriate manner with different technically feasible options being

ranked in terms of practicality, effectiveness, durability, sustainability,

environmental benefits, timescale, cost etc.;

Remediation Strategy – this would be prepared based on the findings of

the Options Appraisal for the highest ranked solution. Any

Environmental Permits required for the remediation will also be

indicated;

Consolidation of shallow mine workings (particularly in the northern part

of the site) prior to construction;

Grouting and capping of shafts present on the site; and

Proposals for the mitigation of other geotechnical risks.

9.3 Baseline

9.3.1 As part of the ES process, a Phase 1 desk-based assessment of the

Application Site has been carried out which incorporates the results from the

previous activities listed below. Based on previous site investigations at the

site for the proposed development and the current understanding of the

ground and groundwater conditions at the site, no new intrusive investigation

works will be required in order to provide sufficient information for the ES. The

assessment for this ES chapter is based on assessment of the following

information sources summarised in Table 9.4 (below). This ES chapter only

summarises the relatively extensive number of reports regarding the site.

These reports should be referred to if any additional details are required.


Table 9.4: Sources of Geological and Ground Conditions Information

Data Source Information Obtained

British Geological Survey Hydrogeological Map (at 1:625,000 scale): Scotland

British Geological Survey Groundwater Vulnerability Map (at 1:625,000 scale): Scotland

British Geological Survey (BGS) Map (at 1:50,000 scale): Edinburgh, Bedrock and Superficial Deposits

Superficial and solid geology. Hydrogeology

Ordnance Survey Historic Maps. Previous site use, possible contaminant sources, existing foundations, former excavations and infilled ground etc.

SEPA website (www.sepa.org.uk) with regard to Water Framework Directive water quality.

Existing background conditions, aquifer designations, Groundwater Source Protection Zones, groundwater and aquifer information

Environmental Data Base Search (EnviroCheck / GroundSure report & web-based searches) including Scottish Natural Heritage (SNH), Sitelink, online designated site database

Contamination sources (historic colliery, landfilling etc) and receptors (including adjacent lake, surface waters), heritage sites.

Historic aerial photography Information on geology, hydrogeology, contamination sources, potential buried obstructions etc.

Coal Authority Coal Mining Report Historic mining, shafts, mining risk

BGS Borehole Logs Superficial and solid geology.

White Young Green Environmental Ltd (2005) Preliminary Geotechnical Interpretative Report: Millerhill Depot.

Details of ground conditions on the development and adjacent areas with particular reference to the stability of the site from shallow coal workings and the presence of shafts/mine entries.

WSP Environment and Energy (WSPE) (2009a) Millerhill Waste Facility

Site: Geo‐environmental Review for The City of Edinburgh Council and Midlothian Council

Desk study information and preliminary risk assessments.

WSP Environment and Energy (WSPE) (2009b) Millerhill Waste Facility Site: Geotechnical and Mineral Stability Assessment for the City of Edinburgh Council and Midlothian Council

Geo-environmental conditions for the development area.

WSP (2009c) Proposed Millerhill Waste Facility Site. Geotechnical and A more in depth study on ground conditions for the development area with


Mineral Stability Assessment. WSP Report No 12141325/003 particular reference to the stability of the site from shallow coal workings and the presence of shafts/mine entries.

WSP (2009d) Proposed Millerhill Waste Facility Site – Geo-Environmental Investigation Report WSP Report No 12141325/004

Geo-environmental investigation including desk study, and intrusive investigation concentrating on geo-environmental aspects.

Van Elle Limited (2011) Factual report – Mineral Stability Ground Investigation

Factual ground investigation report comprising cable percussive boreholes, trial pits, plate bearing tests and rotary probeholes.

WSP(2012) Proposed Access Road and Bridge, Millerhill Waste Facility Site – Ground Investigation Report

Ground investigation report including cable percussive boreholes, trails pits including a mine shaft excavation area. Laboratory and in-situ testing.

Unknown author (2014) Ground Investigation Report – Proposed Millerhill Residual Site Access Road. Job Number G135550

Factual ground investigation report round, comprising cable percussive boreholes, trial pits, plate bearing tests, rotary probing (for 3 possibly abandoned mine entries) and laboratory testing (laboratory testing referenced as being reported within a WSP report)

Midlothian Council to provide information on private water supplies Potential water supply receptors.

Topographical Survey Ground levels


9.3.2 A site walkover was also undertaken in order to inspect areas of potential

interest from the plans and other pertinent information, identifying key features

that are visible and assess the site specific conditions.

Site History

9.3.3 In the earliest historical mapping in 1895, the site was agricultural with a single

railway line running from north to south. In the 1952 mapping, a large colliery

(Monktonhall) was located to the west, with associated coal marshalling yards,

spoil heap and mine water treatment lagoons. The Millerhill sidings to the east

were extensive by this stage. Monktonhall Colliery initially closed 1989, but

was briefly reopened in 1993, before it finally closed in 1997. The use of the

marshalling yard commenced in 1963 and ceased in 1983, with the exception

of two railway lines which serviced the colliery. The railway lines were

removed following closure of the colliery.

Previous Investigations

9.3.4 The reports of four previous site investigations on the site are listed in Table

9.4 (above). The report from 2005 presents the results of a desk-based geo-

environmental assessment, including an assessment of the site history.

9.3.5 The geo-environmental review report of 2009 has not been made available for

review but is understood to be superseded by later reports.

9.3.6 The geo-environmental investigation report from 2009 presents a revised

Phase 1 desk-based study, which leads into a preliminary conceptual site

model and intrusive site investigations of ground investigation. The report

notes that the assessment of potential coal mining in the previous report of

2005 did not assess the entire current site, and only assessed approximately

the eastern 20% of the site.

9.3.7 The revised desk-based study shows that the site is underlain by Glacial Till

with thicknesses varying between 10 and 20m, increasing in thickness to the

north. The bedrock geology underlying the site is the Coal Measures, with

applied geological mapping showing the site is potentially subject to shallow

mining. Assessment of Coal Authority reports and mine abandonment surveys


revealed that the site is potentially underlain by worked coal seams at depth of

between 24m and 73m, with deeper seams also possibly worked. Up to 6

possible mineshafts are present on site.

9.3.8 The intrusive investigation comprised 30 trial pits to a maximum depth of 3m,

10 boreholes to a maximum depth of 10m included soil, groundwater and

geotechnical analysis, installation of 10 monitoring wells and 4 rounds of

ground gas monitoring, soil and groundwater environmental laboratory

analysis, and geotechnical laboratory analysis. Potential risks to human health

from contaminants in soils were only found in relation to asbestos.

9.3.9 The maximum methane concentration was 2.3% and the maximum carbon

dioxide concentration was 10.3%. Ground gas conditions were classified as

Characteristic Situation 2.

9.3.10 No significant risks to controlled waters were encountered and buried concrete

ground conditions were found to be AC-1 with DS-1, locally DS-4.

9.3.11 It was assessed that potential risks from the presence of asbestos could be

mitigated via clean cover systems, use of appropriate PPE by site personnel

during construction and implementation of appropriate construction methods

during earthworks. It was recommended to have the identified soils buried

beneath soils with lower concentrations as part of the planned cut and fill

exercise. Geotechnical recommendations included the use of deep strip or

pad foundations onto the underlying Glacial Till deposits. Re-engineering of

Made Ground would leave areas of the site suitable for landscaping and

roads.

9.3.12 The Geotechnical and Mineral Stability Assessment report of 2009 provides

an additional assessment of existing geotechnical data and details an

extensive intrusive investigation to further assess coal mining related ground

stability. The intrusive investigations comprised the drilling of 30 rotary open

hole boreholes and 2 rotary cored boreholes to investigate shallow mine

workings and 900 rotary probe holes to investigate the position of reported

mine entries. The shallow mine working investigations found that 3 coal

seams were present, with 2 potentially workable seams. One seam was

encountered at between 35.8 and 37.2mbgl comprising a 1.2 to 2.0m thick


seam. The deeper third seam was encountered a further 12m to 16m below

the second seam, and comprised between 0.9 and 2.0m thick seam. Ground

stability risks were assessed as minimal due to the age of the workings, depth

to the seams and a lack of voids being encountered. The shaft investigation

proved the presence of 3 shafts on site out of a possible 9 that were identified

as potentially being located on the site. The three encountered shafts were

between 2m and 3m wide and between 31m and greater than 70m deep. No

caps were encountered. The report recommends that three of the suspected

mine entries require further investigation.

9.3.13 A factual report (written by Van Elle Limited) was issued in 2011 and included

11 days of trial pitting and trenching in to locate one possible mine entry;

progression of thirteen rotary probeholes and 4 rotary cored boreholes to

investigate former mine workings in three coal seams and provide information

on rock integrity at rockhead.

9.3.14 The first coal seam was encountered at depths of between 18.4m bgl and

20.3m bgl, and varied in thickness between 0.6m and 1.25m. The second coal

seam was encountered at depths of between 23.5m bgl and 27.3m bgl and

varied in thickness between 0.22m and 0.9m. The third seam was

encountered at depths of between 32.0m bgl and 28.1m bgl and varied in

thickness between 0.8m and 1.6m. Evidence of former mine workings in the

south of the site were encountered at depths below ground level of between

23.8m and 24.9m, 36.7m and 37.1m, 36.1m and 37.4m, 36.1m and 37.0m,

35.7m and 37.0m, 32.0m and 33.4m, 35.7m and 37.0m. In eight probeholes,

there was no evidence of mine workings recorded. The investigation

undertaken to prove a mine entry did not find any evidence of an entry.

9.3.15 Ground gas concentrations did not find methane above the limit of detection.

Carbon dioxide concentrations were not recorded.

9.3.16 The WSP interpretative report based on the Van Elle factual report issued in

2011 was issued in 2012 providing interpretation of the investigation in relation

to a proposed bridge structure and roads. The report recommends some

localised grouting of workings in relation to the proposed bridge and additional

investigation in relation to two unidentified mine entries.


9.3.17 A factual report by an unknown author (although the field work was

undertaken by Van Elle Limited) reported in 2014 comprised the drilling of

numerous rotary Probeholes in an attempt to located Shafts 012, 013 and 065

along a proposed access road. Soft ground was encountered during drilling for

Shaft 013 (indicating this was a likely location of this shaft), but evidence of

Shafts 012 and 065 was not encountered. Further information relating to the

depth and details of evidence for Shaft 013 is not provided in the report. The

reports makes references to an interpretative report issued by WSP, but this

has not been made available.

9.3.18 Documents provided by CNIM in relation to the design and construction of the

proposed facility indicate that additional site investigation was undertaken in

relation to shallow mine workings and shafts in July 2014. The original report

has not been made available for review. The CNIM document summarises

findings the investigation which encountered evidence of shallow mine

workings at 23.5m bgl. Investigations to locate additional mine shafts were

unsuccessful and further investigatory works are recommended during the

pre-engineering construction phase of the proposed facility.

Geology / Proven Ground Conditions

9.3.19 Made Ground deposits were encountered in all exploratory holes and were

shown to be predominantly of granular in nature comprising variable amounts

of brick, ash, colliery spoil (including sandstone, coal and mudstone), red

burnt shale (blaes) and some slag and wood. In places the top 100mm

comprised and limestone hardcore gravel or topsoil. Possible reworked clay

was encountered in some locations. Made Ground was proven to vary in

thickness between 0.5m a maximum thickness of 2.9m bgl. When considering

the possible reworked clay, Made Ground deposits extended to depths of

between 4.7m and 6.3m bgl.

9.3.20 Drift deposits are shown to comprise firm to stiff sandy gravelly clay with

occasional cobbles and boulders. The top surface of the Glacial Till varied

from 36.9m AOD to 44.96mm AOD. These deposits were proven to extend to

rockhead (where encountered) at depths of between approximately 10 and

15mbgl in the south of the site and between approximately 15m and 20m bgl

in the central and northern parts of the site.


9.3.21 The bedrock Middle Coal Measures deposits were proven to a depth of

40mbgl by rotary coring and to a conjectured depth of 52m based on all

investigatory information. Rockhead was encountered at between 11.8m and

21.3m bgl (32.75m and 21.65m AOD). The deposits were found to comprise

mudstone, siltstone, sandstone and two proven seams of coal.

Coal Mining

9.3.22 The geology indicates that there is the potential for shallow mining at the site.

Geological maps indicate the possible presence of the following shallow

seams:

Splint Coal (1.35m thick);

Rough Coal (0.15m to 1.2m thick); and

Beefie Coal (1.125m thick).

9.3.23 Assessment of depths to the seams indicates that the Rough Coal may be

present at 40m to 60m bgl, placing the Splint Coal at approximately 30m to

50mbgl. The geological maps indicate the Clayknowes seam (0.75m thick) is

present above the Splint Coal, although it is shown to be absent at the site.

9.3.24 The Coal Authority report and mine abandonment surveys generally confirm

the findings of the geological assessment. The Coal Authority and mine

abandonment reports indicate that the site is underlain by two worked seams

at depths of 24m and 73m and a further fourteen seams at depths of up to

950m. The last recorded mine workings ceased in 1996.

9.3.25 Within the site, or within 20m of the site boundary, there are a total of ten mine

entries. The Coal Authority does not hold any further information of the nature

of the mine entries or any treatment of mine entries.

9.3.26 Further information was obtained from mine abandonment plans for the site.

This has shown that the Splint Coal and Rough Coal seams have been

worked in the southern part of the site, with the seams located 41m and 72m

bgl respectively. Mine abandonment plans would also indicate the Four Foot

Coal has been worked, although this seam is not shown on geological maps.


The seam may have been misinterpreted and it is actually the Clayknowes

Coal. This seam has been shown to have been worked close to outcrop

beneath the majority of the site. The northern third of the site is shown as

having this seam worked at outcrop level.

9.3.27 The Coal Authority report and the mine abandonment plans contain no

information on the diameter, treatment or completion of the shafts, although

notes indicate that shafts extend into the Splint and Rough Coal seams, with

inferred depths of 40m to 72m bgl.

9.3.28 Two probehole intrusive investigations were undertaken to allow an

assessment of shallow coal seams and any associated workings. Probeholes

were drilled between 35m and 50mbgl to encounter the Four Foot and Splint

Coal seams.

9.3.29 Proven ground conditions were:

Rockhead encountered at between 10.6mbgl and 21.3mbgl, with

thickness increasing from north to south;

3 coal seams proven:

o Shallow seam found in approximately 40% of probeholes, and less

than 0.5m thick, but locally up to 1.25m thick;

o Four Foot Coal was found to be outcropping or encountered at

between 18.3m and 41.5m bgl and found to be between 0.22m to

2.0m thick and comprises coal, coal with mudstone or mudstone

with coal traces. Limited evidence of being worked, with only 3

probeholes showing the presence of soft ground or voids; and

o Splint Coal encountered 12m to 16m beneath the Four Foot Coal

at a depth of 31m to 41m bgl dipping to the south and east. The

seam was only encountered in the north of the site. The seam was

found to be 0.8m to 2.0m thick and comprised mudstone with coal

traces or coal with mudstone bands or 1.5m thick coal seam.

Hydrogeology

9.3.30 The bedrock Middle Coal Measures Formation is reported as a ‘Minor Aquifer’

although a more recent classification scheme for aquifers classifies the

bedrock Secondary Aquifer being of Intergranular / Fracture: Moderate


Productivity. The Glacial Till deposits are classified as Not a Significant

Aquifer / Unproductive Strata.

9.3.31 During previous investigations at the site groundwater was not encountered

during progression of exploratory holes. In subsequent monitoring visits,

groundwater levels were found at depths of between 1.71m bgl and 8.33m

bgl, with monitoring levels also recording groundwater to be absent during

some of the monitoring. This was interpreted as representing discontinuous

groundwater perched within the Made Ground deposits.

Surface Waters

9.3.32 There are no surface waters on the site. The nearest surface watercourse is

the River Esk located 2.5km east. The Carinie and Niddrie burns are

understood to be culverted beneath an adjacent site. The findings of a

previous desk study indicate that no water quality data is available for these

water courses.

9.3.33 There is localised areas of standing water of limited depth at the site after

periods of heavy rainfall indicating that the Made Ground does not drain

rapidly.

Summary of Current Baseline Conditions

9.3.34 Currently the ground and groundwater conditions are considered to have a

low to medium effect on the environment in the surrounding area.

Investigations have generally shown low concentrations of potential

contaminants with only localised elevated concentrations of a limited number

of contaminants and then not at particularly high concentrations. Isolated

occurrences of asbestos have been encountered in shallow soils but given the

current site use and that of the surrounding area this has a negligible effect to

environmental receptors. There is a localised presence of elevated sulphate

concentrations (which is relatively common in many coal mining areas due to

natural background concentrations from the bedrock) and this presents a

negligible effect to environmental receptors.


9.3.35 Previous investigations at the site indicate the permanent ground gases are

classified as Characteristic Situation 2 based on monitoring from 2009. There

is no impact from radon and minimal impact from volatile organic compounds.

9.3.36 Overall the current baseline conditions prior to development of the site overall

presents a low to negligible impact to environmental receptors.

9.3.37 Investigations have shown that the site has been subject to shallow mine

workings, although mine workings are not ubiquitous across the site and

sixteen worked coal seams are present beneath the site. From intrusive

investigations, two seams are present at relatively shallow depths, being

encountered at depths between rockhead and 41m. Coal seam thicknesses

ranged between 0.5m and 2.0m. Due to the thickness of the seams, the depth

of the seam and the dip of the beds, there is only a significant risk from mined

seams in the northwest of the site.

9.3.38 Nine historic mine shafts are recorded to be present on site. Shaft

investigations have proved the presence of 3 shafts on site out of a possible 9

that were identified as potentially being located on the site. The three

encountered shafts were between 2m and 3m wide and between 31m and

greater than 70m deep. No caps were encountered. Three suspected mine

entries require further investigation because they pose a potential stability risk.

Investigations in July 2014 to locate the additional mine shafts were

unsuccessful and further investigatory works are recommended during the

pre-engineering construction phase of the proposed facility.


9.3.39 No additional baseline risks are envisaged as being encountered in relation to

the proposed Millerhill RERC development than would be encountered for the

previous proposed development which was granted PPiP.


9.4.1 This section of the assessment reviews the effects of the Proposed

Development upon geology and hydrogeology together with geotechnical


stability. Particular emphasis will be made on the possibility of contamination

due to soil, groundwater and ground gases and the risk from historic mining.

9.4.2 The following has been carried out in order to establish the baseline

conditions:

Review of all site investigation and geo-environmental information

provided by the Client;

Environmental setting: former and current land-uses and the

hydrogeological setting of the site;

Intrusive investigation data obtained during mineral stability assessment

works;

Potential contaminant sources both on-site and off-site including soil

contamination, groundwater and ground gas conditions;

Potential receptors both on-site and off-site including humans, controlled

waters, structures and ecology;

Contaminant linkages (pathways) between contaminant sources and

receptors will be reviewed and described;

Use of the above information to develop a Conceptual Site Model, which

identifies potential receptors and helps to characterise the physical and

geochemical parameters.

9.4.3 The assessment complies with the relevant principles and requirements of:

BS5930:1999: +A2 2010: “Code of practice for site investigations”, BS10175:

2011 +A1 2013 “Investigation of Potentially Contaminated Sites - Code of

Practice” and the DEFRA / EA Report CLR11 “Model Procedures for the

Management of Land Contamination” together with the SEPA, British

Standards, CIRIA and a range of other guidance.

9.4.4 A Tier 2 assessment on soils, groundwater and ground gas will be undertaken

if deemed necessary. Chemical data from the existing site investigation

results have been used to inform the Tier 2 assessment which was

undertaken in line with the SEPAs guidelines and recommendations.


Construction Phase

9.4.5 The likely significant effects of the construction phase of the Proposed

Development on the environment prior to mitigation are summarised under the

following sub-headings:

Hazards identified with the proposed development;

Potential sources of contamination;

Potential receptor of contamination;

Identification of pathways;

Geotechnical hazards associated with the Proposed Development; and

Summary of the likely significant effects of the construction phase of the

Proposed Development on the environment prior to any mitigation

measures.

Hazards Identified with the Proposed Development

9.4.6 The hazard identification is based on the assumptions presented below:

The site will be a commercial / industrial development consisting of a

waste treatment facility including ancillary offices and car parking areas;

and

Drinking water will be from mains supply.

Potential Sources of Contamination

9.4.7 The site is located in an area which is currently largely undeveloped, although

there are some remnants of railway sidings including railway tracks, isolated

concrete foundations and some small derelict buildings. Further remnant

railway sidings and a maintenance yard are located to the east. As part of the

baseline assumptions, the land to the west is assumed to have been

redeveloped within the Shawfair new community development. Historical

sources of contaminants associated with lagoons previously used for mine

water treatment will have been remediated as part of the Shawfair

development, and no potential sources are assumed to be associated with

these. The site was part of the Millerhill Marshalling Yard which was

associated with the adjacent Monktonhall colliery. Coal mining and

abandonment records show that the site has nine former shafts on site.


9.4.8 Intrusive investigations and associated laboratory analysis has been

undertaken for environmental sources. The main sources of potential

contaminants are associated with areas of Made Ground which locally has

elevated concentration of contaminants, specifically locally with asbestos. The

ground gas regime was classified as Characteristic Situation 2 from

monitoring reported in 2009. The main potential sources of contamination are

listed in Table 9.5 below.

9.4.9 Information provided by NCIM indicates that the adjacent maintenance yard is

impacted with petroleum hydrocarbon contaminants which are impacting the

Carinie Burn. It is understood that the adjacent site was considered to be

classed as a ‘contaminated site’ with respect to S57 of the Environment Act

(1995) or the Control of Pollution Act (1974). It is unknown whether the

adjacent site has formerly been determined as ‘contaminated land’, or

impacting environmental receptors under any other Act.

Table 9.5: Potential Sources of Contaminants

Main Potential Sources of Contaminants

On-site: Asbestos (free fibres of amosite and chrysotile) encountered in 10 % of samples analysed

On-site: Soils with elevated calorific value which are potentially combustible (not analysed for).

On-site: Soils with elevated sulphate.

On-site: Contaminants associated with possible historic spillages from railway rolling stock.

On-site: Elevated methane and carbon dioxide (Characteristic Situation 2 based on 2009 monitoring)

Potential Receptors of Contamination

9.4.10 Based upon the data previously discussed in sub-section 9.3, the following

potential receptors to contamination have been identified.

Table 9.6: Identified Potential Receptors

Identified Receptors

A Humans – pre-development completion - including construction staff and adjacent residential and commercial receptors

B Humans – including adjacent residents and people on the site and adjacent sites post construction.


C Controlled waters – surface waters (culverted burns, lagoons and rivers) and groundwater.

D Local flora and fauna during and post construction.

E Building structure and services.

9.4.11 It should be noted that humans on adjacent sites (specifically Shawfair, the

AD Facility and the existing Network Rail marshalling yards to the east) are

potential receptors but the risk to commercial / industrial workers on site under

Receptors A and B is assessed to be higher than humans off-site. In addition,

risks to residential receptors at Shawfair will occur only during the construction

phase due to the potential release of fugitive dust/vapours. Risks to

construction staff will be greater than off-site residential receptors and on-site

control measures to reduce risks to construction staff will reduce potential

risks to off-site residential receptors to being negligible. Therefore off-site

human receptors are not considered further in detail to reduce the complexity

of the report as the risk to these humans is covered through the assessment

for Receptors A and B.

9.4.12 The preliminary assessment of risks undertaken for the development

considers potential risks to receptors A to E (in Table 9.6 above).

Human Health (A and B);

Property (including buildings, crops, livestock, pets, woodland, service

lines) (E);

Adjoining Land (B, D and E);

Controlled Waters (C);

Ecological Systems (D); and

Building and Structures (E).

9.4.13 The nearest of each of the above receptor categories to the application site

are considered to be:

On-Site:

Site users;

Proposed buildings and associated structures including roadways;

Aquifer of Moderate Productivity; and

Flora and fauna.

Off-Site:

Culverted burn;


Low grade agricultural land; and

Commercial/industrial developments:

Maintenance yard; and

AD Facility.

Residential, commercial, community and employment development

associated with Shawfair.

9.4.14 Identification of Pathways

9.4.15 There are various routes by which a potential contaminant may reach a

receptor. For example, in areas where contaminated material is exposed,

dermal contact with the material, inhalation or ingestion of dust may occur.

9.4.16 Inhalation or ingestion of dust and water could occur during the construction

and operational phase of the Millerhill RERC development. Pathways from

dermal contact with soil and groundwater may also arise. It is considered that

the risk of short term exposure for ground workers and other construction

workers is low except for the presence of asbestos fibres in Made Ground.

9.4.17 Post-development, the surface of the development area will be occupied with

buildings and hard standing. This will break pathways for human health

receptors post-development for the potential contaminants at this site.

9.4.18 Gas and vapour entry into buildings due to the possibility of advection and

diffusion into buildings is considered to be an unlikely pathway for the

proposed development. From existing site investigation data the ground gas

regime is classified as Characteristic Situation 2. No hydrocarbon

contaminants which may give rise to a significant vapour phase have been

encountered, above generic assessment criteria values.

Pathways to Controlled Waters

9.4.19 Shallow groundwater within Made Ground deposits was generally not

encountered during intrusive investigations. Perched groundwater in

monitoring wells was attributed to discontinuous perched groundwater within

Made Ground.


9.4.20 Where Made Ground is present on site this is likely to have a higher

permeability than the underlying Glacial Till. The vertical leaching of

contaminants from any Made Ground into deep groundwater is not considered

a potential pathway due to the thickness of low permeability Glacial Till.

However, surface runoff to adjacent surface water features and drains may be

a potential pathway. Due to a lack of a hard standing site surface, this will be

uncontrolled prior to and during the groundworks phase when this must be

carefully managed. Post-construction the majority of the site will be covered

through buildings and hard standing so infiltration into the ground will be

negligible. Post construction surface runoff will be controlled through the site’s

proposed drainage system.

Pathways to Buildings / Structures

9.4.21 The ground gas regime is classified as Characteristic Situation 2 based on

monitoring data reported in 2009.

9.4.22 Other potential pathways that are possibly less significant to the site but still

require consideration are:

Chemical attack on foundations and services (especially from elevated

sulphate in Made Ground and burnt shale materials);

Permeation of contaminants through water pipes; and

Potential phytotoxic effects on sensitive landscaping plants.

9.4.23 Previous investigations have noted the presence of historical coal mining, and

outcropping coal seams. Potential combustibility assessment of shallow soils

has not been undertaken as part of previous studies. However, based on an

assessment of the geological/site investigation information and the Coal

Authority’s database of coal seams susceptible to combustion it is assessed

that there is no significant risk from combustibility to the development.

Contamination Linkages

9.4.24 For each contamination source there are potential contaminant linkages with

all potential receptors. However, in the context of this site, not all of the


contaminant linkages are plausible. The likelihood of the various pathways

linking the contaminants to the receptors is presented in Table 9.7 below.

Table 9.7: Matrix of Contaminant Linkages

Source / Contaminated Medium

Pathway

Receptor

A

–

Hu

man

s

p

re-

develo

pm

en

t

co

mp

leti

on

–

inclu

din

g

co

nstr

ucti

on

sta

ff

an

d

ad

jacen

t

resid

en

tial

an

d

co

mm

erc

ial

recep

tors

B

–

Hu

man

s

–

inclu

din

g

ad

jacen

t

resid

en

ts

an

d

peo

ple

w

ork

ing

at

the o

n t

he s

ite a

nd

ad

jacen

t s

itesp

ost

co

nstr

ucti

on

. C

–

Wate

r

Recep

tors

D

–

Flo

ra

an

d

Fau

na

E

–

Bu

ild

ing

an

d

Serv

ices

Soil

/ M

ade G

rou

nd

Ingestion P U - P -

Dermal Contact P U - P P

Inhalation P U - P -

Infrastructure / Drainage U U U U P

Groundwater - - U U U

Surface water U U - U U

Gro

undw

ate

r

Ingestion U U - - U

Dermal Contact P U - - U

Inhalation U U - - U

Groundwater U U U - U

Surface water U U U U U

Gas

(CH4 CO2)

Migration P P - U P

Key of significance of contamination linkages: (S = Significant Pathway P = Possible Pathway U = Unlikely Pathway = Not Applicable). Only significant and possible linkages are taken forwards to the next part of the risk assessment

9.4.25 Piling may be carried out at the site. On some sites piling and other deep

foundations can cause a contaminant pathway to be formed between

contamination and a groundwater receptor (e.g. the piling forms the

completion of a pollutant linkage by creating a pathway between the

contaminant and the receptor). At this site there is a negligible contaminant

source with respect to the effects of piling (e.g. the localised presence of

asbestos will not affect the groundwater receptor, there is likely to be similar

concentrations of sulphate in the bedrock to the Made Ground etc.) and that

due to the significant thickness of relatively low permeability Glacial Till being

present, the piling will not form a pathway for any remnant contamination on

site to reach the groundwater in the bedrock. Therefore the environmental risk


from piling at this site is negligible and no further assessment or mitigation is

required and it will not be considered further.

Preliminary Contamination Hazard Assessment

9.4.26 The preliminary hazard assessment has been based upon contemporary

published guidance. This is based on a preliminary conceptual site model

which has been established using the desk study information and has formed

the basis for the preliminary hazard assessment. Only the significant and

possible potential pathways (referred to in Table 9.7 above) are considered in

the hazard assessment.

9.4.27 The preliminary hazard assessment is a qualitative assessment of the risks

posed by each viable pollution link identified. The hazard assessment leads to

a recommended subsequent activity which could comprise:

Action Required (AR) in the short term to break existing contaminant-

pathway-receptor (CPR) link;

Site Investigation Required (SIR) with objectives for impact estimation;

or

No Action Required (NAR) at this stage.

9.4.28 The hazard assessment for the Application Site is provided in Table 9.8 (over

the page) and is based upon current site conditions with no mitigation

measures being implemented.


Table 9.8: Preliminary Hazard Assessment

Hazard Identification Hazard Assessment

Link Contaminant Pathway Receptor Probability Consequence Impact Hazard Assessment

1 Contaminated soil / groundwater

Ingestion (via soil dust) and inhalation (via soil

dust and vapours), ingestion through dirty hands, dermal contact

with soil/water.

A- Humans using the site during construction and adjacent residential

and commercial receptors

Medium/ Reasonably Foreseeable

Medium Medium SIR -. Site hygiene, PPE and monitoring of air in accordance with requirements of CAR may be sufficient. Adjacent residential and commercial receptors must be considered

in terms of control of fugitive releases to air.

Additional analysis for suspected asbestos containing materials may be required.

2 Contaminated soil /groundwater

Ingestion (via soil dust) and inhalation (via soil

dust and vapours), ingestion through dirty hands, dermal contact

with soil/water.

B- Humans using the site after development

completion.

Low/Unlikely Mild Low NAR


Via service pipes C- Surface Waters.

E- Building structures



Lateral migration C – Groundwater / Surface water features


5 Gas – methane & carbon dioxide

Inhalation, explosion A & B- Humans using the site during

construction and after development

completion, E - buildings.

Low/Unlikely Severe High/ Medium

SIR – Ground gas conditions classified as Characteristic Situation 2. Appropriate

ground gas protection measures should be installed within building foundations.

During construction phase, atmospheric monitoring in excavations should be

undertaken.

6 Contaminated soil/groundwat

Ingestion, inhalation, dermal/direct contact

D- Ecology (Flora/Fauna)

Low/Unlikely Negligible Near Zero

NAR


er

7 Contaminated soil/groundwater

Direct contact. E- Building structures. Medium/ Reasonably Foreseeable

Medium Medium SIR – Concrete specific chemical analysis for designer’s risk assessment.

Analysis has been undertaken in previous reports

8 High calorific value soils

Direct Contact/combustion E- Building structures Medium/ Reasonably Foreseeable

Medium Medium SIR – Analysis of soils should be undertaken to assess potentially

combustible soils


9.4.29 It must be reiterated that the impacts presented within the hazard assessment

does not take any mitigation measures into account.

Geotechnical Hazards Associated with the Development

9.4.30 In addition to the potential contamination hazards, there are also potential

geotechnical hazards associated with the stability of the ground (including

load bearing capacity, slope stability and effects of ground (mining) cavities. A

summary of the geotechnical considerations are provided in Table 9.9 below.

Table 9.9: Summary of Geotechnical Hazards

Potential Risk Assessment

Highly compressible ground

Made Ground deposits are likely to be highly variable.

Combustion Possibility that some of the Made Ground could locally be combustible due to a high calorific value because coal has been stored at the site.

Collapsible soils Very low.

Swelling clay Low – Glacial Till

Running sand Negligible.

Ground dissolution No

Landslip Low.

Obstructions

Localised relic foundations/basements/obstructions may be present at the site. The extent of any buried structures is assessed as being limited because none have been encountered in the investigations and trial trenching carried out at the site.

Mining and quarrying

No quarrying at the site.

Shallow mining has been shown to have occurred on site with at least 2 worked seams within 50 m of ground level, potential risk in northwest of the site.

Nine shafts present on site, with no records of any backfilling or treatment, three of these have not been located by the investigations carried out so far.


Summary of the likely Significant Effects of the Construction Phase of

the Development prior to Mitigation Measures

9.4.31 If no mitigation measures are implemented as part of the Proposed

Development there would be the following unacceptable environmental risks:

High Risk

o With the presence of coal mining related shafts remaining unlocated

and treated there is the risk of ground instability due to collapse of

non-engineered backfill.

o Loose and poorly compacted Made Ground materials may result in

differential settlement. This could affect structures associated with

the Proposed Development together with roads and services.

Medium/High Risk

o Previous investigations have identified some elevated ground gas

concentrations in shallow deposits on the site. Ground gasses

including methane and carbon dioxide have the potential to result in

an explosion or asphyxiating atmosphere respectively and result a

potential impact to buildings, infrastructure and human health.

o In the northwest of the site there is an area where shallow mining

potentially causes a risk of high settlements from collapse of

workings induced by the new and higher imposed loads from the

development in this area of the site.

o Asbestos fibres (amosite and chrysotile) have been detected in

shallow soils. If appropriate measures are not taken to minimise

exposure during construction, risks to construction works health will

be present.

Medium

o Soils which are potentially highly combustible may locally be

present, due to the historic use of the site for coal mining and the

storage of coal at the surface. Laboratory analysis of soils is

recommended so that risk can be quantified because earthworks

which disturb the ground and introduce oxygen could trigger

combustion. Note that this is relatively unlikely and the affected

area should this happen would be relatively small but it needs

quantifying and appropriate mitigation measures implemented if

required.


Assessment of Effects Against Existing Baseline

Operational Phase

9.4.32 As previously indicated a number of the above likely significant effects

identified during the construction of the Proposed Development would also

have the potential to give rise to adverse impacts and likely significant effects

on the environment during the operational phase if no mitigation measures are

put in place. The likely environmental effects are associated with:

Effects of contaminants (e.g. sulphate) on construction materials;

Potential effect of high calorific value soils;

Leakage from facility plant or associated structures;

Leakage or runoff from storage areas;

Spillage/leakage of stored fuels, materials and chemicals; and

The discharge of effluent.

9.4.33 The effects of contaminants (e.g. sulphate) on construction materials and from

the potential effect of high calorific value soils will be mitigated through

appropriate design and construction methods so there is no effect during

operation.

Decommissioning

9.4.34 In general during decommissioning there will be no significant geo-

environmental risks that are not mitigated through standard demolition and

decommissioning practice. The one area where there could be an elevated

risk is if there is to be excavation into ground which has asbestos. The

location of the asbestos in the ground will be known following the construction

so this risk can be managed through standard health and safety measures in

relation to encountering asbestos in the ground.

9.4.35 Therefore the decommissioning scenario is neutral in terms of impact and

risks and are assessed as being of negligible significance.


Assessment against PPiP Future Baseline Scenario

9.4.36 No additional impact or risks will be associated with the proposed Millerhill

RERC development compared to the PPiP development. The baseline

scenario will not change significantly and therefore the baseline scenario is

neutral in terms of impact and risks.


9.5.1 The incorporated mitigation measures within the current design are

considered to be suitable for the proposed development during the

construction, operational and decommissioning phase. However, the following

additional mitigation measures will be required.

Construction Phase Mitigation



compensate for potential environmental impacts. These include:

Pre-Construction Mitigation - Site Investigation

9.5.3 Prior to commencing the construction works further site investigation would be

carried out in order that the geo-environmental and geotechnical risks can be

assessed in more detail. Identified data gaps (notably soil combustibility,

possibly additional asbestos identification and quantification plus further mine

shaft investigation) can be investigated and assessed and appropriate

geotechnical design carried out. Investigations would be carried out in

accordance with current UK guidance and best practises, such as

BS10175:2011+A1:2013, BS5930:1999+A2 2010, CIRIA and CLEA guidance

etc.

9.5.4 Geotechnical investigations would be required especially in relation to three

shafts identified in the vicinity of proposed structures which have not currently

been located. Upon location and investigation, appropriate treatment

methodologies can be designed and appropriate agreements made with the

Coal Authority.


9.5.5 During the investigation, additional data should be obtained from shallow soils

including laboratory analysis of shallow soils for combustibility and asbestos

identification and quantification. Additional parameters for geotechnical design

of foundations, floor slabs and roadways may also be required by the

Designer and this information should be obtained during any intrusive works,

as required.

9.5.6 The report on the conditions and risk associated with the site would be

forwarded to MLC for approval. If the investigations indicate that any remedial

measures are considered necessary to reduce environmental risk to

acceptable levels these would have to be agreed with the Council.

Pre-Construction Mitigation – Geotechnical Design

9.5.7 All of the geotechnical impacts indicated in Table 9.9 can be mitigated by

appropriate site investigation, design and through the standard construction

methods. The proposed mitigation measures described above would

effectively ameliorate the potential impacts of the Proposed Development in

connection with:

Contamination within Made Ground (notably asbestos fibres and

possibly high calorific soils);

Ground gases;

Geotechnical instability associated with historical coal mining; and

Pollution of surface water from day to day construction activities.

9.5.8 The desk study assessment and intrusive investigations have shown that

there are mine shafts present on site. There are no records of any backfilling

or treatment of these shafts. Site investigation for shallow mine workings has

shown that three shallow coal seams have been proven beneath the site.

9.5.9 From the proposed location of the structures associated with the development,

it is understood that additional site investigation and treatment of shafts is

planned to take place prior to commencement of construction phase of works.

Following the investigation and assessment treatment of the shafts may be

required.


9.5.10 Whilst there are three shallow coal seams at the site, potential historic

workings are only considered provide an adverse risk to the development in

an area in the northwest of the site.

9.5.11 Following the investigation and assessment it is likely that treatment of the

mine shafts will be required. Generally no structures should be built over

shafts, or within an area of two cap diameters (to be determined) centred on

the shafts even after they have undergone standard shaft capping and

treatment treated unless additional mitigation measures are incorporated into

the design. Location / shaft specific treatment measures will have to be

agreed with the Coal Authority before buildings are constructed over any

treated shafts.

9.5.12 In the northwest area of the site where there is a shallow coal seam. Some

localised consolidation treatment of the workings may be required beneath

structures sensitive to differential settlement in order to mitigate the potential

risk of settlement on the structure.

9.5.13 If potentially combustible materials are identified and delineated as part of the

pre-construction site investigation these will need to either be removed from

site or excavated and placed at a depth of more than 1.5m below final ground

level. If retained on site these soils will have to be re-compacted so the air

voids content is less than 5% as this has been shown to prevent combustion.

9.5.14 It is anticipated that there will be relatively high foundation loads. Based on

the thickness of Made Ground it is consider piled foundations or for more

moderate loads use vibro (stone) columns will be appropriate but this will be

determined by the detailed geotechnical design. An 8m deep basement

(waste bunker) is proposed for the northern part of the main building adjacent

to the tipping hall. Standard geotechnical risks associated with deep

basements will be mitigated through appropriate design and construction

methods.

9.5.15 Relatively high floor loadings are anticipated which may need to be supported

on vibro (stone) columns or it may be possible to excavate and re-engineer

the Made Ground and to have conventional load bearing floors. This will be


mitigated through implementation of standard appropriate design and

construction methods.

9.5.16 The pH and sulphate content of the soils require checking with respect to its

potential attack on concrete and take appropriate action in terms of specifying

a suitable mix in line with Building Research Establishment Special Digest 1

Concrete in Aggressive Ground (2005). From existing data, soils are generally

classed as AC-1 with DS-1, locally DS-4.

9.5.17 Current understanding of the ground gas regime shows Characteristic

Situation 2 conditions to prevail. BS8485:2007 indicates that for an industrial

building one level of gas protection is required. Given the nature of the

proposed development, 1.5 levels of protection can be provided by a floor slab

solution comprising a reinforced concrete ground bearing slab with limited

service penetrations that are cast into the slab. Such a floor slab solution will

be used for the proposed development and no further mitigation works will be

required with regard to ground gases in the main area of the development.

However within office areas it is understood from CNIM documentation that 2

levels of protection is be installed within office areas, via the installation of

propriety gas resistant membrane installed to reasonable levels of

workmanship under CQA with integrity testing and independent validation.

Therefore the standard design will mitigate the risks from carbon dioxide in the

ground.

Construction Phase Mitigation of Environmental Risks

9.5.18 A Construction Environmental Management Plan (CEMP) would be developed

for the facility construction works in accordance with good practice.

Appropriate environmental method statements would be developed and

mitigation works implemented where necessary. The works would follow

appropriate legislation and guidance including the SEPAs Pollution Prevention

Guidelines and also include measures to ensure effective site management,

including procedures for dealing with accidental oil and fuel spillages during

the use of plant, equipment and machinery would be included as part of the

CEMP for the site.


9.5.19 The CEMP would include appendices that would provide remediation

implementation and validation plans for areas of higher geo-environmental risk

(if appropriate) together with environmental monitoring plans. The monitoring

plans would be implemented to demonstrate that the development is not

having a significant impact on the surrounding environment. With the potential

for asbestos to be present the CEMP will include mitigation measures in

accordance with the Control of Asbestos Regulations (2012) (CAR) and the

HSE’s ACoP for asbestos (2013).

9.5.20 The impacts to groundworkers installing foundations, below ground

infrastructure and groundworks in/through potentially contaminated Made

Ground is anticipated to be relatively low, with the exception of risks from

inhalation of asbestos fibres, but this would be assessed following the site

investigations. An appropriate action plan will be agreed with the Council and

the HSE in accordance with CAR. The action plan will include the preparation

of the Risk Assessment and Plan of Work in accordance with CAR and other

statutory requirements including:

Site mobilisation;

Excavation methodology;

Handling, movement and storage on site of excavation arisings;

Any processing of excavation arisings containing ACMs;

Movement and placement of arisings to final destination;

Placing of cover system over soils with and ACMs remaining on

site;

Off-site disposal of ACMs;

Licences;

PPE & RPE;

Dust and fibre monitoring.

9.5.21 Potential mitigation measures that would be required include:

Further site investigation and risk assessment;

Removal or treatment of asbestos hotspots;

Using construction plant which limits direct contact and dust inhalation;

Monitoring of air during earthworks in accordance with CAR;

Appropriate PPE / RPE appropriate to the CAR; and

A good level of personal hygiene.


9.5.22 Appropriate measures would be implemented to reduce the generation of dust

from earthworks by implementing standard earthworks practices (e.g.

damping down exposed materials during dry conditions, reducing vehicle

speeds, minimising drop heights of vehicles being loaded with soils etc.).

9.5.23 It is possible that there would be a risk to personnel entering trenches from

build-up of ground gases (carbon dioxide). Historical ground gas monitoring

has shown limited elevated occurrences of ground gases. However, some

localised although short-lived, occurrences have been encountered. This

would be mitigated by implementing standard procedures in relation to

confined spaces.

9.5.24 The proposed development will result in the re-compaction of Made Ground

materials and the installation of hard standing. These measures will reduce

the possibility for the release of asbestos fibres and potential inhalation by

humans both on and off site, thus reducing the risk to potential exposure to

asbestos.

9.5.25 All excavations would be carried out in accordance with current UK best

practice so as to prevent the spread or mobilisation of any contaminated

excavated material and cause surface water pollution.

9.5.26 In addition to the above works, the groundworks may create a significant

quantity of spoil including from the excavation of the waste bunker. These

excavated soils which would be reused or disposed of as follows:

Re-use on site for to create a suitable development platform or for

landscaping purposes;

Re-use of excavated Glacial Till as clean capping soils;

Direct transfer of clean natural soils to third party development site for

re-use;

Transfer to soil treatment centres where the soils are treated before

being re-used on other sites;

Direct transfer of soils to quarry restoration sites or similar; and/or

Disposal of soils at landfills which are licensed appropriately for the type

of soils being disposed.


9.5.27 The re-use of soils on site would be carried out in accordance with the SEPAs

guidance on land remediation and waste management. Based on the current

understanding of the proposed development, the re-use of soils on site would

be possible under these guidelines.

9.5.28 If unexpected contaminated material is encountered in the ground during

construction. If this occurred during construction the nature and extent of the

contamination would be assessed and appropriate mitigation implemented.

The following procedures should be adhered to:

1. All site works at the position of the suspected contamination will cease.

2. A suitably trained geo-environmental specialist should assess the

visual and olfactory observations of the condition of the ground and the

extent of contamination and the Client and the Local Authority should

be informed of the discovery. Should the contamination be likely to

affect controlled waters the EA shall also be informed.

3. The suspected contaminated material will be investigated and tested

appropriately in accordance assessed risks. The investigation works

will be carried out in the presence of a suitably qualified geo-

environmental engineer. The investigation works shall commence to

recover samples for testing and, using visual and olfactory

observations of the condition of the ground, delineate the area over

which contaminated materials are present.

4. The unexpected contaminated material will either be left in situ or be

stockpiled whilst testing is carried out and suitable assessments

completed to determine whether the material can be re-used on site or

requires to be disposed as appropriate.

5. Where the material is left in situ awaiting results it will be reburied or

covered with plastic sheeting.

6. Where the potentially contaminated material is to be temporarily

stockpiled it will be placed either on a prepared surface of Glacial Till,

or on 2000 gauge Visqueen sheeting (or other impermeable surface)

and covered to prevent dust and odour emissions.

7. Any areas where unexpected visual or olfactory ground contamination

is will be surveyed, a photographic record kept and testing results

incorporated into the Verification Report.

8. A photographic recorded will be made of relevant observations.


9. The testing suite will be determined by the independent geo-

environmental specialist on the basis of visual and olfactory

observations.

10. Test results will be compared against current assessment criteria

suitable for the future use of the area of the site affected.

11. The results of the investigation and testing of any suspect unexpected

contamination will be used to determine the relevant actions. After

consultation with the Local Authority and if necessary the EA, materials

should either be:

Re-used in areas where test results indicate that it meets

compliance targets so it can be reused without treatment; or

Treatment of material on site to meet compliance targets so it can

be reused; or

Removal from site to a treatment centre or to a suitably licensed

landfill or permitted treatment facility.

12. Verification Report will be produced for the work.

Operation Phase Mitigation of Environmental Risk

9.5.29 The following mitigation measures are proposed to be implemented in order to

prevent environmental impacts from occurring during the operation of the

facility in respect of creation of pathways to groundwater and surface water

and effects on construction methods.

Waste materials brought in to the facility should be stored to ensure they

have minimal opportunity to develop leachates due to rainfall, and

placed on hardstanding;

Fuels/chemicals should be stored in appropriate tanks/bunded areas;

Hardstanding should be designed in an appropriate way that any runoff

should be directed to an oil/water separator and any other treatment

facility which may be required;

Discharge of effluent during the operation will be mitigated through

appropriate design appropriate operation;

Areas of vehicle parking should be designed so that run-off is directed to

an oil/water separator; and

The site will operate through an Permit which will include an

Environmental Management System (EMS). By implementation of this


EMS there will be a reduction of environmental impacts to humans, the

ground, groundwater and surface waters.

9.6 Residual Effects and Conclusions

9.6.1 In terms of geology, hydrology, hydrogeology, contamination and ground

stability, most environmental effects have the potential to occur during the

construction phase, when major excavations and ground disturbance would

take place. However, these effects will be mitigated through further site

investigation, standard design and implementation of standard construction

site practices. Only a number of the effects could carry through to the

operational phase of the development. During the operational phase the site

will operate through a Permit which will include an EMS. By implementation of

this EMS there will be a reduction of environmental impacts to humans, the

ground, groundwater and surface waters mitigating these relatively low risks.

Construction Phase

9.6.2 Following mitigation, the potential for adverse residual effects arising from the

construction of the Proposed Development in terms of geology, hydrogeology

and ground conditions are assessed as being very low or negligible.

9.6.3 Conversely, following implementation of the remediation measures described

in the preceding sub-section, there would be a material improvement in the

local geological, hydrological and hydrogeological environment when

compared to the existing baseline position. This would give rise to significant

beneficial effects.

Operational Phase

9.6.4 No additional impact or risks will be associated with the operation of the

proposed Millerhill RERC development compared to the baseline scenario.

Therefore the operational scenario is neutral in terms of impact and risks.

With the implementation of the proposed mitigation measures during the

construction of the Millerhill RERC development, the potential residual

environmental effects due to ground conditions during the operational phase

are assessed as being of negligible significance.


Operational Phase Future Baseline

9.6.5 No additional impact or risks will be associated with the proposed Millerhill

RERC development compared to those identified in the PPiP development.

Thus, the development would have a neutral impact when compared with the

future baseline position

9.7 Conclusions

9.7.1 This chapter has assessed the potential effects of the Proposed Development

upon the geology and water local to the Application Site and the required

design and mitigation works required to ensure suitable geotechnical

performance for foundations and earthworks during construction and

throughout its operational lifetime. The risk from historic mining has also been

assessed and additional investigation and assessment is required in order that

appropriate design and construction can be implemented to mitigate these

risks. A comparison has also been made between the Proposed Development

and the previous proposals for developing the site which has a PPiP.

9.7.2 The facility is located in an area which has been used as a colliery and railway

sidings and retains a number of structures associated with the sidings. This

study has identified a number of contamination sources on and off the

Application Site. The main sources are:

Off-site Made Ground containing petroleum hydrocarbon which may be

adversely affecting surface water quality. There is no evidence this

contamination has migrated onto the subject site;

On-site Made Ground containing potentially elevated calorific value

which could lead to combustion of the ground;

Asbestos fibres locally identified in Made Ground;

Elevated methane and carbon dioxide (characterised as Characteristic

Situation 2); and

Locally elevated sulphate concentrations.

9.7.3 Notwithstanding the above, previous site investigations carried out at the

Application Site indicate that is contains relatively low concentrations of

contaminants, with the exception of localised identified amosite and chrysotile


asbestos fibres. Localised slightly elevated concentrations of leachable

contaminants have been identified, although these have been assessed as

having a low risk to water receptors.

9.7.4 Current understanding of the ground gas regime shows Characteristic

Situation 2 conditions to prevail. or the proposed industrial building one level

of gas protection is required which will be provided by a floor slab solution

comprising a reinforced concrete ground bearing slab with limited service

penetrations that are cast into the slab. Two levels of protection should be

installed within office buildings. No further mitigation works will be required

with regard to ground gases.

9.7.5 Due to the nature of the facility the main geo-environmental risks would occur

during the construction process. These risks would be managed through the

following mitigation measures:

Further site investigation;

Risk assessment;

Remediation where required;

The geo-environmental design of the facility;

Production and implementation of a CEMP which would include:

a) Consideration of adjacent residential and commercial / industrial

human receptors;

b) Generic measures to ensure effective environmental site

management;

c) Procedures for working in ground contaminated with asbestos in

accordance with CAR and the HSE ACoP.

d) Procedures for working near surface waters in accordance with

the SEPA guidance;

e) Excavations carried out in accordance with current UK best

practice; environmental monitoring plan to demonstrate that the

facility is not having a significant impact on the surrounding

environment;

f) Mitigating risks to groundworkers during installation of

infrastructure; and

g) Re-use of soils carried out in accordance with appropriate the

SEPAs Guidelines.


9.7.6 During the operation of the facility there are a number of on-going risks that

could potentially develop into higher risks. These include:

Effects of contaminants on construction materials;

Leakage from the facility plant or associated structures; and

Leakage or run off from storage areas.

9.7.7 The first item will be mitigated through design and the last two through

standard industry mitigation measures and adherence to the site’s Permit.

9.7.8 As a result of the proposed mitigation measures there will be no significant

residual adverse effects due to geology and ground conditions on any

receptors during the operation of the facility. Overall, after completion of the

facility it is assessed that there would be a beneficial geo-environmental effect

due to the removal or remediation of any contaminant hotspots and the

construction of buildings and hard standing will effectively cap the site from

breaking pathways between potential contaminant sources and receptors.

9.7.9 The mining related risks are the presence of the unidentified mine shafts with

unknown treatment status and shallow mining below the north western part of

the site. Further assessment of the requirement for treatment of these will be

made following an additional phase of site investigations. Once located and

treated appropriately these shafts and the shallow mining will pose a

negligible long term risk to the development.

9.7.10 Geotechnical impacts have also been assessed. All of the geotechnical

impacts can be mitigated thorough the standard process of appropriate site

investigation, design and through the normal construction methods to leave a

negligible residual impact to the development.

9.7.11 In terms of the Proposed Development in comparison to the PPiP

development, the impacts are considered to be neutral.

9.7.12 On the basis of the assessment presented in this chapter there is considered

that there are no significant residual environmental effects associated with

geology, hydrogeology and ground conditions.


9.7.13 It is considered that the desk based and intrusive investigation reports listed in

Table 9.4 provides sufficient information to enable the determination of this

planning application. However, it is acknowledged that the planning

permission (should it be granted) is likely to include conditions requiring

further intrusive investigations prior to the commencement of construction.

The results of the investigation would be used to update the current

conceptual site model and risk assessment and ensure a more detailed

assessment of potential risks can be made and any required mitigation

measures can be designed and implemented.

9.8 References

9.8.1 This Chapter of the ES generally complies with the relevant principles and

requirements of a wide range of guidance including:

Part IIA of the Environment Protection Act, 1990;

Contaminated Land (Scotland) Regulations 2005;

BS5930:1999 + A2 2010: Code of practice for site investigations;

BS10175: 2011 + A1 2013: Investigation of Potentially

Contaminated Sites - Code of Practice;

DEFRA/Environment Agency (2004) Report CLR11 Model

Procedures for the Management of Land Contamination;

SEPA (2010) “An Introduction to Land Contamination and

Development Management”;

SEPA (2010) “Environmental Standards for Discharges to Surface

Waters.” WAT-SG-53 V3.1, August 2010;

Environment Agency (2001) Piling and Penetrative Ground

Improvement Methods on Land Affected by Contamination:

Guidance on Pollution Prevention” (Ref: NC/99/73);

Health & Safety Executive (2013) Approved Code of Practice:

Managing & working with asbestos. Control of Asbestos

Regulations 2012.


10.0 SURFACE WATERS AND FLOOD RISK

10.1 Introduction

10.1.1 This chapter of the ES has been prepared to consider the potential impacts of

the proposals, in terms of the effects upon surface waters and flood risk.

10.1.2 It addresses the development in the context of contemporary planning

guidance on flood risk issues, and establishes the extent to which flood risk

assessment is necessary.

10.1.3 An appraisal is also presented of on-site activities, during the construction,

operational and decommissioning phases of the development, and the

potential effects these may have upon the local water environment, in terms of

contamination of surface waters by suspended solids or other pollutants.


10.1.4 There is a range of planning legislation and guidance relating to development,

flood risk and pollution of water resources, and the following documents are

considered to be those most pertinent to the proposed development. The

assessment presented in this chapter has been prepared cognisant of the

content of these documents:

Scottish Planning Policy (June 2014);

Technical Flood Risk Guidance for Stakeholders (SEPA February 2014);

and

Water Framework Directive (2000/60/EC), implemented in Scotland

through the Water Services Act 2003.

10.2 Methodology

10.2.1 The assessment has primarily involved a desk-based study using information

gleaned from the following sources:

Ordnance Survey mapping;

Scottish Environment Protection Agency (SEPA) - Flood Maps;

A site-specific topographical survey;


Millerhill Zero Waste Facilities PPiP Application – Environmental

Statement (March 2011) – Appendix 10-1 Flood Risk Assessment; and

Millerhill Zero Waste Facilities PPiP Application – Environmental

Statement (March 2011) – Chapter 10 Geology, Hydrogeology,

Hydrology and Water Resources.

10.2.2 An analysis has also been undertaken of the surface water runoff generated

by the proposed development using the ‘Micro Drainage’ simulation program;

the output from which has been used to design the preliminary surface water

drainage scheme submitted as part of the planning application (see Appendix

10-1).

10.2.3 Given the work previously undertaken to prepare the PPiP application for the

Millerhill Zero Waste Facilities and, ultimately, the acceptability of the

supporting Environmental Statement, it has not been considered necessary to

re-consult technical stakeholders in advance of preparing this chapter.


10.2.4 The significance of impacts attributable to the proposed development is

derived from a combination of the magnitude of the potential impact and the

sensitivity of the receptor (either beneficial or adverse). The criteria used to

determine magnitude are set out below in Table 10.1.

Table 10.1: Impact Magnitude

Impact Magnitude Description

Negligible

Undetectable change in hydrological conditions, including water quality.

Low

Detectable but minor change to hydrological conditions or slight deterioration in water quality unlikely to affect most sensitive receptor.

Medium

Detectable change to hydrological conditions or deterioration in water quality likely to affect most sensitive receptor on a temporary basis.

High

Substantial change to hydrological conditions or deterioration in water quality likely to affect most sensitive receptor on a permanent basis.


10.2.5 The criteria used to establish the sensitivity of potential receptors has been

based upon the degree of environmental response to a specific impact or the

conservation status of the receptor itself, as set out below in Table 10.2.

Table 10.2: Sensitivity

Sensitivity Description

Negligible Receptor insensitive to impact. Receiving environment/habitat has low conservation value.

Low Receptor responds minimally to impact. Receiving environment/habitat has only local value/status.

Medium Receptor exhibits material response to impact. Receiving environment/habitat has a regional value/status.

High Receptor exhibits substantial response to impact. Receiving environment/habitat has a national or international status (i.e. SSSI, SAC etc).

10.2.6 The impact magnitude and receptor sensitivity established from Tables 10.1

and 10.2 respectively have then been combined in the matrix presented below

in Table 10.3 to categorise overall impact significance.


Magnitude

Sensitivity

Negligible Low Medium High

Negligible Negligible Negligible Negligible Negligible

Low Negligible Minor Minor Minor/Moderate

Medium Negligible Minor/Moderate Moderate Moderate/Major

High Negligible Moderate Major Major

10.2.7 The assessment of predicted impacts is based upon the significance before

any mitigatory measures are introduced. In accordance with the EIA

Regulations, any impacts predicted to be moderate or major are considered to

be significant.

Limitations

10.2.8 No specific limitations were encountered in the preparation of this assessment

chapter.


10.3 Baseline

Baseline Conditions

10.3.1 Reference to SEPA’s indicative flood map identifies the site as being of ‘low

risk’ from both fluvial and pluvial sources, i.e. having a flooding risk less than

0.5% annual probability in any given year (also referred to as 1 in 200).

10.3.2 In accordance with SEPA’s technical flood risk guidance, only sites with a

medium to high risk of flooding (i.e. >0.5% annual probability) need to be

subjected to detailed flood risk assessment, although it is important to

understand how a developed site will respond to statistically infrequent storm

events, to ensure that downstream properties are not adversely affected.

10.3.3 The proposed development lies within the hydrological catchment of the

Cairnie Burn which, in turn, is fed by a number of watercourses and drains to

the west of the site. Cairnie Burn flows in a north-easterly direction via a series

of open channel and culverted sections, before its confluence with the River

Esk at Monktonhall, approximately 2km from the site. Ultimately, the River Esk

discharges to the Firth of Forth at Musselburgh approximately 2.5km from the

site.

10.3.4 Cairnie Burn has yet to be classified under the Water Framework Directive

(WFD). However, the River Esk has been classified as moderate under the

WFD, by virtue of the morphological alterations that have resulted from urban

development and pollution from various sources (sewage disposal, aggregate

and coal mining and farming activities).

10.3.5 As described elsewhere in the ES, the proposal site can presently be

described as brownfield in nature, largely comprised of regenerating

woodland. Accordingly, surface water runoff is limited to overland flow,

influenced by the prevailing ground conditions and specific rainfall events.

10.3.6 In hydrological terms, there are no designated sites on or near the proposed

development.



10.3.7 As described earlier in this ES, the proposal site already benefits from PPiP

for a comprehensive waste management scheme, which would see the site

largely covered by impermeable roofs and hardstandings.

10.3.8 With this in mind, it is appropriate to consider the development now being

proposed (i.e. the Millerhill RERC) in the context of the scheme already

approved, assuming that the PPiP development and associated infrastructure

and environmental mitigation works have been implemented.

10.3.9 In this scenario, the future baseline condition envisages that the surface water

runoff from the proposal site is regulated to the ‘greenfield’ rate set out in the

site-specific runoff assessment, prepared by Midlothian Council’s Consulting

Engineers, Fairhurst, i.e. 3.6l/s/Ha or 19.8l/s for the developed site area of

5.5Ha (see Appendix 10-1).

10.3.10 In addition, it is also assumed that the dedicated foul and surface water

drainage systems, proposed as part of the aforementioned PPiP development,

both on-site and off-site, have been implemented in full.


Existing Baseline

Potential Effects – Flood Risk

Construction Phase

10.4.1 During the construction phase of the project there would be a gradual increase

in impermeable areas until the development is complete. Without regulation,

the consequential increase in surface water runoff would result in overloading

of the off-site receiving drainage infrastructure and a modest increase in flood

risk to property ‘downstream’ from the site. This potential impact is assessed

as having a low magnitude and medium sensitivity, combining as minor

significance.


Operational Phase

10.4.2 During the operational phase of the development, without regulation, the

increase in surface water runoff from the developed site would substantially

exceed that from the existing ‘greenfield’ conditions. The consequences of this

increase would be overloading of the receiving drainage infrastructure and an

increased risk of flooding to properties downstream. This potential impact is

assessed as having a medium magnitude and medium sensitivity, combining

as moderate significance.

Decommissioning

10.4.3 During the decommissioning phase of the project there would be a gradual

decrease in impermeable areas until the development is completely removed

and pre-existing conditions are restored. Without retaining the proposed flow

attenuation facilities and associated drainage system intact, the potential

increase in surface water runoff could result in overloading of the receiving

drainage infrastructure and a consequential increase in flood risk to property

‘downstream’ from the site. This potential impact is assessed as having a low

magnitude and medium sensitivity, combining as minor significance.

Potential Effects – Surface Waters

Construction Phase

10.4.4 During construction, the potential effects upon surface water quality which

should be considered include:

The mobilisation of site soils (via storm runoff), into the off-site surface

water regime; and

Plant operations including cleansing, refuelling etc.

10.4.5 Suspended solids exist in all surface water runoff, to some extent or another.

However, during the earthworks phase of a construction project this situation

can be exacerbated beyond acceptable levels, without appropriate measures

being implemented.


10.4.6 The site investigation works undertaken (and reported upon in Chapter 9)

confirm that there are some ‘hotspots’ of contamination within the proposed

development site. The presence of these contaminant sources increases the

potential for adverse impact upon the quality of surface water flows.

10.4.7 In light of the above, it is considered that the potential impact during

construction upon surface waters from suspended solids and contamination is

of medium magnitude with low sensitivity, resulting in minor / moderate

significance.

10.4.8 Like all construction projects, there is a risk of spillage from plant and

equipment used during the construction phase. However, in the absence of

any direct physical connectivity to the wider water environment, via surface

flow paths, the potential impacts are considered to be of low magnitude and

low sensitivity, resulting in minor significance.

Operational Phase

10.4.9 The potential effects upon surface waters which should be considered during

the operational life of the development are:

Oils, fuels and/or suspended solid contamination, emanating from

vehicles using the roads, car parks and hardstandings; and

Inundation of parts of the site where waste materials are stored.

10.4.10 The prospect of surface water contamination arising from oils, fuels and/or

suspended solids is most unlikely to occur, as a result of the drainage features

that would be installed at the site. In particular, the development would be

drained by surface water channels and trapped gullies providing a primary

phase of interception / separation. In addition, the site’s internal roadways and

hardstandings would discharge to the below-ground system via the SEPA

approved oil / petrol interceptors. Accordingly, the potential impact has been

assessed as negligible magnitude and negligible sensitivity, resulting in

negligible significance.

10.4.11 It should also be noted that the proposed facilities would operate under the

controls imposed by a PPC permit, issued and regulated by the SEPA. One


important aspect of this permit would be to ensure that there would be no

pollution / contamination of surface waters on or surrounding the site.

10.4.12 The proposed development lies in an area identified as having a low flooding

risk and has limited physical connections to the wider land drainage network.

In addition, the proposed drainage system has been designed with the

capacity to accommodate statistically infrequent storm events and there is no

recorded history of on-site surface water inundation / flooding. Accordingly,

the risk of those areas used for the storage of waste being inundated is very

low and, consequently, the potential impact is assessed as negligible

magnitude with negligible sensitivity and, as such, negligible significance.

Mitigation

10.4.13 As stated earlier in this chapter, assessment work undertaken in support of

the previously approved PPiP application and the construction of related off-

site surface water drainage infrastructure, has resulted in a strategy for

bringing forward the proposal site in a sustainable manner, from a flood risk

perspective.

10.4.14 The surface water drainage scheme serving the proposed development (as

illustrated in Figure 10.1) has been designed to ensure that post-development

flows from the site are regulated to a maximum rate of 19.5l/s, via a series of

attenuation ponds/lagoons. The Micro Drainage model outputs that

demonstrate this are presented in Appendix 10-2.

10.4.15 Provided these attenuation facilities and associated controlled outfall are

constructed at an early stage, and run-off from the site is directed into the

system as the development progresses, there should be no increase in

surface water flows to the off-site drainage network.

10.4.16 These storage facilities would also capture silt and suspended solids present

in run-off, during the construction phase of the project, pending the

construction of finished surfacing and associated drainage features.

10.4.17 In terms of the construction phase, best practice techniques, in line with the

measures outlined in the CIRIA document: ‘Control of Water Pollution from


Construction Sites’ would be employed to minimise the risk of any potential

impacts upon surface water resources.


10.4.18 When assessed against the Future Baseline conditions, which assume that

the proposal site has been developed for the approved alternative waste

management facilities, it is evident that there would be very little difference

between:

The scale of the facilities;

The construction practises that would be employed; and

The drainage infrastructure that would be installed to serve each

development scenario.

10.4.19 In light of the above, it is considered that the development now proposed is

neutral in terms of flood risk and surface water impacts.


Residual Effects - Existing Baseline

Flood Risk

10.5.1 Following the introduction/application of the mitigation measures described

above, those potential impacts originally assessed as being of moderate or

greater significance have been reconsidered, as follows.

10.5.2 During the operational life of the development, the implementation of the

proposed surface water drainage system (as illustrated in Figure 10.1) will

serve to ensure that post-development runoff is regulated to existing

‘greenfield’ (pre-agreed) flow rates. Accordingly, the risk of downstream

infrastructure being overloaded and, consequentially, third-party properties

being inundated is negated.

10.5.3 The residual effect of this potential impact is reduced to low magnitude

(beneficial), as off-site flows cannot exceed those attributable to the pre-


developed state, irrespective of the statistical infrequency of the storm event,

with a medium sensitivity receptor, resulting in a minor beneficial effect.

Surface Waters

10.5.4 Adopting best practice techniques, as outlined in the CIRIA document “Control

of Water Pollution from Construction Sites”, throughout the construction phase

of the development, would serve to ensure that the risk of surface water

resources becoming polluted or contaminated would be minimised.

Accordingly, the residual effect attributable to this potential impact is

considered to be low magnitude with a low sensitivity receptor, resulting in

minor significance.

Comparison with PPiP Future Baseline Scenario

10.5.5 As identified earlier in this chapter, the residual effects attributable to the

proposed development are unlikely to be different to those considered for the

PPiP application. Accordingly, the position from a flood risk and surface

waters perspective can be regarded as neutral.

10.6 Conclusions

10.6.1 The site lies in an area of low flood risk and will discharge surface water into

off-site infrastructure designed to receive regulated flows from the

development, approved as part of the wider, previously approved, PPiP

proposals.

10.6.2 The infrastructure serving the proposed development has been designed

using criteria, pre-agreed as part of the PPiP development, to ensure that the

resulting flows do not exceed those envisaged during the design of the off-site

infrastructure.

10.6.3 Given that runoff from the site will be restricted to a pre-agreed peak flow rate

that cannot be exceeded, irrespective of the statistical infrequency of storm

events, it has been concluded that the residual effect upon downstream

properties is minor beneficial.


10.6.4 The development would not affect the quality of surface waters in the

surrounding area, by virtue of the drainage systems that would be installed to

serve the site, and the specific practises employed to maintain these systems,

in line with the site’s pre-requisite PPC permit. As such, the residual effects

upon surface waters are not considered to be significant.

10.6.5 When assessed against the residual effects attributable to the PPiP

application, the proposed development is considered to be neutral, from a

flood risk and surface waters standpoint.


11.0 NOISE AND VIBRATION

11.1 Introduction

11.1.1 This chapter of the ES assesses the impact of the Proposed Development

with regard to noise and vibration. It describes the methods used to assess

the impacts, the baseline conditions currently existing at the Application Site

and the potentially affected noise sensitive receptors. The potential direct and

indirect impacts arising from the Proposed Development and an example of

the mitigation measures required.

11.1.2 The assessment includes the consideration of:

Information on representative existing baseline sound climate;

Information on the noise impact upon existing or potential future

residential dwellings from site noise and vibration sources;

Information and predictions on noise from construction and

decommissioning works;

The vibration impact on existing or potential future residential dwellings;

and

Noise mitigation measures, which would be necessary to comply with

current noise standards, guidance and proposed noise conditions.

11.1.3 The aforementioned potential noise impacts are considered in the context of

the existing ambient noise at the site, which is generally influenced by road

traffic movements and intermittent aircraft noise.

11.1.4 Appendix 11-1 provides details of technical terms within the chapter, for ease

of reference. There is also a chart showing typical everyday noise levels to

assist in understanding the subjective level of noise in terms of decibels.

Previous Assessment

11.1.5 As presented in Chapter 2.0 of the ES, the Application Site benefits from PPiP

which was granted in 2012 for the ZWF and comprised:

An EfW Facility;

An AD Facility; and

A MBT Facility.


11.1.6 A Noise Impact Assessment (NIA) was undertaken as part of the EIA

undertaken in support of the application for the ZWF. A further NIA was

prepared in respect of the AD Facility, located immediately to the north of the

Application Site. Planning permission for the AD Facility was granted in June

2013, and construction was on-going at the time of writing.

11.1.7 The Millerhill RERC would be implemented instead of the consented EfW and

MBT facilities. Given that the plant content and layout of the Proposed

Development are likely to be different to those assessed for the PPiP a further

NIA is required.

11.1.8 As mentioned in Chapters 1.0 and 2.0, as construction is underway for three

developments including the AD Facility, Borders Railway and SNCD, these

developments have been taken into account within the noise assessment

presented within this Chapter. Further discussion on this matter is provided in

sub-section 11.4

11.1.9 The elements of the proposed development to be considered and assessed in

terms of noise include the following (see Figure 4.2):

Energy Recovery Centre:

Tipping Hall;

Waste Bunker and Hoppers;

Bottom Ash Treatment Building;

Boiler Hall;

Mechanical Pre-treatment Building;

Flue Gas Treatment Building;

Turbo Generator Hall;

Baled Waste Storage Hall;

Air Cooled Condenser;

Staff and Visitor Facilities;

Step-Up Transformer;

District Heating Building;

Water, Fuel, Oil and Ammonia Tanks;

Weighbridge and Gatehouse.


11.1.10 It is intended that the Proposed Development would operate 24 hours per day

and 7 days per week. The hours proposed for import / export of materials

would relate to daytime periods from 08:00 hours up to 20:00 hours Monday to

Friday. The doors into the buildings would generally be kept closed except to

allow access for vehicles.

11.1.11 Access to the site is to be via an entrance on the northern boundary, which

will lead to the gatehouse and weighbridge.

11.1.12 The objectives of the survey and assessment were to provide information and

advice in respect of the following:

Identify plant equipment and its location;

Identify the nearest existing or potential future noise and vibration

sensitive receptors or sites;

Determine likely source noise and vibration levels;

Provide information on existing background sound levels at the nearest

sensitive receptors;

Provide predictions of resultant noise and vibration levels at the nearest

sensitive receptors; and

Provide an example of amelioration measures to reduce noise for the

proposed development by applying BAT.

11.1.13 Information used in this assessment has been obtained from the following

sources:

Ordnance Survey maps of the local area;

General layout of the proposed development;

Road traffic assessment provided by Axis;

British Standards BS4142:2014, BS7445:2003, BS8233:2014, BS6472-

12008, BS7385:1993: Part 2;

WHO: Guidelines for Community Noise (April 1999);

WHO: Night Noise Guidelines for Europe (2009);

Planning Advice Note (PAN) 1/2011: Planning and Noise (March 2011);

Design Manual for Roads and Bridges, Volume 11, Environmental

Assessment (2011);

Empirical vibration measurements recorded at other waste

management, energy from waste and construction sites;


The SEPA Guidance on the control of noise at PPC installations; and

ISO 9613-2:1996 Acoustics: Attenuation of Sound During Propagation

Outdoors.

11.2 Legislation, Policy and Guidance

11.2.1 The following section outlines the key planning policy and guidance that

relates to the assessment of residential amenity and protection of residents

from general environmental and industrial noise and vibration sources.

Planning Advice Note 1/2011Planning and Noise: 2011

11.2.2 Within the introduction of Planning Advice Note 56, Planning and Noise

(1999), it states: “This Planning Advice Note (PAN) provides advice on the

role of the planning system in helping to prevent and limit the adverse effects

of noise. Information and advice on noise impact assessment methods is

provided in the associated Technical Advice Note Assessment of Noise.

Appendix 3 of the Technical Advice Note provides Excel Workbooks which

have been included to assist in the technical evaluation of noise assessment

as part of the planning process.”

11.2.3 Within the Introduction of PAN 1/2011 it states:

“It supersedes Circular 10/1999 Planning and Noise and PAN 56

Planning and Noise. Information and advice on noise impact

assessment (NIA) methods is provided in the associated Technical

Advice Note. It includes details of the legislation, technical standards

and codes of practice for specific noise issues.

The PAN promotes the principles of good acoustic design and a

sensitive approach to the location of new development. It promotes the

appropriate location of new potentially noisy development, and a

pragmatic approach to the location of new development within the

vicinity of existing noise generating uses, to ensure that quality of life is

not unreasonably affected and that new development continues to

support sustainable economic growth. Environmental Health Officers

and/or professional acousticians should be involved at an early stage in

development proposals which are likely to have significant adverse

noise impacts or be affected by existing noisy developments.”


11.2.4 In respect of development planning, the following issues may be relevant

when considering noise issues during the preparation of a development plan:

Avoidance of significant adverse noise impacts from new developments;

Applying noise impact criteria reasonably;

Use of mitigation measures to manage noise impacts;

Protection of Quiet Areas; and

Avoidance of development significantly adversely affecting Noise

Management Areas.

11.2.5 Under the heading: Noise Impact Assessment (Paragraph 19) the guidance

states: “The preparation and consideration of planning applications that raise

significant noise issues can be greatly assisted by a Noise Impact

Assessment (NIA). Planning authorities can require a NIA either as part of an

Environmental Impact Assessment or separately. The need for noise impact

assessments is best identified during pre-application discussions. The

purpose of a NIA is to demonstrate whether any significant adverse noise

impacts are likely to occur and if so, identify what effective measures could

reduce, control and mitigate the noise impact. Before a NIA is commissioned,

planning authorities and applicants are advised to:

Agree any potential representative limits of noise and /or the relevant

NIA methodology in the context of the proposed development, its

location and the surrounding area, and

Establish criteria for assessing any significant adverse noise impact or

predict and describe ambient noise levels (including noise from transport

sources) that the proposed development is likely to generate and/or is

likely to be subjected to.

For further information on NIA methodologies see the Technical Advice Note.”

11.2.6 The guidance also provides examples of measures that could be considered

as part of a mitigation strategy (where required) which should be proportionate

and reasonable. Examples given include consideration of reduction of noise at

source, layout, operational time, work sequencing, baffle mounds, acoustic

fencing, alternatives to vehicle reversing alarms, off road transport routes and

road surface treatments, setting noise limits and suitable glazing for existing

development.


BS4142:2014 Methods for Rating and Assessing Industrial and

Commercial Sound

11.2.7 BS4142:2014: Methods for Rating and Assessing Industrial and Commercial

Sound, is based on the measurement of background sound using LA90

noise

measurements, compared to source noise levels measured in LAeq

units. The

differential between the two measurements; once any corrections have been

applied for source noise tonality, distinct impulses and intermittency etc. (i.e.

the ‘rating’ level); determines the impact magnitude.

a) Typically, the greater this difference, the greater the magnitude of the

impact.

b) A difference of around +10 dB or more is likely to be an indication of

a significant adverse impact, depending on the context.

c) A difference of around +5 dB is likely to be an indication of an

adverse impact, depending on the context.

d) The lower the rating level is relative to the measured background

sound level, the less likely it is that the specific sound source will have

an adverse impact or a significant adverse impact. Where the rating

level does not exceed the background sound level, this is an

indication of the specific sound source having a low impact,

depending on the context.

11.2.8 In terms of establishing the rating level, corrections for the noise character has

to be taken into consideration. These include the following factors:

Tonality: For sound ranging from not tonal to prominently tonal the

Joint Nordic Method gives a correction of between 0 dB and +6 dB for

tonality. Subjectively, this can be converted to a penalty of 2 dB for a

tone which is just perceptible at the noise receptor, 4 dB where it is

clearly perceptible and 6 dB where it is highly perceptible.

Impulsivity: A correction of up to +9 dB can be applied for sound that

is highly impulsive, considering both the rapidity of the change in

sound level and the overall change in sound level. Subjectively, this

can be converted to a penalty of 3 dB for impulsivity which is just

perceptible at the noise receptor, 6 dB where it is clearly perceptible

and 9 dB where it is highly perceptible.


Other sound characteristics: Where the specific sound features

characteristics that are neither tonal nor impulsive, though otherwise

are readily distinctive against the residual acoustic environment, a

penalty of 3 dB can be applied.

(NOTE: Where tonal and impulsive characteristics are present in the

specific sound within the same reference period then these two

corrections can both be taken into account. If one feature is dominant

then it might be appropriate to apply a single correction. Where both

features are likely to affect perception and response, the corrections

ought normally to be added in a linear fashion.)

Intermittency: When the specific sound has identifiable on/off

conditions, the specific sound level ought to be representative of the

time period of length equal to the reference time interval which

contains the greatest total amount of on time. This can necessitate

measuring the specific sound over a number of shorter sampling

periods that are in combination less than the reference time interval in

total, and then calculating the specific sound level for the reference

time interval allowing for time when the specific sound is not present. If

the intermittency is readily distinctive against the residual acoustic

environment, a penalty of 3dB can be applied.

11.2.9 The assessment of noise from the fixed and mobile plant at the nearest

receptors is considered and our expert opinion is provided below.

Tonality

11.2.10 In terms of tonality the proposed development would include appropriate noise

mitigation measures to ensure that any tonal noise sources (i.e. fans, pumps,

tonal reverse alarms etc.) would be either enclosed within buildings or

acoustically treated by design. It is our experience in dealing with this type of

development that the detailed design mitigation strategy will enable the Site to

operate under normal operating conditions where tonal noise in unlikely to be

significant at Site and imperceptible at receptor locations. The proposed Local

Authority noise condition for the Site includes an NR25 limit on noise levels

within bedrooms during night-time, which provides some additional control

over frequency content. Tonal noise penalties are therefore unlikely to be

applicable and no penalty is deemed to be required.


Impulsivity

11.2.11 In terms of impulsivity (i.e. noise from pressure relief valves, offloading of

waste) these noise sources would also be controlled by the use of quick acting

access doors into buildings to contain noise from offloading operations,

silencers on any intermittent pressure relief valves etc., it is our experience

that impulsive noise is not a character shown to be significant with this type of

site due to design mitigation strategies. Offloading activities within the Tipping

Hall would not occur during night-time periods and doors into building would

be closed. Impulse noise penalty is therefore not deemed to be relevant or

appropriate in this case.

Intermittency

11.2.12 In terms of intermittency the only significant typical intermittent activity on site

is likely to be the noise from daytime vehicle movements on and off Site. The

question is whether these intermittent noise sources would be distinctive at

noise sensitive receptors (NSRs) and whilst the noise associated with these

activities is not expected to be significant, to be robust we have allowed for a

+3dB penalty to the calculated noise contribution in accordance with BS4142:

2014.

11.2.13 In conclusion, we would add +3dB to the calculated noise contribution for

intermittency during the daytime period with the proposed mitigation

measures. During night-time there would be no HGV movements and

therefore no penalties are deemed to be appropriate for the calculated noise

contribution.

BS8233:2014 Guidance on Sound Insulation and Noise Reduction For

Buildings

11.2.14 The British Standard BS8233 provides additional guidance on noise levels

within buildings. These are based on the WHO recommendations and the

criteria given in BS8233 for unoccupied spaces within residential properties.


11.2.15 The guidance provided in Section 7.7 of BS8233 provides recommended

internal ambient noise levels for resting, dining and sleeping within residential

dwellings. Table 11.1 below provides detail of the levels given in the standard.

Table 11.1: BS8233: 2014 Indoor Ambient Noise Levels For Dwellings

Activity Location 07:00 to 23:00 23:00 to 07:00

Resting Living Room 35 dB LAeq,16hours -

Dining Dining Room / Area 40 dB LAeq,16hours -

Sleeping (daytime resting) Bedroom 35 dB LAeq,16hours 30 dB LAeq,8hours

11.2.16 The attenuation from an open window, referred to in BS8233: 2014 and other

guidance is -10dB(A) to -15dB(A). Therefore, to achieve a ‘good’ design

according to the standard, the level outside a living room window would

be within the range 40-45dB(A) Leq and for a ‘reasonable’ standard a

level of between 50-55dB(A) Leq. For night-time periods a `good’ design

within the bedroom would be an external level of between 40dB and 45dB.

World Health Organisation (WHO) Guidelines for Community Noise: April

1999

11.2.17 This document provides further updated information on noise and its effects

on the community. Within the document for noise ‘In Dwellings’ it states that:

“The effects of noise in dwellings, typically, are sleep disturbance, annoyance

and speech interference. For bedrooms the critical effect is sleep disturbance.

Indoor guideline values for bedrooms are 30dB LAeq for continuous noise and

45dB LAmax for single sound events. Lower noise levels may be disturbing

depending upon the nature of the noise source.”

11.2.18 The WHO document also states: “At night-time, outside sound levels about 1

metre from facades of living spaces should not exceed 45dB LAeq, so that

people may sleep with bedroom windows open. This value was obtained by

assuming that the noise reduction from outside to inside with the window open

is 15dB. To enable casual conversation indoors during daytime, the sound

level of interfering noise should not exceed 35dB LAeq. To protect the majority

of people from being seriously annoyed during the daytime, the outdoor sound

level from steady, continuous noise should not exceed 55dB LAeq on


balconies, terraces and in outdoor living areas. To protect the majority of

people from being moderately annoyed during the daytime, the outdoor sound

level should not exceed 50dB LAeq. Where it is practical and feasible, the lower

outdoor sound level should be considered the maximum desirable sound level

for new development.”

11.2.19 In 2009, the WHO published: Night Noise Guidelines for Europe, which it

describes as an extension to the WHO Guidelines for Community Noise

(1999). It concludes that: “Considering the scientific evidence on the

thresholds of night noise exposure indicated by Lnight,outside as defined in the

Environmental Noise Directive (2002/48/EC), an Lnight,outside of 40dB should be

the target of the night noise guideline (NNG) to protect the public, including

the most vulnerable groups such as children, the chronically ill and the elderly.

Lnight,outside value of 55dB is recommended as an interim target for those

countries where the NNG cannot be achieved in the short term for various

reasons, and where policy-makers choose to adopt a stepwise approach.”

Guidance on Construction Noise

BS 5228: 2009 Code of Practice for Noise and Vibration Control on

Construction and Open Sites

11.2.20 BS5228 refers to: “the need for the protection against noise and vibration of

persons living and working in the vicinity of, and those working on,

construction and open sites. It recommends procedures for noise and

vibration control in respect of construction operations and aims to assist

architects, contractors and site operatives, designers, developers, engineers,

local authority environmental health officers and planners.”

11.2.21 Part 1 deals with noise in terms of background legislation and gives

recommendations for basic methods of noise control relating to construction

and open sites where significant noise levels may be generated. The guidance

is aimed at giving advice on achieving ‘best practice’ in controlling noise and

vibration from construction and open sites. There is an example of noise limits

given in Annex E, which sets out cut-off limits between 65dB(A) and 75dB(A)

or 5dB(A) above the ambient noise, whichever is the greater. Part 2 of BS

5228 deals specifically with vibration control and provide the legislative


background to the control of vibration and recommendations for controlling

vibration at source and management controls (e.g. liaison with communities,

supervision, preparation and choice of plant etc.)

Guidance on Ground Vibration

11.2.22 Most of the available data relating to the effects of ground vibration on

buildings have been obtained during tests using explosives. From these

studies, two regimes of building damage have evolved, those of structural

damage involving major failures of whole or parts of buildings and

architectural damage involving cracking plaster or other brittle materials.

11.2.23 Architectural, sometimes called cosmetic, damage is thought to be more

annoying than dangerous and would start to occur at lower levels of vibration

than structural damage. Recent International and BS define and categorise

building damage under three main headings:

a) Cosmetic - the formation of hairline cracks on drywall surfaces or the

growth of existing cracks in plaster or drywall surfaces. In addition, the

formation of hairline cracks in mortar joints of brick / concrete block

construction.

b) Minor - the formation of large cracks or loosening and falling of plaster

or drywall surfaces, or cracks through bricks/concrete blocks.

c) Major - damage to structural elements of the building, cracks in support

columns, loosening of joints, splaying of masonry cracks, etc.

11.2.24 An investigation into the effects of induced vibration undertaken by the British

Standards Institution has culminated in BS7385:1993; Part 2 which gives

guide values to prevent cosmetic damage to property of 15 to 20mms-1

between 4Hz and 15Hz, whilst above 40 Hz the guide value is 50mms-1. The

BSI suggests reducing these figures by a factor of 50% for continuous

vibration, for example from rail traffic, thus the values become 7.5-10mms-1 at

4-15Hz, and 25.0mms-1 at 40Hz and above.

11.2.25 With regard to the threshold of cosmetic damage, for continuous vibration

such as road or rail traffic, levels below 5.0mms-1 are unlikely to be significant.


For a given level of vibration the risk of damage decreases as the frequency of

that vibration increases.

11.2.26 BS5228-2:2009 Annex B gives guidance on the effects of vibration levels,

which is summarised below in Table 11.2.

Table 11.2: Guidance on Effects of Vibration Levels

Vibration Level

mm.s-1

Effect

0.14 Vibration might be just perceptible in the most sensitive situations for most vibration frequencies associated with construction. At lower frequencies, people are less sensitive to vibration.

0.3 Vibration might be just perceptible in residential environments.

1.0 It is likely that vibration of this level in residential environments will cause complaint, but can be tolerated if prior warning and explanation has been given to residents.

10 Vibration is likely to be tolerable for any more than a very brief exposure to this level.

11.2.27 In terms of response limits of buildings BS5228-2:2009 (Annex B, Table B.2)

refers to BS7385-1 and BS7385-2 and sets out guide values for transient

vibration for cosmetic damage, which gives a low frequency limit of 15mm/sec

(4Hz) increasing to 20mm/sec at 15Hz for residential or light commercial

buildings. For reinforced or framed structures the limit is 50mm/sec at 4Hz and

above.

Vibration Nuisance

11.2.28 The fact that the human body is very sensitive to vibration can result in

subjective concern being expressed at energy levels well below the threshold

of damage.

11.2.29 Guidance on the human response to vibration in buildings may be found in

British Standard BS 6472-1:2008. Weighting curves related to human

response to vibration of buildings are presented within this document.

Estimates are given on the probability of adverse comment, which might be

expected, from human beings experiencing vibration in buildings. This is

based on a vibration dose value (VDV), assessed from frequency weighted

vibration measurements and based on a 16-hour day and 8 hour night period.


11.2.30 For the purposes of assessing the potential to cause nuisance the guidance in

BS6472-1:2008 has been used.

11.3 Assessment Methodology

11.3.1 To establish the impact of the Proposed Development in relation to noise on

existing residential areas it is necessary to consider the relevant noise

guidance, standards and policy for an industrial development. The following

section examines the guidance and establishes the methodology to be

adopted for assessing noise and vibration impacts.

11.3.2 The Technical Advice Note ‘Assessment of Noise’ associated with PAN1/2011

gives guidance on what issues relating to Noise Impact Assessments. At

paragraph 2.6 it states: “Issues which may be relevant when considering noise

in relation to a development proposal include:

Type of development and likelihood of significant noise impact;

Sensitivity of location (e.g. existing land uses, Noise Management

Areas, Quiet Areas);

Existing noise level and predicted change in noise level;

Character (tonal, impulsivity etc.), duration, the number of occurrences

and time of day of noise that is likely to be generated; and

Absolute level and possible dose-response relationships e.g. health

effects, if robust data available.”

“When noise impact assessments are being prepared, the recommended

approach is to consider both the likely level of noise exposure at the time of

the application and any increase that may reasonably be expected in the

foreseeable future using the most appropriate parameters. The extent to

which it is possible to mitigate the adverse effects of noise should also be

considered.” (Paragraph 2.7)

Noise and Vibration Assessment Criteria

Construction Noise

11.3.3 For construction noise BS5228 is the appropriate standard. This is an

approved code of practice under the Control of Pollution Act and consequently


there is a legal requirement for construction noise to be controlled according

to the recommendations given in this standard. The standard places emphasis

upon ensuring that best practical means are adopted to control noise on site.

During the decommissioning phase, similar plant would be utilised and

therefore the same standard would apply.

Road Traffic Noise

11.3.4 Access to the site is via the northern boundary and Whitehill Road, which

utilises the existing access road then connects to the local road network.

Please refer to the Transport Assessment that supports the planning

application for more information.

11.3.5 In order to assess the likelihood of any impact upon existing residential

properties from traffic noise generated by the Proposed Development, noise

calculations have been undertaken using BS5228-1:2009 methodology for on-

site movements and ‘Calculation of Road Traffic Noise’ (CRTN) methodology

for movements on the local road network. The movements on site are too low

for CRTN methodology calculations to be valid.

11.3.6 For existing residents, who may be affected by road traffic noise from the

Proposed Development through increased traffic along the local road network,

the limits referred to in the Design Manual for Roads and Bridges (DMRB)

would be relevant. This is based on an assessment against an 18-hour

daytime average.

11.3.7 The DMRB (May 2008) Part 2 GD 01/08 provides information and advice

principally for Trunk Road works. The guidance states: “It may also be

applicable in part to other roads with similar characteristics. Where it is used

for local road schemes, it is for the local highway authority to decide on the

extent to which the documents in the manual are appropriate in any particular

situation.”

11.3.8 Volume 11, Section 3, Part 7 (HD 213/11) of the DMRB (November 2011)

provides advice on noise and vibration. The procedure for assessing noise

impacts advises the use of a LA10 measurement index based on an 18 hour

time period (i.e. 06:00 to 24:00 hours). Further assessment of the impact

would be required where changes of 1dB(A) or more are expected in the


short-term and changes of 3dB(A) in the long term. Section 3.37 (of the

DMRB) provides an example of the magnitude of impact for different changes

in noise level for the short-term and long-term situation. Tables 3.1 and 3.2

within Part 7 of the DMRB are provided below, represented as Table 11.3 and

11.4 below.

Table 11.3: Magnitude of Impact for Changes in Road Traffic Noise in the

Short Term

Noise Change, LA10,18hour Magnitude of Impact

0 No Change

0.1-0.9 Negligible

1-2.9 Minor

3-4.9 Moderate

5+ Major

Table 11.4: Magnitude of Impact for Changes in Road Traffic Noise in the

Long Term

Noise Change, LA10,18hour Magnitude of Impact

0 No Change

1.0-2.9 Negligible

3.0-4.9 Minor

5-9.9 Moderate

10+ Major

11.3.9 The impact magnitude scale in Tables 11.3 and 11.4 have been used in the

assessment of operational impacts of the Proposed Development as well as

being relevant to the assessment of road traffic noise.

11.3.10 According to the DMRB Volume 11, Section 3, Part 7 (HD 213/11) (November

2011) the two tables represent the situation related to the opening of a new

road and in the short term the smallest impact that is considered perceptible is

a change of 1dB LA10 18hr. In the longer term (typically 15 years after project

opening) a 3dB LA10 18hr change is considered perceptible.

11.3.11 Reference to Paragraph 3.38 of the DMRB states: “Research into the

response to changes in road traffic noise is largely restricted to daytime

periods. Until further research is available only noise impacts in the long term


is to be considered and Table 3.2 should be used to consider the magnitude

of noise change at night. However, given the caution with predicting night time

noise levels as traffic flows fall (see 3.24) only those sensitive receptors

predicted to be subject to a Lnight,outside exceeding of 55dB should be

considered. The Lnight,outside of 55dB corresponds to the Interim Target

level specified in the WHO Night Noise Guidelines for Europe.”

Fixed and Mobile Plant Noise

11.3.12 The assessment for fixed industrial noise has been undertaken with reference

to BS4142:2014. The standard indicates that if the level difference between

the background noise and the site rating noise is +5dB(A) or greater then

there may be an adverse impact depending on the context. The rating level

includes any deemed noise character penalty based on tonal, impulsive or

intermittent noise characteristics and the perceptibility of these features.

Consultation

11.3.13 Following extensive consultation with MLC’s EHO and appointed noise

consultant (acting on their behalf), the baseline noise monitoring positions and

methodology and assessment method were agreed.

11.3.14 The Local Authority advised that the noise assessment should be designed to

achieve a design criteria similar to that imposed on the AD Facility located to

the immediate north of the Application Site at Millerhill. The condition relates

to the following limits:

(i) Daytime: Fixed and mobile plant (including site vehicles): 0800-2100

hours 40dB LAeq1hr (free field).

(ii) Evening: Fixed plant: 2100-2300 hours 39dB LAeq1hr (free field)

(iii) Night-time: Fixed plant: 2300-0800 hours 39dB LAeq5mins (free field) and

internal level with windows open of NR25.

(iv) All reversing alarms to be of the broadband type (restricted between

0800-2000 hours).

(v) Construction noise (all site operations): 70dB LAeq12hr (1m façade) `best

practicable means’ applied at all times in accordance with BS5228

guidance.


(vi) Construction (piling): 75dB LAeq1hr (1m façade), 80dB LA01(1hr) `best

practicable means’ applied at all times in accordance with BS5228

guidance.

(vii) Construction (Community Relations): A community liaison

representative will be appointed to: ensure (a) availability of information

and (b) complaints are dealt with expeditiously.

11.3.15 Although the noise limits detailed in the above condition is shown to be lower

in terms of existing baseline sound levels recently measured at the nearest

Shawfair development plot location, it is understood that the Local Authority

wish to keep similar conditions to those imposed on the permitted AD Facility.

The only modification that is proposed is to the reference times to which the

noise limits apply, as the daytime and night-time periods do not concur with

defined reference times as stated in BS4142 (1997 or 2014 versions) and

BS8233:2014 as being 07:00 to 23:00 hours for daytime and 23:00 – 07:00 for

night-time. This would affect items (i) and (iii) above in paragraph 11.3.14.

11.3.16 The calculation method used in this study is based upon ISO9613:2, noise

propagation model, which takes into account source position, screening

effects, distance and direction in relation to the nearest receptor.

11.3.17 The assessment has used empirical field data taken at other sites in the UK

(having similar plant) to calculate the expected resultant noise contribution at

the nearest property boundary locations during daytime and night-time

operations.

11.3.18 The assessment is based on plant noise levels as outlined in Appendix 11-5

and assumes that a reasonable level of noise amelioration measures have

been included in the design, similar to those outlined in sub-section 11.8.

These measures are intended to minimise noise impacts relative to the

nearest receptor so that any noise characteristics associated with the

Proposed Development are controlled.


Vibration Criteria

11.3.19 For the purposes of assessing cosmetic damage from construction vibration

(i.e. transient vibration), the following limiting criteria has been chosen in

accordance with BS5228-2: 2009:

For residential or light commercial buildings: Limit of 15mm/sec (4Hz)

increasing to 20mm/sec at 15Hz.

For reinforced/framed structures or industrial and heavy commercial

buildings: Limit of 50mm/sec at 4Hz and above.

11.3.20 For the purpose of assessing cosmetic damage at residential properties, the

following limiting criteria would be considered:

A limiting value for continuous vibration of 5.0mms-1; and

A limiting value for intermittent vibration of 10.0mms-1.

11.3.21 For the purpose of assessing vibration nuisance, BS6472:2008 gives the

vibration dose values which might result in various probabilities of adverse

comment within residential buildings, which is detailed below in Table 11.5.

Table 11.5: Vibration Nuisance according to BS 6472: 2008 based on

VDV

Place and time Low probability of adverse

comment

m.s-1.75

Adverse comment

possible

m.s-1.75

Adverse comment

probable

m.s-1.75

Residential 16hr day 0.2 to 0.4 0.4 to 0.8 0.8 to 1.6

Residential 8hr night 0.1 to 0.2 0.2 to 0.4 0.4 to 0.8

11.3.22 For the assessment of vibration the DMRB guidance advises that initial

screening to consider properties where the level of vibration has the potential

to rise above a level of 0.3mm/sec or an existing background level (above

0.3mm/sec) is predicted to increase. Where this occurs this should be classed

as a change in magnitude of the vibration impact.


Assessment of Significance

11.3.23 Chapter 3 of the Technical Advice Note associated with PAN 1/2011 provides

the procedure suitable for the situation where you have a new noisy

development affecting a noise sensitive building. For ease of reference, the

procedure is detailed below.

“Example 2: New Noisy Development (incl. commercial and recreation)

Affecting a Noise-Sensitive Building – This example illustrates the procedure

for assessing the noise impact on a residential property where an industrial

development is proposed. The assessment is based on the principles

described in BS 4142:1997: Method of rating industrial noise affecting mixed

industrial and residential areas, but does not adhere to the BS 4142: 1997

method of evaluation.” (Paragraph 3.16)

“Stage 1: Initial Process: BS4142:1997 can be described as a context,

comparison based, noise assessment. The assessment is carried out by

comparing specific noise levels from a source, against appropriate indicators

for the situation without the specific noise source operating or influencing the

ambient noise level. Examples of context comparisons might include

comparing Rating Level (L Ar,Tr) (derived from the Specific Noise Level (L Aeq,T)

with an appropriate character correction, as necessary) with the existing

background noise level L A90,T (The LAeq,T of the Residual Noise Level (L

Aeq,T)) Where the Rating Level, as defined in BS 4142: 1997, exceeds the pre-

existing noise levels this is taken as indicative of the likelihood of adverse

complaints arising.” (Paragraph 3.17)

“With BS 4142:1997 the measured background noise level (L A90,T) is

subtracted from the Rating level (L Ar,Tr) under investigation. Paragraph 9 of

BS 4142:1997 advises that as the difference increases, the likelihood of

complaints increases, and that:

A difference of around 10 dB indicates that complaints are likely

A difference of around 5 dB is of marginal significance.” (Paragraph 3.18)

“If the rating level is more than 10 dB below the measured background noise

level this is a positive indication that complaints are unlikely.” (Paragraph 3.19)


“In deciding if a significant impact occurs in regard to the assessment of

industrial noise, or noise of an industrial nature, using the methodology of BS

4142 (where appropriate); the Scottish Government consider impacts are

normally not significant (in a quantitative sense only) the difference between

the Rating and background noise levels is less than 5 dB(A), and that usually

the threshold of minor significant impacts is when the difference between the

Rating and background noise levels is at least 5 dB(A); and commonly do not

become sufficiently significant to warrant mitigation until the difference

between the Rating and background noise levels is more than 10 dB(A).”

(Paragraph 3.20)

“In assessing the noise impact from an industrial development, the noise

sensitivity of a receptor is described in terms of the level of exceedance of the

rating level, L Ar,Tr above the background noise level, L A90,T, where the

sensitivities are defined as follows:

Rating Level (L Ar,Tr) - Background (L A90,T) <5 dB(A), the sensitivity is

Low;

Rating Level (L Ar,Tr) - Background (L A90,T) = 5 dB(A), but less than 10

dB(A), the sensitivity is Medium;

Rating Level (L Ar,Tr) - Background (L A90,T) = >10 dB(A), the sensitivity is

High” (Paragraph 3.21)” (Paragraph 3.21).

“Stage 2: Quantitative Assessment – In this example, a quantitative

assessment is based on an estimate of the change in noise level, L Aeq,T

before and after the industrial development is operational. Table 3.4 [i.e. Table

9.6 in this chapter] shows the criteria used to define the magnitude of noise

impacts for this example.” (Paragraph 3.22)

Table 11.6: Assigning Magnitudes of Noise Impact

Magnitude Change in noise level,L Aeq,T dB (After - Before) 1

Major = 5

Moderate 3 to 4.9

Minor 1 to 2.9

Negligible 0.1 to 0.9

No change 0


Note: 1 when evaluating noise levels for magnitude of impact purposes, all levels should be rounded to 1 decimal point i.e. when the 2nd decimal is 5 or more, round up.

“If the local authority or representative carrying out the assessment considers

that the above assignment of magnitudes of noise impacts is not appropriate for

a particular situation an alternative assessment approach needs to be justified.

In addition, should it be decided that the assessment would be more

appropriately undertaken on the basis of internal levels it must be clearly stated

whether or not the assessment is to be made with the windows open or closed

and reference should be made to the use of internal design standards,

corrected for the character of the noise source being assessed.” (Paragraph

3.23)

“For example, the above magnitude of noise impacts could be derived on the

basis of the ambient noise level, when the development is operational,

exceeding a target noise level that is based on WHO precautionary guideline

levels.” (Paragraph 3.24)

“For a continuous noise source, the recommended WHO precautionary

guideline internal noise levels within dwellings is 35 dB L Aeq,16h for day and

evening periods, this is to avoid critical effects of speech intelligibility and

moderate annoyance, and to avoid sleep disturbance for the night time period

30 dB L Aeq,8h is reported as being representative of the noise level at which the

onset of effects occur, with no, single sound events exceeding 45 dB L Amax,

FAST. The effects on sleep become increasingly more marked at levels of 35 dB

L Aeq,8h and greater. However, the WHO levels are in respect of general

environmental noise and not industrial / commercial in isolation. Therefore, the

nature of the noise requires to be taken into account.” (Paragraph 3.25)

“The World Health Organisation publication entitled Night Noise Guidelines

advises that: considering the scientific evidence on the thresholds of night noise

exposure, as indicated by L night, external noise level, as defined in the

Environmental Noise Directive (2002/49/EC), an external L night of 40 dB should

be the target of the night noise guideline (NNG) noise level to protect the public,

including the most vulnerable groups, such as children, the chronically ill and

the elderly. However, the World Health Organisation also recognises that this is

a very onerous and precautionary noise level, and further advises that a target


L night, external noise level of 55 dB is recommended as an interim target for the

countries where the NNG cannot be achieved in the short term for various

reasons, and where policy-makers choose to adopt a stepwise approach.”

(Paragraph 3.26)

“Stage 3: Qualitative Assessment: The derivation of the magnitude of impact

as described above may not be adequate. This is because the magnitude of

impacts based on changes in noise level alone will be dependent on a number

of factors including the nature of the noise source, in particular, the spectral

content of the noise source and its absolute level. In addition, the period of the

day will be a further factor that needs careful consideration in assigning

magnitudes of noise impacts.” (Paragraph 3.27)

“Stage 4: Level of Significance: The level of significance of the noise impacts

from the industrial development on the residential property is then determined

from Table 3.5 [i.e. Table 11.7 in this chapter].”

Table 11.7: Significance of Effects

Magnitude of Impact (After - Before) L Aeq,T dB

Sensitivity of Receptor based on likelihood of complaint x = (Rating (L Ar,Tr) - Background (L A90,T)) dB

Low (x < 5) Medium (5 = x < 10) High (x =10)

Major (=5) Slight/Moderate Moderate/Large Large/Very Large

Moderate (3 to 4.9) Slight Moderate Moderate/Large

Minor (1 to 2.9) Neutral/Slight Slight Slight/Moderate

Negligible (0.1 to 0.9) Neutral/Slight Neutral/Slight Slight

No change (0) Neutral Neutral Neutral

“The sensitivity of the receptor is based on the likelihood of complaint as

determined by the difference between the Rating level and the background

noise level. The sensitivity of the receptor to noise increases from 'Low' to 'High'

as the probability of complaint increases. The level of significance depends on

the difference in noise levels as determined by the magnitude of the impact and

the sensitivity of the receptor as determined by the probability of complaint.”

(Paragraph 3.28)


“Stage 5: The Decision Process: Depending on the outcome of the

assessment, the decision making process would take into account the level of

significance of the noise impact on the property according to:

Very Large: These effects represent key factors in the decision-making

process. They are generally, but not exclusively associated with impacts

where mitigation is not practical or would be ineffective.

Large: These effects are likely to be important considerations but where

mitigation may be effectively employed such that resultant adverse

effects are likely to have a Moderate or Slight significance.

Moderate: These effects, if adverse, while important, are not likely to be

key decision making issues.

Slight: These effects may be raised but are unlikely to be of importance

in the decision making process.

Neutral: No effect, not significant, noise need not be considered as a

determining factor in the decision making process.” (Paragraph 3.29)

11.3.24 The impact magnitude scale in Table 11.6 has been used in the assessment

of operational noise and road traffic noise (refer to Tables 11.3 and 11.4). The

impact scale in relation to construction or decommissioning noise is slightly

different as this type of noise is of a temporary nature and therefore the

magnitude of impact is different.

11.3.25 Table 11.8 over the page shows the impact scale used to assess construction

and de-commissioning noise. The construction impact semantic scale is

based on the ABC method of assessment, which sets out threshold values

depending upon the ambient noise at receptors, which have been defined

from the baseline sound survey.


Table 11.8: Impact Magnitude Category: Construction and De-

commissioning Noise

Threshold Value

LAeq dB

Time of Day Change in total noise level above threshold dB(A) [i.e. ambient + construction noise]

Impact Magnitude

65

55

45

Daytime (0700-1900)

Evening (1900-2300) or weekend

Night-time (2300-0700)

0 or lower No significant

impact (negligible)

65

55

45

Daytime (0700-1900)



+0.1 to +3.0 Slight

65

55

45

Daytime (0700-1900)



+3.1 to +9.9 Moderate

65

55

45

Daytime (0700-1900)



+10.0 or more Substantial

Note: Construction or de-commissioning noise is a temporary noise source and whilst peak noise events may exceed +10dB(A) above the threshold during peak noise events, the nature of the impact is unlikely to produce anything greater than a moderate change in noise levels due to its temporary nature. However the application of `best practice’ would be followed in this situation to mitigate effects.

11.3.26 The impact magnitude categories applied to the assessment of ground

vibration are described in Table 11.9 below.

Table 11.9: Impact Significance Category: Ground Vibration

Vibration Level

(mm.s-1

)

Subjective Response

(Residential)

Impact Magnitude Significance Level

0.14 to 0.29 Imperceptible to Barely perceptible Negligible Neutral

0.3 to 0.99 Just perceptible Minor Slight

1.0 to 4.99 Noticeable Moderate Moderate

5 to 14.99 Potential cosmetic damage (continuous vibration)

Major Large

15 or more Potential structural damage (continuous vibration) Potential cosmetic damage

(transient vibration)

Substantial Very Large


Ground Vibration – Fixed Plant and Mobile Plant

11.3.27 Measurements of ground borne vibration from empirical data obtained from

measurements at a waste, construction and a Biomass site have been

referred to for an indication of ground borne vibration levels from HGVs,

mobile plant and fixed plant. Definitions of all vibration measurement

parameters noted during the survey are presented in Appendix 11-7.

11.3.28 Vibration measurements were made, in the three mutually perpendicular axes,

during the monitoring period. The seismograph monitored the ground borne

vibration in terms of Peak Particle Velocity (PPV). Further detail of the

vibration surveys are provided in Appendix 11-8.

Limitations

11.3.29 Measurement of prevailing background sound levels has involved monitoring

over the quietest likely daytime and night-time periods (i.e. weekend period) to

represent a ‘worst case’ scenario. Monitoring involved the use of both fixed

monitoring positions and also spot roaming ‘round robin’ measurements where

access and security of equipment was an issue. This methodology was

agreed with the Local Authority and the assessment is therefore deemed to be

robust in its assessment of impacts.

11.4 Baseline

11.4.1 As previously stated, the assumed baseline for the EIA includes the AD

Facility to the immediate north, Borders Railway and the SNCD. Further

details regarding this approach can be found in Chapter 2.0 of this ES.

11.4.2 As these developments are not yet operational, their contribution to

background noise levels has, self-evidently, not been included within the

background noise modelling.

11.4.3 In order to provide a robust assessment, it has been assumed that these

developments would not have any effect on the measured existing

background and residual sound levels. Additionally, due to the lack of

available detail in respect of the future development of plots on Shawfair, it


has been assumed that the residential receptors are built up to the site

boundary, which represents a worst case basis for assessment.

11.4.4 Both of these assumptions enable a worst case assessment to be undertaken

in relation to BS4142:2014, BS8233:2014 and in terms of impact magnitude.

In reality the AD Facility, Borders Railway and the SNCD would contribute to

the background sound climate, thereby reducing the predicted impacts from

the Proposed Development.


11.4.5 The background sound survey was carried out in accordance with BS4142

(1997 or updated version in October 2014 as appropriate) and advice given in

BS 7445:2003 Description and measurement of environmental noise.

11.4.6 A detailed environmental sound survey was carried out at the site to

determine details of the noise climate at the nearest residential properties to

provide typical background sound data. The site inspection and detailed

baseline survey was carried out on Saturday 24th May through to Monday 26th

May 2014 and Saturday 17th January to Monday 19th January 2015.

11.4.7 Fixed position and spot roaming noise measurements were undertaken at

nearest receptor locations to establish representative background levels

relative to the existing noise climate.

11.4.8 Following consultation with the EHO and their appointed noise consultant at

MLC, the areas surrounding the site were examined and the following suitable

locations for noise monitoring were established:

NMP1 (Harelaw Farm): General ambient noise was associated with

birdsong, distant road traffic noise, occasional aircraft noise, and

occasional distant train noise and dog barking.

NMP2 (Old Craighall): Noise observed at this location related to local

and distant road traffic noise and birdsong.

NMP3 (Whitehall Mains): This location is relatively close to the A1 road

and is therefore dominated by road traffic noise. During late night


periods low level noise from train engine `tick-over’ was just audible

from the rail sidings.

NMP4 (Newton Cottages): Noise observed at this location relates to

local and distant road traffic movement. During early morning periods on

the Monday goods train movement was also audible.

Position 1: Position 1 is west of the Application Site on existing

farmland and on higher ground. Noise observed at this location during

the evening and night-time periods related to distant road traffic noise

and birdsong. Noise from the railway sidings was just audible on

occasions as a low level `engine’ type noise.

Position 2: Position 2 was located at the closest accessible approach to

the Application Site in a westerly direction. The noise climate at this

location was dominated by distant road traffic noise, with occasional

noise from high level aircraft and birdsong during evening periods and

occasional noise from train engine tick-over’ emanating from the existing

rail sidings to the south east of the Application Site. This position was

only accessible during the 2015 survey due to railway construction

works and available access to this part of the Application Site.

Position 3: Position 3 is south of the Application Site in the field north of

Old Craighall Road and the background sound is formed by distant road

traffic noise, birdsong and occasional train movements.

Position 4: Monitoring at the newly constructed railway line bridge was

only possible during the Sunday evening period in the 2014 survey due

to the influence of local lighting generators on site and the noise climate

was observed to be formed by distant road traffic noise, birdsong and

occasional distant train noise.

Position 5: Position 5 is located towards the end of the access road

leading to the newly constructed railway bridge off Millerhill Road. Noise

levels at this location are formed by distant and local road traffic and

birdsong during the evening and night-time periods.

Position 6: Monitoring at position 6 at the opposite end of the access

road leading to the railway bridge included one measurement during

Sunday evening in the 2014 survey with distant road traffic and birdsong

was audible.

Position 7: This static monitoring position is southwest of the

Application Site on relatively low lying land and is generally dominated


by distant road traffic noise and birdsong during the evening and distant

road traffic noise during night-time periods. This position was chosen in

the 2014 survey which was one of the nearest accessible positions to

the Application Site boundary (access was limited due to railway

construction works).

Position 8: The spot roaming measurement position was chosen as

being the closest approach to the Application Site during the 2014

sound survey. The noise climate was formed by distant road traffic

noise. During the bank holiday night-time period there was very little

road traffic movement along the A1 road which resulted in unusually

lower background sound levels compared with typical weekend periods.

11.4.9 The sound monitoring positions are indicated on Figure 11.1. The monitoring

positions are representative of residential properties adjacent to the

development.

11.4.10 The fixed monitoring positions provide broadband noise data of the existing

noise climate around the site at the nearest residential properties.

11.4.11 The initial monitoring exercise was carried out over a bank holiday Sunday

morning through to early hours of Bank Holiday Monday morning which was

used to establish the worst case baseline. To establish the typical ambient

noise climate (i.e. representative baseline as required by BS4142: 2104) an

additional survey on a Saturday into Monday morning period was undertaken.

Details of the instrumentation used for the surveys are detailed in Appendix

11-2.

Baseline Conditions

Site Baseline Noise Survey

11.4.12 The results of sound measurements taken at the fixed monitoring positions at

site are presented in Tables 11.10 to 11.14 (over the page) and detailed

measurements in Appendix 11-3.


Table 11.10: Baseline Sound Levels at Monitoring Positions (Saturday Daytime)

Position Time Period (Year) LAeq

dB

LA10

dB

LA90

dB

LAmax

dB

Representative

Daytime (complete survey

period) LA90 dB

P1.West of site (Shawfair zone B)

Daytime (bank holiday 2014)

Daytime (weekend 2015)

46

47

48

45

44

42

55-58

47-79

44

41

P2.Western boundary (zone D)

Daytime (weekend 2015) 48 47 42 52-84 41

P3.South of site

(zone R)


47

48

44

49-66

45

P6. Southwest of site

(access road to bridge)


47

52

45

61-68

45


(zone A)

Daytime (bank holiday 2014) 50 51 46 51-82 45

NMP1: Harelaw Farm Daytime (bank holiday 2014) 47 49 43 56-63 47

NMP2: Old Craighall Daytime (bank holiday 2014) 59 60 54 76-78 54

NMP3: Whitehall Mains Daytime (bank holiday 2014) 55 57 52 62-65 50

NMP4: Newton Cottages Daytime (bank holiday 2014) 57 58 53 73-79 53

Table 11.11: Baseline Sound Levels at Monitoring Positions (Sunday Daytime)


dB

LA10

dB

LA90

dB

LAmax

dB

Representative

Daytime (complete survey period)

LA90 dB




49

49

50

49

47

45

55-61

49-82

44

41

P2.Western boundary (zone D)

Daytime (weekend 2015) 50

50 46 54-89 41

P3.South of site

(zone R)



49

47

50

47

46

43

44-69

49-74

45

45

P4.Southwest of site

(Bridge)



52

46

53

47

50

41

57-72

52-65

50

41

P5.Southwest of site

(zone P)



48

44

50

46

45

40

56

53-57

45

40



Daytime (weekend 2015) 51 52 42 54-66 42


(zone A)

Daytime (bank holiday 2014) 54 53 47 53-86 45

NMP1: Harelaw Farm



48

46

51

47

44

43

56-62

52-55

44

43

NMP2: Old Craighall Daytime (bank holiday 2014) 56 56 50 73-76 50


Daytime (weekend 2015) 59 63 53 68-69 54

NMP3: Whitehall Mains Daytime (bank holiday 2014)


52

46

54

48

49

43

61-63

50-55

49

43

NMP4: Newton Cottages Daytime (bank holiday 2014)


54

57

56

60

51

50

61-64

63-68

51

49

Table 11.12: Baseline Sound Levels at Monitoring Positions (Monday Daytime)


dB

LA10

dB

LA90

dB

LAmax

dB

Representative

Daytime (complete survey

period) LA90 dB

P1.West of site (Shawfair zone B) Daytime (weekend 2015) 48 48 45 58-68 41

P2.Western boundary (zone D) Daytime (weekend 2015) 50 50 46 56-84 41

P3.South of site (zone R) Daytime (weekend 2015) 49 50 47 55-65 45

Table 11.13: Baseline Sound Levels at Monitoring Positions (Saturday – Sunday Night-time)


dB

LA10

dB

LA90

dB

LAmax

dB

Representative night (complete survey period)

LA90 dB

P1.West of site (Shawfair zone B) Night (bank holiday 2014)

Night (weekend 2015)

44

41

46

43

42

39

53-62

45-65

42

38

P2.Western boundary (zone D) Night (weekend 2015) 44 46 42 47-61 41

P3.South of site (zone R) Night (bank holiday 2014)


45

42

47

44

43

39

45-58

49-65

41

40

P7. Southwest of site (zone A) Night (bank holiday 2014) 51 53 46 48-73 46

NMP1: Harelaw Farm Night (bank holiday 2014) 45 46 42 56-58 42

NMP2: Old Craighall Night (bank holiday 2014) 53 54 49 64-74 47

NMP3: Whitehall Mains Night (bank holiday 2014) 50 53 46 60-64 46

NMP4: Newton Cottages Night (bank holiday 2014) 49 51 45 64-69 45

Table 11.14: Baseline Sound Levels at Monitoring Positions (Sunday – Monday) Night-time


dB

LA10

dB

LA90

dB

LAmax

dB

Representative night-time

(complete survey

period) LA90 dB


Night (bank holiday 2014)


38

41

38

42

34

39

52-54

43-81

34*

38

P2.Western boundary (zone D) Night (weekend 2015) 45 46 42 48-67 41

P3.South of site

(zone R)



37

41

39

41

35

37

40-46

43-65

41

40


P4.Southwest of site (Bridge) Night (weekend 2015) 39 41 36 46-52 36

P5.Southwest of site (zone P) Night (weekend 2015) 42 44 39 45-58 39



Night (weekend 2015) 47 49 40 52-66 39

P7.Southwest of site (zone A) Night (bank holiday 2014) 38 39 35 38-59 46

NMP1: Harelaw Farm



41

35

39

37

35

33

48-69

38-43

35

33

NMP2: Old Craighall



46

56

45

51

37

42

50-71

72-79

39

42

NMP3: Whitehall Mains Night (bank holiday 2014)


40

42

41

43

36

38

53-61

48-56

35

38

NMP4: Newton Cottages Night (bank holiday 2014)


43

56

47

49

39

43

56-60

66-83

39

43

*Note: This is based on limited set of readings during a quiet bank holiday period and not deemed to be ‘representative’ of typical baseline sound climate.

11.4.13 The results of baseline sound measurements taken at the fixed and spot

roaming monitoring positions in the vicinity of the Application Site during

daytime and night-time periods are summarised in Table 11.15 below.

Table 11.15: Summary of Representative Noise Levels in accordance with

BS4142:2014

Location Representative

Daytime

LA90 dB

Daytime

LAeq

dB

Representative

Night-time

LA90 dB

Night-time

LAeq

dB

P1.West of site (Shawfair zone B) 41 48 38 42

P2.Western boundary (zone D) 42 49 42 45

P3.South of site (zone R) 45 48 40 44

P4.Southwest of site (Bridge) 45* 50 36* 39

P5.Southwest of site (zone P) 40* 44 39* 42



44* 50 43* 48

P7. Southwest of site (zone A) 45 53 46 50

NMP1: Harelaw Farm 42* 46 37* 42

NMP2: Old Craighall 50* 58 42* 52

NMP3: Whitehall Mains 49* 53 39* 46

NMP4: Newton Cottages 50* 55 42* 52

*Note: Levels are averaged due to spread of data and limited data set.

11.4.14 From the results of the background noise survey and observations at the

nearest residential receptors, it is clear that the noise climate is dominated by


local and distant road traffic noise (i.e. along A1(T) and the local road network)

and intermittent aircraft and occasional train noise from the rail sidings.


11.4.15 The noise impacts predicted for the ZWF development indicates that the noise

levels from the development would not exceed background sound levels +5dB

and the combined effect of the AD Facility, EfW Facility and MBT Facility

would not exceed a design limit of background sound +5dB. The resultant

conclusion in terms of residual noise was a negligible to minor adverse impact

magnitude.

11.4.16 The Local Authority has sought to control the ZWF development through a

noise condition to ensure the residual impact is achieved.

Ground Vibration

11.4.17 Measurements of ground borne vibration from empirical data obtained from

measurements at a energy from waste facility, construction site, Waste

Management Facility (WMF) and HGVs travelling along a busy main road

have been referred to for an indication of ground borne vibration levels similar

to plant and vehicles proposed for the Millerhill RERC. Definitions of all

vibration measurement parameters noted during the survey are presented in

Appendix 11-7.



11.5.1 The Local Authority are able to impose planning conditions on any planning

permission to ensure that the planning guidance noise limits for daytime and

night-time operations is achieved.

11.5.2 Whilst this can be achieved by mitigation, it must be noted that this

assessment considers one method of treatment. There are a number of

different ways in which the criteria can be achieved, for example, the use of

noise control at source and / or the selection of different plant equipment,


which may be quieter, can be investigated. The chosen method(s) of

mitigation should be appropriate to meet the noise criteria and the application

of BAT.

11.5.3 The predicted noise levels from the Proposed Development have been

calculated using the noise levels provided within Appendix 11-5. The noise

levels are based on empirical test data provided by the technology provider

and include the following inherent mitigation measures:

(i) Building constructed from single skin cladding.

(ii) Air cooled condenser fans each operating at a sound power level of

89dBW.

(iii) Fan stack designed to a sound power level of 88dBW at end of stack.

(iv) Ventilation louvres attenuated to same level as the cladding acoustic

performance.

(v) Doors closed except for access to vehicles for offloading and collection

unless for maintenance or emergency.

(vi) Sound power levels of plant as detailed in Appendix 11-5.

Construction Phase

Noise

11.5.4 Initial site preparation works is likely to involve the movement of soils and the

construction of new buildings and infrastructure. It is considered that

excavators, haulage lorries, piling rigs, cranes, dumpers, concrete mixers,

diggers and paving machines would all, at some time during the construction

programme, be operating at the site. In addition, ancillary equipment such as

small generators and compressors may also be operating on occasions during

the construction period.

11.5.5 The above noise sources and their associated activities would vary from day

to day and may be in use at different stages of the Proposed Development for

relatively short durations. The noisiest activities are expected to be generated

during soil movement and piling work during the initial stages of the Proposed

Development when excavators, piling rigs, dozers or similar may be in use.


11.5.6 The actual noise level produced by construction work would vary at the

nearest property boundary at any time depending upon a number of factors

including the plant location, duration of operation, hours of operation,

intervening topography and type of plant being used. Refer to Appendix 11-4

for construction plant inventory.

11.5.7 Detailed below is an indication of the highest likely noise levels at the nearest

receptors during different site activities. The calculations use the calculation

methodology given in BS5228-1: 2009.

11.5.8 The results of calculations (excluding mitigation measures) are shown in Table

11.16 below.

Table 11.16: Noise Predictions for Highest Likely Construction and

Decommissioning Noise for existing residential receptors

Position Distance

to

receptor

(m)

Activity Noise

Level, dB

LAeq 1hr

Typical

Residual

Noise LAeq

dB

Total noise

(residual +

constructi

on)

LAeq dB

BS5228

Threshold

Value LAeq

dB

(daytime)

R1 South West (NMP1)

660-720 Site Preparation Piling

General activities

Infrastructure

Building Constr

43-45

45-46

39-41

36-38

45-47

46 48-49

49

47

46-47

49-50

65

R2 South East (NMP2)


General activities

Infrastructure

Building Constr

41-42

42-44

37-38

34-35

41-42

58 58

58

58

58

58

65

R3 North West (NMP3)


General activities

Infrastructure

Building Constr

46-50

47-51

42-46

39-43

46-50

53 54-55

54-55

53-54

53-54

54-55

65

R4 South (NMP4)


General activities

Infrastructure

42-44

44-45

38-40

55 55

55

55

65


Building Constr 35-37

42-43

55

55

R5 West


General activities

Infrastructure

Building Constr

48-50

50-52

44-47

41-44

48-50

48 51-52

52-53

49-51

49-50

51-52

65

R6 Western boundary (area D of Shawfair development)


General activities

Infrastructure

Building Constr

49-78

57-71

52-66

49-63

56-70

50 53-78

58-71

54-66

53-63

57-70

65

11.5.9 For the Proposed Development, the highest noise levels are likely to be

created during piling and building construction activities. The movement of soil

may be part of the initial site preparation works and it is unlikely that any other

significant sources of noise would be present on the site while these activities

were being carried out.

11.5.10 The increase in noise, as a result of construction, is likely to result in an

impact magnitude classification of negligible resulting in a neutral magnitude

impact significance at all receptors except the potential nearest receptor in

Shawfair area D, which indicates under worst case noise conditions to be

substantial impact without mitigation.

11.5.11 The application of applying best practice in accordance with BS5228:2009 will

assist in minimising impact from construction noise. As a result, the

assessment of impact magnitude from construction noise concludes that there

would be a neutral effect at all receptors except the potential receptor at

Shawfair development area D where worst case impacts could be of

moderate impact magnitude. It should be noted however that this assessment

assumes (in accordance with the baseline for assessment) that Shawfair Area

D development would be implemented and occupied as a sensitive receptor

prior to the commencement of construction works. The reality is that the

development within Shawfair area D is not expected to commence until after

the Proposed Development has been constructed. Therefore these

construction related noise issue would only actually be expected to occur


during the decommissioning phase. Accordingly, the predicted impact for

construction is deemed to be robust and pessimistic.

Construction Road Traffic Noise

11.5.12 Table TA6.1 of the Transport Assessment details the baseline traffic flows and

construction traffic demand for the Proposed Development.

11.5.13 The following table provides details of the impact due to the increased traffic

flow along the local road network. The dwelling positions off Whitehill Road

are the most sensitive receptors to any direct traffic flow increase.

Table 11.17: Predicted Change in Road Traffic Noise on local road

network during 24 hours due to construction works

Road Baseline noise

level

(no development)

LAeq24hours (dB)

Predicted noise

level LAeq24hours

(dB)

Change

(with development)

LA1018 hours

(dB)

A6095 Newcraighall Rd / The Wisp 69.5 69.6 +0.1

Fort Kinnaird Main Western R’bout 67.0 67.2 +0.2

Fort Kinnaird Main Eastern R’bout 67.2 67.3 +0.1

Whitehill Road / Redcroft Cottage Jnt 59.6 60.2 +0.6

A1 Interchange Western Jnt 69.2 69.3 +0.1

* The predicted noise levels are based on a notional 10m distance from the kerbside.

11.5.14 The results show no significant change in noise levels during daytime

operations in respect of traffic movements relative to the nearest local road

network and residential properties. In terms of the DMRB guidance, an

increase of <1dB(A) is negligible.

Construction Mitigation – Noise

11.5.15 In accordance with BS5228, best practical means would be employed to

control the noise generation (e.g. using equipment that is regularly

maintained, where practicable use equipment fitted with silencers or acoustic

hoods).


11.5.16 In consideration of the likely highest levels of construction noise, the following

approach would be considered as part of any CEMP:

Introduce any proposed operational boundary screening at the start of

the construction phase so that it provides additional screening benefits

during the construction phase.

Restriction of construction hours to non-sensitive times of day would

normally form part of the planning consent conditions.

Sensible routing of the construction plant to avoid the nearest residential

properties (where practicable).

Careful choice of piling rigs to minimise noise.

Avoid un-necessary plant operation and revving of plant or vehicles.

Locate plant away from nearest sensitive receptors or in locations which

provide good screening in the direction of sensitive receptors.

Use of broadband noise reverse alarms (where practicable) on mobile

plant.

Decommissioning Phase Effects – Noise

11.5.17 The decommissioning phase would involve dismantling, demolition and the re-

instatement of the site. The equipment used during the decommissioning

phase is likely to involve similar equipment to that described for the

construction phase (e.g. bulldozers, excavators, HGVs, dumpers,

compressors, generators etc). There are also likely to be concrete breakers

and crushers required to break-up the concrete foundations as part of the

decommissioning phase. The predicted noise levels during concrete removal

at receptors are not anticipated to be any higher than that predicted for piling

activities during the construction phase. The increase in noise, as a result of

decommissioning, is therefore likely to result in an impact magnitude

classification with noise mitigation measures to be negligible during general

and peak noise periods at all receptors except the potential Shawfair

Development Area D where impacts are likely to be of moderate impact

magnitude.


Construction or De-commissioning Phase: Vibration

Typical Vibration Levels

11.5.18 The highest levels of vibration generated by Plant is likely to include the

following:

Piling rigs;

Vibratory rollers and compactors;

Material offloading onto hard surfaces; and

Concrete vibratory plant.

11.5.19 Typical field measurements taken at sites in the UK where piling or vibratory

rollers have been used (on clay-based ground, which is likely to be the highest

likely generated vibration) would indicate that at a distance of around 20

metres the peak particle velocity is around 14 – 17mm/s reducing to 1.5 to 2

mm/s at 30 metres distance and <1mm/s at 50 metres. For vibro piling

measured levels of vibration are shown to be between 1mm/sec and 3mm/s at

a distance of between 20 to 30 metres (ref. BS5228-2: 2009 Table D4).

BS5228:2009 Part 2: Vibration

11.5.20 Part 2 of the Standard deals with vibration from construction and open sites

and provides information on the effects of the levels of vibration, human and

structural response, response limits of structures and practical measures to

reduce vibration.

11.5.21 The distance from nearest residential receptors to any likely use of piling rigs

(i.e. building foundation construction) and vibratory compaction (i.e. during

road construction) is likely to exceed a distance of 400 metres based on the

nearest existing receptors. The potential sensitive receptors at the Shawfair

Development Area D are likely to be approximately 50m from piling under the

worst case scenario. The distance to any existing commercial or industrial

buildings would also be in excess of 150 metres (i.e. relative to the AD

facility).


Conclusion

11.5.22 Based upon the above information, it is clear that even at the closest

approach to existing residential properties, the likely levels of ground-borne

vibration would be well below the limiting value for continuous vibration of 5.0

mm/s for cosmetic damage and also below perceptible levels of vibration (i.e.

0.3mm/s) at all receptors except the potential receptor at Shawfair Area D

where vibration levels are likely to be <1mm/sec. The levels of vibration at the

closest approach to existing industrial/commercial buildings would be greater

than 150 metres. It is unlikely therefore for vibration to be perceptible within

the nearest industrial / commercial buildings and certainly well below threshold

levels where cosmetic or structural damage occurs. The results of empirical

measurements of vibration from vibratory plant at distances greater than 30

metres according to BS6472:2008 would indicate that the vibration levels are

unlikely to give rise to an ‘adverse comment’ from a nuisance aspect.

11.5.23 It should be noted that the type of equipment, ground conditions and structural

form could all affect the resultant level of vibration. At this stage, it has been

assumed that the highest likely vibration level scenario occurs (i.e. a

conservative estimate of potential effects).

11.5.24 It is also normal practice to monitor the vibration levels during initial periods of

construction (e.g. where piling or vibration compaction equipment is being

used) if the activity is within 30-50 metres of a residential or commercial

property.

11.5.25 The levels of vibration, as a result of construction, are likely to result in an

impact magnitude classification of negligible to minor and a significance

level of neutral to slight during general and peak vibration. The highest

vibration levels would be at the nearest receptor (i.e. residential properties at

Shawfair Area D) but it is not anticipated to be significant. Use of concrete

breaking plant, dozers, mobile plant, cranes and excavators during any de-

commissioning phase are unlikely to generate any significant vibration and

impacts under a worst case scenario are predicted to be negligible to minor

and a neutral to slight impact significance.


Operational Phase

Plant Noise

11.5.26 Tables 11.18 and 11.19 show the highest likely noise prediction relating to

fixed and mobile plant noise sources operating during daytime and fixed plant

noise sources during night-time periods at the Proposed Development. This

assumes that the development includes inherent noise control measures

similar to those outlined previously in this sub-section.

Daytime Operations

11.5.27 Table 11.18 over the page provides information on the predicted noise levels

during daytime operations at the Proposed Development.

Table 11.18: Predicted Noise Contribution from the RERC and HGV movement

(including inherent noise control measures) during Daytime

Receptor Position

(Refer to Figure 11.1)

Time Period Predicted Noise

Contribution from Site

LAeq1hr dB

Representative

Background Noise level

without site

LA901hr dB

[LAeq]

Rating compared

to background

noise LAeq1hr dB

Noise change

(after & before)

LAeq dB

R1 South West (NMP1) Daytime 28 42 [46] -14 0

R2 South East (NMP2) Daytime 27 50 [58] -23 0

R3 North West (NMP3) Daytime 27 49 [53] -22 0

R4 South (NMP4) Daytime 29 50 [55] -21 0

R5 West Daytime 31 41 [48] -10 0

R6. Western boundary (area D of Shawfair

development)

Daytime 39-44 42 [49] * 0 to +5 0 to +1.2

Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment an allowance of +3dB has been added for R6 due to proximity to the Site. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.

11.5.28 The predicted noise levels are for site attributable noise with the inherent

noise control measures. The fifth column in Table 11.18 shows the difference

between the predicted site noise and typical background noise at the receptor

positions. The Proposed Development would be designed to eliminate any

unusual noise characteristics. The rating level in column 5 is therefore in

accordance with the methodology found within BS4142:2014, which is the


most relevant noise criterion. For the closest receptor (R6) a +3dB penalty is

added to allow for intermittent noise sources, which may occur during the

daytime.

11.5.29 Using the PAN1/2011 tables to establish the noise impact (i.e. refer to Tables

11.6 and 11.7) the sensitivity of the receptors is low to medium. The

magnitude of the impact during daytime periods based on the quantitative

assessment shows that the change in noise level ranges between zero and

+1.2dB LAeq and therefore shown to be no change to minor impact. The

level of significance according to PAN1/2011 is neutral to slight.

11.5.30 According to BS4142: 1997, the rating level relative to background noise

would indicate complaint is unlikely at all positions. The operational noise

impacts from the Proposed Development are therefore not considered to

represent any significant impact. In terms of BS4142: 2014 the impact is likely

to be low to adverse impact without further mitigation.

11.5.31 In relation to the noise condition proposed by the Local Authority during pre-

application discussions, this would be exceeded at position 6, which is the

closest potential receptor on the Shawfair development. Further noise

mitigation measures are therefore proposed in sub-section 11.6.

Night-time Operations

11.5.32 Table 11.19 below provides information on the predicted noise levels during

night-time activities (i.e. site operational without the receipt of waste and HGV

movement).

Table 11.19: Predicted Noise Contribution from the RERC (including inherent

noise control measures) during Night-time

Receptor Position


Time Period Predicted Noise Contribution from Site

LAeq1hr dB

Representative


without site

LA901hr dB

[LAeq]

Rating compared to background noise LAeq1hr dB

Noise change

(after & before)

LAeq dB

R1 South West

(NMP1)

Night-time 27 37 [42] -10 0

R2 South East

(NMP2)

Night-time 27 42 [52] -15 0


Receptor Position



LAeq1hr dB

Representative


without site

LA901hr dB

[LAeq]


Noise change

(after & before)

LAeq dB

R3 North West

(NMP3)

Night-time 27 39 [46] -12 0

R4 South

(NMP4)

Night-time 29 42 [52] -13 0

R5 West

Night-time 31 38 [42] -7 0

R6. Western

boundary (area D

of Shawfair

development)

Night-time 42-44 42 [45] 0 to +2 +1.8 to +2.5

Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment no noise characteristic penalties are deemed to be appropriate. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.

11.5.33 Using the PAN1/2011 tables to establish the noise impact (refer to Tables

11.6 and 11.7) the sensitivity of the receptors is shown to be low. The

magnitude of the impact during night-time periods based on the quantitative

assessment shows that the change in noise level ranges between 0dB and

+2.5dB LAeq and therefore shown to be no change to minor impact. The


11.5.34 According to BS4142:1997, the rating level relative to background noise would

indicate complaint is unlikely at all positions. The operational noise impacts

from the facility are therefore not considered to represent any significant

impact. In terms of BS4142: 2014 the impact is likely to be low to adverse

impact without further mitigation.


application discussions, this would be exceeded at position 6, which is the

closest potential receptor on the Shawfair development. Further noise

mitigation measures are therefore proposed in sub-section 11.6.


Frequency Analysis

11.5.36 The predicted noise level in terms of frequency spectra compared with the

proposed internal room noise limit proposed by MLC is provided in Table

11.20 below.

11.5.37 The internal noise levels are predicted based on an open window (i.e. 15dB(A)

reduction as assumed in WHO guidance and BS8233: 2014) for comparison

with a limit of NR25 night-time..

Table 11.20: Comparison of RERC Predicted Noise Levels (inside dwellings) and

NR Night-time Noise Limits

Position Night- time

NR25

Noise limits – Octave band frequencies (Hz)

63 125 250 500 1k 2k 4k

55 44 35 29 25 22 19

R6. Western boundary with Shawfair development

48 39 31 24 21 20 8

11.5.38 The above table indicates that the internal noise limits would be achieved. The

external levels at the receptor are predicted to be approximately NR33.

Road Traffic Noise

11.5.39 The waste delivery demand would be spread across the daytime delivery

window which would be between 0800 and 2000 hours. According to the

Transport Assessment: “The maximum operation of the Proposed

Development could be anticipated to generate of the order of 128 HGV

movements on an average day (64 arrivals / 64 departures).”

11.5.40 The TA considers the PPiP for the ZWF with the traffic demand from the

Proposed Development and cumulative operation of the AD Facility. The

assessment concludes that the maximum traffic demand when compared with

the consented ZWF scheme is substantially less. It concludes: “Given that

ZWF predicted traffic levels have already been demonstrated as being

expected to result in only a negligible level of traffic and transport related

impact, there can be a high degree of confidence that the day-to-day

operation of the Proposed Development would also not give rise to material


traffic related operational or environmental effects. Indeed delivery of the

current proposals would result in an overall ‘net benefit’ in traffic and transport

impact terms when compared against the current reference planning position.”

11.5.41 Given the conclusions of the traffic analysis and number of HGV vehicle

movements compared with typical baseline traffic flows (e.g. in the order of

5,000 vehicles per day along Whitehill Road), it is therefore concluded that the

resultant noise impacts for the Proposed Development would be negligible.

Operational Phase: Vibration

Ground Vibration Monitoring – Fixed and Mobile Plant

11.5.42 Monitoring of ground-borne vibration have been previously undertaken at an

energy from waste facility, a construction site and a waste management

facility (WMF) having similar plant during typical operating conditions. Further

detail is provided in Appendix 11-8 and vibration parameters are presented in

Appendix 11-7

11.5.43 During the survey at the construction site, the seismograph transducer did not

trigger at the measurement distance of 3-5 metres from mobile plant,

indicating that the level of vibration was below the transducer sensitive

threshold of 0.3mm/sec. The only trigger recorded during the survey was

during measurements of a passing HGV at a distance of 1 metre, which

recorded a level of 0.635mm/sec.

11.5.44 At the WMF site, the seismograph was placed at 10 metres from the kerbside

of the access road to the site. The seismograph transducer did not trigger

when the HGVs were travelling along the access road prior to reaching the

speed hump (which was opposite the monitoring position). The seismograph

did however trigger during HGV movements when certain vehicles were

travelling over the speed `hump’. The maximum levels of vibration recorded

ranged between 0.45mm/s to 0.83mm/s at the 10-metre position. This level of

vibration is still relatively low and experience has shown that according to

BS6472: 2008, even when properties are at this distance, there is normally a

‘low probability of adverse comment’ over the operating period indicating that

nuisance conditions are unlikely.


11.5.45 For the monitoring of night-time operations at the energy from waste facility,

the seismograph transducer did not trigger at the measurement distance of 50

metres from the plant, indicating that the level of vibration was below the

transducer sensitive threshold of 0.3mm/sec.

11.5.46 The vibration survey results at a similar facility would indicate that vibration

levels from site operations is negligible and would therefore be imperceptible

at nearest receptors. In terms of BS6472 this would conclude that vibration

levels would be well below a ‘low probability of adverse comment’ and

therefore nuisance conditions are highly unlikely to occur.


11.6.1 The incorporated mitigation measures described previously adequately

address the needs to avoid, reduce and compensate for many of the

prevailing significant effects of the Proposed Development. However, in order

to comply with the proposed noise condition (as advised by the Local

Authority), and to meet the required noise levels at the nearest potential

receptor on the Shawfair development, further noise mitigation would be

required. These could include the following measures:

Fan stack reduced by 10dB(A) (i.e. approx. 70dBA @ 1m from end of

stack)

Turbine air cooler fans - acoustically screened to reduce noise by

approx. 8-9dBA

All buildings clad to Rw=25dB or equivalent except the MPT building in

insulated cladding and Boiler Hall (western wall) above MPT building

which would require Rw=35dB performance cladding

Turbine Hall 10dB(A) lower inside or cladding increased by 10dB(A) in

performance (i.e. SWL = 85dBW or Rw=45dB)

All doors closed during night-time periods except for maintenance or for

emergency.

Step Up Transformers – Walls and Roof acoustic panels and door made

with acoustic louvres

11.6.2 As noted in sub-section 11.5, a range of alternative measures could be

adopted to achieve noise criteria at the site. The aforementioned measures


are just one combination that would be effective in achieving the requisite

noise levels during the daytime and night-time periods.


11.7.1 The following tables (11.21 and 11.22 over the page) provide the results of re-

analysis during the daytime and night-time periods following the introduction of

the aforementioned additional noise mitigation measures.

Table 11.21: Predicted Noise Contribution from the RERC and HGV movement

(including additional noise control measures) during Daytime

Receptor Position



LAeq1hr dB

Representative


without site

LA901hr dB

[LAeq]


Noise change

(after & before)

LAeq dB

R1 South West (NMP1) Daytime 24 42 [46] -18 0

R2 South East (NMP2) Daytime 26 50 [58] -24 0

R3 North West (NMP3) Daytime 26 49 [53] -23 0

R4 South (NMP4) Daytime 28 50 [55] -22 0

R5 West Daytime 28 41 [48] -13 0

R6. Western boundary (area D

of Shawfair development)

Daytime 35-40 42 [49] * -4 to +1 0 to +0.5

Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment an allowance of +3dB has been added for R6 due to proximity to the Site. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.

11.7.2 The predicted noise levels are for site attributable noise with the additional

noise control mitigation measures.

11.7.3 Using the PAN1/2011 tables establish the noise impact (i.e. refer to Tables

11.6 and 11.7) the sensitivity of the receptors is low. The magnitude of the

impact during daytime periods based on the quantitative assessment shows

that the change in noise level ranges between zero and +0.5dB LAeq and

therefore shown to be of negligible impact. The level of significance

according to PAN1/2011 is neutral to slight.

11.7.4 According to BS4142: 1997, the rating level relative to background noise

would indicate complaint is unlikely at all positions. The operational noise

impacts from the Proposed Development are therefore not considered to


represent any significant impact. In terms of BS4142: 2014 the impact is likely

to be low.


application discussions, the noise limit is achieved at position 6, which is the

closest potential receptor on the Shawfair development.

Night-time Operations

11.7.6 Table 11.22 over the page provides information on the predicted noise levels

during night-time activities (i.e. site operational without the receipt of waste

and HGV movement).

Table 11.22: Predicted Noise Contribution from the RERC (including additional

noise control measures) during Night-time

Receptor Position



LAeq1hr dB

Representative


without site

LA901hr dB

[LAeq]


Noise change

(after & before)

LAeq dB

R1 South West (NMP1) Night-time 24 37 [42] -13 0

R2 South East (NMP2) Night-time 25 42 [52] -17 0

R3 North West (NMP3) Night-time 25 39 [46] -14 0

R4 South (NMP4) Night-time 27 42 [52] -15 0

R5 West Night-time 27 38 [42] -11 0

R6. Western

boundary (area D

of Shawfair

development)

Night-time 35-39 42 [45] -7 to -3 0 to +1.0

Site designed to eliminate any tonal or impulsive noise characteristics at receptor locations. * For BS4142: 2014 assessment no noise characteristic penalties are deemed to be appropriate. Column 6 is calculated by the logarithmic addition of columns 3 and column 4 Leq level and column 4 Leq level subtracted from the result.

11.7.7 Using the PAN1/2011 tables to establish the noise impact (refer to Tables

11.6 and 11.7) the sensitivity of the receptors is shown to be low. The

magnitude of the impact during night-time periods based on the quantitative

assessment shows that the change in noise level ranges between 0dB and

+1.0dB LAeq and therefore shown to be minor impact. The level of

significance according to PAN1/2011 is neutral to slight.


11.7.8 According to BS4142:1997, the rating level relative to background noise would

indicate complaint is unlikely at all positions. The operational noise impacts

from the Proposed Development are therefore not considered to represent

any significant impact. In terms of BS4142: 2014 the impact is likely to be a

low.


application discussions, the noise limit is achieved at position 6, which is the

closest potential receptor on the Shawfair development.

Comparison with PPiP Future Baseline Scenario

11.7.10 The noise impacts predicted for the ZWF development indicate that the noise

levels from the EfW site would not exceed background sound levels +5dB and

the combined effect of the AD Facility, EfW and MBT Facility would not

exceed a design limit of background sound +5dB. The assessment concludes

that, in terms of residual noise, the ZWF development would give rise to

environmental effects of negligible to minor adverse significance. The noise

predictions from the Proposed Development and reported in this Chapter,

show noise levels to be below existing background sound levels and based on

a worst case assessment, would only give rise to a negligible to minor impact.

In light of this, it can be concluded that the Proposed Development would only

give rise to a ‘neutral’ impact when compared to the future baseline scenario.

11.7.11 Furthermore, MLC have advised that the noise assessment should be

designed to achieve a design criteria similar to that imposed on the ZWF. If

the same planning condition is applied to the Proposed Development, there it

would not be possible for it to give rise to greater impact than the ZWF

development.

11.8 Summary and Conclusions

Introduction

11.8.1 Noise and vibration levels have been considered and assessed during the

construction and operational phases of the Proposed Development. Relevant

and appropriate noise and vibration guidance and standards have been used


to determine the impact. The assessment has been undertaken to inform and

guide the design of the Proposed Development, such that any likely noise and

vibration impact on existing dwellings is minimised.

11.8.2 To establish any likely impact from noise a baseline sound survey was

undertaken to establish the existing background levels at the nearest

receptors to the site.

11.8.3 The Environmental Health Officers and their appointed noise consultant at

Midlothian Council have been formally consulted to seek advice in respect of

appropriate noise criteria and receptor locations.

Existing Baseline Noise Conditions

11.8.4 In accordance with relevant planning policy guidance on noise the existing

baseline sound levels at the nearest receptors have been established. These

have been undertaken during daytime and night-time weekday and weekend

operating periods to establish the representative background sound levels.

11.8.5 As set out in Sub-section 11.4 the assessment has been undertaken on a

worst case basis in the context of the assumed baseline for assessment (set

out in detail in Chapter 2.0 of the ES).

Residual Effects

11.8.6 During the construction phase there would be a variety of noise sources in use

at different stages and their associated activities would vary from day to day.

The highest noise levels relative to nearest receptors are likely to occur during

site preparation and piling activities. The peak noise activities do not normally

occur over long periods of time and best practical means would be employed

to control the noise being generated. It is concluded that the increase in noise,

as a result of construction, is likely to result in an impact magnitude

classification of negligible to moderate at receptors and a neutral to

moderate impact significance.

11.8.7 During the operation of the site, it is concluded in respect of the resultant

residual impact, that with appropriate mitigation measures within the detailed


design, there is likely to be a negligible to minor impact at receptors. The


11.8.8 The assessment of impact on existing residential areas from any increase in

road traffic noise during the daytime shows no significant change in noise

levels and therefore there is likely to be a negligible impact at receptors and

neutral impact significance.

11.8.9 In terms of ground borne vibration from the operation of the site or from HGVs,

this would be below the level of perceptibility and therefore a negligible

impact and a neutral level of significance.

11.8.10 During the construction period, in terms of vibration there would also be a

negligible to minor impact and neutral to slight impact significance at the

nearest residential receptor and well within guidance limits for nuisance and

cosmetic damage.

11.8.11 During the de-commissioning period if the Shawfair Area D is developed for

residential use the impact from noise is likely to be negligible to moderate

adverse impact and neutral to moderate significance and vibration based on

a worst case scenario would be negligible to minor adverse impact

magnitude and neutral to slight impact significance.

11.8.12 In summary, no significant noise effects have been identified by the noise

assessment in relation to operational plant noise or plant vibration. Table 9.23

below summarises the predicted effects of the construction, operational and

decommissioning phases of the Proposed Development.

Table 11.23: Residual Impact at Nearest Receptor after Amelioration Measures

Source Nature of

Effect

Time Period

Impact

Magnitude

Level of

Significance

Construction noise Temporary Daytime Negligible to

Moderate

Neutral to

Moderate

De-commissioning noise Temporary Daytime Negligible to

Moderate

Neutral to

Moderate

Road traffic noise (construction)

Temporary Daytime Negligible Neutral


Road traffic noise (operation) Permanent Daytime Negligible Neutral

Industrial noise Permanent Daytime

Night-time

Negligible

Negligible to Minor

Neutral to Slight

Neutral to Slight

Construction Vibration Temporary Daytime Negligible to Minor Neutral to Slight

De-commissioning vibration Temporary Daytime Negligible to Minor Neutral to Slight

Industrial Vibration Permanent Daytime

Night-time

Negligible

Negligible

Neutral

Neutral

Road traffic vibration Permanent Daytime Negligible Neutral

Cumulative effect with AD Permanent Daytime

Night-time

Negligible to Minor

Negligible to Minor

Neutral to Slight

Neutral to Slight

Conclusions

11.8.13 For construction and de-commissioning noise, in accordance with appropriate

standards, best practical means would be employed to control noise

generation at the Proposed Development. Measures may include restriction

on operating hours, sensible routing of equipment to site and careful choice of

piling rigs to minimise noise. Such measures would be defined within the

CEMP.

11.8.14 For construction, operational and de-commissioning noise, a robust

assessment of baseline sound levels, excluding the effects of local and

significant permitted development, have been considered and the potential

nearest sensitive receptors relative to the undeveloped Shawfair Development

in order to ensure that a worst case scenario has been presented.

11.8.15 The introduction of appropriate mitigation measures would ensure that the

resultant noise levels are within appropriate guidance, standards and the limits

Midlothian Council intend to impose through a planning condition. The

measures would be based on the employment of Best Available Techniques

(BAT) to mitigate any potential peak noise sources.

11.8.16 The assessment confirms that:

1. there would be no significant impacts during the operation of the

proposed development and the noise and vibration related

environmental effects of the Proposed Development would be

negligible to slight.

2. during construction and de-commissioning under worst case conditions


the noise related environmental effects of the Millerhill RERC

development would be neutral to moderate and the vibration neutral

to slight.

3. the Proposed Development would only give rise to a neutral effect when

compared to the future baseline scenario associated with the ZWF

development.

11.9 References

Noise

BS4142: 1997 Method for rating industrial noise affecting mixed

residential and industrial areas.

BS4142: 2014 `Methods for rating and assessing industrial and

commercial sound’

BS8233: 2014 `Guidance on sound insulation and noise

reduction for buildings’

Planning Advice Note (“PAN”) 1/2011, `Planning and Noise’ –

March 2011

PAN1/2011 Technical Advice Note

Guidelines for Community Noise – World Health Organisation:

April 1999

World Health Organisation `Night Noise Guidelines for Europe’

– 2009;

BS7445: 2003 - Description and measurement of environmental

noise.

BS5228-1 & 2 2009 Code of Practice for noise and vibration

control on construction and open sites.

ISO 9613-2: 1996 Acoustics – Attenuation of Sound During

Propagation Outdoors.

Design Manual for Roads and Bridges, Volume 11,

Environmental Assessment; June 2010 (Part 2 GD 01/08)

Vibration

BS7385:1990 Evaluation and measurement for vibration in

buildings: Part 1 Guide for measurement of vibrations and


evaluation of their effects in buildings. British Standards

Institution

ISO4866:1990(E) Mechanical vibration and shock - Vibration in

buildings - Guidelines for the measurement of vibrations and the

evaluation of their effects on buildings. International

Organisation for Standardisation.

BS7385:1993 Evaluation and measurement for vibration in

buildings: Part 2 Guide to Damage Levels from Ground Borne

Vibration. British Standards Institution.

German Standard DIN 4150, Part 3 1986

Whiffin, A C and Leonard, D R (1971) "A Survey of Traffic-

Induced Vibrations" Transport and Road Research Laboratory

(TRRL) Report 418.

Steffens, R J Structural vibration and damage - Some notes on

aspects and a review of available information. Building

Research Establishment Report.

BS6472: 2008 Evaluation of human exposure to vibration in

buildings (1Hz to 80Hz). British Standards Institution


12.0 AIR QUALITY

12.1 Introduction

12.1.1 This chapter of the ES has been prepared to consider the potential impacts of

the Proposed Development on air quality.

12.1.2 The approach undertaken in the air quality assessment that is presented

within this Chapter varies from that set out within Chapter 2.0 regarding the

assumed baseline position. The reason for this is that the monitored

background air quality data, for obvious reasons, does not include aerial

emissions from the AD Facility, SNCD and the Borders Railway. As such, this

Chapter presents an assessment of the proposed development on the existing

background air quality conditions and then, subsequently, goes on to assess

the cumulative effects of the Proposed Development and the AD Facility.

12.1.3 On the basis that the other developments (Borders Railway and SNCD) would

not have point source emissions, they have not been modelled. It is

considered that this methodology would provide the clearest approach to an

assessment of air quality effects.

Assessment Overview

12.1.4 The Air Quality Assessment (AQA) is based on an atmospheric dispersion

modelling study of releases from the Application Site in isolation and in

combination with the adjacent AD Facility; the study was undertaken using

one of the modelling packages (ADMS5) recognised as being suitable for

such assessments. It follows guidance issued by both the SEPA and, where

suitable Guidance from the SEPA is not available, the EA. The scope and

approach of all elements of the assessment was agreed with the SEPA

beforehand.

12.1.5 The assessment provides details on the sources, nature and potential impacts

of the emissions to air from the Application Site in isolation and then in

combination with those from the adjacent AD Facility. The study takes account

of the effects of meteorological conditions, local terrain, building downwash

and existing local air quality on emissions from both the Application Site in


isolation and then in combination with the adjacent AD Facility. The model

predicted the impact of emissions at the points of maximum ground level

concentration (GLCs) on local air quality and at a range of sensitive human

and environmental receptors which could be affected by releases from the

Application Site.

12.1.6 The objectives of the study were:

To determine a suitable height for the Application Site’s discharge stack;

To determine the maximum GLCs arising from the emission of pollutants

from the Application Site discharge stack based on the discharges being

at the maximum permitted concentrations and the ERC operating

normally and abnormally;

To determine the maximum GLCs arising from the emission of pollutants

from the Application Site discharge stack based on the discharges being

at the actual concentrations measured in FCC’s sister plant, which is of

the same design and specification (at North Hykeham, Lincolnshire);

To assess the impact of emissions from the Proposed Development on

existing local air quality in relation to human health at a range of

potentially sensitive receptors by comparison with relevant air quality

standards (AQSs);

To predict deposition rates of acids and nutrient Nitrogen from the

modelled emissions and compare these with relevant Critical Loads and

Critical Levels at a range of sensitive habitat sites;

To assess plume visibility; and

To provide an assessment of cumulative impacts of the discharges from

the Proposed Development and the adjacent AD Facility.

12.1.7 A copy of the full study is provided in Appendix 12-1 of this ES.

Previous Assessment

12.1.8 As discussed in Chapter 1.0 of the ES, the Application Site benefits from PPiP

(granted in 2012) for the ZWF, comprising:

An EfW Facility;

An AD Facility; and

A MBT Facility.


12.1.9 An AQA in the form of an atmospheric dispersion modelling study was carried

out for the ZWF. The results of the assessment indicated that a discharge

stack height of 65m for the EfW facility would be acceptable.


EfW and MBT facilities. Given the difference in technology proposed and the

different discharge stack height proposed 75m (see below), the results of the

AQA for the Proposed Development would differ from those assessed for the

ZWF, and, hence, the current air quality assessment is required.


12.1.11 A detailed description of the Proposed Development is set out Chapter 4.0 of

this ES. Key aspects of the development that are of relevance to this air

quality assessment are the emissions from the proposed 75m high exhaust

stack. All discharge stack parameters are fully described in the AQA which is

provided in Appendix 12-1.


12.1.12 Key legislation and policies relevant to the air quality assessment are

summarised below.

National Planning Policy

12.1.13 PAN 51 (Revised 2006) sets out advice from the Government in terms of core

policies and principles in relation to planning and pollution control.

Accordingly, the planning system should focus on whether the development

itself is an acceptable use of the land and the impacts of those uses, rather

than seeking to control the processes or emissions themselves as these are

covered through other regulatory processes such as the PPC permitting

regime: “...the planning authority should have regard to the impact of a

proposal on air or water quality although the regulation of emissions or

discharges will fall to be dealt with under other legislation.” (Paragraph 57 of

SPP1)


12.1.14 The Edinburgh and Lothian’s Structure Plan (ELSP) 2015 includes a policy

for the protection of habitats, ENV1 F: Environmental or Biodiversity

Assessments. The policy states: “Development proposals that would affect

any designated natural heritage site, protected priority habitat or species or

other important non-statutory locations will require an appropriate level of

environmental or biodiversity assessment.”

Local Planning Policy

12.1.15 The Midlothian Local Plan 2008 implements the ELSP 2015, Policy ENV1

Criterion F also states that: “the Local Plan will not permit development that

will adversely affect such species other than in circumstances where

appropriate measures can be taken to minimise the effect of the

development or make positive provision for the protection of such species

and habitats.”

Industrial Emissions Directive (2010/75/EU)

12.1.16 The key legislation relating to discharges to air from the Application Site is

the Industrial Emissions Directive (IED). The IED prescribes measures

relating to the control of emissions to air and sets limits on emissions of a

wide range of air pollutants, for both normal and abnormal operation.

12.1.17 Chapter IV, Articles 42 to 55, of the IED ‘Special Provisions for Waste

Incineration Plants and Waste Co-incineration Plants’, sets out the

requirements that need to be met for the EfW activities that would be

undertaken at the Application Site. These Articles specifically address:

Article 42 – Scope;

Article 43 – Definition of residue;

Article 44 – Application for permits;

Article 45 – Permit conditions;

Article 46 – Control of Emissions;

Article 47 – Breakdown;

Article 48 – Monitoring of emissions;

Article 49 – Compliance with emission limit values;

Article 50 – Operating conditions;


Article 51 – Authorisation to change operating conditions;

Article 52 – Delivery and reception of waste;

Article 53 – Residues;

Article 54 – Substantial change; and

Article 55 – Reporting and public information on waste incineration

plants and waste co-incineration plants.

12.1.18 Furthermore, Annex VI of the IED: ‘Technical Provisions Relating to Waste

Incineration Plants and Waste Co-incineration Plants’, in Part 3: ‘Air

Emission Limit Values for Waste Incineration Plants ‘prescribes the limits

that releases to air must meet under both normal and abnormal operating

conditions.

Pollution Prevention and Control (Scotland) Regulations 2012 (as amended)

12.1.19 The proposed development would require an environmental permit to

operate under the provisions of the Pollution Prevention and Control

(Scotland) Regulations 2012 (as amended) (PPC Regulations). The

requirements of the IED are implemented through the PPC Regulations. In

order to be issued with a PPC Permit, the Application Site would need to

demonstrate that Best Available Techniques (BAT) are being used to

minimise emissions to all media. In relation to the proposed activities at the

Application Site, compliance with the requirements of the IED is regarded as

BAT.

The Air Quality Strategy for England, Scotland, Wales and Northern Ireland

2007

12.1.20 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland

2007 (AQ Strategy) sets out air quality objectives and options to further

improve air quality in the UK both in the present and in the long term.

12.1.21 The AQ Strategy provides an overview and outline of the ambient (outdoor)

air quality policy for all UK Governments / devolved administrations,

including the Scottish Government. It sets out a way forward for work and

planning on air quality issues, details objectives to be achieved, and


proposes measures to be considered further to help reach them. The

Strategy document comprises three volumes, namely:

Volume 1 of the Strategy provides an overview of the approach taken

and details the actual standards and objectives for the UK. For the

purposes of the Strategy:

o ‘Standards’ are the concentrations of pollutants in the

atmosphere which can broadly be taken to achieve a certain

level of environmental quality; the standards are based on

assessment of the effects of each pollutant on human health,

including the effects on sensitive subgroups or on ecosystems;

and

o ‘Objectives’ are policy targets often expressed as a maximum

ambient concentration not to be exceed, either without exception

or with a permitted number of exceedances, within a specified

timescale.

Table 2 of Volume 1 details the: ‘National Air Quality Objectives and

European Directive Limit and target values for the protection of human

health.’ These, together with other relevant AQS have been used in this

AQA.

Volume 2 sets out the scientific and economic evidence base; and

Volume 3 represents a fully updated Third Report of the

Interdepartmental Group on Costs and Benefits (IGCB).

12.1.22 In the context of this assessment, the AQ Strategy defines objectives for

particulate matter (as both PM10 and PM2.5), Carbon Monoxide, Sulphur

Dioxide, Nitrogen Dioxide and Benzene.

12.1.23 The AQ Strategy also sets objectives for Nitrogen Oxides and Sulphur Dioxide

for the protection of vegetation and ecosystems.

Air Quality Standards (Scotland) Regulations (SSSI 2010 No 204)

12.1.24 The standards and objectives for air quality detailed in the AQ Strategy are

laid down in the Air Quality Standards (Scotland) Regulations (SSSI 2010 No

204). For substances not specified in these regulations, air quality guidelines


Environment Assessment levels (EALs) – are provided in the SEPA guidance

(see below).

The Fourth Air Quality Daughter Directive (2004/107/EC)

12.1.25 The Fourth Air Quality Daughter Directive (AQDD, 2004/107/EC) details

Target Values for Arsenic, Cadmium and Nickel. These are all relevant to this

assessment.

Expert Panel on Air Quality Standards – Metals and Metalloids

12.1.26 The Expert Panel on Air Quality Standards (EPAQS), which advises the UK

Governments on air quality, has set recommended Guideline Values for

arsenic, chromium VI and nickel in their document: Metals and Metalloids

(2009). The EPAQS Guideline Value for nickel is the same as the AQDD

Target Value, but the EPAQS Guideline Value for arsenic is half that of the

AQDD value. The lowest of these values have been taken into account in this

study.

EPAQS – Guidelines for Halogens and Hydrogen Halides in Ambient Air

12.1.27 EPAQS, in its document: Guidelines for Halogens and Hydrogen Halides in

Ambient Air (2009), has also set recommended Guideline values for Hydrogen

Chloride and Hydrogen Fluoride and these have been taken into account in

this study.

Council Directive 92/43/EEC on the Conservation of Natural Habitats and of

Wild Flora and Fauna (the Habitats Directive)

12.1.28 The Habitats Directive (together with Council Directive 2009/147/EC on the

Conservation of Wild Birds (the Birds Directive), forms the cornerstone of

Europe's nature conservation policy. It is built around two pillars: the Natura

2000 network of protected sites and the strict system of species protection.

The Directive protects over 1,000 animals and plant species and over 200:

‘habitat types’ (e.g. special types of forests, meadows, wetlands, etc.), which

are of European importance.


12.1.29 The requirements of the Directive are implemented through the

Conservation Habitats and Species Regulations (SI 2010 No 490) (see

below).

Conservation Habitats and Species Regulations (SI 2010 No 490) (as

amended in Scotland)

12.1.30 The Conservation Habitats and Species Regulations (SI 2010 No 490) (as

amended in Scotland) transpose the requirements of the Habitats Directive

into national law. The Regulations provide for the designation and protection

of: ‘European Sites’ and the protection of: ‘European Protected Species’. If an

assessment carried out as part of the planning process indicated that

predicted impacts at a European designated site could not be screened out as

insignificant, the decision-making authority would be required to carry out an:

‘Appropriate Assessment’ in close consultation with SNH. This is designed to

establish whether a proposed development would adversely affect the integrity

of any such European Sites.

12.2 Methodology

Current Guidance

12.2.1 The key guidance document in relation to the air quality assessment is the

SEPA’s Guidance Note H1, and this is discussed below.

SEPA Guidance Note H1: Environmental Assessment and Appraisal of BAT

12.2.2 The SEPA Guidance Note H1: Environmental Assessment and Appraisal of

BAT provides guidance on the assessment of Best Available Techniques for

the purposes of the PPC permitting system. In terms of air quality

assessment, it provides guidelines on how to assess impact and criteria on

how to determine whether an impact is significant or not. It also details,

where AQSs have not been assigned, what are known as EALs for a range

of polluting substances; these have been derived from a variety of published

UK and international sources (including the World Health Organisation

(WHO). The EAL is the concentration of a substance which in a particular

environmental medium the Regulators regard as a comparator value to


enable a comparison to be made between the environmental effects of

different substances in that medium and between environmental effects in

different media and to enable the summation of those effects. EALs for air

are detailed in Appendix D4 of H1. In the context of the air quality

assessment for the Proposed Development, EALs for Ammonia. Antimony,

Chromium (III), Cobalt, Copper, Manganese, Mercury, Thallium and Vanadium

have been used.

12.2.3 Appendix D7 of H1 also details maximum deposition rates (MDRs) for

various substances. In the context of this study, deposition of the metals

Arsenic, Cadmium, Chromium, Copper, Lead, Mercury and Nickel were

considered (the only substances for which MDRs have been assigned that

are relevant to this assessment).

The UK ADMS Model

12.2.4 The UK-ADMS model was developed jointly by the Cambridge Environmental

Research Consultants (CERC), Her Majesty’s Inspectorate of Pollution (the

EA’s predecessor body), the Meteorological Office and National Power, with

sponsorship from the UK Government and a number of commercial

organisations. UK-ADMS is a computer based model of dispersion from both

point and non-point sources in the atmosphere and is one of the modelling

packages that are suitable for this type of study.

Scope of Modelling Study

12.2.5 The first part of the study comprised a screening assessment to determine a

suitable height for the facility’s discharge stack. Based on experience of

similar plants, the stack height screening assessment was undertaken using

oxides of nitrogen (NOx, expressed as nitrogen dioxide NO2) and the trace

metals Arsenic, Cadmium, Hexavalent Chromium and Nickel. The impacts of

NOx and ammonia at Habitat sites were also considered, together with the

effect of nutrient nitrogen deposition at thirty-two potentially sensitive

ecological sites (also agreed with the SEPA). The effects of emissions from

the facility operating under abnormal conditions, as defined in the IED, were

also considered. The impact of the facility on human health and sensitive

habitats was assessed for a range of stack heights between 50m and 90m.


12.2.6 The main study determined the maximum predicted GLCs of the following

pollutants (using the stack height determined in the stack height screening

assessment):

Nitrogen Oxides (NOx, expressed as Nitrogen Dioxide (NO2));

Total fine particles (PM10 and PM2.5);

Carbon Monoxide (CO);

Gaseous and vaporous organic substances (VOCs), expressed as total

organic carbon and assumed to comprise entirely of benzene (in

accordance with the guidance provided in Guidance Note H1, which

indicates that, where characterisation of VOCs has not been

undertaken, a precautionary approach is taken and all VOCs are

assumed to present as benzene);

Sulphur Dioxide (SO2);

Hydrogen Chloride (HCl);

Hydrogen Fluoride (HF);

Ammonia (NH3);

Mercury (Hg) and its compounds;

Cadmium (Cd) and Thallium (Tl) and their compounds;

Antimony (Sb), Arsenic (As), Chromium (Cr), Cobalt (Co), Copper (Cu),

Lead (Pb), Manganese (Mn), Nickel (Ni), Vanadium (V) and their

compounds (note for ease of reporting, this group of nine metals and

their compounds are hereinafter referred to as: ‘Group 3 metals and

their compounds’;

Dioxins and Furans;

Polychlorinated Biphenyls(PCBs); and

Polyaromatic Hydrocarbons (PAH), expressed as Benzo[a]pyrene (the

AQS for PAH is expressed as Benzo[a]pyrene, and, accordingly, for the

purposes of the assessment, all PAH are assumed to be present as

Benzo[a]pyrene).

12.2.7 Modelling was carried out using the appropriate Emission Limit Values (ELVs)

as specified in the IED. Daily ELVs were used for the main assessment as the

frequency with which the half hourly limit can be exceeded is limited by the

provisions of Annex VI of the IED. Consequently, it would be unreasonable to

assume that the facility operates continually at the half hour limits even for the

prediction of short-term concentrations. Half-hourly ELVs, where such limits


have been assigned, were used for assessing abnormal releases. The effects

of prevailing meteorological conditions, building downwash effects, local

terrain and existing ambient air quality were also taken into account.

12.2.8 The maximum predicted pollutant GLCs, also known as the process

contributions (PCs),- for each of the releases were compared with the relevant

AQSs i.e. the UK Air Quality Strategy Objective or Target Value, the EPAQS

Guideline Value or the EALs (as detailed in Table D4 of H1), as appropriate.

12.2.9 The impacts were also assessed using actual emissions monitoring data -

rather than the IED ELVs from FCC’s sister plant, which is of the same design

and specification, at North Hykeham, Lincoln.

12.2.10 The maximum predicted pollutant GLCs at thirty-four human receptors were

also compared to the relevant AQSs. There are no declared Air Quality

Management Areas (AQMAs); in Midlothian, however, there are five AQMAs

within the City of Edinburgh. The closest to the site being City Centre AQMA

at Cowgate (6.7km from the facility stack) which is declared for annual mean

concentrations of NO2. This location has also been included in the

assessment as a potentially sensitive receptor.

12.2.11 The predicted environmental concentrations (PECs), the sum of the pollutant

PC and the existing pollutant background concentration from other sources,

were also compared to the relevant standards where necessary.

12.2.12 Metals deposition was also considered. Maximum predicted deposition rates

for those substances for which MDRs have been assigned (see above) were

compared to the MDRs detailed in Table D7 of H1.

12.2.13 The maximum predicted annual mean GLCs of oxides of nitrogen, sulphur

dioxide, hydrogen fluoride and ammonia were compared with the critical levels

for the Protection of Ecosystems or Vegetation detailed in Table D3 of H1 at

thirty-two sensitive ecological receptors. (Critical levels are thresholds of

airborne pollutant concentrations above which damage may be sustained to

sensitive plants and animals).


12.2.14 The rates of deposition for acids (nitrogen and sulphur) and nutrient nitrogen

were predicted for all relevant Habitat sites. These rates were then compared

to the appropriate critical loads for the type and location of each habitat.

Critical loads are defined as: “a quantitative estimate of exposure to one or

more pollutants below which significant harmful effects on specified sensitive

elements of the environment do not occur according to present knowledge.”

12.2.15 Abnormal operating conditions were also considered in the study to take

account of short-term abnormal conditions permitted under Article 46(6) of the

IED.

12.2.16 In relation to the cumulative effects, it is known that, at the time of writing, that

the only potential development within a 15km radius that should be considered

in a cumulative assessment is the neighbouring AD Facility (this was agreed

with the SEPA). Emissions from the CHP stack and the flare stack at the AD

Facility were considered.

The Study Area

12.2.17 For assessing the point of maximum ground level concentration of pollutants

an area 10km by 10km was used with the ERC stack as the central location.

12.2.18 For assessing the impact on ecologically protected sites, all sites within 15km

from the stack were included.

12.2.19 Sensitive human receptors within the assessment included residential

locations, schools, universities, farms and medical facilities. These vary in

distance from 0.5km to 3km from the ERC stack.

Model Parameters

Key Assumptions

12.2.20 The study has been undertaken on the basis of a worst case scenario.

Consequently, the following assumptions have been made:

The release concentrations of the pollutants would be at the ELVs and

emission rates as provided by the IED on a 24 hourly basis, 365 days


of the year; in practice, when the plant is operating, the release

concentrations would be below the ELVs, and, for most pollutants,

considerably so; furthermore, taking shutdowns for planned

maintenance into account, the ERC would not operate for 365 days a

year.

The highest predicted pollutant GLCs for the five years of

meteorological data for each averaging period (annual mean, hourly,

24 hourly etc.) have been used;

All of the particulate releases would be present as PM2.5 and also as

PM10; this enables direct comparison with the particle AQSs, which are

expressed in terms of PM2.5 and PM10; in practice, this would not be the

case as some of the particles present would be larger than PM10;

For the purposes of the short-term assessments, 35% of the oxides of

nitrogen in the releases would be present as nitrogen dioxide; in

practice, at the time of discharge from the stack, the percentage of

nitrogen dioxide in the releases is likely to be below this; for the long-

term assessments, it has been assumed that 70% of the oxides of

nitrogen in the releases would be converted to nitrogen dioxide in the

atmosphere (these assumptions are in accord with current the SEPA

guidance); and

Maximum predicted GLCs at any location, irrespective of whether a

sensitive receptor is characteristic of public exposure, are compared

against the relevant AQSs for each pollutant; in addition, the predicted

maximum sensitive receptor GLC has also been assessed.

12.2.21 Taken together, the assumptions used for the modelling study are likely to

have resulted in a conservative estimate i.e. an overestimate, of the impact of

the proposed facility.

Model Input Parameters

Stack Emission Parameters

12.2.22 The stack emission parameters for the Proposed Development discharge

stack used in the study are presented in Table 10 of the modelling study

report, and the associated pollutant discharge rates are presented in Table 11


of the modelling study report. The stack emission parameters for the AD

Facility CHP and flare stacks and the associated pollutant discharge rates are

presented in Tables 12 and 13, respectively, of the modelling study report.

Meteorological Data

12.2.23 Five years (2009 – 2013) of hourly sequentially analysed meteorological data

from Gogarbank, which is 16km north-west of the Application Site, was used;

it was agreed with the SEPA that this was the most appropriate data to use in

the assessment.

Building Parameters

12.2.24 The building parameters utilised for the study are detailed in Table 15 for the

Millerhill RERC and Table 16 for the AD Facility of the modelling study report,

respectively.

Terrain Data

12.2.25 Terrain data was used for an area of 1024km2 and was created by compiling

the data from the relevant Ordnance Survey tiles. The terrain data used was

of sufficient size to ensure that it would encompass all of the sensitive human

and ecological receptors.

Roughness Length

12.2.26 The surface nature of the terrain is defined in terms of roughness length. The

roughness length is dependent on the type of terrain and its physical

properties; agricultural areas are classed as 0.3m, parkland and open

suburbia as 0.5m and cities and woodlands as 1.0m. Given the nature of the

terrain, the intended end use of both the Application Site and the surrounding

area, it was considered that the most appropriate surface roughness would be

0.5m. To test this, three roughness lengths were assessed, namely 0.3m.

0.5m and 1.0m; the results of the assessment are presented in Table 18 of the

modelling study report. Following this assessment, a surface roughness of

0.5m was selected as being the most representative of the Application Site

and surrounding area.


Deposition Parameters

12.2.27 The deposition rates modelled for metals were taken from Table D7 of H1.

12.2.28 The deposition rates for sulphur dioxide, oxides of nitrogen, ammonia and

hydrogen chloride were taken from Guidance Note AQTAG 06: Technical

Guidance on Detailed Modelling Approach for an Appropriate Assessment

(April 2010).

Significance of Effects

General Criteria for the Assessment of Significance

12.2.29 This section identifies the criteria used to determine the significance of the

effects produced by the Proposed Development on air quality.

12.2.30 Module 3 of H1 details the guidelines upon which the assessment of the

significance of impact can be established. In the first instance, it indicates that

process contributions (PCs) can be considered insignificant if:

The long-term PC is <1% of the long-term environmental standard; and

The short-term PC is <10% of the short-term environmental standard.

12.2.31 Where a PC exceeds the above criteria, then the impact is deemed ‘potentially

significant’, and further assessment has to be undertaken. The next step of

the assessment takes account of the existing background concentrations of

the pollutant of interest, and H1 indicates that environmental standards are

unlikely to be exceeded provided:

The long-term PEC is <70% of the long-term environmental standard

(where the long-term PEC is the sum of the long-term PC and the long-

term pollutant background concentration); and

The short-term PC is <20% (short-term standard 2 x long-term

pollutant background concentration).

12.2.32 However, it is important to note that, for the Group 3 metals, there is an

additional criterion that states that the environmental standard is unlikely to be

exceeded if:


The long-term and short-term PEC is <100% of the long-term and

short-term environmental standard (as appropriate) (where the short-

term PEC is the sum of the short-term PC and twice the long-term

pollutant background concentration).

Additional Assessment of Significance Guidelines for Trace Metals

12.2.33 For trace metals, Annex VI of the IED assigns ELVs for three groups. Group 1

comprises Cadmium and Thallium, Group 2 comprises Mercury and Group 3

comprises Antimony, Arsenic, Chromium, Cobalt, Copper, Manganese, Lead,

Nickel and Vanadium. The ELVs are the total for the combined emissions, and

it would not be reasonable to assume that each metal emits at the maximum

ELV for the group. In this regard, the EA has provided guidance on the steps

required for assessing the impact of such metal emissions, namely: Releases

from Municipal Waste Incinerators: Guidance to Applicants on Impact

Assessment for Group 3 Metals (V3, September 2012), and these are

discussed below. The use of this guidance has been agreed in writing with the

SEPA. Also please note that although the guidance applies to Group 3 metals,

a similar approach has been adopted here for the Group 1 metals.

12.2.34 Step 1 of the guidance is to assume that all emissions are at the maximum

ELV for the group. For example, all of the Group 3 metals would be assumed

to be emitted at a concentration of 0.5mg/Nm3 and the Group 1 metals at a

concentration of 0.05mg/Nm3. For Step 1 it is assumed that hexavalent

chromium is 20% of total Cr. This is based on information on background

concentrations provided by EPAQS: Guidelines for Metals and Metalloids in

Ambient Air for the Protection of Human Health (May 2009).

12.2.35 Where the release is considered to be potentially significant, Step 2 of the

guidance allows the applicant to assume that all emissions are an equal

proportion of the ELV for the group. For example, all of the Group 3 metals

would be assumed to be emitted at 11% of the ELV (i.e. 0.056mg/Nm3), and

the Group 1 metals are assumed to be emitted at 50% of the ELV (i.e.

0.025mg/Nm3). For Step 2 it is assumed that chromium VI is 20% of total

chromium.


12.2.36 Where the release is still considered to be potentially significant, Step 3 of the

guidance allows the applicant to justify lower percentages for each Group 3

metal. In this case, mean emissions from operational municipal waste

incineration plants as indicated in the EA Guidance have been used (as

agreed with the SEPA).

12.2.37 The effects of the Proposed Development would be considered significant in

the context of this EIA in the event that they exceed the stated thresholds for

impacts upon air quality.

Consultation

12.2.38 The SEPA was consulted with regard to all aspects of the modelling study.

The scope of the study described below was agreed with the SEPA.

12.3 Baseline

12.3.1 As described in the introduction, this sub-section provides baseline data on

the air quality conditions in and around the Application Site as they currently

exist. It does not allow for the other facilities that fall within the assumed

baseline for assessment.

Background Nitrogen Dioxide Concentrations

12.3.2 There are no measurements of NO2 undertaken by MLC, East Lothian Council

or the ECC in the vicinity of the site. The nearest measurements are taken in

Dalkeith, approximately 3km south of the site.

12.3.3 Accordingly, annual mean ambient background concentrations of NO2 for

2014 have been obtained from the DEFRA UK Background Air Pollution

Maps. The concentration of NO2 at NGR 332500, 670500, the appropriate

1km grid square - is 10.72µg/m3.

Background Sulphur Dioxide Concentrations

12.3.4 The DEFRA mapped SO2 concentration for the area surrounding the

proposed facility is 2.716µg/m3 and, accordingly, this value is assumed to be


representative of the background concentration at the site and nearby

sensitive receptor locations.

Background Particulate Matter Concentrations

12.3.5 The 2015 DEFRA mapped PM10 concentration for the area surrounding the

Application Site is 13.49µg/m3, and, accordingly, this value is assumed to be



12.3.6 The 2015 DEFRA mapped PM2.5 concentration for the area surrounding the

Application Site is 7.94µg/m3, and, again, this value is assumed to be



Background Volatile Organic Compounds (as Benzene) Concentrations

12.3.7 The 2015 DEFRA mapped benzene concentration for the area surrounding

the Application Site is 0.329µg/m3, and, accordingly, this value is assumed to

be representative of the background concentration at the site and nearby


Background Trace Metal Concentrations

12.3.8 Monitoring of trace elements has been undertaken by DEFRA since 1976.

Currently, monitoring of twelve metals is carried out locations throughout the

UK, predominantly in urban locations. In addition, concentrations of Arsenic,

Cadmium, Mercury, and Nickel are monitored at a further ten rural locations.

12.3.9 The closest location to the application site is the rural site at Auchencorth

Moss, approximately 18km to the south waste of the site. The mean

concentrations measured at the site in 2013 have been used for the

assessment and are as follows:

Arsenic – 0.213 ng/m3;

Cadmium – 0.0248 ng/m3;

Chromium – 0.790 ng/m3;


Chromium VI* – 0.158 ng/m3; and

Nickel – 0.279 ng/m3.

*Note: For chromium VI, it has been assumed that the background concentration is 20% of the total Cr concentration (as indicated in the EPAQS May 2009 report: Guidelines for Metals and Metalloids in Ambient Air for the Protection of Human Health).

Background Polyaromatic Hydrocarbons (as Benzo[a]pyrene)

Concentrations

12.3.10 Ambient monitoring of benzo[a]pyrene (B[a]P) is carried out as part of the

DEFRA PAH Network at a number of locations around the UK.

12.3.11 There are two monitoring sites in close proximity to the Proposed

Developemnt, namely Edinburgh St Leonards and Auchencorth Moss. The

latest data available from Edinburgh St Leonards is for 2006, whilst for

Auchencorth Moss, 2013 data is available. Although the Edinburgh St

Leonards monitoring station is closer to the Proposed Development (6.5km

north-west of the stack) as the data is significantly older, the Auchencorth

Moss data (17.6km south-west of the stack) has been used. The average

annual mean B[a]P concentration for 2013 of 0.035ng/m3 is assumed to

provide a reasonable estimate of the background concentration at the

proposed facility and at sensitive receptor locations.




granted planning consent. The assessment of effects in this Scenario seeks to

set out in brief any additional air quality effects that would derive from the

Proposed Development, over and above those deriving from the consented

ZWF development, which it would effectively replace. The principal differences

between the consented ZWF and the Proposed Development, in so far as

they relate to the assessment of air quality effects, as set out in paragraph

12.1.8 in this Chapter.




12.4.1 A detailed description of the Proposed Development is set out in Chapter 4.0

of the ES. A series of measures have been incorporated into the design of the

Proposed Development, and into its construction and operational procedures,

which are intended to provide a suitable degree of mitigation against

potentially adverse air quality impacts from either controlled or fugitive

releases.

12.4.2 The mitigation measures that would be in place to control emissions to air

during the construction phase would be detailed in the CEMP. The CEMP

would include detailed method statements for, amongst other things, the

control of emissions to air from the construction activities, and as described in

Chapter 4.0 of the ES. The CEMP would include details of measures required

mitigate the adverse effects of the construction phase including:

Hard-surfaced haul roads;

Stockpiles of materials that have the potential to generate dust would be

securely sheeted;

Drop heights would be minimised;

Dust suppression, including measures to ensure the correct treatment of

disposal of run-off from dust suppression activities;

No-idling of vehicles;

Effective vehicle cleaning and wheel washing at site exit;

The covering of all loads which have the potential to generate dust;

No site run-off; and

All vehicles and plant would be well maintained.

12.4.3 A whole range of mitigation measures would be incorporated into the

Proposed Development to ensure that there are no unacceptable impacts on

air quality during its operational phase. These would comprise a combination

of design measures and management and operational procedures covering

both the MBT and the EfW plant, and would include those measures detailed

below.


Management and Staffing Arrangements:

The Proposed Development would have an appropriate management

structure in place and would be suitably staffed;

It is FCC’s intention that the an integrated management system (IMS)

would be developed at the proposed development; the IMS would be

based on the requirements of:

The international quality management standard ISO9001,

The international environmental management standard ISO14001, and

the international occupational health and safety management standard

OHSAS18001;

These arrangements would ensure that the Proposed Development is

managed and operated to the highest standards at all times;

All operational procedures would be properly documented; this would l

help to ensure that the plant is operated in an appropriate manner at all

times; and

All staff would be properly trained in their respective duties; again, this

would help to ensure that the plant is operated in an appropriate manner

at all times.

Operational Measures:

General Arrangements

12.4.4 All aspects of the plant would be controlled by a series of sophisticated

computer control systems which would provide feedback to the plant

operators on the operational status of the plant at all times.

Mechanical Treatment Plant

All waste coming into the MBT would be off-loaded inside the Waste

Reception Building with the access doors closed;

All internal areas of the MBT would be kept under negative pressure;

and

When the EFW is not operational (approximately 2 weeks per year) air

from inside the mechanical treatment plant would not be under negative


pressure and accordingly air from this area would be ducted through a

biofilter to control odour emissions from the plant.

12.4.5 These arrangements would help to ensure that the potential for fugitive dust

and odour emissions from the MBT would be minimised.

Energy from Waste Plant

All elements of the ERC plant have been designed to meet the

requirements of the IED;

The ERC would incorporate a selective non-catalytic reduction (SNCR)

system to ensure that NOx are reduced to a level that would ensure that

the emissions meet the requirements of the IED;

The ERC would incorporate a flue gas treatment stage to remove acid

gases and particulate matter from the gas stream before discharge to

atmosphere; this comprises a lime and activated carbon injection

system and a high specification bag filtration system; again, these

arrangements would ensure that IED requirements would be met in

relation to emissions of particulate matter, sulphur dioxide, hydrogen

chloride and hydrogen fluoride;

The plant would be equipped with a comprehensive range of continuous

monitoring devices to ensure that the plant operators are fully aware of

the status of the emissions from the plant at all times; these devices

would monitor: Particulate Matter, Carbon Monoxide, Oxides of Nitrogen

(Nitrogen Monoxide (NO) and Nitrogen Dioxide (NO2) expressed as

NO2), Ammonia, Sulphur Dioxide, Volatile Organic Compounds (VOCs,

expressed as Total Organic Carbon (TOC)), Hydrogen Chloride,

Ooxygen, moisture, temperature, pressure and velocity and flow; the

continuous emissions monitoring data generated by these devices

would enable the operators to adjust and / or shut down the Proposed

Development if necessary; and

The ERC would be equipped with a comprehensive series of alarms and

interlock systems throughout; these would provide an indication of any

potential or actual system faults and would, if necessary, automatically

close the ERC down.


12.4.6 It is evident from the measures described above, that the Proposed

Development would benefit from extensive mitigation through a combination of

design, management procedures and operational procedures.

Construction Phase






likely to take place within the first 5 months. Erection of building frames, plant

and equipment and then cladding would follow.


Application Site and in the surrounding area, associated with the Borders

Railway, the AD Facility and the SNCD. The baseline for the AQA assumes

that this construction activity is complete (see the introduction to this chapter

for further details). The construction of the Proposed Development would

introduce involve construction activity from approximately mid-2015 until

spring 2018. There would be some potentially adverse air quality impacts of

short-term duration associated with this construction activity.



specific environmental limitations, including control of air quality, imposed by

the planning consent, as well as the requirements of relevant legislation,

regulations and best practice guidance. The CEMP would include detailed

method statements for, amongst other things, the control of emissions to air

from the construction activities, and as described in Chapter 4.0 of the ES.

12.4.10 The likely effects on air quality from the construction phase would be from

dust (particulates) during construction and site clearance operations.

12.4.11 Within the Proposed Development, the main sources of dust would arise from

materials handling and removal, construction and road traffic passing over


exposed soil surfaces, site excavations for foundations and groundwork and

batching of concrete on site (if required).

12.4.12 The effects of construction dust are likely to be limited to areas downwind

within 200m of dust generating activities, and are predicted to remain within

the boundary of the Proposed Development. Elevated concentrations of dust

are most likely to occur on dry windy days and areas downwind of the

prevailing wind direction would be affected more frequently. The nearest

sensitive receptors are immediately adjacent to the Application Site western

boundary (the housing proposed as part of the proposed Shawfair

development), with the measures implemented in the CEMP (see Section

12.4.2) it is unlikely that any significant dust emissions would arise.

12.4.13 Emissions from diesel construction equipment would be confined to the

construction area. This would increase levels of associated pollutants within a

localised area. However, these would be rapidly dispersed in the atmosphere

and are not expected to have any impact off-site. As a consequence, the

Proposed Development would not give rise to any significant effects in this

regard


12.4.14 The construction period for the ZWF was proposed to take place between

2013 / 2014 and 2015 / 2016, covering a period of approximately 24 months.

Whilst exact details relating to construction are limited in the ES prepared in

support of the application, it seems reasonable to assume that the

construction phase of the ZWF would involve similar activities, and, therefore

similar air quality impacts, as the Proposed Development.

12.4.15 The difference between the construction phase for the Proposed Development

when compared with that for the ZWF Development, would be the increased

duration of construction activity. However, as the footprint of the Proposed

Development is smaller, the physical extent of the construction area would be

reduced. As such, the temporary adverse effects of the Proposed

Development would be for a more prolonged duration, but would be of smaller

physical scale and are likely to be quantitatively less on a daily basis. It is not

considered that other aspects of the construction process would result in any


effect that is appreciably different from that would could be anticipated from

the ZWF Development. Thus the Proposed Development would have a

‘neutral’ effect when compared to the future baseline.

Operational Phase

12.4.16 An atmospheric dispersion modelling study was undertaken to assess the

impact of releases from the discharge stack of the Proposed Development

during its operational phase. The study was undertaken after consultation with

the SEPA. The full scope of the study is described earlier in this Chapter. A

copy of the full modelling study report is provided in Appendix 12-1, and

should be read in conjunction with this Chapter. The findings of the study are

summarised below.

12.4.17 The results of the stack height screening assessment (see Appendix B of the

main modelling study report), which took account of the emissions from the

Proposed Development that could potentially have the highest impact,

demonstrated that the proposed stack height of 75m would not result in any

significant impacts on either human health or the environment.

12.4.18 The results of the assessment of the impact of the releases from the Proposed

Development discharge stack at the IED ELVs are presented in Section 4. and

Tables 21, 22 and 23 of the main modelling study report. It can be seen from

the data that the impacts of releases of all pollutants can be screened out as

not being significant and would not lead to any exceedance of air quality

standards. The pollutants assessed were:

Oxides of Nitrogen (expressed as nitrogen dioxide);

Sulphur Dioxide;

Particulate matter as PM10;

Particulate matter as PM2.5;

Carbon Monoxide;

VOCs (expressed as benzene);

Ammonia;

Hydrogen Chloride;

Hydrogen Fluoride;

Antimony;


Arsenic;

Chromium III;

Chromium VI;

Cobalt;

Copper;

Lead;

Manganese;

Mercury;

Nickel;

Thallium;

Vanadium;

Polyaromatic Hydrocarbon (expressed as benzo[a]pyrene;

Polychlorinated Bphenyls; and

Dioxins and Furans.


Development discharge stack at the actual concentrations measured at FCC’s

sister plant at Lincoln are presented in Section 5 and Tables 24 and 25 of the

main modelling study report (Appendix 12-1). The data in Table 24 indicates

that the actual concentrations of pollutants at FCC’s Lincoln plant are, in most

cases, much lower than the IED ELVs. Accordingly, as would be expected, it

can be seen from the data in Table 25 that releases of all pollutants (as

detailed above) have a lower impact than at the IED ELVs. Again, as would be

expected, the impacts of the releases can be screened out as not being

significant and would not lead to any exceedance of any air quality standard.

12.4.20 The results of the assessment of the impact of metals deposition associated

with the releases from the Proposed Development discharge stack are

presented in Section 6 and Table 26 of the main modelling study report

(Appendix 12-1). It can be seen from the data in Table 26 that metals

deposition can be screened out as not being significant.

12.4.21 The results of the assessment of the emissions from the Proposed

Development discharge stack (at IED ELVs) at the thirty-four human sensitive

receptors considered are presented in Section 7 and Tables 27, 28 and 29 of

the main modelling study report (Appendix 12-1). It can be seen from the data


that all releases can be screened out as not being significant and would not

lead to any exceedance of any air quality standard at any of the human

sensitive receptors.

12.4.22 The results of the assessment of impact of the emissions from releases from

the Proposed Development discharge stack at the IED ELVs at the thirty-two

environmental receptors considered are presented in Section 8 and Tables

30, 31, 32 and 33 of the main modelling study report (Appendix 12-1). It can

be seen that:

From the data in Table 30, none of the annual or daily mean oxides of

nitrogen process contributions at any of the sensitive habitat sites are

significant in relation to critical levels;

From the data in Table 31, none of the annual mean sulphur dioxide

process contributions at any of the sensitive habitat sites are

significant in relation to critical levels, even at those with sensitive

lichen communities;

From the data in Table 32, none of the annual mean ammonia process

contributions at any of the sensitive habitat sites are significant in

relation to critical levels; and

From the data in Table 33, none of the 24 hour mean or weekly mean

hydrogen fluoride process contributions at any of the sensitive habitat

sites are significant in relation to critical levels.

12.4.23 The results of the assessment of impact of the nutrient nitrogen and acid

deposition from releases from the Proposed Development discharge stack at

the IED ELVs at the thirty-two environmental receptors considered are

presented in Section 9 and Tables 34 and 35 of the main modelling study

report (Appendix 12-1). It can be seen that:

From the data in Table 34, none of the nutrient nitrogen deposition

rates at any of the sensitive habitat sites are significant in relation to

either the upper or lower critical loads; and

From the data in Table 35, none of the acid deposition rates at any of

the sensitive habitat sites are significant in relation to the critical loads.

12.4.24 The results of the assessment of the impact of visible plumes from the

Proposed Development discharge stack are presented in Section 10 and


Table 36 of the main modelling study (Appendix 12-1). Plumes would only

extend beyond the site boundary for less than 5% of daylight hours per year

and are therefore classed as being of low impact in accordance with the SEPA

guidance.


Development discharge stack under abnormal operating conditions are

presented in Section 11 and Tables 37 and 39 of the main modelling study

report (Appendix 12-1). It can be seen that:

From the data in Table 37, with the emissions at the half-hourly ELVs,

emissions of: Particulate Matter, VOCs, Hydrogen Chloride, Hydrogen

Fluoride, Sulphur Dioxide and Nitrogen Dioxide are not significant; and

From the data in Table 39, with the plant operating under abnormal

operating conditions, emissions of: Particulate Matter, Hydrogen

Chloride, Hydrogen Fluoride, Sulphur Dioxide, Nitrogen Dioxide and

Carbon Monoxide are not significant.

Cumulative Effects

12.4.26 The results of the assessment of the cumulative impact of releases of:

Nitrogen Dioxide, Sulphur Dioxide and Carbon Monoxide from the Proposed

Development discharge stack and the AD Facility CHP and flare stacks are

presented in Section 12 and Tables 42 – 48 of the main modelling study report

(Appendix 12-1). It can be seen that, the impacts in relation to all of the

scenarios addressed above for the Proposed Development in isolation are not

significant. (Note that abnormal emissions were not considered in the

cumulative assessment as the IED abnormal operating requirements do not

apply to the AD Facility).

From the data in Table 40, the emissions of: Nitrogen Dioxide, Sulphur

Dioxide and Carbon Monoxide at the points of maximum GLC are not

significant; and

From the data in Table 41, the emissions of: Nitrogen Dioxide, Sulphur

Dioxide and Carbon Monoxide at the points of maximum GLC are not

significant.



12.4.27 The AQA prepared in support of the application for the ZWF, concluded that

the predicted concentrations of pollutants are within the relevant air quality

objective and guidelines for the maximum point of ground level concentration,

for all ecological and human receptors and in relation to the cumulative effects

including the AD Facility. The same conclusions are reached in this

application, albeit with an increased stack height of 75m. Thus the operational

air quality effects of the Proposed Development would be neutral when

compared to the ZWF.


12.4.28 The decommissioning stage of the project would be similar to the construction

phase. The main effects on human health would be from dust (particulate

matter) which would be generated during any demolition of buildings and site

clearance operations.

12.4.29 As with the construction phase, it is likely that the effects of dust would be

limited to areas downwind within 200m elevated concentrations of dust are

most likely to occur on dry windy days and areas downwind of the prevailing

wind direction would be affected more frequently. As part of the PPC Permit

the site would have to be decommissioned in accordance with a Site Closure

Report which would include dust control measures. Consequently, in the event

that emissions of dust were to arise during decommissioning, they would be

controlled in such a manner to prevent a risk to human health. Accordingly,

there would be no significant effects during the decommissioning phase.

12.4.30 Mobile plant used would also produce emissions which may temporarily

increase levels of pollutants within a localised area, However, they would be

rapidly dispersed in the atmosphere.



impacts on air quality.








Proposed Development would be as set out in sub-section 12.4 above.

12.7 Conclusions

12.7.1 An assessment has been carried out to determine the local air quality impacts

associated with the emissions from the Proposed Development, both on its

own and in combination with emissions from the adjacent AD Facility.

12.7.2 Detailed air quality modelling using the ADMS dispersion model has been

undertaken to predict the impacts associated with stack emissions from the

facilities. As a worst-case, emissions from the Millerhill RERC stack has been

assumed to be at the maximum ELV for the purposes of carrying out the

assessment. This represents a conservative assessment of the impact as the

actual emissions from the site are likely to be significantly lower.

12.7.3 A detailed screening assessment has been carried out to derive conservative

assumptions for the assessment and to determine the optimum discharge

stack height for the facility. This confirmed that the optimum stack height

is75m.

12.7.4 Predicted maximum GLCs (PCs) are within the short and long term air quality

objectives and are assessed as not significant (less than 1% of the AQS /

EAL) for most pollutants assessed. For those are potentially significant, further

screening has demonstrated that it is unlikely that any AQSs would be

exceeded as a result of emissions from the Proposed Development.


12.7.5 A comparison of the actual monitoring data for FCC’s sister plant at Lincoln

with the IED ELVs was undertaken on the basis that it uses the same EfW

technology as the proposed Millerhill RERC development. Based on the data

from FCC’s Lincoln plant, the actual emission concentrations are, in the

majority of cases, much lower that the IED ELVs. PCs based on actual

emissions data were calculated and are, in most cases, much lower than

those based on the IED ELVs. As such, they can all be screened out as not

being significant.

12.7.6 For the sensitive habitat sites, it has again been demonstrated that the impact

from the Proposed Development is unlikely to result in a breach of the relevant

Critical Loads or Critical Levels, or have a detrimental effect on local habitat

sites. Therefore, the Proposed Development would not give rise to any

significant effects in this regard.

12.7.7 An assessment was also made of the impact of the Proposed Development

when operating under the abnormal conditions permitted under Article 46(6) of

the IED. The results of the assessment indicated that it would be unlikely that

any AQSs would be exceeded under such abnormal operating conditions and

thus, no significant effects would occur.

12.7.8 The cumulative impact of the Proposed Development and AD Facility has also

been considered. The assessment concluded that there would not be a

significant impact on local air quality or sensitive habitat sites.

12.7.9 In summary, therefore, it can be concluded that during its construction,

operation or decommissioning, the Proposed Development would not give rise

to significant effects on local air quality, or sensitive habitat sites, either in

isolation or in combination with the adjacent AD Facility.

12.7.10 Finally, an assessment has also been carried out of the Proposed

Development against the future baseline position associated with the PPiP

development. The assessment concluded that in relation to air quality the

effects of the Proposed Development during its construction, operation and

decommissioning would be ‘neutral’.

12.8 References


12.8.1 All references used can be found in the main report, Appendix 12-1


13.0 ARCHAEOLOGY AND CULTURAL HERITAGE

13.1 Introduction

13.1.1 This Chapter of the ES describes the effects of the Proposed Development on

archaeological and cultural heritage receptors. The potential for direct effects

upon heritage assets within the development boundary are assessed, as is

the potential for indirect effects upon the setting of heritage assets in a wider,

5km, study area. The need for mitigation, beyond that incorporated in the

design, is discussed and any residual effects identified.

13.1.2 The assessment considers the effect of the Proposed Development, in terms

of the existing baseline conditions. These are here assumed to include the

completed AD Facility immediately to the north of the Proposed Development,

the Borders Railway which passes the Proposed Development, on a north /

south alignment, to the west, and the SNCD which is located to the west and

northwest of the Proposed Development. The effects predicated from the

Proposed Development would be compared to the: ‘Future Baseline

Scenario’, which assumes construction of the consented PPiP development

(see Chapter 2.0 for full details).



13.1.3 The statutory framework for heritage in Scotland is outlined in the Town and

Country Planning (Scotland) Act 1997, as supplemented and amended by the

Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997 and

the Ancient Monuments and Archaeological Areas Act 1979, both of which are

modified by the Historic Environment (Amendment) (Scotland) Act 2011.

13.1.4 The implications of these acts with regard to local government planning policy

are described within Scottish Planning Policy (SPP)6, Scottish Historic

Environment Policy (SHEP)7 and Planning Advice Notes (PAN) for Scotland.

6 Scottish Government 2014, Scottish Planning Policy 7 Historic Scotland 2011, Scottish Historic Environment Policy


SPP, SHEP and PAN 2/2011 ‘Archaeology and Planning' (Scottish

Government 2014) deal specifically with planning policy in relation to heritage.

The planning guidance expresses a general presumption in favour of

preserving heritage remains ‘in situ’ wherever possible. Their ‘preservation by

record’ (i.e. through excavation and recording, followed by analysis and

publication, by qualified archaeologists) is a less desirable alternative. SPP

expresses the following policy principles: “The planning system should:

Promote the care and protection of the designated and non-designated

historic environment (including individual assets, related settings and the

wider cultural landscape) and its contribution to sense of place, cultural

identity, social well-being, economic growth, civic participation and

lifelong learning; and

Enable positive change in the historic environment which is informed by

a clear understanding of the importance of the heritage assets affected

and ensure their future use. Change should be sensitively managed to

avoid or minimise adverse impacts on the fabric and setting of the asset,

and ensure that its special characteristics are protected, conserved or

enhanced.” (Scottish Government 2014, Para 137).

13.1.5 Paragraph 145 of SPP details the consideration of Scheduled Monuments

(SM) within development management, stating: “Where there is potential for a

proposed development to have an adverse effect on a scheduled monument

or on the integrity of its setting, permission should only be granted where there

are exceptional circumstances. Where the proposal would have a direct

impact on a scheduled monument, the written consent of Scottish Ministers

via a separate process is required in addition to any other consents required

for the development.” (Scottish Government 2014, Para 145).

13.1.6 SHEP (Historic Scotland 2011) sets out the Scottish Government’s policy for

the sustainable management of the historic environment. Key principles of the

policy note that: “there should be a presumption in favour of preservation of

individual historic assets wherever possible and also the pattern of the wider

historic environment; no historic asset should be lost or radically changed

without adequate consideration of its significance and of all the means

available to manage and conserve it.” (1.14.b).


Local Planning Policy

13.1.7 Strategic policy is provided by the Strategic Development Plan for Edinburgh

and South East Scotland8, 2013 (SESPlan). Whilst detailed Historic

Environment Matters fall outside the remit of the Strategic Development Plan it

clearly respects Scottish Planning Policy, which contains policies for the

protection and enhancement of environmental resources including heritage

assets. Policy 1B of the SESPlan requires local authorities to ensure within

their own development plans that there are no: “significant adverse impacts on

the integrity of international and national built or cultural heritage sites.”9

13.1.8 The Midlothian Local Plan10 was adopted by MLC on the 23rd of December

2008 and provides an important framework for coordinating future

development and guidance in dealing with development proposals in

Midlothian. The following policies, relating to indirect effects on the settings of

designated heritage assets, contained within the Midlothian Local Plan are

relevant to the Proposed Development (Table 13.1):

Table 13.1: Cultural Heritage Policies relating to Indirect Effects contained within

the Midlothian Local Plan 2008

Policy No. Policy Extract

Policy RP22: Conservation Areas

Within or adjacent to a Conservation Area, development will not be permitted which would have any adverse effect on its character and appearance.

Policy RP24: Listed Buildings

Development will not be permitted which would adversely affect the character of the Listed Building, its setting or any feature of special architectural or historic interest that it possesses.

Policy RP25: Nationally Important Gardens and Designed Landscapes

Development will not be permitted which would harm the character or appearance or setting of a garden or designed landscape which is included in the Inventory of Historic Gardens and Designed Landscapes.

Policy RP26: Scheduled Monuments

Development which could have an adverse effect on a Scheduled Monument or the integrity of its setting will not be permitted.

Policy RP27: Other Important Archaeological or Historical Sites

Development will not be permitted where it could adversely affect an identified regionally or locally important archaeological or historic site or its setting unless the applicant can show that:

A. There is a public interest to be gained from the proposed development which outweighs the archaeological importance of the site.

8 SESPlan 2013

9 SESPlan 2003, Policy 1B

10 Midlothian Council, 2008, Midlothian Local Plan


B. There is no alternative location for the proposal: and C. The proposal has been sited and designed to minimise damage

to the archaeological resource.

Policy RP 28: Assessment, Evaluation and Recording

Where any development proposal could affect an identified site of archaeological importance, the applicant will be required to provide an assessment of the archaeological value of the site and of the impact of the proposal on the archaeological resource.

Emerging Policy

13.1.9 Midlothian Council is currently in the process of preparing the Midlothian Local

Development Plan to replace the 2008 Local Plan. MLC approved the

Midlothian Local Development Plan Proposed Plan in 2014 and a Draft Plan is

due to be published in May 2015.

Planning Considerations Pertaining to the Site

13.1.10 The setting of Listed Buildings is a competent planning matter; Section 14.2 of

the Planning (Listed Buildings and Conservation Areas) Act 1997 states that

when determining applications for development which could impact upon the

setting of a listed building: “…the planning authority or the Secretary of State,

as the case may be, shall have special regard to the desirability of preserving

the building or its setting or any features of special architectural or historic

interest which it possesses.”

13.1.11 A new development must not impact upon the area of a SM without the prior

formal consent of Historic Scotland (HS). A development may not have a

direct, i.e. physical, impact upon a SM without Scheduled Monument Consent.

Setting is also a key consideration when determining applications which could

impact upon the settings of SMs, This principle is outlined in SPP Paragraph

145: “Where there is potential for a proposed development to have an adverse

effect on a scheduled monument or on the integrity of its setting, permission

should only be granted where there are exceptional circumstances. Where a

proposal would have a direct impact on a scheduled monument, the written

consent of Scottish Ministers via a separate process is required in addition to

any other consents required for the development.”11

11 Scottish Government 2014, Para 145


13.2 Methodology

Assessment Methodology

Standards

13.2.1 The scope of this assessment meets the requirements of current planning

policy and advice set out in SPP, SHEP and PAN2/2011.

13.2.2 AOC Archaeology Group, who have undertaken this assessment, conforms to

the standards of professional conduct outlined in the Chartered Institute for

Archaeologists' Code of Conduct, the CIfA Code of Approved Practice for the

Regulation of Contractual Arrangements in Field Archaeology, the CIfA

Standards and Guidance for Desk Based Assessments, Field Evaluations

etc., and the British Archaeologists and Developers Liaison Group Code of

Practice. AOC is a Registered Archaeological Organisation of the Chartered

Institute for Archaeologists. This status ensures that there is regular

monitoring and approval by external peers of our internal systems, standards

and skills development. The company is ISO 9001:2008 accredited, in

recognition of its Quality Management System.

Consultations

13.2.3 HS were consulted by MLC in March 2014 in advance of this application. HS

noted that with regard to the PPiP application they agreed with the

conclusions of the ES and found that: “there are unlikely to be any significant

impacts on historic environment features within our statutory remit, and

offered no objection to the proposal.” HS did raise concerns over a statement

in the ES that SMs which are visible only as cropmarks do not have a setting,

a concern which will be addressed in this ES. Commenting prior to the raising

of the stack height to 75m, HS noted that: “It is unlikely that the amended

development would result in a significant adverse impact on the setting of

other assets within our remit.”12

12

Historic Scotland 04 March 2014, Letter to Midlothian Council ,Reference AMN/16/LC


Assessment Structure

13.2.4 Each heritage asset referred to in the text is listed in the Gazetteer in

Appendix 13-1, which lists all designated heritage assets which fall within the

scope of the assessment. Each has been assigned a ‘Site No.’ unique to this

assessment which is cross referenced with its designation number within the

Gazetteer.

13.2.5 Each designated heritage asset, including archaeological or historical sites,

monuments or buildings, referred to in the text is plotted on location maps

(Figures 13.1 and 13.2), using the assigned Site Nos. The Proposed

Development area (the site) is outlined in red.

13.2.6 This assessment follows the methodology proposed in the Informal Scoping

Report13. Known heritage assets within the Proposed Development area have

been identified as have all SMs, Category ‘A’ Listed Buildings, Conservation

Areas, Inventoried Battlefields and Inventoried Gardens and Designed

Landscapes within 5km. Category ‘B’ and ‘C’ Listed Buildings which lie within

2km have been identified. No World Heritage Sites lie within 5km of the

Proposed Development.

13.2.7 Figure 13.1 depicts known heritage assets within the red line boundary as well

as all designated heritage assets located within a 2km of the Proposed

Development, whilst Figure 13.2 shows all SMs, Category A Listed Buildings,

Conservation Areas, Inventoried Battlefields and Inventoried Gardens and

Designed Landscapes within 5km.

13.2.8 Following the methodology outlined by the Informal Scoping Report a three

stage approach was adopted which:

Identified the historic assets that might be impacted by a proposed

change (Stage 1);

Defined the setting by establishing how the surroundings contribute to

the ways in which the historic asset or place is understood, appreciated

and experienced (Stage 2); and

13

Axis 2014, Millerhill Energy Recovery Facility: Environmental Impact Assessment, Informal Scoping Report, January 2014


Assessed how any change would impact upon that setting (Stage 3).

13.2.9 All three stages are reported in appropriate detail as part of the assessment.

13.2.10 As part of Stage 1, ZTV analysis and site visits were used to determine either

whether the Proposed Development would be visible from the heritage asset

or whether, both would be visible in a third view, in such a manner that the

cultural heritage value of the designated heritage asset could potentially be

adversely effected.

13.2.11 A screening exercise was undertaken during the second stage of the

assessment, in order to determine whether any of the assets identified within

the study area would be potentially vulnerable to changes in setting resulting

from the Proposed Development. The screening briefly assessed the cultural

heritage value of each designated heritage asset, based upon the Listing /

citation text (or equivalent) for each asset. A conclusion is then drawn as to

whether the cultural heritage value of each asset is sensitive to changes in its

setting and if so, whether that sensitivity is such that the development could

potentially result in an adverse effect on that value. Where the screening

exercise concludes that there is scope for such an effect, then the asset in

question has been carried forward to the third stage in the assessment,

detailed consideration.

Sensitivity Criteria

13.2.12 The definition of cultural significance is readily accepted by heritage

professionals both in the UK and internationally and was first fully outlined in

the Burra Charter, which states in article one that ‘cultural significance’ or

‘cultural heritage value’ means aesthetic, historic, scientific, social or spiritual

value for past, present or future generations (ICOMOS 1999, Article 1.2). This

definition has since been adopted by heritage organisations around the world,

including HS. In their SHEP, HS note that to have cultural significance an

asset must have a particular: “artistic; archaeological; architectural; historic;

traditional (factors listed in the 1979 Act, (HMSO 1979); aesthetic; scientific;

[and/or] social [significance] – for past, present or future generations.” (2011,

71). Heritage assets also have value in the sense that they: “...create a sense

of place, identity and physical and social wellbeing, and benefits the economy,


civic participation, tourism and lifelong learning” (Scottish Government 2014,

1). For clarity and to avoid confusion, the term cultural value would be used

throughout this assessment though, as outlined above, it is acknowledged this

is the same as cultural significance as identified in SHEP.

13.2.13 All heritage assets have some value, however some assets are judged to be

more important than others. The level of that importance is, from a cultural

resource management perspective, determined by establishing the asset’s

capacity to inform present or future generations about the past. In the case of

many heritage assets their importance has already been established through

the designation (i.e. scheduling, listing and inventory) processes applied by

HS.

13.2.14 The criteria used to establish importance in this assessment are presented in

Table 13.2 below and are drawn from Annexes 1-6 of SHEP which outline the

criteria for establishing National Importance:

Table 13.2: Criteria for establishing relative importance of heritage assets

Asset Importance

Criteria

International and National

World Heritage Sites;

Scheduled Monuments (Actual and Potential);

Category ‘A’ Listed Buildings;

Inventory Gardens and Designed Landscapes;

Inventory Battlefields; and

Fine, little-altered examples of some particular period, style or type.

Regional Category ‘B’ Listed Buildings;

Conservation Areas; and

Major examples of some period, style or type, which may have been altered;

Asset types which would normally be considered of national importance that have been partially damaged (such that their ability to inform has been reduced).

Local Category ‘C’ Listed Buildings;

Lesser examples of any period, style

or type, as originally constructed or altered, and simple, traditional sites, which group well with other significant remains, or are part of a planned group such as an estate or an industrial complex;

Cropmarks of indeterminate origin; and

Asset types which would normally be considered of regional importance that have been partially damaged or asset types which would normally be considered of national importance that have been largely damaged (such that their ability to inform has be reduced).


Negligible Relatively numerous types of remains;

Findspots of artefacts that have no definite archaeological remains known in their context; and

Asset types which would normally be considered of local importance that have been largely damaged (such that their ability to inform has been reduced).

Assessment of Direct Effect

Establishing Magnitude of Effect

13.2.15 The magnitude of the physical impact upon heritage assets caused by the

development has been rated using the classifications and criteria outlined in Table

13.3 below.

Table 13.3: Criteria for Classifying Magnitude of Physical Effect

Criteria Magnitude

High Major loss of information content resulting from total or large-scale removal of deposits from a site whether or not the site is associated with a monument;

Major alteration of a monument’s baseline condition;

Any physical alteration to a Scheduled Monument;

Any physical alteration to a Category A Listed Building;

Massive alterations to a Category B or Category C Listed Building.

Medium Moderate loss of information content resulting from material alteration of the baseline conditions by removal of part of a site whether or not the site is associated with a monument;

Moderate alteration of a monument’s baseline condition.

Low Minor detectable impacts leading to the loss of information content;

Minor alterations to the baseline condition of a monument.

Marginal Slight or barely measurable loss of information content;

Loss of a small percentage of the area of a site’s peripheral deposits;

Very slight and reversible alterations to a monument.

None No physical impact anticipated.

Establishing Significance of Effect

13.2.16 The predicted significance of effect upon each asset is determined by

considering its importance in conjunction with the magnitude of impact

predicted on it. The method of deriving the significance of impact

classifications is shown in Table 13.4 over the page.


Table 13.4: Method of Rating Significance of Effect on Heritage Assets

by the Proposed Development

Magnitude of Effect

Importance of Heritage Asset

Negligible Local Regional National International

High Minor-Moderate

Moderate* Moderate-Major*

Major* Extreme*

Medium Minor Minor-Moderate


Major*

Low Negligible Minor Minor-Moderate


Marginal Negligible Negligible Minor Minor-Moderate

Moderate*

None None None None None None

*The effects recorded in grey highlighted cells are ‘significant’ in terms of the Environmental Impact Assessment (Scotland) Regulations 2011

Indirect Effects

Establishing Sensitivity of Assets

13.2.17 Whilst determining the relative cultural value of a heritage asset is a key

consideration in establishing the importance of an asset and therefore its

sensitivity to direct effects, it is widely recognised (see Lambrick 2008) that the

importance of an asset is not the same as its sensitivity to changes to its

setting. Thus in determining effects upon the setting of assets by a proposed

development, both importance and sensitivity to changes to setting need to be

considered.

13.2.18 Setting is a key issue in the case of some, but by no means all assets. A

nationally important heritage asset does not necessarily have high sensitivity

to changes to its setting (relative sensitivity). An asset’s sensitivity to changes

to its setting refers to its capacity to retain its ability to inform this and future

generations in the face of changes to its setting. The ability of the setting to

contribute to an understanding, appreciation and experience of the asset and

its value also has a bearing on the sensitivity of that asset to changes to its

setting. Assets with high sensitivity will be vulnerable to changes which affect


their setting and even slight changes may reduce their information content or

the ability of setting to contribute to the understanding, appreciation and

experience (see HS Setting Guidance 2010) of that asset. Less sensitive

monuments would be able to accommodate greater changes to their settings

without significant reduction in their ability to inform and in spite of such

changes the relationship between the assets and its setting would still be

legible. The relative sensitivity of SMs, Listed Buildings and other statutory

monuments and non-statutory monuments of national importance within the

study area to changes to their settings was determined using the criteria

outlined in Table 13.5.

Table 13.5: Criteria for Establishing Relative Sensitivity to Changes in Setting

Relative sensitivity

Criteria

High An asset whose setting contributes significantly to an observer’s understanding, appreciation and experience (Factors noted in HS guidance on setting 2010) of it should be thought of as having High Sensitivity to changes to its setting. This is particularly relevant for assets whose settings, or elements thereof, contribute directly and substantially to their significance (e.g. form part of their Contextual Characteristic (SHEP 2011, Annex 1). For example an asset which retains an overtly intended or authentic relationship with its setting and the surrounding landscape. These may in particular be assets such as ritual monuments which have constructed sightlines to and/or from them or structures intended to be visually dominant within a wide landscape area i.e. castles, tower houses, prominent forts etc.

An asset, the current understanding, appreciation and experience of which, relies heavily on its modern aesthetic setting. In particular an asset whose setting is an important factor in its protection (as per SPP 2014 definition of setting) and in retention of its cultural value.

Medium An asset whose setting contributes moderately to an observer’s understanding, appreciation and experience of it should be thought of as having Medium Sensitivity to changes to its setting. This could be an asset for which setting makes a contribution to significance but whereby its value is derived mainly its intrinsic characteristics (SHEP 2011, Annex 1). This could for example include assets which had an overtly intended authentic relationship with their setting and the surrounding landscape but where that relationship (and therefore the ability of the assets’ surroundings to contribute to an understanding, appreciation and experience of them) has been moderately compromised either by previous modern intrusion in their setting or the landscape or where the monument itself is in such a state of disrepair that the relationship cannot be fully determined.

An asset, the current understanding, appreciation and experience of which, relies partially on its modern aesthetic setting regardless of whether or not this was intended by the original constructors or authentic users of the asset. An asset whose setting is a contributing factor to its protection and the retention of its cultural value.

Low An asset whose setting makes some contribution to an observer’s understanding, appreciation and experience of it should generally be thought of as having Low Sensitivity to changes to its setting. This may be an asset whose main significance lies in its intrinsic characteristics and whereby changes to its setting would not materially diminish our understanding, appreciation and experience of it. This could for example include assets which had an overtly intended authentic relationship with their setting and the surrounding landscape but where that relationship (and therefore the ability of the


assets’ surroundings to contribute to an understanding, appreciation and experience of them) has been significantly compromised either by previous modern intrusion to its setting or landscape or where the asset itself is in such a state of disrepair that the relationship cannot be determined.

Marginal An asset whose setting makes minimal contribution to an observer’s understanding, appreciation and experience of it should generally be thought of as having Marginal Sensitivity to changes to its setting. This may include assets for which the authentic relationship with their surrounding has been lost, possibly having been compromised by previous modern intrusion, but who still retain cultural value in their intrinsic and possibly wider contextual characteristics.

13.2.19 The determination of an asset’s sensitivity is first and foremost reliant upon

the determination of its setting. The criteria set out in Table 13.3 above are

intended to be a guide. Assessment of individual assets will be informed by

knowledge of the asset itself, of the asset type if applicable and by site visits

to establish the current setting of the assets. This would allow for the use of

professional judgement and each asset would be assessed on an individual

basis. It should be noted that assets may fall into a number of the sensitivity

categories presented above e.g. a country house may have a high sensitivity

within its own landscaped park or garden but its level of sensitivity to changes

in the wider setting may be less.

13.2.20 In establishing the relative sensitivity of an asset to changes to its setting an

aesthetic appreciation of that asset and its setting must be arrived at.

Appendix 13-2 alongside Appendix 13-3 outlines the range of factors which

must be considered when establishing an aesthetic appreciation and therefore

determining sensitivity. These have been used as a guide in assessing each

asset from known records and in the field. In defining these criteria, emphasis

has been placed on establishing the current setting of each asset.

Magnitude of Effect

13.2.21 The magnitude of effect by a proposed development is an assessment of the

magnitude of change to the setting of any given designated heritage asset.

Table 13.6 (over the page) outlines the main factors affecting magnitude of

effect.


Table 13.6: Factors Affecting Magnitude of Effect

Site Details Importance of detail for assessing Magnitude of Effect

1 Proximity to centre of development

The greater the distance an asset is from the proposed development would in most cases diminish the effects on its setting.

2 Visibility of development (based on ZTV model and

wire lines where appropriate)

The proportion of the development that would be intervisible with the asset would directly affect the magnitude of effect on its setting.

3 Complexity of landscape The more visually complex a landscape is, the less prominent the new development may seem within it. This is because where a landscape is visually complex the eye can be distracted by other features and would not focus exclusively on the new development. Visual complexity describes the extent to which a landscape varies visually and the extent to which there are various land types, land uses, and built features producing variety in the landscape.

4 Visual obstructions This refers to the existence of features (e.g. tree belts, forestry, landscaping or built features) that could partially or wholly obscure the development from view. The form of mapping called ZTV always presents a worst case scenario for visibility precisely because the readily accessible digital mapping does not take cognisance of vegetation, structures and local micro-topography. Site visits are always necessary for a real appraisal of the magnitude of effects.

13.2.22 It is acknowledged that Table 13.6 primarily deals with visual factors affecting

setting. While the importance of visual elements of settings, e.g. views,

intervisibility, prominence etc., are clear, it is acknowledged that there other,

non-visual factors which could potentially result in setting effects. Such factors

could be other sensory considerations, e.g. noise or smell, or could be

associative. Where applicable these would be considered in coming to a

conclusion about magnitude of effect. Once the above has been considered,

the prediction of magnitude of effect upon setting would be based upon the

criteria set out in Table 13.7 (over the page). In applying these criteria particular

consideration would be given to the relationship of the Proposed Development

to those elements of setting which have been defined as most important in

contributing to the ability to understand, appreciate and experience the heritage

assets and its value.


Table 13.7 Criteria for Establishing Magnitude of Effect on Setting

Magnitude of setting effect

Criteria

High Direct and substantial visual impact on a significant sightline to or from a ritual monument or prominent fort;

Direct severance of the relationship between an asset and its setting;

Major alteration to the penumbral or close settings of a Scheduled Monument;

Major imposition within a Cultural Landscape;

An effect that changes the setting of an asset such that it threatens the protection of the asset (SPP 2014) and the understanding of its cultural value.

Medium Oblique visual impact on an axis adjacent to a significant sightline to or from a ritual monument but where the significant sightline of the monument is not obscured;

Impacts upon the glacis of a prominent fort (based on the proportion of the glacis that would be obscured);

Partial severance of the relationship between an asset and its setting;

Significant alteration to the setting of an asset of beyond those elements of the setting which directly contribute to the understanding of the cultural value of the asset;

Significant but not major imposition within a Cultural Landscape.

An effect that changes the setting of an asset such that the understanding of the asset and its cultural value is diminished.

Low Peripheral visual impact on a significant sightline to or from a ritual monument;

Insignificant alteration to the setting of an asset of beyond those elements of the setting which directly contribute to the understanding of the cultural value of the asset;

Minor imposition within a Cultural Landscape.

An effect that changes the setting of an asset, but where those changes do not materially affect an observer’s ability to understand, appreciate and experience the asset.

Marginal All other setting effects.

None No setting effects anticipated.

Establishing Significance of Effect

13.2.23 The significance of the effect on the setting of cultural heritage assets is

judged to be the interaction of the asset’s sensitivity to changes to its setting

(Table 13.5) and the magnitude of the effect (Table 13.7) and also takes into

consideration the importance of the asset (Table 13.2). In order to provide a

level of consistency to the assessment of sensitivity, the prediction of

magnitude of effect and the assessment of significance of effect have been

guided by pre-defined criteria.

13.2.24 The interactions determining significance of effect on settings is shown in

Table 13.8 over the page.


Table 13.8: Significance of Effect on the Setting of Heritage Assets

Impact

magnitude

Relative Sensitivity

Marginal Low Medium High

High Minor Minor-Moderate Moderate* Major*

Medium Negligible Minor Minor-Moderate Moderate*

Low None/Negligible Negligible Minor Minor-Moderate

Marginal None None Negligible Minor

*The effects recorded in grey highlighted cells are ‘significant’ in terms of the Town and Country Planning (Environmental

Impact Assessment) (Scotland) Regulations 2011.

13.3 Baseline


13.3.1 The following data sources were consulted during preparation of this

assessment:

National Monuments Record for Scotland (NMRS) (RCAHMS, Bernard

Terrace, Edinburgh). For NMRS data, aerial photographs, archive

photographs, NMRS maps, various archaeological and historical

publications, and unpublished archaeological reports;

National Map Library (National Library of Scotland, Causewayside,

Edinburgh): For old Ordnance Survey maps (1st & 2nd Edition, small-

and large-scale) and pre-Ordnance Survey historical maps;

Historic Scotland (Longmore House, Salisbury Place, Edinburgh): For

SM data, Listed Buildings data, Conservation Area data, Inventoried

Battlefield Data and Inventory Garden and Designed Landscape data;

Midlothian Historic Environment Record (online; John Gray Centre,

Haddington): for Historic Environment Record Data; and

ES prepared in support of the application for PPiP (2011).

13.3.2 This assessment is based upon data obtained from publicly accessible

archives as described above and visits to designated heritage assets

undertaken during November 2014 and March 2015. All site visits to

designated heritage assets were undertaken in clear weather and a

photographic record was maintained.


Baseline Conditions

13.3.3 The Proposed Development area lies between the operational Millerhill

railway marshalling yards and the site of the former Monktonhall Colliery a

now demolished 1960’s ‘super pit’. The marshalling yards originally extended

westwards across the Proposed Development area. The area is now derelict

and overgrown with young birch. This forms the Proposed Development site’s

current baseline context.

13.3.4 The existing baseline for this ES assumes that:

The site remains in its current undeveloped condition (see previous

paragraph);

The AD Facility immediately to the north of the Proposed Development

would be constructed and operational with a maximum roof height of

17.3m.

The SNCD to the west would have been constructed in accordance with

the approved masterplan;

The Borders Railway is constructed and operational and

That the site access bridge over the Borders Railway is in place and

operational.

Archaeological and Cultural Heritage Baselines within the Proposed

Development Area

13.3.5 There are three heritage assets recorded within the Proposed Development

boundaries. These include a portion of the Millerhill Marshalling Yards (Site

223) which was one of five large marshalling yards built in Scotland the early

1960s in an attempt to modernise British Railways. The western part of the

yards, where the Proposed Development is located, was closed in 1983 the

eastern part remains operational.14 The former Innocent Railway (Site 224)

was a tramway opened in 1831 and later purchased by the British Railway

Company who upgraded the track for use by trains and reopened the line in

1847.15 The former route of the railway runs along the eastern boundary of the

14

Rhodes, M. 1988. The illustrated history of British marshalling yards. passim. esp. 105-13 15

Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011) Appendix 11.1


Proposed Development and crosses the south-eastern corner where it turned

southwest. An associated bit of track was located in the western portion of the

Proposed Development area, as shown on Figure 13.1.

13.3.6 The only other known heritage asset within the Proposed Development

boundaries is the site of the no longer extant Middlefield Farmstead (Site 225),

which was shown in the northeast corner of the Proposed Development on

Roy’s Map of 1747-55. It did not appear on later maps.16

13.3.7 The remains are considered to be of negligible importance as they are

common types and unremarkable. The ground disturbance caused by the

construction of the marshalling yards in the 1960s is likely to have resulted in

the destruction, or at least significant damage, of any archaeological remains

associated with the Innocent Railway and the former farmstead. The works

associated with the construction of the marshalling yard also means that there

is negligible potential for encountering hitherto unknown remains within the

Proposed Development boundaries. The marshalling yard is also considered

to be of negligible significance being of modern date and unremarkable type.

There are extant marshalling yards of this type.

Baselines for the 5km Assessment Area

13.3.8 With regard to the potential for indirect effects upon the settings of designated

heritage assets, GIS data downloads obtained from HS record 43 SMs, 86

Category ‘A’ Listed Buildings, 13 Conservation Areas, 13 Inventoried Gardens

and Designed Landscapes and one Inventoried Battlefield (Pinkie, 1547)

within 5km of the Proposed Development area. A further 24 Category ‘B’

Listed and 46 Category ‘C’ Listed Buildings are located within 2km of the

Proposed Development area. In total 222 designated heritage assets fall

within the scope of this assessment. The nearest of these, the Category B

Listed Building at Whitehill Mains farmhouse (Site 142) stands to the north of

the development, west of the northern end of the former railway siding and

within circa 100m of the site access track.

16

Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011) Appendix 11.1


13.3.9 All 222 designated assets are listed in the Gazetteer (Appendix 13-1) and

mapped on Figures 13.1 (2km assessment area) and 13.2 (5km assessment

area). The identification of these assets and their presentation within the

gazetteer was carried out as Stage 1 of the methodology described in 13.2.10

and 13.3.1 above).

13.3.10 Detailed consideration of the settings of these designated assets is included in

the sub-section 13.4, which references the current settings of these assets. It

is however appropriate to note here that the Proposed Development site is

located on the eastern fringe of Edinburgh across which an established

suburban and industrial landscape extends. The prominent building within this

landscape, Queen Margaret’s University stands to the north of the Proposed

Development, north of the A1 dual carriageway, whilst railway lines, overhead

power lines and the retail sheds both within and surrounding the Fort Kinnaird

Retail Park at Newcraighall appear in existing views of the Proposed

Development from many of the designated heritage assets. The 2km and 5km

assessment areas contain urban settlements including the Edinburgh suburbs

of Liberton, Gilmerton, Craigmillar, Prestonfield, Duddingston, Craigentinny

and Portobello; the East Lothian communities of Musselburgh and Inveresk

and the Midlothian settlements of Danderhall, Dalkeith and Lasswade. These

urban areas all prohibit views of the Proposed Development from certain

designated assets within them. The AD Facility, Borders Railway and the

SNCD form part of the baseline and also screen the Proposed Development

when viewed from a number of heritage assets. Whilst the Proposed

Development area is currently brownfield, a number of high floodlights stand

on the adjacent operational marshalling yards and these were of use in

locating the proximity of the Proposed Development within views when

undertaking the site visits.

13.3.11 It is within this landscape and townscape context, much altered from the

settings within which many of the designated assets were created, that any

visibility with the Proposed Development would occur.


13.3.12 The PPiP ES determined that there is a potential for a: “major impact upon

known features of negligible sensitivity, leading to an impact of negligible


significance”.17 The PPiP ES also found that due to the previous ground

disturbance there is: “negligible potential for the survival of previously

unrecorded cultural heritage assets.”18 within the site. In the event that PPiP

development was progressed any existing archaeological remains on site

would be destroyed.

13.3.13 The PPiP ES’s Cultural Heritage Chapter concluded that there would be no

significant impacts upon the setting of any designated heritage assets within

the 5km study area. IGDLs were assessed in the LVIA chapter of the PPiP

ES. This assessment found a significant effect upon the designated

landscape at Newton House (Site 216)

13.3.14 The effects predicted for the future Baseline Scenario, as set out above, would

be compared against the predicted effects of the Proposed Development in

sub-section 13.4 below.



13.4.1 Design measures which have been incorporated to minimise the effects of the

development, including the potential for adverse effects on the settings of

designated heritage assets are summarised in Chapter 7.0 (Paragraph 7.4.1).

Measures which are particularly helpful in reducing the effect of the Proposed

Development on heritage assets include:

Form of buildings;

o The buildings have been designed using the principal that the

process equipment should be enclosed in a volumetrically efficient

manner so as to minimise the overall building height and volume.

Colour of buildings;

o The built form has been designed with a dark ‘plinth’ below a paler

upper structure. This has the effects of ‘grounding’ the building

and reducing the apparent overall scale.

17

Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011) Para 11.6.3 18

Environmental Statement Prepared in Support of the Application for Planning Permission in Principle (2011)Para 11.6.4


Construction Phase - Direct Effects


13.4.2 Potential effects on known or unknown buried archaeological remains in the

case of the Proposed Development relate to the possibility of disturbing,

removing or destroying in situ remains and artefacts during ground-breaking

works (including excavation, construction and other works associated with the

development) on the site.

13.4.3 Only three sites have been identified within the Proposed Development

boundary and these include the marshalling yard (Site 223), a post medieval

tram / railway (Site 224) and the former site of Middlefield Farmstead (Site

225). While it is unlikely that any remains of the Innocent Railway or the

farmstead survive, given the development of the marshalling yard in the

1960s; the development would result in a High magnitude effect to any

surviving remains. The Proposed Development would have a High magnitude

effect upon any surviving remains of the marshalling yard as well. Given the

negligible importance of these heritage assets such effects would result in, at

worst, effects of Minor-Moderate significance. Such effects are not considered

to be significant in terms of EIA Regulations.

13.4.4 There is a negligible potential for previously unrecorded remains to survive

within the Proposed Development area. Assessment of Effects against PPiP

Future Baseline Scenario

13.4.5 The PPiP ES also found that land within the Proposed Development

boundaries had been extensively disturbed during the construction of the

Millerhill marshalling yards and considered that, while there remains a

potential for direct effects on archaeological remains, these would not be

Significant. Whilst the location of the specific proposed groundworks may

differ, the Proposed Development lies within the boundaries of the site

consented under the PPiP scheme. Any direct effects resulting from the

Proposed Development, would be unchanged, in terms of significance of

effect, from those effects consented under the PPiP. The difference in effect

between the Proposed Development and the PPiP Future Baseline Scenario

is consequently neutral.


Constructional Phase - Indirect Effects

13.4.6 Whilst it is acknowledged that there could be some indirect effects on setting

during the construction phase, for example as a result of the construction plant

and machinery such as cranes, as well as the partially constructed energy

plant itself, these would be temporary in nature and are not judged to be

significant. Any effects upon the setting of heritage assets during the

construction phase would be of lower magnitude than effects during the

operational phase. As such detailed consideration of effects upon setting are

discussed in the section on the operational phase below

Operational Phase - Direct Effects


13.4.7 No direct effects on buried archaeological remains would occur during the

operational phase, as any direct effects would cease following the completion

of construction.


13.4.8 The Cultural Heritage Chapter for the PPiP ES noted that there would be no

direct effects on heritage assets during the operational phase as any effects

would cease following the completion of the construction phase. A comparison

of the effects of the Proposed Development with the effects of PPiP future

baseline scenario indicates that there would be no difference in the effects

and as such they are neutral.

Operational Phase - Indirect Effects

13.4.9 Indirect effects include effects upon the settings of designated heritage assets

including Listed Buildings, SMs, Historic Gardens and Designed Landscapes

and Inventoried Battlefields. No such designated assets are located within the

Proposed Development area although this assessment has identified 222

designated heritage assets within the 2km and 5km assessment areas (Stage

1). These designated assets are listed in the Site Gazetteer (Appendix 13-1).

Figure 13.1 records all designated heritage assets located within 2km of the


Proposed Development, whilst Figure 13.2 shows all SMs, Category ‘A’ Listed

Buildings, Conservation Areas, Inventoried Battlefields and Inventoried

Gardens and Designed Landscapes within 5km. There are no World Heritage

Sites located within 5km of the Proposed Development although the

Edinburgh Old and New Town World Heritage Site extends to within 5.8km of

the Proposed Development.

13.4.10 Initially this section considers the effects of the Proposed Development, with a

41.6m roofline and a 75m stack upon the existing baseline. The subsequent

section, the Assessment of Effects against PPiP Future Baseline Scenario,

will measure this assessment against those predicted effects already

consented under the PPiP scheme, for a 20m roof height and a 65m stack

height, in order to assess the difference in the levels of effect resulting from

the two developments.


13.4.11 ZTV Analysis has shown that 26 designated assets (Sites 28, 39, 51, 52, 57,

64, 70, 74-7, 86-7, 99-102, 108, 110, 112-3, 122, 124, 125 and 145) fall

outside the ZTV for both the 41.6m roofline and the 75m stack elements of the

Proposed Development and as a consequence no intervisibility with any

elements of the Proposed Development is predicted. Similarly site visits found

that intervening buildings, trees and townscapes will prohibit visibility from a

further 59 designated assets (Sites 27, 32-5, 37, 41, 44 -6, 53-6, 59, 65-7, 71

– 3, 78–80, 82, 88- 91, 93 -4, 97, 104-7, 109, 111, 118, 120-1, 130, 136, 162,

194, 196–201. 203, 213-5, 217-9). The Shawfair New Community

Development, assumed to have been built for the purposes of this

assessment, will screen the Proposed Development from the Category B

Listed Chalfont (Site 134) and from the Category ‘B’ Listed Edmonstone

House East Gate Lodge (Site 128). The North Danderhall element of the

SNCD will surround the Category A Listed Woolment House Gateway (Site

61) and impede views toward the Proposed Development. Consequently, the

setting of these assets would not be affected by the Proposed Development

and they are not discussed further.

13.4.12 Forty-three SMs fall within 5km of the Proposed Development, of which 23 of

the designations (Sites 2-6, 7-8, 10-15, 18-20, 22-6, 29, 31 and 43) represent


buried archaeological remains recorded only from cropmark evidence, whilst

Site 9 is only detectable on the ground surface as a vegetation mark. Whilst

upstanding remains associated with Site 6, the late prehistoric fort at St Mary’s

Mount do survive, these are only present within a wood and the majority of the

site is only identifiable through cropmarks. Cropmarks are often only

detectable from aircraft and are visible at certain times of the year within

specific types of crops. Cropmarks result from specific weather conditions

which cause the moisture levels within buried features to vary from the levels

within the surrounding soils. It can be reasonably argued that where no

upstanding remains survive, such as is the case with these Scheduled

Monuments, their value primarily lies in their intrinsic characteristics,

represented by their buried remains. The contribution that their setting makes

to an understanding of them and their cultural value is limited and as a

consequence does not have the potential to reach the level deemed

significant in terms of the EIA regulations. A further five Scheduled

Monuments (Sites 16-7, 36, 38 and 42), all associated with Inveresk Roman

Fort and settlement, now lie buried beneath the modern settlement and

therefore have no visual presence within the landscape. Consequently, whilst

all these SMs have been considered as part of this assessment no significant

effect has been found and as such they are not discussed further here.

13.4.13 A site visit to Duddingston Parish Church (Site 121), its churchyard (Site 47)

and watch tower (Site 58), found that visibility from the churchyard and church

would be entirely blocked by the intervening churchyard wall. Whilst the watch

tower rises above the height of the wall, the ‘windows’ on the two elevations

facing the Proposed Development are false, that is to say that they are

geometric Georgian window frames painted onto stone indentations.

Consequently there would be no visibility from any of these three assets and

no effect on their settings

13.4.14 Two villas Eskbank House (Site 81) and 12 Melville Road (Site 92) both lie

within the settlement of Eskbank. Whilst the potential for visibility from these

cannot be discounted, any visibility would be severely compromised by

intervening trees and the townscape. It is also clear that both the original

authentic setting of these villas and their modern associative setting, relates

solely to the settlement of Eskbank and adjacent market town of Dalkeith and


its gradual evolution, which the villas in part represent. For these reasons any

effect on the setting of these two buildings assets would not be Significant.

13.4.15 The settings of the Conservation Areas of Broomieknowe (Site 204) and

Lasswade and Kevock (Site 206), relate primarily to the immediate

surroundings of the settlements that the designations protect. The

Conservation Area Appraisal for Lasswade and Kevock defines the key views

within the Conservation Area as extending along the axis of the River North

Esk, which lies outwith the ZTV. The Scheduled remains of Lasswade Old

Church (Site 1) within the Conservation Area lies on the extreme periphery of

theoretical visibility. Any theoretical visibility from these Conservation Areas

would be further compromised by the presence of trees, within the thickly

planted designated areas and intervening buildings. For these reasons any

effect on the setting of these assets would not be Significant and they are not

considered further.

13.4.16 The Conservation Areas of Newbattle (Site 205) and Dalkeith House and Park

(Site 207) substantially overlap the boundaries of the Inventoried Gardens and

Designed Landscapes of Newbattle (Site 219) and Dalkeith Palace (Site 209)

and to avoid duplication would be considered in relation to the inventoried

areas.

13.4.17 Willie’s Temple (Site 73) stands within the grounds of Melville Castle.

Although it was originally intended to be a visual marker within the designed

landscape, the single storey structure now stands within woodland which

would prevent intervisibility with the Proposed Development and consequently

no effect on its setting is predicted.

13.4.18 Thirty nine Category ‘C’ Listed Buildings (Sites 149, 152-3, 155-160 and 164

to 193) extend to the north of the development along the axis of Newcraighall

Road. These buildings all relate to Newcraighall a small planned 19th century

colliery village formed around the Klondyke pit, which stood immediately north

of Newcraighall Road, between the two clusters of Listed Buildings. The mine

closed in the 1960’s and its site has now been developed as a leisure and

retail park, meaning that the relationship between the village and the mine has

now been lost and can only be understood through historical OS mapping.

The site visit demonstrated that visibility with the Proposed Development


would be largely blocked by intervening buildings which line the southern side

of Newcraighall Road. However, the possibility of very limited visibility

occurring from one or two of the cottages along the terraces cannot be

discounted. Visibility is more likely from the parish church and hall (Site 166),

the primary school (Site 183) and the miners’ welfare institute (Site 168),

although these views would be impeded by the intervening presence of the A1

embankment. However the significance of Sites 166, 183 and 168 is derived

from their common intent, to improve the wellbeing and education of the

miners and their families and the significance of all the Listed Buildings at

Newcraighall lies in their relationships to one another and the wider village in

which they are set and their geographical placing in relation to the mine. This

means that whilst limited visibility is predicted from the Newcraighall assets,

the Proposed Development would not have the potential to have a Significant

effect on their setting For these reasons these assets are not considered

further, although the Category B Listed Craigmillar Arts Centre (Site 129), a

former church at the extreme western end of Newcraighall would be

assessed.

13.4.19 Fifty three designated assets which have a potential for a Significant effect on

their settings, either because of their Relative Sensitivity to changes in their

settings or because of their proximity to the Proposed Development have

been taken forward to detailed assessment and are noted in Table 13.9

below.


Table 13.9 Significance of Effect on the Setting of Heritage Assets

Site No.

Site Name Designation Distance to Stack

Current Factors Affecting Visibility within the Existing Baseline

Relative Sensitivity

Magnitude of Effects

Level of Effects (*

Significant Effect

21 Newton Church, Enclosures and Field System

Scheduled 1.9km None Medium Low Minor

30 Craigmillar Castle and Gardens

Scheduled, Category A

Listed

3.57km Only the eastern part of the Scheduled area falls within the ZTV

High Marginal Minor

40 Holyrood Park Scheduled 3.95km Only the eastern part of the Scheduled area falls within the ZTV

High Marginal Minor

49 Inveresk, Inveresk Lodge, Sundial

Category A Listed

2.85km Trees will partially impede view Low Low Negligible

50 Musselburgh, Newhailes Stables

Category A Listed

1.82km Trees and structures within the parkland will block visibility

High None None

62 Inveresk, Inveresk Village Road, Halkerston

Category A Listed

2.83km Trees may partially impede visibility from the garden

High Low Minor-Moderate

63 Inveresk, Inveresk Village Road, Halkerston Stable

Category A Listed

2.85km Intervening building will block visibility from the stable

- None None

68 Musselburgh Old Bridge Category A Listed

2.61km Trees and intervening buildings will at least partially block visibility

High Marginal Minor

83 Old Craighall, Old Craighall Road, Monkton House, Stable with Sundial

Category A Listed

1.13km Trees within the grounds and the northwest boundary wall will impede visibility

Medium Low Minor

84 Inveresk, The Manor House Category A Listed

2.83km Trees will partially impede visibility High Low Minor-Moderate

85 Inveresk, The Manor House, East Pavilion

Category A Listed

2.85km Trees will at least partially block visibility High Marginal Minor


95 Old Craighall, Old Craighall Road, Monkton House

Category A Listed

1.15km Views to the northwest from the house are blocked by the intervening stable block, trees within the grounds and the wall along the northern boundary of the grounds. Limited windows in the north elevation


96 Inveresk, Inveresk Lodge, Outbuilding Remains

Category A Listed

2.83km Trees will partially impede visibility Low Low Negligible

98 Musselburgh, Newhailes Category A Listed

2.05km Trees will block visibility None None None

103 Dalkeith House Category A Listed

2.90km House on periphery of ZTV, tree belts will block visibility

High None None

115 Inveresk, Inveresk Lodge Category A Listed

2.85km Trees will partially block visibility High Low Minor-Moderate

116 Musselburgh, Inveresk Parish Church and Graveyard

Category A Listed

2.58km Intervening trees and buildings will block visibility from the church and graveyard

High None None

119 Edinburgh, Craigmillar Castle, Dovecot

Category A Listed

3.47km Intervening trees and buildings may partially block visibility

High Marginal Minor

123 Inveresk, The Manor House, Dovecot

Category A Listed

2.76km Trees will at least partially block visibility Low Marginal None

126 Millerhill, Newton Farmhouse Category B Listed

1.23km Visibility may be partially impeded by intervening features

Medium Low Minor

127 Newton House Category B Listed

1.29km Trees will impede visibility Medium Low Minor

129 Edinburgh, 58 Newcraighall Road, Craigmillar Arts Centre

Category B Listed

1.59km Visibility will be most apparent from the rear of the building and may be partially impeded by intervening buildings and trees. The Proposed Development would be mostly screened by the Shawfair New Community Development, AD Plant and

Medium Marginal Negligible


Borders Railway.

131 Castlesteads House, Dovecot

Category B Listed

1.56km Trees will block visibility Low Marginal None

132 Edinburgh, Brunstane House Steading

Category B Listed

1.88km Intervening trees and townscape will block visibility

Low None None

133 Newton Village, Newton Church

Category B Listed

1.50km The Shawfair New Community Development will likely fully impede visibility of the Proposed Development though visibility of the stack cannot be completely discounted

High Marginal Minor

135 Musselburgh, Newhailes, Walled Gardens, Fruit Store and Terraced Walk

Category B Listed


High None None

137 Millerhill, Newton House, Newton Dovecot

Category B Listed

1.3km Located within wooded garden adjacent to Newton House.

19

Medium Low Minor

138 Whitehill Mains Farmhouse Category B Listed

0.66km Property derelict and boarded up, trees will at least partially block visibility. The Proposed Development will be mostly screened by the AD Plant and Borders Railway

Low Marginal None

141 Musselburgh, Newhailes, Dovecot

Category B Listed


High None None

142 Musselburgh Newhailes Grotto

Category B Listed


High None None

143 Musselburgh, Stoneyhill, Former Steading

Category B Listed

2.09km Possible visibility from upper floor rear windows (possibly later insertions during residential conversion)

Low Marginal None

19

Historic Scotland’s co-ordinates incorrectly place the dovecot within a ploughed field c.1km west of its correct location.


144 Musselburgh Newhailes, Earl of Stair’s Monument

Category B Listed


High None None

146 Musselburgh, Newhailes, Ice House

Category B Listed


High None None

147 Musselburgh, Newhailes, Main Gate with Gate Piers

Category B Listed

1.72km Trees and structures will partially block visibility

High Marginal Minor

148 Old Craighall, Monkton House, Gardener’s House with Sundial

Category B Listed

1.11km Trees and structures will partially block visibility

Medium Low Minor

150 Musselburgh, Newhailes, Gardener’s Cottage

Category C Listed


High None None

151 Millerhill, Newton Farmsteading and Gatepiers

Category C Listed

1.22km Large metal sheds will block visibility from the core of the steading

Low Marginal None

154 Smeaton Shepherds Cottage, Stable Court

Category C Listed

1.90km A720 Edinburgh Bypass intervenes between stables and Proposed Development

Low Marginal None

161 Smeaton, Shepherd’s Cottage

Category C Listed

1.90km A720 Edinburgh Bypass intervenes between cottage and Proposed Development

Medium Marginal Negligible

163 Newton Village, Newton Church, Watch House

Category C Listed

1.54km The Shawfair New Community Development will likely fully impede visibility of the Proposed Development though visibility of the stack cannot be completely discounted

Low Marginal None

195 Musselburgh Conservation Area

2.37km Trees and the intervening townscape will largely block visibility

High Marginal Minor

202 Inveresk (Musselburgh) Conservation Area

1.90km The Proposed Development would only be partially visible in outward views from the southern side of the Conservation Area



208 Inveresk Lodge Garden Inventoried Garden and Designed

Landscape

2.64km Intervening trees will partially block visibility


209 Dalkeith House (Palace) Inventoried Garden and Designed

Landscape

1.88km Tree belts will largely if not completely block visibility

High (core of IGDL)

Marginal (worst case,

core of IGDL)

Minor (worst case, core of

IGDL)

The Proposed Development will be visible from the northern part of the IGDL, including from a footbridge crossing the A68.

Low (footbridge

A68)

Low (footbridge

A68)

Negligible (footbridge

A68)

210 Carberry Tower Inventoried Garden and Designed

Landscape

3.67km Tree belts will partially impede visibility High Marginal Minor

211 Palace of Holyroodhouse Inventoried Garden and Designed

Landscape

4.25km Only the eastern part of the park falls within the ZTV

High Marginal Minor

212 Newhailes Inventoried Garden and Designed

Landscape

1.57km Trees and structures both within and beyond the parkland will largely block visibility


216 Newton House (Midlothian) Inventoried Garden and Designed

Landscape

1.07km Core garden area thickly planted with trees. Wider designated field system bisected by A720 Edinburgh bypass.

Medium Low Minor

220 Craigmillar Castle Inventoried Garden and Designed

Landscape

3.31km Only the eastern part of the Inventoried area falls within the ZTV

High Marginal Minor

221 Pinkie Inventoried 850 m The visibility of the development will be Medium Low Minor


Battlefield variable throughout the Inventoried area, but it will be visible from Inveresk Fields and from certain locations on the slopes of Falside and Carberry Hill.

222 Edinburgh, Brunstane House Category A Listed

1.88km Intervening trees and townscape will at least partially block visibility at ground floor level

High Marginal Minor


13.4.20 The Category ‘A’ Listed Monkton House (Site 95) (Plate 2) stands to the

southeast of the site and is a substantial, three storey, late 17th century, L plan

laird’s house attached to an earlier 16th century tower. The property’s origins

are unclear, although it is believed to have originated prior to the reformation

as a grange for the Cistercian abbey at Newbattle. The property faces

southeast over its gardens and the principal windows are located within this

elevation. The house’s northwest elevation, by contrast contains fewer

windows, all of which are either set within the stair turret or an adjacent

landing. The house’s separate one and a half storey stable block (Site 83) of

circa 1625 is set to the northwest of the house to form small courtyard and is

clearly ancillary to the main structure. Both the house and the stable block are

Category ‘A’ Listed and together have a coherent collective value as a well

preserved example of a 17th century Lothian lairds seat. It is therefore

reasonable to argue that the ’eminence’ of the house gives it a high relative

sensitivity as its setting clearly contributes significantly to its understanding.

The stable block by contrast was clearly intended to be subservient to the

main house and is best understood in relation to the house and it has a

medium sensitivity to changes beyond that immediate relationship.

13.4.21 The Proposed Development would stand to the northwest of Monkton House

and its stables and would be largely shielded from them both by trees within

the northern part of the Hall’s grounds and by a high wall which, in places

extend along the northwest boundary. However greater visibility is predicted

from the upper floor windows set within the northwest elevation of the stables.

The positioning of the principal windows in the southeast elevation indicates

that the builders and early occupiers of Monkton Hall placed greater emphasis

on the importance of views southeast from the house than they did for views

north-westwards from the house’s subsidiary elevation. Whilst limited visibility

is predicted from within the grounds of the house, this will be restricted by

trees and will not interfere with south-eastward views out from the principal

elevation. For these reasons the magnitude of effect of the Proposed

Development upon the settings of both Monkton Hall and the stable block is

predicted to be low as it would result in an insignificant alteration, beyond

those elements of the setting which directly contribute to the cultural heritage

value of the assets. Given that the house has a high relative sensitivity and

the stables a medium one, the Significance of these effects on the settings of

the assets is predicted to be Minor-Moderate in the case of Monkton Hall and


Minor in the case of its stables. Neither of these effects will be Significant in

terms of the Town and Country Planning (Environmental Impact Assessment)

(Scotland) Regulations 2011.

13.4.22 The Category ‘B’ Listed Gardener’s House (Site 148), stands north of Monkton

House on the southeast side of Old Craighall Road. Of 17th century origin, the

building was altered and extended in the 18th century. The house is

positioned, flush against the road in the northern corner of the walled garden

which extends northwards from Monkton Hall. Whilst there are windows in the

external west elevation, the absence of a door shows that the house was

intended to be accessed exclusively from within the gardens. Although the

placing of windows in the west elevation would suggest that some value was

placed in the importance of views outward towards the Proposed

Development, it is clear that the house’s principal setting relates to the former

walled garden which is concealed from the Proposed Development behind a

high wall. This means that although the Gardener’s House may have a high

sensitivity to changes within the walled garden, outwith it, its relative sensitivity

can be assessed as Medium. Whilst the Proposed Development would

potentially appear in views of the house from the garden, it would not prevent

the observer from understanding the relationship between the house and the

garden. For these reasons the effect of the Proposed Development upon the

setting of the Gardeners House is predicted to be of Low Magnitude and Minor

Significance.

13.4.23 A second 17th century Lairds House, Newton House (Site 127) stands c.1km

to the south of Monkton House, southeast of the Proposed Development.

Although the house originally fronted northwest, the house was substantially

rebuilt c.1820 and now fronts to the southeast over looking its gardens. The

northwest elevation became secondary following the rebuild. The thickly

wooded gardens surrounding Newton House (Site 216) are included on the

Inventory of Historic Gardens and Designed Landscapes (IGDL) and define

the principal setting of the house. Whilst the Inventoried area includes

elements of the surrounding farmland, bisected by the A720 Edinburgh

Bypass, the Inventory Designation notes that:

“The garden at Newton is enclosed on all sides and as a result there are

limited views out across the adjacent low-lying farmland. The house set

in its garden, with its associated farm complex and enclosed parks,


occupy a prominent position in the landscape viewed from the south-

east round to the south-west.

The site is compact, defined by the walls of the walled garden, and the

approach ground leading off the old Dalkeith/ Musselburgh road

(B6415). The fields or ‘parks’ outwith the garden boundary which are

part of the 18th century enclosure are also included.” 20

13.4.24 Apart from the house, a distinct set of listed assets are present at Newton

including a dovecot (Site 137) and Newton Farmhouse (Site 126), both of

which are Category ‘B’ Listed and a Category ‘C’ Listed steading and set of

gate piers (Site 151). These assets are located within the area enclosed by

the garden and steading complex. Taken together this group of assets have a

distinct group value. Whilst Newton House (Site 127) undoubtedly has a high

relative sensitivity to changes to the southeast, the re-orientation of the house

in the 1820’s has reduced its sensitivity to change in the opposing, northwest

direction, where the house’s curtilage is in part functional, defined by the farm

house steading. For this reason Newton House is considered to have a

Medium sensitivity to change, to the northwest in the direction of the Proposed

Development. Newton Farmhouse (Site 126) is a late 18th century classically

embellished farmhouse, erected prior to the re-orientation of the main house

in the 1820’s, for these reasons it also has a Medium sensitivity to change.

Whilst dovecots are generally seen to have a Low relative sensitivity,

representing as they do a pragmatic method of food production, the Newton

example (Site 137) originated as a 16th century circular tower, presumably a

watch tower for an earlier antecedent to Newton House and for this reason

also has Medium relative sensitivity. The Category ‘C’ Listed steading

complex (Site 151) by contrast has been compromised by the erection of large

agricultural sheds adjacent to it. These, coupled with its own agricultural

function, give it a Low relative sensitivity to change. The boundaries of the

IGDL (Site 216) have been drawn so as to exclude the steading and

farmhouse although an area of open fields beyond the garden, bisected by the

A720 is included. The IGDL designation states that the walled gardens,

containing both the house and the dovecot is central to the definition of the

site, implying that IGDL is less sensitive to changes outwith its walled core.

20

http://data.historic-scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00301, Accessed 11th of

March 2015

http://data.historic-scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00301


For this reason whilst the IGDL is undoubtedly highly sensitive to changes

which either fall within or directly impinge upon its walled core, its sensitivity to

changes across the open fields is considered to be Medium.

13.4.25 The Proposed Development area is located northwest of the Newton asset

group and any visibility, beyond the assets would be across an open

landscape which includes both pylons and the existing Millerhill sidings.

Visibility from both Newton House (Site 127) and the dovecot (Site 137) would

be impeded by trees and the Proposed Development would not interfere with

the critical views south-eastward from the house’s principal elevation. Whilst

the farmhouse stands upon more open ground it fronts to the southwest away

from the Proposed Development area. Visibility from the steading will be

largely blocked by adjacent agricultural sheds. For these reasons the

Magnitude of change upon the settings of Newton House, its farmhouse and

the dovecot is predicted to be Low; whilst an effect of Negligible magnitude is

predicted for the steading. The Proposed Development would be visible from

across the open fields included within the IGDL designation, however views

from within the walled garden would be impeded by the tree cover within the

garden and as a consequence the magnitude of effect would be Low. The

Proposed Development would fall outwith those elements of the IGDL which

directly contribute to the understanding of its cultural value. Given these

magnitudes of effects, the effect of the Proposed Development on each asset

is predicted to be of Minor significance in the case of Newton House (Site

127), its farmhouse (Site 126), the dovecot (Site 137) and the IGDL (Site 216).

The effect on the steading (Site 151) will be of no significance.

13.4.26 Whitehill Mains Farm (Site 138), a Category ‘B’ Listed late 19th century

farmhouse, stands north of the Proposed Development area adjacent to the

northwest corner of the Millerhill Marshalling Yard and is the nearest

designated asset to the site. A site visit found the farmstead to be derelict and

boarded up. Given this and the fact that it is primarily a functional structure

related to its undesignated steading to the north, its relative sensitivity to

changes to its setting is considered to be Low. Viewpoint 14 taken from a

railway bridge to the east of the farm, suggests that whilst the Proposed

Development would be partially visible, though in the main it would be

screened by the AD Plant and Borders Railway. Given the limited visibility the

effect of the proposal on the setting of the farmhouse would be of Marginal


Magnitude. Consequently an effect of No Significance is predicted upon the

setting of the farmhouse.

13.4.27 Craigmillar Arts Centre (Site 129), the former Church of St Andrew stands to

the north of the Proposed Development area beside a roundabout on the

southern side of Newcraighall Road. It dates from 1900 and is Category ‘B’

Listed. Whilst intervisibility with the Proposed Development is predicted it

would be mostly screened by the AD Plant, Borders Railway and SNCD.

Indeed the development of land between the A1 and Whitehill Road as part of

the SNCD may screen the Proposed Development entirely, though some

visibility of the stack associated with the Proposed Development cannot be

discounted. The closure and removal of the colliery which the church was built

to serve, has robbed it of its context, whilst the erection of large retail

developments in proximity to it mean that its authentic immediate setting has

been compromised. The former church consequently has a Medium relative

sensitivity to changes to its setting. Whilst the Proposed Development would

be visible it would not interfere with the church's critical surviving setting

relationship, its relationship to its frontage and consequently any effect would

be of Marginal magnitude and Negligible significance.

13.4.28 Shepherds Cottage, Smeaton (Site 161) of c.1860 and its adjacent stable

court (Site 154) stand to the southeast of the Proposed Development on the

opposite side of the A720, both are Category ‘C’ Listed. Whilst the cottage’s

Tudor styling gives it a Medium relative sensitivity, any visibility with the

Proposed Development would be set at a distance of 1.90km and would be

across the intervening presence of the A720 dual carriageway. It would also

fall outwith the setting of the cottage which can reasonably be defined as the

land of the Dalkeith Estate upon which it was erected. For these reasons the

effect on the cottage is predicted to be of Marginal magnitude and Negligible

significance. The late 18th Century U-shaped stable court opens to the

southeast away from the Proposed Development and its setting is limited to its

immediate environs and its relationship with the adjacent, later cottage. Due to

its functional purpose it is judged to have a Low relative sensitivity. It is

therefore clear that any effect would fall outwith the setting of the stable and

consequently will be of Marginal Magnitude and No significance.


13.4.29 The Category ‘B’ Listed dovecot, Castlesteads (Site 131) stands within thick

woodland to the southeast of the Proposed Development close to the A720

dual carriageway. The Listing description describes it as a single chambered

lean-to structure of probable 18th Century date, the only apertures being the

single door in the southern elevation and the flight holes in the centre of the

roof pitch. The remaining walls including those facing the Proposed

Development are blind. The dovecot’s practical form means that it is

considered to have a Low relative sensitivity. Given that any visibility will be

largely, if not entirely, impeded by tree cover and will fall considerably outwith

the dovecot’s immediate setting, the effect is predicted to be of Marginal

Magnitude and No significance.

13.4.30 Three Category B Listed buildings Stoneyhill (Site 130), Stoneyhill House (Site

136) and the former Stoneyhill Steading (Site 143) stand to the northeast of

the Proposed Development, subsumed within an intervening housing estate.

The housing estate would block all visibility with Sites 130 and 136, which

have consequently been excluded from the detailed assessment. However the

possibility of visibility occurring southward from the southwest elevation of the

former steading (Site 143) along the axis of Stoneyhill Road cannot be

discounted as the lighting masts of the existing marshalling yard appear in this

view. Whilst windows are set within the steading’s southwest elevation it is

unclear whether they are original to its design or result from its later residential

conversion. Given its functional purpose and the fact that the steading opens

to the northeast, in the opposite direction to the Proposed Development, it can

be argued that it has Low sensitivity to changes to the southwest and that any

effect resulting from the Proposed Development would be of Marginal

magnitude. Any effect will consequently be of No significance.

13.4.31 The Scheduled remains of Newton Old Church (Site 21) lie within its

churchyard and set within a field system southeast of the Proposed

Development area on the opposite side of the A720 dual carriageway. The

Category B Listed tower is the only element of the church to survive above

ground. The church was abandoned in 1742 when the new parish church (Site

133) was built, closer to the mines within which its congregation worked.

Whilst the core of the upstanding tower is early 17th century, the upper two

storeys appear to have been rebuilt circa 1915 and relate to its post

abandonment function as an eye catcher within the Duke of Buccleuch’s


Dalkeith Estate. Whilst the tower is well preserved it is shouldered by high

trees which mask it to a degree, making it less visually distinctive in views

from the northwest. The immediate setting of the tower has been

compromised by the routing of the A720 within 165m of it. As originally

constructed the tower was intended to be a visual marker within the parish of

Newton, and also a focal point within the immediate surroundings of the

church, namely the churchyard. However, the tower’s post abandonment use

as a folly re-focussed its setting to the south towards the core of the Dalkeith

Estate. The upper two storeys, the most visible, appear to have been rebuilt

post abandonment and consequently relate to this later setting. For these

reasons it is argued that the tower has a Medium sensitivity to changes in the

direction of the Proposed Development. Whilst visibility with the development

is predicted, the intervening A720 dual carriage way, is an overriding presence

within these views. For this reason the predicted visibility would represent an

insignificant alteration beyond those core elements of the setting which

directly contribute to the asset’s cultural value. Consequently the effect will be

of Low Magnitude and Minor Significance.

13.4.32 Newton old church was replaced in 1742 by a new church (Site 133) located

west of the original between the modern settlements of Danderhall and

Newton. Both the replacement church (Site 133) and the watch house and

boundary walls (Site 163) within its grounds are Category ‘B’ and ‘C’ Listed

respectively. The watch house was constructed c.1828, the year of the Burke

and Hare murders, in response to the ‘body snatching’ that Edinburgh was

notorious for. It is a small single storey functional building and given its

purpose its setting can be said to relate to the gate it guarded. It therefore has

a Low relative sensitivity. The Georgian church is by contrast a simple

classical structure and when built would have been clearly visible in westward

views from Millerhill Road (the A6106), whilst this view is now impeded by tree

growth within the churchyard, the church has a High relative sensitivity

although it would clearly be more susceptible to change within the churchyard

than outwith it. Visibility of the Proposed Development will be severely

impeded by the SNCD, though the possibility that the stack may be visible

beyond this cannot be entirely discounted. The Proposed Development would

stand considerably outwith the church’s immediate setting which can be

defined as the tree shielded graveyard and its immediate environs.

Consequently the effect of the Proposed Development upon the setting of the


church is predicted to be of Marginal Magnitude, but given its High Relative

sensitivity of Minor Significance. Any visibility from the watch house would be

at worst of Marginal magnitude and given its Low sensitivity of No

Significance.

13.4.33 Eight Listed Buildings stand to the north of the Proposed Development within

the IGDL (Site 212) surrounding Newhailes House. Listed designations

include the House (Site 98, Category ‘A’), the Stables (Site 50, Category ‘A’),

the Walled Gardens Fruit Store and Terraced Walk (Site 135, Category ‘B’),

the Dovecot (Site 41, Category ‘B’), the Earl of Stair’s Monument (Site 144,

Category ‘B’), the Ice House (Site 146, Category ‘B’), the Main Gate and Pier’s

(Site 147, Category ‘B’) and the Gardeners Cottage (Site 150, Category ‘C’).

Whilst individually some of the assets may have a lower sensitivity, when

taken together and placed within the designed landscape to which they each

contribute, their group value is elevated and all are considered to have a High

relative sensitivity, although in many cases their setting can be reasonably

held to be restricted to the confines of the designed landscape. The

Inventoried Designed Landscape (Site 212) represents a rare survival of an

early to mid-18th century rococo landscape garden, surrounding a house

which has been little altered from that period. The IGDL designation notes

views southward towards the Moorfoot Hills and places emphasis on the

importance of views northwards and eastwards from the house noting that:

“although enclosed on its south-west and south sides, it commands extensive

views out to the north-east, over lawns and parkland, to the Firth of Forth.”21 It

is therefore clear that both the setting of the designed landscape and its

aesthetic value contribute directly to the observer’s experience of it and that

the IGDL therefore has a High relative sensitivity to change. Although it has a

greater degree of vulnerability to changes which fall either within its

boundaries or are visible from across the more open landscape to the north

and northeast.

13.4.34 A site visit demonstrated that there will be no visibility, either from Newhailes

House (Site 98) or six of the Listed Buildings within the IGDL (Sites 50, 135,

41, 144, 146 and 150) and consequently no effect upon the settings of these

21

http://data.historic-scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00296 accessed 12th

of

March 2015



assets is predicted (Plate 3). The site visit also found that there will be no

visibility from within the majority of the IGDL (Site 212). While there may be

some visibility from the Category ‘B’ Listed Main Gate and Piers (Site 147) this

will be restricted and distinct from the setting of the gate which is limited to the

much altered road which it fronts. Consequently, the effect on the setting of

the gate would be of Marginal magnitude, but given its High relative sensitivity

of Minor Significance.

13.4.35 The Listed Main Gate (Site 147) leads into an open grassed enclosure ringed

by a belt of trees, this forms the southwest tip of the IGDL (Site 212) and

views northwards towards Newhailes House are largely blocked by an

intervening wood. The integrity of the enclosure has in part been

compromised by the National Trust for Scotland’s asphalt car park which

extends along its northern edge. A site visit established that whilst visibility

with the stack, particularly during the winter months cannot be discounted, any

visibility would be extremely limited. The proposed stack would not appear in

views either towards or from Newhailes House via the enclosure. Given this

limited degree of predicted visibility, the effect of the Proposed Development

on the setting of the Newhailes IGDL (Site 212) would be of Low Magnitude,

representing at worst an insignificant alteration beyond those elements which

directly contribute to the cultural value of the landscape, and of Minor-

Moderate Significance.

13.4.36 Category ‘A’ Listed Brunstane House (Site 222) stands to the north of the

Proposed Development and any visibility would be across a complex

landscape featuring railway lines, the A1 dual carriageway, the settlement of

Newcraighall and elements of the Gilberstoun housing development.

Brunstane is a fine, comparatively intact example of a 17th century Lothian

mansion, built originally in 1639 for the Earl of Lauderdale, a prominent Scots

politician and altered by William Adam in 1733. It was clearly designed so as

to both appear prominent within its surroundings and enable views out across

the landscape from its windows and therefore, undeniably, has a High relative

sensitivity. The house was laid out on a distinct east-southeast / west-

northwest alignment and it is thus reasonable to argue that it is particularly

sensitive to changes in these directions. A site visit found that at ground level

visibility of the Proposed Development would likely be impeded or possibly

even blocked entirely by the intervening trees, townscapes and route networks


although it is possible that the stack would show. A greater degree of visibility

is predicted in views out from the upper storey windows although the

Proposed Development would neither impinge in views out eastward from the

principal elevation or westward along the approach to the house. Given this

predicted limited visibility and the fact that any views of the Proposed

Development would occur within a modern, complex landscape, totally

changed from the one within which Brunstane was erected and beyond its

immediate setting, the effect is predicted to be of Marginal Magnitude and of

Minor Significance. No visibility is predicted with the adjacent Category ‘B’

Listed steading and cottages (Site 132), which were being converted to

residential use at the time of the visit.

13.4.37 Nine designated assets within the Inveresk Conservation Area (Site 202) have

been included within the detailed assessment. The remaining assets within

the Conservation Area were excluded after the site visit established that there

would be no visibility with the Proposed Development. The nine designated

assets include the Inventoried Inveresk Lodge Garden (Site 208), as well as

three Category ‘A’ Listed assets; Inveresk Lodge (Site 115); the remains of an

outbuilding (Site 96) and a sundial (Site 49).

13.4.38 The Lodge and its garden stand northeast of the Proposed Development on a

ridge overlooking the east bank of the Esk. Inveresk Lodge is an L Plan

mansion of 1683 – 1700 built along the southwest side of Inveresk Village

Road and is one of a group of substantial villas laid out along the ridge by

prosperous Edinburgh citizens between the 17th and 19th Centuries. The

garden, which is open to the public, steps down to towards the floor of the Esk

Valley on a series of terraces which were laid out in the second half of the 19th

Century, although the present layout of the garden post-dates its acquisition

by the Trust. Whilst it is Category A Listed and dates to 1644, the sundial (Site

49) was moved to the garden by the Trust in 1968 from Pitreavie Castle, Fife.

Tradition holds that the ruinous outbuilding (Site 96) conceals a subterranean

passage to the neighbouring villa, Halkerston (Site 62) although no evidence

for this has been found. Overall, both the garden and the Lodge have a High

relative sensitivity to change, although the Lodge’s critical setting relationship

is with its garden, the significance of which is derived largely from its modern

aesthetic. The outbuilding’s ruinous condition and the sundial’s lack of any


historical provenance within the garden mean that their relative sensitivity is

considered to be Low.

13.4.39 A site visit to Inveresk Lodge Garden (Site 208), undertaken during winter,

found that whilst the Proposed Development is likely to be visible, intervening

trees both within the garden and beyond would substantially impede views

(Plate 4). It is likely that from within some parts of the garden the Proposed

Development would not be visible, whilst from other perspectives only the

stack or elements of the stack would show. As Plate 4, looking south-

westwards from the upper terrace of the garden shows, the Proposed

Development would be set within a wide, tree dominated vista extending out

to the Pentland ridge. Whilst the Inventory designation for the garden notes

that: “from within the garden, views can be obtained on a clear day to Arthurs

Seat in the west and the Pentland hills in the south, due to the south-westerly

aspect of the site, it acknowledges that ‘to the south beyond the River Esk lies

Monktonhall Golf Course and beyond, the sprawling industrial and suburban

landscape of Midlothian,”22 and it is within this vista that the Proposed

Development would appear. The degree of masking afforded by the tree cover

within the garden would also of course vary according to the season and

would be reduced during the winter. Although the garden is laid out along

terraces and the landscape outwith it to the southwest is visible, the focus of

the garden is essentially inward looking with distinct planned views along the

alignment of the terraces towards ornaments placed within the garden, such

as the sundial from Pitreavie. For these reasons, the Proposed Development

would result in an insignificant alteration to the setting of the garden beyond

those elements of its setting which directly contribute to its cultural value. The

predicted effect will therefore be of Low Magnitude and of Minor-Moderate

Significance.

13.4.40 Inveresk Lodge (Site 115) stands in the northern corner of the garden

adjacent to the road. The L Plan house has a principal elevation, the

southwest elevation which overlooks the Esk Valley and the southeast

elevation which fronts onto the garden terraces. Whilst the Proposed

Development may be visible from the windows of the southwest elevation, any

visibility would be impeded by trees, which during the summer could

22



potentially block visibility from some of the windows. Whilst the garden and the

Lodge and assets within the garden are distinctly different in date, they clearly

relate to each other and each contributes to the value of the other. The

southeast elevation, clearly relates to and opens out onto the garden, the

southwest elevation is separated from it in part by height and in part by a

small courtyard which excludes part of the ground floor from the garden. The

Proposed Development would not intrude into views out from the southeast

elevation across the garden although it would potentially appear in views out

across the Esk Valley from the southwest elevation. However, as the

designation for the IGDL acknowledges, views in this direction take in

industrial and suburban Midlothian and it is in this context that the Proposed

Development would be seen, and more critically understood by the observer.

For this reason the Proposed Development would result in an insignificant

effect on elements beyond the core setting of the house, its garden, and

consequently the effect would be of Low Magnitude and of Minor-Moderate

Significance.

13.4.41 Whilst the outbuilding (Site 96) and the sundial (Site 49) are Category ‘A’

Listed, the contribution that their setting makes to their value has been

diminished and they have a Low relative sensitivity. Any effect upon the

setting of these assets would, in the worst case represent an insignificant

alteration to their setting and would consequently be of Low Magnitude and

Minor-Moderate Significance.

13.4.42 Halkerston (Site 62), immediately northwest of Inveresk Lodge, is a Category

A Listed square plan house of c.1640 and is probably the oldest building in

Inveresk although it was restored in 1960. Halkerston is approached from the

road via a stable court and fronts south-westwards onto gardens which

overlook the Esk Valley. The stable block (Site 63) is also Category ‘A’ Listed

although it has been excluded as views of the Proposed Development from it

would be blocked by the main house. Visibility out from the house towards the

Proposed Development is predicted to be at similar level to those views out

from the adjacent Inveresk Lodge and would also likely be impeded at least to

a degree by intervening tree cover. Whilst Halkerston has a similar High

relative sensitivity to the Lodge and will be particularly sensitive to changes

which interact in views outwards across its garden, any visibility with the

Proposed Development would occur across the wider suburban and industrial


Midlothian landscape and consequently the effect of any alteration would be of

Low magnitude and Minor-Moderate Significance.

13.4.43 Inveresk Manor (Site 84) is, after the Lodge and Halkerston, the third in the

line of mansions extending northwest along the Inveresk Ridge. The most

recent of the three, it is a substantial Category ‘A’ Listed, seven bay classical

villa of 1748, and like the others its rear, southwest elevation fronts onto a

substantial garden which extends down towards the Esk. The Manor has the

same level of High relative sensitivity as the Lodge and Halkerston, for similar

reasons; although unlike the others it’s formal classical elevation fronting

northeast onto to the road is considerably embellished and is clearly the

principal elevation. The Proposed Development could potentially be visible in

views out across the garden from the Manor, however any visibility would, at

least to a degree, be impeded by trees and given that the Proposed

Development would be set within the wider suburban and industrial landscape

would represent an insignificant alteration. Consequently any effect would, at

worst, be of Low Magnitude and Minor-Moderate significance.

13.4.44 Two Category ‘A’ Listed buildings; the East Pavilion (Site 85) and the Dovecot

(Site 84) stand within the grounds of Inveresk Manor. The Pavilion has a High

relative sensitivity, being an ornamental structure, positioned alongside the

road and was clearly intended to form part of the Manor's street front

composition. Although visibility from the rear of the Pavilion towards the

Proposed Development would be possible, any views would be at least

impeded by intervening trees and possibly the Manor House itself.

Consequently any effect on the setting of the Pavilion would be, in the worst

case, exceedingly limited, of Marginal magnitude, and of Minor Significance.

The dovecot stands within the rear garden. Although subsequently converted

into a summer house the building is now roofless and classified as being in

very poor condition on the Buildings at Risk Register for Scotland. Its primary

setting is within the garden and it is considered to have a Low relative

sensitivity particularly to changes outwith this immediate setting. Any visibility

with the Proposed Development would be limited by intervening trees.

Consequently any effect would be of Low magnitude and No Significance.

13.4.45 Site visits have found that there would be no visibility of the Proposed

Development either from the Category ‘A’ Listed Inveresk Church (Site 116) or


the historic core of its graveyard, even during those months when the

intervening tree cover is at its most diminished. Whilst the church and it's spire

form a prominent landmark, noted as a 'signature' by the Inveresk

Conservation Area Character Appraisal, the distance of separation between

the church and the Proposed Development coupled with the fact that

Proposed Development will stand within a markedly modern complex

landscape, mean that the stack will neither impinge in or challenge distant

views of the church. Consequently, despite its High relative sensitivity, No

effect is predicted on the setting of the church.

13.4.46 The core of the Inveresk Conservation Area (Site 202) can be defined by the

axis of Inveresk Village Road and the densely built up post-medieval

townscape of, predominantly Listed Buildings which line it. The Proposed

Development would not be visible in views from this townscape as outward

views are unobtainable due to the extent of the enclosure. Consequently No

effect is predicted from the core of the Conservation Area. However, a site

visit found that limited visibility is possible from the garden of Inveresk Lodge,

and a similar degree of visibility is predicted from those other southeast facing

gardens which extend to the rear of properties along the southern side of

Inveresk Village Road. Whilst these gardens fall beyond the core of the

Conservation Area, the Conservation Area Appraisal notes the 'buildings laid

out along the high flat ridge above the river and the large mature gardens that

sweep down towards the river' are part of the 'Essential Character' of the

designation. However, this assessment has found that views of the Proposed

Development from these gardens would be impeded by trees and furthermore,

as the designation for the IGDL acknowledges, views in the direction of the

Proposed Development area take in industrial and suburban Midlothian and it

is in this context that the Proposed Development will be seen, and more

critically understood by the observer. For these reasons whilst the Inveresk

Conservation Area has a High relative sensitivity, when considered overall,

the Proposed Development would represent an insignificant alteration beyond

those core elements of its setting which directly contribute to our

understanding of it. Consequently the effect on the setting of the Conservation

Area is predicted to be of Low magnitude and Minor-Moderate Significance.

13.4.47 Musselburgh Conservation Area (Site 195) lies north of Inveresk and covers

the historic core of Musselburgh. Site visits demonstrated that the intervening


townscape would block all visibility of the Proposed Development from the

greater proportion of the Conservation Area, including both the High Street

and the grounds of Pinkie House. However, visibility could potentially occur

from the centre of the Category ‘A’ Listed 16th century Musselburgh Old

Bridge (Site 68) as it crosses the Esk, although any visibility would be, at the

least, severely impeded by the intervening presence of trees. Any visibility

from within the Conservation Area is unlikely to extend too far beyond the

bridge due to the built up nature of the townscape. Although no Conservation

Area Appraisal has been published for Musselburgh, a Conservation Area

Character Statement published with the 2008 East Lothian Local Plan (East

Lothian Council 2008, Appendix 7, 32, para 1.2) notes that: “the river adds an

additional dimension to Musselburgh's townscape quality, along with its

bridges particularly the Roman Bridge (or Old Bridge) which is Category A

Listed.” Whilst the Old Bridge is essentially functional, it also has a High

relative sensitivity derived from both its own aesthetic quality and the

additional qualities which result from its interaction with the Esk. The core

setting of the bridge is limited to the river and its banks and the immediate

surroundings characterised by the townscape. This means that any visibility,

should it occur, from either the bridge or the banks of the Esk, would be both

restricted and would fall considerably outwith the setting of both the bridge

and the Conservation Area. Consequently the effects upon the settings of both

the bridge and the Conservation Area are predicted to be Marginal and of

Minor Significance.

13.4.48 Category ‘A’ Listed Dalkeith House (Site 103) (Plate 5) lies south-southeast of

the Proposed Development and is set within the extensively wooded Dalkeith

Palace IGDL (Site 209). Dalkeith House, or Palace as it is alternatively known,

dates from 1702-11 and incorporates fabric from the earlier 15th century

Dalkeith Castle. The Dalkeith Estate was purchased by the Earl of Buccleuch

in 1642 and both the house and park remain in the hands of his descendants.

The IGDL is thickly wooded, being characterised by thick belts of trees which

converge on the confluence of the rivers North and South Esk within the park.

The rivers pass through steeply incised valleys. The majority of the Listed

Buildings within the park, including Dalkeith House, stand in proximity to the

rivers and accordingly lie on the periphery of the ZTV. Following a site visit no

visibility from the Listed Buildings is predicted. The site visit also found that the

thick belts of trees which extend both through the park and define its edges


comprehensively block any low level views out from the park. Whilst the

possibility of the proposed stack appearing above the tree line in certain views

cannot be discounted, this is unlikely given the distance of separation between

the IGDL and the 75m stack. It is likely that any visibility, should it occur would

be extremely limited and confined to the northern edge of the IGDL. The

House and the IGDL clearly have a High relative sensitivity. However, given

the above No effect is predicted upon the setting of the House, whilst any

visibility from within the IGDL would be extremely limited and would fall

considerably beyond the parkland elements of the landscape. Consequently

should any effect occur it would be of Marginal Magnitude and Minor

Significance.

13.4.49 Despite the above it needs to be acknowledged that the designated area of

the Dalkeith IGDL extends northwards to include areas of open fields and

plantations astride the Esk which comprised the core of the historic

agricultural estate. Whilst the Proposed Development will be visible from these

areas, this part of the IGDL has historically been segregated from the core

parkland surrounding Dalkeith House by belts of trees and has been further

compromised by the recent addition of the A1 and A68 trunk roads, from

which much of the visibility would occur. It is reasonable to argue that views

from the modern footbridge over the A68 are inconsequential to the historic

character and significance of the designed landscape and as a consequence

will not diminish our understanding of it. Whilst the core of the park has a high

relative sensitivity the bisection of the northern part of the IGDL by the A1 and

A68 has significantly compromised it, dislocating its association with the

Dalkeith Estate. Consequently in cultural heritage terms, this part of the IGDL

is considered to have a Low relative sensitivity to change and the predicted

visibility will represent an insignificant alteration beyond those core elements

of the IGDL (the park surrounding Dalkeith House). Any effect on the northern

part of the IGDL will therefore be of Negligible Significance.

13.4.50 Newbattle Abbey IGDL (Site 219) lies south of Dalkeith, within the valley of the

South Esk. The park was developed to provide an appropriate setting for

Newbattle Abbey (Site 112), the historic seat of the Marquess' of Lothian. The

core of the park along the banks of the South Esk falls outwith the ZTV and

consequently No effect is predicted upon the settings of any of the Category A

Listed Buildings within it. Whilst the ZTV does indicate that some visibility is


possible, it would only occur in areas which lie beyond the core of the park.

Visibility would potentially be restricted to the higher ground in the northeast

corner of the IGDL where the original parkland has been compromised by the

laying out of the Newbattle Golf Course. Despite infringement by the golf

course, overall the IGDL retains a High Relative Sensitivity. Visibility would be

across a wide intervening landscape and would also be impeded by

intervening trees and plantations. Given only limited visibility is predicted

beyond the core of the IGDL any effect would be of Marginal magnitude, and

of Minor Significance.

13.4.51 Carberry IGDL (Site 210) extends along the ridge line to the east of Whitecraig

and was created to provide an appropriate setting for Carberry Tower, a

Category B Listed Stately home, the IGDL itself being largely an 18th and 19th

century creation. Whilst the IGDL has a High relative sensitivity to change, it is

surrounded by thick tree belts and is consequently more sensitive to change

within these confines. Although some visibility is predicted, from many parts of

the park views would either be blocked or severely impeded by the tree belts

which surround it. Whilst the Proposed Development would potentially be

visible from the open ground away from Carberry Tower, it would appear with

the wider suburban and industrial Lothian landscape and will represent only a

Marginal alteration to the setting of the IGDL of Minor Significance.

13.4.52 Two further IGDL's The Palace of Holyroodhouse (Site 211) and Craigmillar

Castle (Site 220) lie to the north and east of the Proposed Development within

Edinburgh. The boundaries of the Holyroodhouse IGDL largely correspond

with those of the Holyrood Park Scheduled Monument (Site 40) which will be

discussed with it. Arthur's Seat and Salisbury Crags, the landforms which

define the park will not be discussed specifically as they fall beyond the

cultural heritage remit of this assessment. Holyrood Park contains a wide

ranging assemblage of archaeological remains and Listed Buildings, including

Holyrood Abbey, the Palace of Holyroodhouse, St. Anthony’s Chapel, four

prehistoric or early historic hillforts, extensive ridge and furrow remains and

cultivation terraces on the eastern slopes, quarrying and 19th and 20th

century military ranges. Whilst as a whole both the IGDL and the Scheduled

Monument undoubtedly have a High Relative Sensitivity, this is largely due to

its high aesthetic quality as a 'highland' area set in the midst of the Scottish

capital. The park is completely encircled by suburban and industrial


development which needs to be considered as part of its baseline, indeed it

could be argued that the contrast between urban and highland is one of the

principal qualities of the park. Only the eastern part of the park falls within the

ZTV, the western part of the park including the Salisbury Crags, Holyrood

Abbey, the Palace of Holyrood House and St. Anthony's Chapel all fall outwith

the ZTV and consequently No effect on their settings are predicted. Whilst the

Proposed Development would be visible from the eastern slopes, it would

represent an insignificant alteration to a wider urban and suburban landscape,

clearly outwith the setting of the park. Consequently any effect upon the

setting of both the Scheduled Monument (Site 40) and the IGDL (Site 211)

would be of Marginal magnitude, and of Minor Significance.

13.4.53 Craigmillar Castle IGDL (Site 220) lies east of the Proposed Development and

includes the Scheduled remains of the castle (Site 30) which is also Category

‘A’ Listed, along with a Category A Listed dovecot (Site 119) which is

incorporated into the structure of the castle. The Scheduled area extends east

from the castle to include the eastern part of its grounds. Taken together the

designated Craigmillar assets represent a fine example of a late medieval

castle set within its deer park, with remnants of its 16th century garden clearly

visible. Whilst collectively all the designated assets undoubtedly have a High

relative sensitivity, the IGDL is now largely surrounded by the eastern suburbs

of Edinburgh and it is across this modern landscape, clearly outwith the

castle's immediate setting which is confined to the IGDL that any predicted

visibility with the Proposed Development would occur (Plate 1). This means

that whilst the Proposed Development would be visible from the castle roof, it

would represent only a Marginal alteration to the already greatly changed

modern landscape. However given the High sensitivity of the IGDL and the

designated assets within it, any effect on their setting will be of Minor

Significance.

13.4.54 The Battlefield at Pinkie, 1547 is included on the Inventory of Nationally

Important Battlefields in Scotland. The Inventory boundary includes much of

modern day Musselburgh, Wallyford, Inveresk and Pinkie as well as Inveresk

Fields and Falside and Carberry Hills. This vast area encompasses the areas

of the Scottish and English camps, the skirmish on the 9th of September, the

manoeuvrings and ultimately the main engagement, followed by the rout of the

Scots on the 10th of September. While the landscape in which the battle took


place has changed significantly in the years since the battle, through the

development of settlements, enclosure and improvement of fields and

insertion of the railway and the A1 dual carriageway there are still many

features within the landscape which aid in understanding and appreciating the

battle and its outcome. These include St Michael’s Church at Inveresk, Pinkie

Cleugh, Carberry Road and Falside Hill and Castle as well as Inveresk Fields

and Carberry Hill. The relationship of the low ground at Inveresk Fields (now

bisected by the A1) with higher ground at Falside and Carberry Hill is

particularly important for the current understanding of the battle. Views to the

west and southwest along the lines of the rout also have value and add to our

understanding of the events of the battle. The battlefield is judged to be highly

sensitive to change within its boundaries and particularly to changes which

could obscure the relationships noted above. However, changes beyond the

boundaries of battlefield are less likely to impact upon the ability to

understand, appreciate and experience the battle. The battlefield is judged to

be of Medium Relative Sensitivity to changes beyond its boundaries.

13.4.55 The Proposed Development is located some 850 m to the west of the western

boundary of the Battlefield, beyond the area likely to have contained the

Scottish Camp. While the Proposed Development will be visible from Inveresk

Fields (LVIA VP1, Battlefield Memorial Salter’s Road) it will not interfere with

or inhibit the understanding of the relationship between the fields and the

higher ground to the south. Further, while located to the west, and in views in

this direction, the Proposed Development will not impede understanding of the

rout which was in the direction of Dalkieth, along the Esk, along the coast to

Leith and towards Edinburgh and Arthur’s Seat. As such the effect is judged to

be of Low Magnitude, the overall effect would therefore be of Minor

significance and not significant in terms of EIA regulations.


13.4.56 The cultural heritage chapter of the PPiP ES found that there would be no

significant effects upon the setting of heritage assets. IGDL were not

assessed in the cultural heritage chapter, but rather the LVIA chapter. The

assessment presented therein considered IGDLs within 3km of the PPiP

development and found a potential significant effect upon the IGDL at Newton

(Site 216 in this assessment). This assessment has not found significant


effects upon the IGDL at Newton. The PPiP assessment appears to have

been carried out by a landscape architect rather than a heritage specialist and

to only consider visual change in the direction of the Proposed Development,

without consideration of the other site specific factors set out in this chapter.

13.4.57 A comparison of the boiler house roof for the PPiP Development at 20m to

Proposed Development at 41.6m, and of the PPiP consented 65m stack

height with the Proposed Development 75m stack height, has not resulted in

an increase in the overall visibility of the Proposed Development from

designated heritage assets within the assessment area in terms of the ZTV.

That is comparisons between the consented PPiP ZTV and that of the

Proposed Development (Figures 13.1 and 13.2) have found that the

substitution of the consented PPiP scheme with the Proposed Development,

will not result in any further designated assets falling within the ZTV. The

possibility that the Proposed Development will be in view from assets, where

no visibility would have occurred under the consented PPiP development due

to the presence of intervening built and vegetation features cannot be

discounted.

13.4.58 The heights for the roof and the stack at 20m and 65m for the consented PPiP

scenario compared to 41.6 m and 75 m for Proposed Development may mean

that there is a marginal increases in visibility for the Proposed Development.

Thus there could be slightly higher effects upon the setting of a limited number

of heritage assets. Overall this assessment has found that the Proposed

Development will not result in any Significant effects upon the settings of

designated heritage assets. Consequently there is no material increase in

effects on the settings of designated heritage assets when comparing the

consented PPiP scheme with Proposed Development.

Decommissioning Phase


13.4.59 The decommissioning and removal of the Proposed Development itself would

not result in any direct effects assuming there was no need for ground-

breaking works outwith areas impacted during the construction phase.


13.4.60 No Significant indirect effect upon the setting of any designated heritage asset

would result from the decommissioning of the Proposed Development. Indeed,

where non-significant indirect effects have been identified, these would be

reversed following the decommissioning and removal of the development.


13.4.61 The culture heritage chapter for the PPiP ES noted that there would be no

direct effects on heritage assets resulting from the decommissioning, provided

ground works were limited to areas disturbed during the construction phase. It

did not address the potential for indirect effects resulting from

decommissioning. The difference in the effects on heritage assets resulting

from the decommissioning of the PPiP consented development compared with

the Proposed Development is considered to be neutral.

Cumulative Effects


13.4.62 Cumulative Effects, in so far as they relate to cultural heritage, are limited to

indirect effects upon the settings of heritage assets.

13.4.63 Two developments require consideration in terms of potential cumulative

effects:

The Edinburgh Royal Infirmary (ERI), 51 Little France Crescent,

Edinburgh:

o Four applications (11/02/02454/PPP, 14/00078/AMC,

14/01796/AMC and 14/03599/AMC) relate to the proposed

erection of the Royal Hospital for Sick Children at Little France

c.2km west of the Proposed Development. The proposal includes

an energy centre with a 29m stack

Millerhill Marshalling Yard, Dalkeith:

o Three applications (12/00060/DPP, 12/00514/PAC and

12/00837/DPP) relate to the proposed redevelopment for

continued rail use of the marshalling yard immediately east of the



13.4.64 The proposed developments at Millerhill Marshalling Yard are within very

close proximity to the Proposed Development. However, they are markedly

different in character and will be lower in height. This assessment has found

that for many designated assets the Proposed Development will be viewed

either across or in many cases, from within the wide suburban and industrial

landscape which extends eastwards from Edinburgh. The developments at

Millerhill Marshalling Yard taken together with the Proposed Development

would not result in a significant alteration to the current setting of the heritage

assets in the study area and no significant cumulative effects are predicted.

13.4.65 Whilst the proposed energy centre at the ERI will have a stack, at 29m it is

considerably shorter than the Proposed Development and will be set c.2km to

the west. Consequently it is unlikely that the two schemes will appear together

in views from many of the designated assets identified as part of this

assessment. They are likely to both be visible from Craigmillar Castle,

Holyrood IGDL and potentially from some locations within Pinkie Battlefield.

However, given the separation distance between the two developments and

the highly complex urban landscape, the insertion of the Proposed

Development into views which also include the ERI stack will not materially

elevate the level of effect beyond those predicted for the Proposed

Development when it is considered on its own. No significant cumulative

effects are predicted.

Assessment against the PPiP Future Baseline

13.4.66 The PPiP ES assessed cumulative effects based upon the PPiP proposals,

the SNCD and the Borders Railway (referenced in the PPiP cultural heritage

chapter as the Waverley Line Development). The latter two developments

have been taken as part of the baseline in this assessment and so their

presence in the landscape is accounted for. The PPiP ES also found that

there would be no significant cumulative effects upon the setting of heritage

assets.

13.4.67 Given the lower stack and roof height of the PPiP development it is unlikely

that there would be any significant cumulative effects resulting from its

development alongside the ERI and Millerhill Marshalling Yard developments.


13.4.68 Comparison of cumulative effects for the PPiP Future Baseline Scenario and

the Proposed Development indicate that the level of effect between the two is

neutral.


Construction Phase

13.5.1 This assessment has indicated that there three known heritage assets within

the Proposed Development boundaries. These include the site Middlefield

Farmstead (Site 225) and the Innocent Railway (Site 224). Both of these

assets are likely to have been removed during the construction of Millerhill

Marshalling Yard in the 1960s. The yard itself (Site 223) forms the third known

heritage asset. All of these assets are of negligible heritage value. Therefore,

while impacts upon any surviving remains by Proposed Development would

be of High magnitude, these effects would not be significant in terms of EIA

regulations. Given the previous ground disturbance within the Proposed

Development boundaries, the potential for hitherto unknown archaeological

remains to survive is negligible. As such no mitigation for direct effects is

considered necessary.

13.5.2 Indirect effects associated with construction phase will be temporary and will

not be significant in terms of EIA Regulations and as such no mitigation is

proposed.

Operational Phase

13.5.3 No direct effects are predicted during the operational phase and as such no

mitigation is proposed.

13.5.4 Indirect effects include effects upon the settings of designated assets such as

Listed Buildings, SMs, Conservation Areas and Inventoried Gardens and

Designed Landscapes and Battlefields. This chapter has assessed potential

effects upon the settings of designated heritage assets within both a 2km and

a 5km radius of the Proposed Development in detail and found no significant

effects. No mitigation measures, beyond those incorporated in the design, are


available to minimise or offset the predicted effects, neither are they

considered necessary.

Decommissioning Phase

13.5.5 No direct effects are predicted during the decommissioning phase, provided

that ground works are limited to those areas impacted during construction.

Setting effects will cease following decommissioning provided the building and

stack are removed. No mitigation measures are considered necessary.



13.6.1 Direct effects upon any archaeological remains which may be present within

the Proposed Development are possible. However this assessment has found

that the known heritage assets within Proposed Development boundary are of

negligible importance. There is negligible potential for hitherto unknown

remains to survive within the Proposed Development area given previous

ground disturbance on site. As such mitigation is not considered necessary

and no residual effects are predicted

13.6.2 This assessment has identified non-significant effects upon the settings of

designated heritage assets, in the absence of additional mitigation measures

these will be as predicted in sub-section 13.4. All Operational effects upon the

settings of designated assets would be reversed following decommissioning.


13.6.3 The cultural heritage chapter for the PPiP ES noted negligible potential for any

direct effects of EIA significance. It stated that no significant setting effects

had been predicted and as such no mitigation recommended. As such

residual effects, under the PPiP Future Baseline Scenario would be limited to

insignificant effects on the setting of heritage assets during the operational

period. There would be no material difference between residual effects for the

PPIP Future Baseline Scenario and the Proposed Development and the


difference between the effects resulting from the two developments is

considered to be neutral.

Conclusions

13.6.4 This assessment has considered the potential for effects upon heritage assets

resulting from the Proposed Development in relation to a baseline scenario

agreed with MLC in which the: SNCD, Borders Railway and AD Facility are all

assumed to be completed. Direct effects were considered and it was found

that there would be no significant direct effects and that there was negligible

potential for hitherto unknown archaeological remains to survive within the

Proposed Development site. This is consistent with the findings of the PPiP

ES. Indirect effects upon the settings of designated heritage assets including

Listed Buildings, SMs, Historic Gardens and Designed Landscapes,

Inventoried Battlefields and World Heritage Sites were assessed. The

potential for such effects has been assessed for the Proposed Development

and the findings then compared with those for the PPiP Future Baseline

Scenario.

13.6.5 All designated assets within 2km of the Proposed Development have been

assessed along with all Category ‘A’ Listed Buildings, Scheduled Monuments,

Conservation Areas, Inventoried Battlefields and Inventoried Gardens and

Designed Landscapes within 5km. In total 222 designated assets were

assessed.

13.6.6 No Significant direct or indirect effects are predicted and any non-significant

effects on the setting of heritage assets will be confined to the operational

lifespan of the Proposed Development and will cease with its

decommissioning and removal. The Proposed Development would not

materially elevate the effects on the settings of designated assets beyond the

levels predicted for the PPiP Scheme. No mitigation is considered necessary.

13.7 References

Axis 2014, Millerhill Energy Recovery Facility: Environmental Impact Assessment,

Informal Scoping Report, January 2014


Environmental Statement Prepared in Support of the Application for Planning

Permission in Principle (2011)

HMSO. (1979). The Ancient Monuments and Archaeological Areas Act 1979.

HMSO. (1997). Town and Country Planning (Scotland) Act 1997.

HMSO. (1997). Planning (Listed Buildings and Conservation Areas (Scotland)) Act

1997.

HMSO. (2011). Historic Environment (Amendment) (Scotland) Act 2011.

HMSO. (2011). Town and Country Planning (Environmental Impact Assessment)

(Scotland) Regulations 2011.

Historic Scotland. (2010). Managing Change in the Historic Environment: Setting.

Historic Scotland. (2011). SHEP Scottish Historic Environment Policy.

ICOMOS. (1999). The Burra Charter.

ICOMOS. (2005). Xi’an Declaration on the Conservation of the Setting of Heritage

Structures, Sites and Areas.

Lambrick, G. (2008) Setting Standards: a review prepared on behalf of the IFA.

Midlothian Council, 2008, Midlothian Local Plan

Rhodes, M. 1988. The illustrated history of British marshalling yards. passim. esp.

105-13

Scottish Executive. (2002). PAN 45 Renewable Energy Technologies.

Scottish Government. (2011). PAN2/2011 Planning and Archaeology. Available at:

http://www.scotland.gov.uk/Resource/Doc/355385/0120020.pdf [Accessed on

30/01/15].

Scottish Government. (2014). Scottish Planning Policy. Available at:

http://www.scotland.gov.uk/Resource/0045/00453827.pdf [Accessed on 30/01/15].

SESPlan 2003, Policy 1B

Online Sources:

http://data.historic-

scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00301, Accessed 11th

of March 2015

http://data.historic-

scotland.gov.uk/pls/htmldb/f?p=2400:15:0::::GARDEN:GDL00225 Accessed 11th

of March 2015

http://www.scotland.gov.uk/Resource/Doc/355385/0120020.pdf

http://www.scotland.gov.uk/Resource/0045/00453827.pdf






14.0 SOCIO-ECONOMIC EFFECTS

14.1 Introduction

14.1.1 This Chapter of the ES assesses the socio-economic effects arising from the

Proposed Development during its construction and operation. The

assessment considers the effects at the local level (i.e. Dalkeith Ward),

authority level (i.e. Edinburgh and Midlothian) and Scotland as a whole.

14.1.2 A key issue of this assessment is to understand the existing socio-economic

context and to consider whether the Proposed Development would result in

any beneficial or adverse socio-economic effects on identified receptors within

the local impact area. The significance of these is judged under a framework

outlined in the following sub-section.

14.1.3 This Chapter describes the methods used to assess the impacts, the baseline

conditions within Dalkeith, Edinburgh, Midlothian and Scotland; the potential

effects of the proposed development; any mitigation measures required to

prevent, reduce, or offset the impacts and the residual effects.


14.1.4 An appraisal of planning policy and guidance associated with the proposed

development is presented in the Planning Statement contained within Part 3 of

the Planning Application Document. For the purposes of this Chapter, a

summary of the most relevant socio-economic policies are identified below.

14.1.5 The Scottish Government published their Economic Strategy in September

2011. The strategy gives priority to accelerating economic recovery and seeks

to focus actions upon six strategic priorities including: a supportive business

environment; transition to a low carbon economy; learning, skills and well-

being; infrastructure development and place; effective government; and

equality. These priorities are intended to drive sustainable economic growth

and develop a more resilient and adaptable economy.

14.1.6 The National Performance Framework (NPF) December 2011 sets out a

range of high level targets and objectives through which Scotland’s


performance is measured. It also includes 16 national outcomes and 50

national indicators. The Proposed Development would contribute to the

achievement of the NPF by assisting in the achievement of the:

“Greener” Strategic Objective;

“We value and enjoy our built and natural environment and protect it and

enhance it for future generations” and: “We reduce the local and global

environmental impact of our consumption and production” National

Outcomes; and

“Reduce Scotland’s Carbon Footprint” and “Reduce Waste Generated”

National Indicators.

14.1.7 The National Planning Framework (NPF) and the Scottish Planning Policy

(SPP) set the context for development planning and provide the spatial

development for Scotland. The latest versions of the NPF (i.e. NPF3) and SPP

were prepared and published concurrently (June 2014). Consequently, they

share a single vision which includes living in a growing, low carbon economy

with progressively narrowing disparities in wellbeing and opportunity.

14.1.8 The NPF3 identifies that the SES Plan area is projected to have the second

largest rate of growth of the four Strategic Development Plan Areas (SDPAs),

a 20% increase in population and 32% increase in households between 2010

and 2035. A planned approach is required to ensure the development needs

are met, whilst taking into account existing and future infrastructure capacity.

14.1.9 The Midlothian Local Plan identifies a range of aims and objectives, of

relevance to this Chapter including; providing positively for development which

secures long-term social, economic and environmental benefits.

14.2 Methodology

14.2.1 The assessment of socio-economic effects has been based on a widely used

and accepted methodology which considers the sensitivity of the socio-

economic receptors and the magnitude of the impact arising from the

proposed development on the identified receptors. The significance of effect is

then determined by considering both the sensitivity and the magnitude.


14.2.2 The assessment considered the potential for the Proposed Development to

affect local socio-economic conditions within the impact area during both the

construction phase (potential temporary effects), and through its operation

phase (potential permanent effects) once the development is complete and

operational.

14.2.3 It has been carried out by undertaking a desk based study and reviewing key

statistical information. The background information employs key sources of

data including the: 200123 and 2011 Census24, NOMIS from the Office of

National Statistics (ONS)25, Scottish National Statistics (SNS)26, the Scottish

Government27 and Midlothian Council28 websites.

14.2.4 The proposed development has the potential to effect local socio-economic

conditions through five main forms of socio-economic impacts:

Direct economic impacts: jobs (measured as full time equivalents) and

wealth (measured as gross value added or GVA29) that are wholly or

largely related to the construction and operation of the proposed

development and generated in the impact area.

Indirect economic impacts: full-time equivalent jobs and gross value

added generated in the economy of the impact area via the supply chain

of goods and services which support the direct activities.

Induced economic impacts: full-time equivalent jobs and gross value

added created by direct and indirect employees’ spending in the impact

area.

Wider socio-economic impacts: impacts in both the construction and

operational phases, including wider construction worker effects in the

local area via expenditure, as well as by-products from the process and

fiscal benefits to Midlothian Council via the retention of business rates.

14.2.5 A significance of effect matrix for the socio-economic assessment has been

developed based upon the characteristics of the impact (magnitude and

23

http://www.nrscotland.gov.uk/statistics-and-data/census/2001-census 24

http://www.scotlandscensus.gov.uk/ 25

http://www.ons.gov.uk/ons/index.html 26

http://www.sns.gov.uk/ 27

http://www.gov.scot/Topics/Statistics 28

http://www.midlothian.gov.uk/info/695/about_us/1309/open_data 29 Gross value added or GVA is a standard measure of wealth creation used in economic impact assessments.


nature) and the sensitivity of the receptor. This is summarised in the following

tables.

14.2.6 The framework for assessing the sensitivity of the receptor is outlined in Table

14.1 below. The assessment takes account of the importance attached to the

receptor (or indicator) in policy, together with professional judgement relating

to the scale of socio-economic challenges (drawing on analysis within the

socio-economic baseline).

Table 14.1: Framework for Assessing Sensitivity of the Receptor

Sensitivity of receptor

Criteria Example Criteria

Very High

Receptor is accorded a very high priority in local and

regional development and regeneration policy.

Identification as a highest ranking thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of severe socio-economic challenges, under-performance or vulnerability i.e. patterns of deprivation, employment and wealth generation, employment forecasts, exposure to socio-economic threats.

High

Receptor is accorded a high priority in local and regional economic development and

regeneration policy.

Identification as a key thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of major socio-economic challenges, under-performance or vulnerability i.e. patterns of deprivation, employment and wealth generation, employment forecasts, exposure to socio-economic threats.

Medium

Receptor is accorded a medium priority in local and

regional economic development and


No identification as a key thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of significant socio-economic challenges, under-performance or vulnerability.

Low

Receptor is accorded a low priority in local and regional economic development and


No identification as a key thematic or spatial priority (i.e. as a result of economic potential and / or need). Evidence of economic prosperity, buoyancy and resilience (i.e. low levels of deprivation, relatively high employment and wealth generation rates, relatively strong employment forecasts).

Negligible

Receptor is accorded no particular priority in local and

regional economic development and


No identification as policy priority (i.e. as a result of economic potential and/or need). Evidence of good overall economic performance and long term prospects. No particular economic weaknesses or challenges.

14.2.7 Socio-economic impact magnitude is determined by consideration of the

predicted deviation from baseline conditions. The criteria used for the

assessment of magnitude of socio-economic impact (both positive and

negative) are shown in Table 14.2 over the page. An element of professional

judgement has been used in determining the magnitude of impacts.


Table 14.2: Framework for Assessing Magnitude of Effects

Magnitude of Impact (Positive or Adverse)

Description

High Proposals would cause a large change – judged beneficial or adverse – to baseline environmental conditions in terms of absolute and/or percentage change.

Medium Proposals would cause a moderate change – judged as beneficial or adverse – to existing environmental conditions in terms of absolute and/or percentage change.

Low Proposals would cause a slight change – judged as beneficial or adverse – to existing environmental conditions in terms of absolute and/or percentage change.

Negligible No discernible change in baseline environmental conditions

No change No loss or alteration of characteristics, features or elements; no observable impact in either direction.

14.2.8 Magnitude and sensitivity are combined as shown in Table 14.3 below to

determine the significance of the impacts.

Table 14.3: Framework for Assessing Significance

Sensitivity of Receptor

Magnitude of Impact (Positive or Adverse)

No Change Negligible Low Medium High

Negligible Negligible Negligible Negligible Minor Minor

Low Negligible Negligible Minor Minor Moderate

Medium Negligible Negligible Minor Moderate Moderate

High Negligible Minor Moderate Moderate Major

Very high Negligible Minor Moderate Major Major

14.2.9 Using this scale, effects identified as major or moderate significance are

regards as being significant in EIA terms. Effect of minor or lesser significance

are also identified, but regarded as not significant in EIA terms.

14.2.10 During the preparation of this Chapter it has not been necessary to consult

with any technical consultees. Furthermore, during the preparation of this

Chapter no limitations to carrying out the survey / assessment have been

encountered.


14.3 Baseline

14.3.1 This sub-section provides a summary of the baseline information that has

formed the basis of the socio-economic assessment. In addition, it also

identifies the future baseline scenario in the event that the development which

benefits from PPiP were to be developed at the site.


Baseline Conditions

14.3.2 The Local Government Boundary Commission for Scotland is responsible for

reviewing Local Government boundaries in Scotland. The Commission have

undertaken a number of reviews, however those of most relevance to this

assessment are:

The ‘Third Statutory Review’ which took place between 1996 and 1999

and came into force 1999. Figure 14.1 illustrates the geographical extent

of the Dalkeith / Newton Ward.

The ‘Fourth Statutory Review’ which took place between 2004 and 2006

and came into force 2007. Figure 14.2 illustrates the geographical extent

of the Dalkeith Ward.

14.3.3 As a result of amendments to ward boundaries in 2007, it is not possible to

make a direct comparison between the 2001 and 2011 Census (at a ward

level). However, direct comparison between the 2011 Census and subsequent

mid-year estimates can be compared alongside data for Edinburgh, Midlothian

and Scotland as a whole.

14.3.4 The Application Site is located in the Dalkeith Ward which forms part of the

Midlothian Local Authority Area. The Scottish National Statistics Area Profile

Report30 identifies that the Dalkeith ward was home to circa 11,730 residents

in 2011. Tables 14.4 – 14.6 over the page provide a breakdown of the

residential and working age populations.

30

http://www.sns.gov.uk/Reports/AreaProfile.aspx


Table 14.4: Resident Population

Area 2001 2011 2013

Absolute Change

(2001 – 2011)

Change

(%)

Change (%) p.a.

Dalkeith - 11,730 - - - -

Midlothian 80,941 82,370 84,700 1,429 1.73 0.17

Edinburgh 448,624 476,600 487,500 27,976 5.86 0.58

Scotland 5,062,011 5,254,800 5,327,700 192,789 3.66 0.36

Source: 2001, 2011 Census and NOMIS Local Authority Profile (ONS Mid-year population estimates 2013)

Table 14.5: Economic Activity (All Persons Aged 16 – 74)

Area 2001 2011 2013

Absolute Change

(2001 – 2011)

% Change

% Change

p.a.

Dalkeith - 8,707 - - - -

Midlothian 58,789 61,511 62,227 2,722 4.4 0.44

Edinburgh 342,431 376,018 377,945 33,587 8.9 0.89

Scotland 3,731,079 3,970,530 3,991,395 239,451 6.0 0.60

Source: Census 2001 and 2011 and NOMIS Local Authority Profile (ONS Mid-year population estimates 2013)

Table 14.6: All Persons 16 – 74 (as a Share of Total Population)

Area 2001 (%) 2011 (%) 2013 (%)

Dalkeith - 74.2 -

Midlothian 72.6 74.6 73.4

Edinburgh 76.3 77.6 77.5

Scotland 73.7 75.5 74.9

Source: Table 14.4 and 14.5)

14.3.5 As illustrated by the tables above, working age residents represent around

74.2% of the total residents in Dalkeith. The proportion of working age

residents is similar to Midlothian (74.6%) but below the national level (75.5%).

Whilst a comparison over time cannot be made for the Dalkeith ward, it is

clear that the general trends illustrate an increasing working age population

between 2001 and 2013, but a slight decrease thereafter.


Economic Activity and Inactivity

14.3.6 Economic activity and inactivity data is provided by the SNS Annual

Population Survey31, and this is summarised in Tables 14.7, 14.8 and 14.9

below and over the page. The tables illustrate that for Midlothian the number

of ‘economically active but unemployed’ and ‘long-term unemployed’

individuals are below the national level. However, unemployed 16 – 24 year

olds and those who have never worked is above the national average. In

respect of Edinburgh the number of ‘economically active but unemployed’ and

‘long-term unemployed’ individuals is the same as the national level. However,

unemployed 16 – 24 year olds and those who have never worked is below the

national average. Finally, in terms of earnings in all instances Midlothian is

below and Edinburgh is above the national average.

Table 14.7: Economic Activity and Inactivity (2013)

Area Working

Age Population

%

Economically Active

Economically Inactive

Unemployed Other

Dalkeith 8,707 64.9 35.1 4.9 1.0

Midlothian 61,511 71.1 28.9 4.4 1.7

Edinburgh 376,018 69.0 31.0 3.9 1.9

Scotland 3,970,530 69.0 31.0 4.8 1.9

Source: NOMIS Scotland and Local Authority Profile (ONS mid-year population estimates 2013)

Table 14.8: Economically Active: Unemployment (2011)

Area Economically active:

Unemployed

Unemployed %

Age 16 to 24

Age 50 to 74

Never worked

Last worked in 2010 to 2011

Last worked in 2005 to 2009

Last worked before 2005

Dalkeith 431 36.4 14.8 16.8 17.4 24.2 41.6

Midlothian 2,700 35.6 15.6 14.8 49.7 27.3 8.2

Edinburgh 14,517 26.8 17.3 12.7 50.7 27.5 9.1

Scotland 18,414 30.2 18.4 13.9 47.4 28.0 10.7

Source: SNS Area Profiles Census 2011

31

http://www.scotland.gov.uk/Topics/Statistics/Browse/Labour-Market/Publications


Table 14.9: Earnings by Residence and Workplace (2014)

Area

Residence Workplace

Gross Weekly Pay Hourly Pay

Gross Weekly Pay Hourly Pay

Midlothian (£) 475.5 12.18 479.8 12.45

Edinburgh (£) 562.8 14.49 569.8 14.83

Scotland (£) 518.2 13.17 519.4 13.23

Source: NOMIS Local Authority Profile Midlothian and Scotland – ONS annual survey of hours and earnings 2014)

Unemployment and Worklessness

14.3.7 Job seekers allowance (JSA) claimants is one key measure of unemployment.

It enables analysis to be undertaken at a low spatial scale and at the time of

preparing this assessment the most contemporary data was from January

2015. The data contained within Table 14.10, illustrates that the percentage of

working age population seeking JSA in Midlothian and Edinburgh was 1.9%

which is lower than the national level of 3.1%.

Table 14.10: Total Jobseekers Allowance Claimants (January 2015)

Area Total Claimants %

Midlothian 1,027 1.9

Edinburgh 6,366 1.9

Scotland 84,304* 3.1*

Source: ONS Nomis, Job Seekers Allowance Claimants, December 2015 (Scotland JSA unadjusted figure)

Skills and Occupations

14.3.8 The qualification breakdown data contained within Table 14.11, over the page,

suggests that Midlothian has a lower than average proportion of residents with

NVQ levels 1-4+ and a higher than national average of residents with no

qualifications. This is the exact opposite for Edinburgh.


Table 14.11: Qualifications Breakdown (2011)

No qualifications NVQ1-2 NVQ 3 NVQ 4+ Other

Qualifications

Midlothian 12.8 71.2 52.9 31.4 4.6

Edinburgh 5.3 87.7 73.4 54.6 3.7

Scotland 10.3 73.7 69.3 39.4 6.2

Source: Census 2011 and NOMIS Local Authority Profile – ONS annual population survey % is for 16 - 64 years)

14.3.9 Just over 40% of all employed working age residents in Midlothian are

employed in Standard Occupational Classification (SOC) Code Groups 1-3.

This is slightly below the national average of 41.6%. In terms of SOC Groups

4 – 5 and 6 – 7 Midlothian is above the national average, 23.1 and 19.7 when

compared to 22.2 and 18.3 respectively. However, whilst Midlothian is slightly

below the national average for SOC Groups 8 – 9 at 17.1 when compared to

17.8, it is clear that Midlothian has a higher than average percentage of

elementary occupations. In respect of Edinburgh SOC Groups 1-3 are

significantly higher than the national average, where are all other SOC Groups

are below national average.

Table 14.12: Employment by Occupational (Oct 2013 – Sept 2014)

Occupations (SOC) Midlothian

(%) Edinburgh

(%)

Scotland

(%)

SOC 2010 Major Group 1 - 3 40.1 53.5 41.6

1. Managers, directors and senior officials 8.4 9.2 8.7

2. Professional occupations 17.6 30.1 19.7

3. Associate professional and technical occupations 13.7 14.2 13.0

SOC 2010 Major Group 4 - 5 23.1 19.5 22.2

4. Administrative and secretarial occupations 9.0 12.8 10.6

5. Skilled trades occupations 13.9 6.7 11.5

SOC 2010 Major Group 6 - 7 19.7 14.7 18.3

6. Caring, leisure and other service occupations 11.7 6.5 9.4

7. Sales and customer service occupations 7.8 8.1 8.8

SOC 2010 Major Group 8 - 9 17.1 12.3 17.8

8. Process plant and machine operatives 3.9 3.4 6.3

9. Elementary occupations 13.0 8.9 11.4

Source: NOMIS Local Authority Profile (ONS annual population survey % is for 16+ years)


Travel to Work

14.3.10 Table 14.13 illustrates that 64% of people living in Midlothian travel to work by

car. This is slightly above the national average of 62.5%. In terms of

Edinburgh, 40% of people travel by car. Whilst travelling by train, walking and

working from home is below the national average for Midlothian it is clear that

traveling to work by bus is significantly higher at 18.2% when compared to the

national average of 10%. Figures for Edinburgh illustrate above average bus,

on foot and other travel.

Table 14.13: Travel to Work

Travel to Work Midlothian Edinburgh Scotland

All persons aged 16 to 74 who were in employment (excluding full-time students)

39,423 220,673 2,400,925

Car % (including passengers, car pools and taxis) 63.9 40.3 62.4

Train % 0.4 1.9 3.7

Bus % 18.2 25.6 10.0

On Foot % 6.4 16.3 9.9

Other % 2.2 5.5 3.1

Works mainly at or from home % 9.0 10.3 10.8

Source: NOMIS Local Authority Profile

Average House Prices

14.3.11 The Register of Scotland32 Quarterly House Price Statistical Report (February

2015) provides average house price data at a national and local authority

area. The latest data was gathered between October and December 2014 for

the four main housing tenures. Table 14.14 over the page provides data for

Midlothian, Edinburgh and Scotland.

32

https://www.ros.gov.uk/home


Table 14.14 Average House Price Data (Oct – Dec 2014)

Tenure Midlothian (£) Edinburgh (£) Scotland (£)

Detached 273,227 394,506 241,493

Semi-Dethatched 161,459 271,141 156,494

Terraced 139,443 262,326 133,725

Flatted 128,065 189,827 126,418

Source: Register of Scotland

Scottish Index of Multiple Deprivation

14.3.12 The most contemporary Scottish Index of Multiple Deprivation (SIMD) was

published in December 2012 and identifies small area concentrations of

multiple deprivation across Scotland.

14.3.13 The SIMD ranks the small areas, known as ‘datazones’, from most deprived

(Rank 1) to least deprived (Rank 6,505). This is calculated from the topic

based domains which are weighted 28% (Employment and Income), 14%

(Heath and Education), 9% (Access), 5% (Crime) and 2% (Housing).

14.3.14 The Application Site is located within the Midlothian Shawfair datazone

(reference: S01004228). As illustrated in Table 14.15 below, the overall SIMD

Score is 3,494 which illustrates that this datazone is slightly less deprived then

average.

Table 14.15: Scottish Index of Multiple Deprivation

Domains Midlothian Shawfair (S01004228) Rank

%

Overall SIMD Score 3,494 53.7

Income 4,013 61.7

Employment 3,544 54.4

Health 4,467 68.6

Education, skills and Training 4,054 62.3

Housing 3,404 52.3

Crime 2,149 33.0

Geographical Access 703 10.8

Source: Scottish Index of Multiple Deprivation (SIMD) 2012



14.3.15 The Environmental Statement prepared on support of the PPiP development

considered the socio-economic setting of the region in relation to the

population, employment, education, skills and deprivation. It focused more

upon the social aspects of the proposed development rather than the

economic aspects which form the basis of this assessment.

14.3.16 The socio-economic assessment carried out in support of the PPiP

development identified that, if developed, once operational the scheme would

on the whole give rise to generally beneficial effects in relation to the

assessment parameters, these are summarised in Table 14.16 below.

Table 14.16: PPiP Socio-Economic Effects

Topic Construction Operation

Accessibility and Recreation Temporary Negligible Permanent Negligible

Construction Vehicles Temporary Minor

Adverse Permanent Negligible

Employment Opportunities Temporary Moderate

Beneficial Permanent

Negligible Beneficial

Impact upon Local Businesses Temporary Minor

Adverse Permanent Minor

Adverse

Indirect Employment Temporary Minor

Beneficial Permanent Minor

Beneficial

Impact on Tourism Temporary Minor

Adverse Permanent Minor

Beneficial

The development will ensure that Edinburgh and Midlothian Councils are able to meeting the National and International future waste targets.

- Permanent Moderate

/ Major Beneficial

Source: PPiP ES Socio-Economic Chapter: Table 12.19

14.3.17 Thus in the event that the PPiP development were to be developed it would on

the whole give rise to environmental effects that range from Minor Adverse to

Moderate / Minor Beneficial in their significance but overall can be considered

beneficial.



Construction Phase

14.4.1 The proposed date for the commencement of construction on the Application

Site is September 2015. It is anticipated that the construction programme

would be structured into six key activities (site clearance / establishment,

earthworks, structure, mechanical fit-out, electrical fit-out and ‘cold’

commissioning) lasting circa 28 months. A seventh activity ‘hot’

commissioning would be undertaken by operational staff and as such, this is

excluded from the assessment of temporary construction impacts.

14.4.2 Current construction employment estimates consider the potential on-site

construction impacts of the proposed development over a circa 28 month

construction period. The scale of employment has been derived by the wider

construction team, on the range and types of construction activities which are

anticipated to be required on-site, to deliver the construction and commission

of the proposed development. This was informed by the consultant team’s

knowledge and experience from other energy facilities.

14.4.3 The proposed development has the potential to support, on average around

180 to 200 temporary on-site construction jobs per annum. However, peak on-

site employment is anticipated to be during the fit out and installation phase,

when the construction of the building has been completed, and the internal

fitting out of the facility is underway. During this period circa 300 jobs would be

supported on-site.

14.4.4 The key activity stages in the construction process were discussed with

technical advisors within the project team. Key tier 1 sub-contractors have

been identified, including: CNIM-Lagan (Engineering Procurement and

Construction (EPC) Contractor), Lagan (Civil Contractor) and CNIM

(Technology Provider).

14.4.5 It would be the sole responsibility of these contractors to deliver the project.

However, it is likely that the appointed EPC Contractor would develop a series

of sub-contracting work packages which would go out to tender. This is

anticipated to include further civil sub-contracting opportunities / work


packages such as ground works, steel work and block work etc. Given the

scale of the local construction business base in Midlothian and Edinburgh it is

assumed that many of these identified trades, many quite labour intensive,

could be fulfilled by local contractors from within the local study area.

14.4.6 The local area has a significant level of construction related businesses and

relevant skills base33. There is also demand within the labour market for this

type of employment opportunity based upon the JSA claimants and above

average number of SCO5 ‘Skilled Trades’ and SOC9 ‘Elementary

Occupations’ within Midlothian. It is estimated that around 25% of the overall

construction employment could be local circa 50 FTE).

14.4.7 It is also assumed that the contractors and some of the workforce for

specialised elements of the project (particularly the technical processes) could

come from outside of the local study area. These are most likely be

employees / contractors from national and international specialist contractors

which would be required throughout the construction period, this is an

important consideration.

14.4.8 While challenging, it is useful to get a sense of the potential level of

expenditure which could occur during the construction phase. It is estimated

that the non-local temporary construction workers could spend £170,000 per

annum on food and drink34. Whilst, those non-local workers who would require

overnight accommodation could spend £135,000 per annum35. The underlying

expenditure assumptions are on the conservative side. As a result, the total

injection of expenditure into the local economy, over the duration of the

construction phase, could be greater than the estimated £305,000 per annum.

14.4.9 In light of these estimates, there is clearly scope for some local businesses to

benefit from the short-term opportunities during the construction of the

33

Midlothian Economic Development Framework – Construction Sector Action Plan 2008 34

Evidence from YouGov in 2005 found that on average workers spent £6 per day on food and drink alone. This seems relatively high, so a daily expenditure of £5 per worker as applied. The construction phases leads to, on average 180 workers on-site per day. If local workers are discounted (circa 50), 130 workers could potential be buying food and drink locally, that otherwise would not have done so. Based on a 5 day working week and 52 weeks per year, this equates to a total expenditure of £170,000 per annum. 35

It is assumed that 10% of non-local workers may require overnight accommodation (on average 13 workers per day). Based on a 4 day requirement, an average cost of £50 per night. This equates to expenditure of circa £135,000 per annum.


proposed development. In particular, those within the accommodation and

hospitality sectors.

Operational Phase

14.4.10 This sub-section focuses on the economic benefits of the Proposed

Development once it has become operational. It considers the direct, indirect

and induced employment benefits, as well as quantifies the annual Gross

Value Added (GVA) benefits of the proposal.

Direct employment refers to the workers employed directly at the

Proposed Development;

Indirect employment refers to jobs supported in the supply chain within

the Midlothian and Edinburgh area as a result of the expenditure of the

operator on bought goods and services;

Induced employment refers to jobs supported in the Midlothian and

Edinburgh area through the deployment of additional wage income of

the direct and indirect workers.

GVA is defined as the value of goods and services by an area, sector or

producer minus the cost of the raw materials and other inputs used to

produce them. GVA is mainly composed of the income made by

employees (earnings) and the business (profits / surplus) as a result of

production.

Direct Economic Impacts

14.4.11 The plant would provide permanent employment for up to 39 people, working

in shifts to maintain 24-hour / 7-day per week cover. The majority of

employees would be skilled operatives (electricians / fitters / crane operatives)

or technical engineers (control and plant).

14.4.12 It is anticipated that the proposal scheme would be operated by a total daily

staffing level of the order of 30 staff, broken down into a number of shifts.

Peak day time staffing levels on site are predicted to occur during the early

afternoon shift change period (13:00-14:00) when up to 22 staff could be

present on site. The EfW facility could be expected to operate a three shift

system (5 staff per shift) to support 24 hour operation of the plant, with the MT


facility operating a two shift system (1 staff), reflecting the 05:00 – 23:00

operating hours of this element of the Proposed Development. Up to 5 office /

management staff could be expected to work a more traditional 08:00 – 17:00

weekday pattern.

14.4.13 The proposed development would support a range of different occupations

across these two key elements. However, taking the proposed development

as a whole, the majority of jobs would be skilled trades’ occupations (SOC5).

These jobs would be mainly technician roles for the facility. However the

majority of jobs would be process plant or machine operatives (SOC8) or

elementary roles (SOC9) within the facility.

14.4.14 In light of the majority of jobs requiring lower-level skills, and given the

demand for lower-skilled roles across the local study area (identified in the

baseline analysis), it is assumed that the proposed development would attract

and recruit staff for the middle-level and low-skilled roles from within local

labour market, as well as neighbouring districts. While some experience in

similar roles would be beneficial (in waste or other relevant sectors), with

appropriate training local people could fulfil these roles. Given that a number

of actions could also be implemented to maximise local employment impacts

(see mitigation section), it is anticipated that leakage of job opportunities

outside of the district would be limited.

14.4.15 Given the nature of the more specialised and higher skilled managerial /

engineering roles at the proposed development, it is anticipated that these

roles would be filled by experienced individuals who have experience working

within a waste or energy role. Whilst these roles could potentially be filled by a

resident from within the local study area, this cannot be guaranteed at this

stage, as a recruitment strategy would be developed by the operator.

However, for the purposes of this assessment it has been assumed that the

manager and deputy manager would reside within Midlothian or Edinburgh

(either being an existing resident, or a new resident who moves to the area as

a result of the recruitment process).

14.4.16 In addition to the above, FCC Environment operate its own apprenticeship

programme and the Centre will create up to 3 apprenticeships on an on-going

basis and is committed to making a positive contribution towards the


sustainable economic growth of the area. The aspiration is to provide

employment and modern apprenticeships to people within the region through

the construction and operation of the RERC.

14.4.17 Table 14.17, over the page, highlights the potential roles at the proposed

development and potential average annual FTE salaries. The salary ranges

have been estimated by the project team as appropriate to the role’s skill

requirements in this area of the UK and based on experience with other

projects. It is estimated that the total gross salaries (i.e. employment income)

paid to staff would be in the region of £1M to £1.1M per annum. The analysis

of the potential induced economic impacts takes into consideration the

impacts of this employment income being spent in the local economy by

proposed development employees.

Table 14.17 Potential Average Annual Gross Employment Income

Standard Occupational Categories Total No of FTE jobs

Average FTE wage

Average Annual Gross Employment Income (£)

SOC1/2: Managerial / Professional Occupations

1 £70,000 £70,000

SOC3: Associate Professional and Technical Occupations

3 £40,000 £120,000

SOC5: Skilled Trades Occupations 11 £35,000 £385,000

SOC8: Process; Plant and Machine Operatives

10 £25,000 £250,000

SOC9: Elementary Occupations 14 £17,000 £238,000

Total 39 - 1,063,000

Note: Average annual gross full-time employment income is estimated by using salary estimates provided by the applicant, and employment estimates provided

by the technical consultant team’s previous experience.

Indirect and Induced Economic Impacts

14.4.18 This sub-section quantifies the level of direct jobs (i.e. jobs in the supply chain

supported by expenditure of the Proposed Development on bought goods and

services), as well as induced jobs supported locally (i.e. jobs in the local area

supported through the deployment of additional wage income of direct and

indirect workers). For the purposes of this assessment, impacts have been

considered at the local authority and national level.


Indirect Jobs – Impact from Bought in Goods and Services

14.4.19 The business planning process for the proposed development has indicated

that annual expenditure on bought in goods and services to support the

operation could potentially be in the region of £2.7M per annum. Whilst the

business planning process is ongoing, these costs have been derived from

sector knowledge and understanding of the requirements of operating such a

facility (i.e. purchasing key inputs, raw materials, to support the process);

maintaining the sophisticated mechanical and electronic equipment (both

operational and monitoring equipment); as well as other costs associated with

operating the proposed development.

14.4.20 The majority of this expenditure is expected to flow to businesses and service

providers outside of Midlothian and Edinburgh, predominantly national and

international providers. Notwithstanding this, the potential exists for the local

economy to adapt to the proposal and for new supply companies to establish

locally or local companies to seek to diversify the range of goods and services

they offer. Table 14.18, over the page, demonstrates it is judged that circa

£0.8M (circa 30%) of the centre’s annual expenditure on bought in goods and

services could potentially be spent within Midlothian and Edinburgh.

14.4.21 The following table outlines some of the main goods and services which could

be purchased from within Midlothian and Edinburgh. Annual contract costs

have been estimated for services such as:

Security (based on a CCTV and call out contract basis);

Site landscaping and maintenance;

Supplies of office materials and other services;

Office and communal area cleaning;

Consumables for the centre (i.e. water treatment, oils);

Water supply; and

Haulage of by-products off-site (i.e. bottom ash used as an aggregate

for the construction sector, recycled metals, reject material and APC

residues) which can be transported off site regularly by a locally

contracted haulier. The total amount of haulage of material off-site is

estimated at around 57,300 tonnes per annum.


14.4.22 It is estimated that this level of expenditure could potentially support 7.1 (i.e.

7) full-time within the Midlothian and Edinburgh economy.

Table 14.18: Potential Local Expenditure on Bought in Goods and Services

Expenditure Item Annual Contract Value (£)

FTE Jobs Supported

Site landscaping £10,000 0.25

Office supplies £7,000 0.01

Office and communal area cleaning £9,500 0.5

Facility consumables £70,000 0.09

Haulage of by-products £355,130 3.78

Water supply £270,000 1.03

Security £75,000 1.5

Total 796,630 7.16

Note: This table does not cover all expenditure as information is not available. This table summarises potential local expenditure

from the proposed development.

Direct and Indirect Employee Salary Impacts – Induced Benefits

14.4.23 The induced employment effects for Midlothian and Edinburgh, as a result of

the direct and indirect employment arising from the proposed development,

have also been estimated. Induced employment effects are those jobs

supported in the area via the deployment of income from those employed

directly and indirectly by the Midlothian RERC development.

14.4.24 The estimates are based on the assumption that all of the directly employed

workers would reside within the area. For those workers indirectly employed,

via expenditure on contracted services (i.e. cleaning, maintenance, security

and landscaping), it is also considered that these roles would most likely by

filled by workers or contractors from within the area, given the nature of the

roles.

14.4.25 Estimates for total gross income for direct employees were determined using

experience from other projects. For indirect employees, the Annual Survey of

Hours and Earnings (ASHE)36 was used. In total, it is estimated that, directly

36

http://www.ons.gov.uk/ons/rel/ashe/annual-survey-of-hours-and-earnings/index.html


and indirectly, the proposed development would support circa £1.4M of gross

employment income per annum in the local economy.

14.4.26 Net incomes were estimated by taking account of workers potential income

tax and employee national insurance contributions. Taking these into account,

total annual net employment income is expected to be £0.9M per annum. It is

estimated that around half (i.e. £0.45M) of net income would be spent within

the local study area. It is estimated that this level of expenditure could

potentially support circa 4 FTE induced jobs in the area.

Summary of Direct, Indirect and Induced Economic Impacts

14.4.27 The following table provides a summary of the potential total employment

impacts (including direct, indirect, and induced employment) of the proposed

development, as well as associated annual gross value added impacts.

14.4.28 It is estimated that the proposed development could support 50 FTE direct,

indirect and induced jobs within the area. This has the potential to lead to an

annual gross value added impact of circa £3.8M per annum.

Table 14.19: Summary of Total Economic Impacts (Employment and GVA)

Impacts FTE Jobs GVA (£m) Per Annum

Direct Impacts 39 3.3

Indirect Impacts 7 0.4

Induced Impacts 4 0.1

Total Economic Impacts 50 3.8

Note: Annual GVA impacts estimates are derived from using best-fit industries and their associated GVA per FTE worker estimates from within the ONS

Annual Business Survey, 2011. (See Appendix 14-1 for GVA Details)

Wider Socio-Economic Impacts

14.4.29 The above assessment calculates potential annual gross value added impacts

using national gross value added per full-time equivalent benchmarks for a

sub-sector of the waste industry.

14.4.30 The proposed development could also deliver some wider socio-economic

impacts.


Non-domestic (Business) Rate Retention

14.4.31 The electrical generation capacity of the Proposed Development would be

13.45MWe. A small proportion 2.36MWe of this would be used to power the

Proposed Development itself, with the majority 11.09MWe exported to the

local electricity grid. Based upon maximum electricity output the Proposed


sufficient to meet the domestic electricity needs for over 26,000 homes.

14.4.32 The proposed development would be liable for non-domestic (business) rates

which would be paid to Midlothian Council. Following a government review,

there has been a shift in policy regarding business rate retention for local

authorities who support the development of renewable energy projects.

14.4.33 The biodegradable (or biomass) content of the waste is recognised as a

renewable source of energy. Thus around 50-55% of the energy produced by

the ERC, whether it would heat or electricity, would be classes as renewable

energy. Depending upon a range of factors, the proportion of renewable

energy generation could be subject to business rate relief but this would need

to be determined through a detailed assessment.

14.4.34 The Proposed Development would generate electricity, a proportion of which

would be classified as renewable. Therefore Midlothian Council now have the

ability to retain the business rates associated with these types of energy

generating projects. Business rates for other facilities have been researched

in various locations and sizes. Whilst the nature of the proposed development

could be different to some of those reviewed, the principle of the valuation

process used would be the same (i.e. based on energy generation output).

The review highlighted a range of rates at circa £44,000 per MW to £53,000

per MW.

Taking the conservative, lower position of £44,000 per MW and with

energy output of 11.09MW, this proposed project has the potential to

deliver a business rate contribution to Midlothian Council of circa

£487,960 per annum.

However, based on the percentage of renewable energy generated,

taking the conservative, 50% figure then the proposed project has the

potential to deliver a business rate contribution of circa £243,980.


District Heating and Heat Off-Take

14.4.35 Through the combustion of SRF the Proposed Development could generate

up to 50MW of heat energy in the form of steam. A proportion of this steam

would be used to generate electricity with the balance exported as heat (either

steam or more likely hot water). A number of potential users of the hot water

have been identified in the surrounding area, including the SNCD.

Recyclable and By-products

14.4.36 Waste processing at the RERC development would also lead to outputs or by

products which could deliver economic value in other ways. These include:

Recyclables: The MT plant would recover ferrous and non-ferrous

material for recycling within a suitably licenced facility. While the

assessment has already considered the employment and economic

value associated with the haulage of this material, there would clearly be

further value in these products. The metals could be processed locally

and would assist in reducing demand upon our natural resources.

ERC by-products: The EfW process would lead to the generation of

bottom ash. This can be used in the construction industry as a

secondary aggregate. The RERC development would generate circa

46,500 tonnes per annum. While the assessment has already

considered the employment and economic value associated with the

haulage of this material, there would clearly be further value in these

products. The ash could be processed locally and would assist in

reducing demand upon our natural resources.

14.4.37 In addition to the above, social and community benefits would arise from the

new education and visitors centre which would enable the community and

schools to learn about waste management and how they can take more

responsibility for their own waste.

Decommissioning

14.4.38 It is considered that the decommissioning process would deliver positive

socio-economic impacts through the procurement of a demolition contractor

and standard sustainable demolition practices.



14.5.1 No specific mitigation measures are identified in respect of socio-economic

impacts which arise from the proposed development. The impacts for the local

employment and job market are judged to be positive.

14.5.2 Whist no mitigation measures are presented, there is potential scope to

ensure that employment and supplier opportunities are maximised to their full

potential in the local area. A number of potential actions are summarised in

Table 14.20 below and these can be discussed with the local authority, in due

course. Some of these actions could potentially be pursued by the developer

during the construction phase, and by the future operator.

Table 14.20: Possible Actions to Maximise Local Employment and Supplier

Impacts

Issue Actions

Construction contractors seeking to secure work from lead construction contractor.

Lead contractor could provide and disseminate an Annual Statement of Predicted Tender Work Packages – this would provide advance warning to local firms of upcoming opportunities. Facilitate ‘Supplier Days’ around key construction phase contracts – again to advertise upcoming opportunities.

Local construction workers seeking to access on and off-site employment opportunities.

Ensure lead contractors inform the local Council / other key agencies of all construction-related job vacancies. Ensure that any sub-consultant contracts require sub-consultants to advertise vacancies via the appropriate local channels.

Local traders (shops) wanting to maximise trade from visiting contractors.

Notification to local traders of when key waves of visiting contractors would be on site. Opportunities for local traders to visit site with key provisions (i.e. mobile snacks, drinks provisions), or to provide local discount offers to workers to encourage patronage. Establishment of a local liaison committee.

Local workers wishing to seek long term employment opportunities within the operational phase.

Work with local training providers during the construction phase to ensure they are aware of the upcoming permanent opportunities for staff and are scaling up their provision accordingly. In the peak recruitment period, a local ‘Job and Careers Fair’ could be hosted advertising upcoming opportunities to those in the labour market and those unemployed. Make available a number of local apprenticeships in key occupations to younger residents.

Local traders wanting to benefit from operators requirements for bought-in goods and services.

Operator to provide to local Council/business support organisations requirements for any major bought-in goods and services. Partners to make local businesses aware of any upcoming trading opportunities.



14.6.1 Given that there is no mitigation measures required in relation to the socio-

economic impacts, the following sub-section provides an assessment of the

significance of the identified socio-economic impacts, from both the

construction and operational phases under each scenario.

Residual Effects with Existing Baseline

Construction Phase

14.6.2 The following provides an overview of the judgement made on the sensitivity

of the local employment base receptor. The receptor is judged to have a High

sensitivity for the following reasons:

The socio-economic baseline has identified that there is a higher than

average number of people working in SOC5 ‘Skilled Trades’ and SOC9

‘Elementary Occupations’ in Midlothian. These skill occupation

classifications include the main occupations required to construct the

Proposed Development. Whilst, Edinburgh has a below average number

of people employed in SOC Groups 4 to 9 there considering the number

of economically active individuals in the city there is still a large number

of people working in these Groups.

The number of Individuals who are economically active but unemployed

in Midlothian is below the national average. For Edinburgh it is exactly

the same as the national average. However, for Midlothian the statistics

illustrate a higher than average number of unemployed 16 to 24 year

olds when compared to the national average. The implementation of

actions to maximise local employment opportunities for this age group

could assist.

FCC Environment operate its own apprenticeship programme and the

Centre will create up to 3 apprenticeships on an on-going basis and is

committed to making a positive contribution towards the sustainable

economic growth of the area. The aspiration is to provide employment

and modern apprenticeships to people within the region through the

construction and operation of the RERC.


Total job seekers allowance claimants within Midlothian were 1,027

(January 2015) which equates to 1.9% of the working age population.

Edinburgh exhibits the same percentage. Both are below the national

average which is 3.1%. The Proposed Development could assist in

reducing the number of claimants through the mitigation measures

previously identified.

14.6.3 The following provides an overview of the judgement made on the magnitude

of impacts. This is judged to be of Medium magnitude for the following

reasons:

The construction phase has the potential to deliver up to 180 on-site

temporary employment jobs per annum (circa 28 months). The

Proposed Development has the potential to support on average around

180 to 200 temporary on-site construction jobs per annum.

Of those on-site jobs, it is estimated that circa 50 FTE jobs could be

secured during the construction period by local contractors and workers,

given the nature of the skills required for elements of the civil

engineering work package. For some elements of the construction, the

proportion of local workers could be greater (i.e. ground works).

There could be further benefits locally for some businesses (food and

drink, accommodation providers) that may ultimately benefit as a result

of any temporary visiting workforce.

14.6.4 Applying the identified assessment framework, the socio-economic effects of

the construction phase of the Proposed Development are judged to have

Moderate (beneficial) Significance in the impact area.

Operational Phase

14.6.5 The following provides an overview of the judgement made on the sensitivity

of the local employment base receptor. The receptor is judged to have a High

sensitivity for the following reasons:

The assessment has shown that there were 2,700 residents of a

working age in Midlothian who were seeking employment. There were

14,517 residents of a working age in Edinburgh who were seeking

employment.


The JSA claimant rate for January 2015 illustrated that in Midlothian

1,027 (1.9%) of the working age population were claiming JSA. In

Edinburgh this figure was 6,366 (1.9%).

14.6.6 The following provides an overview of the judgement made on the magnitude

of impacts. This is judged to be of Medium magnitude for the following

reasons:

The proposed RERC is anticipated to directly support circa 39

permanent FTE jobs once fully operational.

The majority of all jobs would be skilled trades’ occupations (SOC5).

These jobs would be mainly technician roles for the ERC, as well as

some supervisory roles for the MT. Around 60% of all jobs would be

process plant or machine operatives (SOC8) or elementary roles

(SOC9). These jobs would be in operational roles within the ERC, as

well as drivers and operatives within the MT.

It is assumed that the operator would be able to recruit staff for the more

middle-level and low-skilled roles from within the Midlothian and

Edinburgh labour markets.

Once indirect and induced employment impacts are also considered, it

is estimated that the energy centre could support 50 permanent FTE

jobs within the impact area. This has the potential to lead to an annual

GVA impact of circa £3.8M per annum.

14.6.7 Applying the identified assessment framework, the socio-economic effects of

the operational phase of the Proposed Development are judged to have

Moderate (beneficial) Significance in the impact area.

Table 14.21: Summary of Significance of Residual Effects

Likely Significant Impact Sensitivity of Receptor

Magnitude of Impact


Construction Phase – Local Employment Base Receptor

High Medium Moderate (positive)

Operational Phase – Local Employment Base Receptor

High Medium Moderate (positive)



14.6.8 The ES prepared in support of the development benefiting from PPiP

concludes that it would give rise to a number of socio-economic effects of

minor beneficial significance. These comprise:

Improved employment opportunities;

Improvements to security and health and safety at the site;

A positive contribution to socio-economic policy at all levels; and

A wider effect on the economy through direct business.

14.6.9 As demonstrated above, the anticipated residual socio-economic effects

associated with the Proposed Development have been assessed as being of

moderate beneficial significance. Accordingly, and whilst acknowledging

that the parameters for the two assessments differ, it is reasonable to

conclude that when compared to the future baseline scenario, the Proposed

Development, would, as a minimum, have a neutral impact.

14.7 Conclusions

14.7.1 This Chapter has reviewed the key socio-economic impacts has of the

Proposed Development, focussing on the direct, indirect, and induced impacts

for the impact area, as well as a series of wider impacts the development

could potentially deliver. The Chapter has considered the significance of the

effects upon the local employment base receptor.

14.7.2 The assessment of the significance of effects of these impacts demonstrated

that during both the construction and operational phases the Proposed

Development would deliver moderate beneficial effect for the local

employment base, given the scale of employment need and the number of

temporary and permanent jobs available.

14.7.3 In conclusion, it is judged that the Proposed Development would not have any

significant negative adverse socio-economic impacts in the impact area. The

development would in-fact deliver a range of socio-economic benefits for

residents and businesses. A summary of these benefits are as follows:


39 FTE permanent direct jobs within the impact area. Given the nature

of the jobs supported (many of the roles require elementary or lower

level skills) and the local labour market need (levels of unemployment

locally and across the study area, types of jobs sought and range of

skills of labour force), it is anticipated that these jobs would be secured

by residents from within the local study area.

50 FTE direct, indirect (local supply chain) and induced permanent jobs

in the impact area. These jobs could support around £3.8M of gross

value added per annum.

Opportunities to ensure that local residents and businesses have access

to the employment and business supply chain opportunities which may

emerge. There are a range of actions which could be implemented

which can maximise and localise the economic benefits of the proposed

development.

FCC Environment operate its own apprenticeship programme and the

Centre will create up to 3 apprenticeships on an on-going basis and is

committed to making a positive contribution towards the sustainable

economic growth of the area. The aspiration is to provide employment

and modern apprenticeships to people within the region through the

construction and operation of the RERC.

Opportunities to deliver annual fiscal benefits of up to £0.4M to

Midlothian Council, through the retention of business rates.

Opportunities to create further value in the waste processing chain

through the sorting of recyclable materials and the creation of by-

products which can be used in other sectors (i.e. bottom ash in the

construction sector).

The generation of circa 13.46MW of electricity, a proportion of which

would be classified as renewable and circa 11.09MW can be exported to

the National Grid.

Through the combustion of SRF the Proposed Development would

generate up to 50MW of heat energy in the form of steam. A proportion

of this steam would be used to generate electricity with the balance

exported as heat (either steam or more likely hot water). A number of

potential users of the hot water have been identified in the surrounding

area, including the SNCD.


14.7.4 In addition when compared to the future baseline scenario (the scheme

benefiting from PPiP), it has been concluded that the effects of the Proposed

Development would be at least a ‘neutral’.


15.0 CUMULATIVE EFFECTS

15.1 Introduction

15.1.1 This Chapter of the ES provides an assessment of the likely significant

cumulative effects of the Proposed Development during its construction and

operation.

15.1.2 The EIA regulations require that a description of the likely significant effects of

the development on the environment should be included in the ES, including

cumulative effects. The EIA regulations do not define cumulative effect.

However, a commonly accepted definition is: “Impacts that result from

incremental changes caused by other past, present or reasonably foreseeable

actions together with the project” (EC, 1999).


15.1.3 The Planning Statement contained within the separately bound Planning

Application Document includes an appraisal of the planning policy context

associated with this proposal. A brief summary of the planning policy context

in so far as it relates to the assessment of cumulative effects is provided

below.

National Policy

15.1.4 SSP provides the Governments planning policies for Scotland. The key

relevant paragraphs with regard to cumulative effects are summarised below.

Paragraph 155 within the section relating to ‘A Low Carbon Place’

identifies that: “Development plans should seek to ensure an area’s full

potential for electricity and heat from renewable sources is achieved, in

line with national climate change targets, giving due regard to relevant

environmental, community and cumulative impact considerations.”

Paragraph 202 within the section relating to ‘A Natural, Resilient Place’

identifies that: “Development management decisions should take

account of potential effects on landscapes and the natural and water

environment, including cumulative effects.”


Paragraph 286 within the section ‘A Connected Place’ identifies that:

“Where a new development or a change of use is likely to generate a

significant increase in the number of trips a transport assessment should

be carried out. This should identify any cumulative effects which need to

be addressed.”

15.1.5 The local development plan currently comprises the SESplan and the

Midlothian Local Plan. The SESplan does not contain any policies relevant to

this ES Chapter. However, there are a number of policies within the Midlothian

Local Plan which make reference to the cumulative effects of development.

The majority of these policies are not relevant to this application as they deal

with matters such as: retail, commercial and leisure development, town centre

development, mineral extraction and residential development. The only policy

of relevance is Policy NRG1, which states: “The cumulative landscape and / or

visual impact of such proposals will be taken into consideration when

assessing individual planning applications,” In this context it must be noted

that the policy specifically refers to renewable energy projects as including

‘biomass’ and combined heat and power generation.

15.2 Methodology

Cumulative Effects

15.2.1 There is no accepted standard methodology in the UK as to how cumulative

effects should be assessed. However, in determining the approach to this

assessment reference has been made to the following guidance:

Guidelines for the Assessment of Indirect and Cumulative Impacts as

well as Impact Interactions (EC, 1999)

Cumulative Effects Assessment Practitioners Guide (Canadian

Environmental Assessment Agency, 1999);

Guidelines for Environmental Impact Assessment (IEMA, 2006); and

Environmental Impact Assessment: A guide to good practice and

procedures – A consultation paper (DCLG, 2006).

15.2.2 The assessment of cumulative effects has been based upon a multi-stage

approach which comprised:


Identification of potential schemes which together with the proposed

development could give rise to cumulative or in-combination effects. The

approach to identifying these ‘relevant’ projects is set out more fully

below.

Obtain information on each ‘relevant’ project in terms of its scale, type

and nature from the relevant planning authority. Where available, this

information has been sourced from the Environmental Statement for the

project. If environmental information is not available, reasonable

assumptions have been made on the likely significant environmental

effects of the project.

Stage 1 Assessment: consideration of the likelihood of significant

cumulative effects (of the construction and operational phases of the

project). Through a qualitative assessment for the following topic areas:

o Landscape and Visual Effects;

o Ecology and Nature Conservation;

o Flood Risk;

o Air Quality;

o Noise and Vibration;

o Traffic and Transportation;

o Archaeology and Heritage; and

o Socio-Economics.

Where the qualitative assessment identifies that there is no potential for

likely significant cumulative environmental effects to occur, no further

assessment is required. Where it concludes there could be a likely

significant cumulative environmental effect, the project (or more

specifically the topic area for the project) is carried forward for more

detailed assessment.

Stage 2 Assessment: carry out a detailed assessment of likely

significant cumulative environmental effects using the methodology

relevant to the topic areas to be appraised.

Approach to Identifying ‘Relevant’ Projects

15.2.3 Projects that have been considered in the cumulative assessment are major

projects that have been granted planning permission, are not yet operational,

or have yet to be constructed. Major projects are considered to be


developments of 10,000m2 in size, or greater, projects that have been subject

to EIA or projects that involve tall buildings or structures. Projects that fall

outside the above criteria, including schemes that are in the planning system

but not approved, have only been included in the assessment where they

have been specifically identified by the planning authority, other statutory

consultees or the project team as being of particular relevance.

15.2.4 The cumulative effect of operational projects are considered to already form

part of the baseline and as such, would be assessed within each of the

discipline Chapters. Further details of the projects that have been included in

the baseline for assessment and the appraisal to the assessment are provided

in Chapter 2.0. Consequently, the focus of the cumulative effects assessment

would be the appraisal of potential significant environmental effects in the

context of reasonably foreseeable future major development proposals.

15.2.5 A search area of 5km has been adopted to identify projects to be included in

the cumulative effects assessment and it is considered that projects beyond

this distance are unlikely to give rise to significant cumulative effects, indeed

for many of the disciplines / environmental topic areas the effects of the

development are more localised than 5km. In such instances some of the

projects identified in the provisional search have been excluded from the

assessment. Figure 15.1 illustrates the geographical extent of the 5km radius.

15.2.6 Information on the scale, type and nature of the projects included within the

cumulative assessment has been obtained from records held by relevant

planning authorities. Where available, this information has been sourced from

a project EIA. If environmental information is not available reasonable

assumptions have been made on the likely significant environmental effects of

the project. Each technical discipline has considered the likelihood of

significant cumulative effects initially through a qualitative assessment and if

necessary, through quantitative modelling. Where significant cumulative

effects have been identified these have been clearly reported and where

necessary mitigation measures recommended.

15.2.7 It should also be noted that as part of the Transport Assessment (TA) the

Highways Authority has been consulted to identify if there were committed

developments that should be included in the TA (Appendix 6-1). As such, the


TA and the Chapters that rely on the assessment (i.e. air quality and noise) by

their nature include cumulative effects of other projects that would be likely to

give rise to significant transport effects.

15.2.8 The project team have not found any limitations to carrying out the survey /

assessment work in association with this Chapter.

15.3 Baseline

Baseline Conditions

15.3.1 For the avoidance of doubt it should be recognised that the baseline position

against which this EIA has been undertaken assumes that:

The Application Site remains in its current state (brownfield site with

self-regenerated woodland;

The Anaerobic Digestion Plant being constructed to the north of the site

is finished and operational;

The Borders Railway being constructed to the north and west of the site

is completed and operational;

The Shawfair New Community development is built and operational in

accordance with the approved masterplan; and

The site access and bridge over the Borders Railway (also under

construction to the north) is in place and operational.

15.3.2 In light of the above, this Chapter has not taken these developments into

consideration as they form part of the baseline for the purposes of this

environmental impact assessment.


Identification of Potential Schemes

15.3.3 The first stage in the data collection process involved the identification of

‘relevant’ schemes which together with the proposed development could

potentially give rise to cumulative or in-combination effects. This involved a


comprehensive review of the planning application records held by the

following local authorities falling within the 5km radius:

Edinburgh City Council;

East Lothian Council; and

Midlothian Council.

15.3.4 The process involved contacting each local authority and requesting details of

any reasonably foreseeable major development projects (i.e. projects subject

to EIA) within their jurisdiction and within 5km of the site. A list of potentially

‘relevant’ schemes provided by each authority is contained within Appendix

15-1.

15.3.5 In addition to the above, each environmental topic has been scoped with the

relevant individual, authority or technical body. As part of the air quality

scoping exercise, the SEPA identified that the proposed new gas fired

Cockenzie Power Station could be a cumulative development worthy of

consideration. The SEPA identified that whilst the development has planning

permission it is only one of a number of options for the site and no permit

application discussions have taken place. Considering it is outside of the area

of search (i.e. beyond the 5km radius) and the lack of certainty over the nature

of development it has not been considered further within this Chapter. The

SEPA did not identify any other proposed development in the vicinity of the

site that could have an in-combination effect with the Proposed Development.

Information on Each Potentially ‘Relevant’ Scheme

15.3.6 Following receipt of the lists, from each authority, a review process was

undertaken. During this process it became apparent that the vast majority of

the applications were not relevant as they were not major applications (i.e.

erection of a satellite dish) or featured multiple times. Therefore the number of

potentially ‘relevant’ schemes was reduced significantly.

15.3.7 The remaining potentially ‘relevant’ schemes are identified in Table 15.1

below. Additional information was obtained through a desk based assessment

process. This entailed reviewing the planning history and making reasonable


assumptions on likely significant environmental effects based upon the

supporting documentation for each scheme.

Table 15.1: Projects Evaluated in Terms of Cumulative Effects

Development Potential for Significant Environmental Effects

Land at Todhills, Old

Dalkeith Road, Dalkeith

The site has been the subject of several applications:

04/00405/OUT – outline application for a business park with supporting facilities (including nursery, restaurant, conference and catering facilities) and hospital with associated landscaping, road car parking and access.

05/00337/FUL – construction of park and ride facility, including car parking, bus turning and waiting facilities, with SUDs drainage and landscaping.

06/00721/FUL – removal of condition 2(c) and 5 (a) of planning permission 04/00405/OUT to allow revised phasing of spine road.

08/00436/FUL – variation of planning permission 04/00405/OUT to allow the deletion of Condition 9

08/00435/FUL – variation of condition 1 of planning permission 04/00405/OUT to amend the developable area.

08/00552/FUL – amendment to condition 1 of planning permission 04/00405/FUL to allow for the erection of a hotel and associated works.

10/00098/DPP – Erection of office building and script management facility and formation of car parking and access road and associated works.

The site is located circa 1.5km to the south west of the Proposed Development within the Shawfair Business Park. Supporting infrastructure (roads) and phased development already existing alongside a park and ride facility. It is not considered that the proposed development would give rise to significant cumulative effects given the distance between the sites and nature of development. Therefore it has not been considered further.

Land on the South side of

Eskbank Road, Bonnyrigg, Midlothian


08/00385/RES – Erection of Community Hospital and associated energy centre, sub-station, service yard, car park, landscaping and SUDS feature (approval of reserved matters relating to planning permission 01/00068/OUT).

The site is located circa 4km to the south of the Proposed Development. The community hospital was built in 2010 and consequently is considered within the baseline. Therefore, it has not been considered further.

Land North of Edmonstone,

The Wisp, Danderhill


06/00439/OUT – outline application for the erection of a 120 bed nursing home and 24 bed private hospital and associated works.

11/00661/PPP – amendment to condition 13 of planning permission 06/00439/OUT to extend the time frame for submission of matters specified within Condition 1 of that permission.

The site is located circa 1.5km to the west of the Proposed Development. It currently comprises of dense vegetation and no development appears to have commenced. Given the distance and nature of the proposal it has not been considered further.

Former Jewel and Esk Valley College Site,

Newbattle Road, Eskbank


06/00347/OUT – outline application for residential development (140 dwellings) with associated access and landscaping.

08/00410/RES – application for reserved matters for residential development, access and landscaping.

10/00172/MSC – application for approval of matters specified in conditions 1(d), 2(c) and 2(I) of planning permission 06/00347/OUT for residential development access and landscaping.

The site is located circa 4km to the south of the Proposed Development and is currently vacant. Given the distance and intervening development it has not been considered further.


Bus Garage, Eskbank Road,

Dalkieth


07/00303/FUL – mixed use development comprising of a supermarket, leisure, restaurant, bar, health and fitness, offices and formation of service yard.

12/00635/DPP – amendment to condition 31 of planning permission 07/00303/FUL to extend the time limit for implementation.

12/00418/PAC – Proposal of application notice for amendment to Condition 31 of planning permission 07/00303/FUL to extend the timescale for implementation.

13/00226/DPP – Erection of a supermarket and formation of associated car parking service area and road access.

The site is located circa 3.2km to the south of the Proposed Development. The site is currently vacant. Due to the distance and intervening development, it has not been considered further.

Land adjoining St Davids

Roman Catholic Primary School, Louder Road,

Dalkeith


07/00465/FUL – erection of 223 dwellings, associated roads, landscaping and drainage.

14/00556/LA – application to partially discharge planning obligations with a legal agreement.

The site is located circa 4km to the south east of the RERC development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.

Millerhill Marshalling

Yard, Dalkeith


12/00060/DPP – Formation of access road, bridge and associated infrastructure.

12/00514/PAC – proposed application notice for new railway depot, stabling, and cleaning facilities associated new railway lines, office and staff welfare and car parking and access.

12/00837/DPP – Formation of train maintenance, cleaning and stabling depot; erection of retaining wall and alterations to ground levels; formation of new railway lines; erection of boundary fencing; and formation of associated car parking and access.

The site is located immediately to the east of the Proposed Development. Given the distance from the Application Site and nature of the proposed development it has been considered in Table 15.2 below.

Wester Cowden,

Thornybank, Dalkeith

The site has been the subject numerous planning applications and is the subject of a Development Brief. Furthermore, a large number of residential properties have been constructed (i.e. Plots L1, L2, M1 and M3). However, it appears that a number of plots within the overall site currently benefit from planning permission for residential properties (i.e. Plot N2) and planning permission in principle is sought for others (i.e. Plot H1).

The site is located circa 3.5km to the south east of the Proposed Development. Given the distance, intervening geography (i.e. the A68 and Dalkeith County Park), and nature of the proposed development it is considered that no significant cumulative effects are anticipated and it has not been considered further.

Kinnard Park, Lowhouse Toll,

Edinburgh


04/03706/OUT – reconfiguration and redevelopment of retail floorspace, provision of additional cafes and restaurants, ancillary development as a whole, transport hub and new access and circulation arrangements.

11/00874/FUL – amendment to Condition 3 to increase upper floorspace for retail from 64,665sqm to 71,502sqm.

12/02085/AMC – detailed design of cafes and restaurants and works to public realm.

12/02091/FUL – erection of a multiplex cinema.

13/02381/FUL – erection of retail unit incorporating 5,612sqm.

The site is located circa 1.5km to the north west of the Proposed Development. Kinnard Park comprises of a large retail / leisure complex which is being redeveloped in phases. From a desk-based assessment it is considered that the majority of this development is built. However, given the distance and nature of the proposal, no significant cumulative effects are anticipated and it has not been considered further.


Land 447 Northeast of

545 Old Dalkeith Road,

Edinburgh

Cemetery, Crematorium, memorial gardens, chapel of rest and associated development. The site is located circa 2km to the west of the Proposed Development. The online planning register identifies that whilst this application (ref: 13/05302/PPP) has been heard at committee it has not been determined. Limited detail is available in relation to the crematorium and therefore it is difficult to determine the extent of potential cumulative effects. Furthermore, as the application has not been determined it is not clear whether it would be appealed, it also falls outside the criteria for inclusion in this assessment.

Cameron Toll Shopping

Centre, Lady Road, EH16

5PB

Extension to Cameron Toll Shopping Centre to include retail (Class 1), restaurant/cafe (Class 3) and leisure (Class 11) uses, external alterations to existing Shopping Centre, creation of pedestrian link from Liberton Road, additional car parking including formation of a car park deck and associated landscaping (as amended). The application (ref: 09/01141/FUL) was approved in 2012.

The site is located circa 4.5km to the west of the Proposed Development. Considering the distance and the intervening built development it is considered that no significant cumulative effects are anticipated and it has not been considered further.

Edinburgh Royal Infirmary, 51 Little France

Crescent Edinburgh


11/02454/PPP – Planning permission in principle for erection of Children's Hospital including department for clinical neurosciences + ancillary facilities, helipad, associated enabling development including energy centre, Vacuum Insulated Evaporator (VIE), car parking, revised access + public transport arrangements, public realm works + landscaping (car parking, access + public transport arrangements in detail).

14/00078/AMC – Approval of Matters Specified in Conditions in relation to Condition 1(i) of application 11/02454/PPP in respect of erection of Children's Hospital including department for clinical neurosciences and ancillary facilities (relating to flood prevention works).

14/01796/AMC – New Royal Hospital for Sick Children, Accident and Emergency, Nero-sciences and adult metal health service unit. Works include heli-pad, energy centre, service yard, car parking and landscaping.

14/03599/AMC – Erection of flue stack at Energy Centre as part of re-provision of Royal Hospital for Sick Children and Department of Clinical Neurosciences, Condition 1(b) on PPP consent (11/02454/PPP).

The site is located circa 2km to the west of the RERC development within the existing Royal Infirmary of Edinburgh Hospital Complex. In March 2014 Integrated Health Solutions Lothian (IHSL) were appointed preferred bidders for the design, build, finance and manage the hospital by NHS Lothian

Amongst other infrastructure the hospital includes an energy centre and associated flue stack which extends 15m in height. As this is has the potential for source emissions within the 5km search area it has been assessed further in Table 15.3 below.

Edinburgh Bioquarter,

Little France


02/04372/OUT – outline planning permission for centre for biomedical research including educational, health and supporting facilities.

05/00022/REM – submission of reserved matters in respect of the first phase of infrastructure works (including roads, drainage and landscaping.

13/05048/FUL – Section 42 application to vary conditions one and three of 02/04372/OUT centre for biomedical research including educational, health and supporting facilities.

Whilst this site is the subject of a range of applications those identified above are understood to the principal applications. The site is located circa 2.5km to the west of the Proposed Development and site enabling works have taken place to create a range of development plots some of which (Nine at the bioquarter) have been developed for medical research and development. Given that the enabling works and some unites have been built it is considered that this part of the development falls within the baseline for the purposes of this Chapter. It is not considered that any of the uses proposed at this site (office and research) would not generate any cumulative effects with the Proposed Development and it has not been considered further.


1 Milton Road Edinburgh EH15 3BY


10/02830/FUL – The erection of new Portobello High School and associated ancillary buildings, site works, car parking, landscaping, pitches and floodlighting Portobello Park And Golf Course.

13/03200/FUL - Renewal of consent 10/02830/FUL for the erection of the new Portobello High School and associated ancillary buildings, site works, car parking, landscaping, pitches and floodlighting.

The site is located circa 2.8km to the northwest of the Proposed Development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.

Pinkie Mains, Pinkie Road, Musselburgh,

EH21 7TY


08/01090/OUT – Planning permission in principle for residential and retail development including associated landscaping and car parking.

11/00974/AMM – Approval or matters specified in conditions of outline planning permission 08/01090/OUT erection of 413 houses and 60 flats and associated works

The site is located circa 3.5km to the north east of the Proposed Development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.

Land to South, East and West of Wallyford, East Lothian


09/00222/OUT | Outline Planning Permission for the proposed mixed use development incorporating residential uses, educational uses, library, retail, office units, restaurant, business units, general industrial units, storage and distribution units, trade counter units, residential institution, non-residential institution, hot food takeaways, playing fields, open space, allotments, drainage arrangements and all associated infrastructure, access, landscaping and site development

12/00924/PPM – Renewal of planning permission in principle 09/00222/OUT for a proposed mixed use development incorporating residential uses; education uses; library; retail (class 1); office units (class 2); restaurant (class 3); business units (class 4); storage and distribution (class 6); trade counter units; residential institution - nursing home (class 8) non - residential institution - day centre (class 10); hot food takeaways; playing fields; open space; allotments; drainage arrangements and all associated infrastructural access; landscaping and site development works on land lying predominantly to the south and east of Wallyford but also including the Strawberry Corner garden centre; the entire length of Salters Road from the interchange with the A1 to the Wallyford Toll roundabout where traffic calming and environmental improvements are proposed; and Inchview Road where road realignment and alterations are proposed in association with the proposed development

The site is located circa 4km to the east of the Proposed Development. No development appears to have taken place. Given the distance and intervening built development no significant cumulative effects are considered to occur and it has not been considered further.

15.3.8 Based on the above information, it is considered that the only potential for

cumulative effects would be from: the proposed train maintenance depot at

the Millerhill Marshalling Yards and the new children’s hospital at the

Edinburgh Royal Infirmary. These proposed developments have been

considered further within the following sub-section.



Stage 1: Assessment

15.4.1 The Stage 1 qualitative assessment of the schemes likely significant effects in

combination with the remaining projects is set out in Tables 15.2 and 15.3

below. These relate to the cumulative effects assessment of the proposed

development with each identified project individually.

Table 15.2 Millerhill Marshalling Yards: Stage 1 Cumulative Impact Assessment

Project Overview: The proposed development at the Millerhill Marshalling Yards is for the formation of a train maintenance cleaning and stabling depot, erection of retaining wall and alterations to ground levels, formation of new railway lines, erection of boundary fencing, and formation of associated car parking and access. The development would take place within the existing Marshalling Yards, i.e. within the bounds of an already developed site.

Assessment Topic

Identification and Assessment of Significant Environmental Effects.

Landscape and Visual Effects

The landscape and visual effects of the proposed development against a baseline where the consented development at the Marshalling Yards is present would be little different to those effects described in Chapter 7.0 of the ES.

The Marshalling Yards development would increase the amount of built development present immediately east of the Application Site and hence the Proposed Development would be introduced into a landscape where built / urban influences are incrementally greater.

This would not materially change the conclusions of the LVIA (Chapter 7.0) regarding effects upon either landscape character or upon views. The Marshalling Yards development would be much smaller than the Proposed Development in terms of building height / mass and its additional influence over and above the LVIA baseline would be very limited. Cumulative landscape and visual effects would be negligible.

Ecology and Nature

Conservation

The proposed development is located on site which has been used for a number of operations in relation to stabling and the maintenance of freight trains and for ballast storage. The Committee Report associated with the development confirms that, due to the nature of the proposed development it will not have any impact upon protected species.

However, the application was supported by a Phase 1 Habitat Survey which concludes that the site contains limited suitable habitats for protected mammals and some areas suitable for nesting birds and reptiles. In light of this habitat surveys were conducted. During this survey, it was considered that the site is of local value for wintering birds and due to the small mammal populations it is thought that thought that barn owl, a schedule 1 protected bird is present. Consequently, a condition was attached to the permission seeking further assessment work in relation to birds and reptiles should be undertaken. This condition was discharged in June 2013.

The effects of the proposed development on flora and fauna will not be significantly different in combination with the planned rail maintenance depot. Surveys undertaken to inform the development of the Marshalling Yard noted that the site supported limited suitable habitats for protected species, nesting birds or reptiles.

The development of the rail maintenance depot does introduce a further degree of incremental urban development onto land to the east of the site. However, the ecological impact assessment for the RERC site assumed a degree of disturbance of wildlife in the current baseline, with regular freight train movements, noise and light spillage. For the purposes of the ecological assessment the Marshalling Yard was not assessed as having any potential to


support species displaced from the site as a consequence of the RERC development, and its development therefore does not affect the assessment of impacts against the current baseline.

In light of the forgoing, it is not considered that the in combination effects of the proposals would have any likely significant cumulative effects in respect of ecological and nature conservation interests.

Flood Risk

The proposed development includes a sustainable urban drainage system and attenuation pond which would ensure that there is no change to the existing hydrological regime at the site. Similar measures are being proposed on connection with the Proposed Development and as such, there would be no likely significant cumulative effects in respect of flood risk.

Air Quality

The planning application submitted in relation to the development does not include an air quality assessment and no issue is made of potential aerial emission from the development in comments received by consultees on the application or in the Officers Report to committee. This suggests that the proposed development would not generate any significant aerial emissions beyond those experience in relation to existing operations.

The only potential cumulative effect that could occur is in relation to dust in the event that the construction of the development occurred at the same time as the Millerhill RERC development. However, the construction of the Proposed Development would be controlled through a CEMP and assuming that standard industrial practices are observed during the construction of the maintenance depot, it is unlikely that any significant effects would occur in this regard.

Based upon the above, it is concluded that there would be not potential for likely significant effect in relation to air quality.

Noise and Vibration

The Committee Report associated with the application confirms that a noise report was submitted with the application and it concludes that noise emissions from the proposal are unlikely to give rise to a noise nuisance. Chapter 9.0 of this ES provides an assessment of cumulative effects in relation to noise concludes that the cumulative effect would be between negligible to minor and a neutral to slight impact significance at the nearest sensitive receptors. Accordingly, there should be no likely significant effects in relation to air quality.


The Transport Statement prepared to support the rail depot application identifies that the development could generate of the order of 172 additional movements per day (in + out). The majority of this additional traffic would be related to staff movements, with 80% of staff working an overnight (19:00-07:00) shift. The majority of traffic associated with the rail depot scheme could therefore be expected to take place outside of the core weekday day-time periods and traditional AM & PM network peak hours. Given this low level of predicted traffic flow and the ‘out of hours’ nature of the majority of these movements, it is anticipated that the cumulative traffic effects of the proposed rail depot scheme and the construction / operation of the Millerhill RERC development would be negligible.

This conclusion reflects the findings of the formal transport appraisal of the rail depot scheme, which was prepared with cognisance of predicted traffic movements associated with the ZWF.

Archaeology and Heritage

The proposed developments at Millerhill Marshalling Yard are within very close proximity to the Proposed Development. However, they are markedly different in character and will be lower in height. This assessment has found that for many designated assets the Proposed Development will be viewed either across or in many cases, from within the wide suburban and industrial landscape which extends eastwards from Edinburgh. The developments at Millerhill Marshalling Yard taken together with the Proposed Development would not result in a significant alteration to the current setting of the heritage assets in the study area and no significant cumulative effects are predicted.

Socio-Economics.

The application identifies that; the proposed development would increase future efficiency and improve services within the rail network. It represents investment in the area and will provide new employment opportunities. The same is also true of the Proposed Development and as such it is considered that in combination the proposals would have a positive socio-economic impact.


Table 15.3 Edinburgh Royal Infirmary, 51 Little France Crescent Edinburgh: Stage 1

Cumulative Impact Assessment

Project Overview: The erection of a children’s hospital at the existing Edinburgh Royal Infirmary. The development would include a helipad, energy centre, car parking and access arrangements, public realm works and landscaping. A series of applications seeking to approval to matters reserved by the planning permission in principle have been submitted.

Assessment Topic

Identification and Assessment of Significant Environmental Effects.

Landscape and Visual Effects

The proposal would be constructed next to the existing hospital buildings which are located between the two developments. On this basis, it is concluded that there would not be any likely significant cumulative landscape or visual effects between the two developments.

Ecology and Nature

Conservation

Given the intervening distance between this proposal and the Millerhill RERC development any direct significant cumulative ecological effects are unlikely. As such, it is considered that the proposals would not result in any likely significant in combination effects, in terms of direct impacts upon habitats / species.

In terms of potential nature conservation effects through emissions to air, the proposal (i.e. the energy centre) and the Millerhill RERC would have aerial emissions. The air quality assessment which supported the energy centre concluded that negligible effects of local air quality are predicted due to the operational traffic associated with the development. As such it is not considered necessary to further evaluate the cumulative effects in respect of the proposal and the Millerhill RERC development.

Based upon the foregoing, it is concluded that there would be no likely significant cumulative effects in respect of ecological and nature conservation interests.

Flood Risk

As set out in Chapter 10.0, the Millerhill RERC development would not give rise to significant flood risk effects. Furthermore, the proposal is located a considerable distance from the Application Site and both have their own flood mitigation in terms of surface water run-off. As such no significant cumulative flood risk is predicted between the two developments.

Air Quality

During the pre-application consultation regarding the preparation of the PPC Permit application and AQA in connection with the Millerhill RERC development, the SPEA confirmed the other existing and proposed developments in the area surrounding the area surrounding the Application Site that they considered could give rise to in-combination air quality effects. They advised that the only facilities that needed to be considered in this regard were the AD Facility to the immediate north of the Application Site and the Cockenzie Power Station development (discussed elsewhere in this ES). They did not identify the proposed biomass boiler at the Edinburgh Royal Infirmary and as such, this has not been the subject of any further assessment.

Noise and Vibration

The assessment work carried out in support of the application concludes that it would not have the potential to give rise to significant effects in terms of noise and vibration effects on local receptors during both the operation and construction phases. The same conclusion has also been reached in realtion to the Millerhill RERC development. Given the separation distance between the proposal and the Millerhill RERC development and the position in respect of development related traffic, there would demonstrably be no significant cumulative effect in respect of noise or vibration.


The Millerhill RERC proposal site is located well outside of the core study area identified as part of the formal traffic and transport assessment of the children’s hospital development. It is therefore not anticipated that the hospital scheme would result in any discernible impact on baseline local network conditions to the Millerhill RERC development. The cumulative traffic effects of the children’s hospital development and the construction / operation of the Millerhill RERC proposals would be negligible.

Archaeology and Heritage

There would be no significant cumulative effect in terms of burred archaeology due to the distance between the two sites. Consequently the only potential effects could be through an impact on setting of heritage features.

Whilst the proposed energy centre at the ERI will have a stack, at 29m it is considerably shorter


than the Proposed Development and will be set c.2km to the west. Consequently it is unlikely that the two schemes will appear together in views from many of the designated assets identified as part of this assessment. They are likely to both be visible from Craigmillar Castle, Holyrood IGDL and potentially from some locations within Pinkie Battlefield. However, given the separation distance between the two developments and the highly complex urban landscape, the insertion of the Proposed Development into views which also include the ERI stack will not materially elevate the level of effect beyond those predicted for the Proposed Development when it is considered on its own. No significant cumulative effects are predicted.

Socio-Economics.

In combination the projects are likely to have some cumulative socio-economic benefits. These benefits are likely to mainly relate to construction phase employment; although when they are considered in combination the permanent employment opportunities would also be considerable. It is considered that in combination the proposals would have a positive socio-economic impact.

In addition to the above, it is worthy of note that the hospital complex has been identified as a potential recipient of the heat from the Millerhill RERC development.

Findings of the Stage 1 Assessment

15.4.2 The Stage 1 qualitative assessment has shown that there would be no likely

significant environmental effects arising from the development of the RERC

development in combination with either the Millerhill Marshalling Yards or the

developments proposed at the Edinburgh Royal Infirmary.

15.5 Mitigation Measures

15.5.1 Given that the assessment has identified that there are no likely significant

cumulative effects arising from the Proposed Development in combination with

the other ‘relevant’ projects assessed within this Chapter, no mitigation

measures are considered necessary.


15.6.1 There would be no significant residual cumulative effects arising from the

Proposed Development in combination with either the Millerhill Marshalling

Yards or the Edinburgh Royal Infirmary.

15.7 Conclusions

15.7.1 The project team has written to the three local planning authorities whose

administrative areas lie within 5km of the Application Site to request details of

any unimplemented developments (with planning permission), referred to as


‘relevant’ projects, which could, in combination with the proposed

development, give rise to likely significant cumulative effects.

15.7.2 The stage 1 assessment has shown that there would be no likely significant

environmental effects arising from the development of the RERC development

in combination with either the Millerhill Marshalling Yards or the Edinburgh

Royal Infirmary.

15.7.3 In light of the above, no ‘relevant’ projects have been carried forward to the

Stage 2 assessment. On this basis, it has been concluded that there would be

no unacceptable cumulative environmental effects would arise from the

construction and operation of the Proposed Development.


16.0 ENERGY EXPORT CONNECTIONS

16.1 Introduction

16.1.1 As described in Chapter 3.0, the Millerhil RERC development would recover

energy from the combustion of SRF by way of electricity and heat production.

This Chapter of the ES provides a high level assessment of the likely

significant environmental effects associated with the development of the

electrical grid connection and potential heat distribution network associated

with the proposed development.

16.1.2 The ERF component of the Millerhill RERC would have a design capacity to

treat up to 195,000t of SRF per annum. Through the combustion of the SRF it

would generate approximately 50MW of heat energy in the form of steam. A

proportion of this steam would be used to generate electricity and the balance

could be exported as heat (in either the form of steam or more likely hot water)

to users within the surrounding area.

Electrical Generation

16.1.3 Electricity from the Millerhill RERC development would be generated by a

steam turbine, the generation capacity of which would be up to 13.45MW. A

proportion of the electricity generated would be reused in the operation of the

facility with the majority of the electricity, 11.09MW, being exported to the local

electricity distribution grid.

16.1.4 The grid connection works required to export electricity from the facility do not

form part of the Planning Application and fall either under Section 37 of the

Electricity Act 1989 or under the permitted development rights of statutory

undertakers. However, on the basis that export of electricity is an integral part

of the scheme, it is considered appropriate that the potential environmental

impacts associated with the connection to the local electricity grid are

assessed within the ES. The application for the grid connection works would

be undertaken by the local District Network Operator (DNO), SP Networks.


16.1.5 Consultation with the local DNO has confirmed that connection to the local

electricity distribution network is feasible. Through this consultation exercise

SP Networks have provided details of their preferred grid connection route.

16.1.6 The proposed route would provide a connection to the Niddrie primary sub-

station which is located circa 1.7km to the north-west of the site, as the crow

flies, or 3.1km by road. The connection would be via underground cabling for

the majority of the distance buried within existing highways carriageway. The

proposed route of the electrical grid connection is illustrated on Figure 16.2.

Heat Recovery

16.1.7 A separate Heat and Power Plan has been prepared in support of the

application (see Part 6 of the separately bound PAD). This confirms that heat

recovery from the Millerhill RERC development would be via steam extraction

points in the turbine to allow low pressure steam to be supplied directly to

consumers, or to be condensed in heat exchangers in order to provide hot

water. The facility would be able to generate up to 20 MW of heat for export to

a heat network.

16.1.8 The Heat Plan sets out the latest identified proposals for heat export, together

with the steps required to maximise benefits in this regard. It identifies the

potential heat pipe network route, which is based around the existing and

potential heat users surrounding the development site. The proposed heat

network includes a number of potential existing / proposed customers in close

proximity of the Millerhill RERC site. These users include:

16.1.9 The location of the identified heat off-take opportunities and potential routing

of a heat pipe network is illustrated on Figure 16.1.

16.1.10 Similar to the grid connection, the heat pipe network does not form part of the

planning application for the Millerhill RERC development and would be

authorised by either a separate planning application, or through permitted

development rights. However, on the basis that export of heat is an integral

part of the scheme, it is considered appropriate that the potential

environmental impacts associated with the delivery of the heat pipe network

are assessed within the ES.


16.1.11 The work carried out in the Heat and Power Plan concludes that the optimum

potential for local heat usage is through the export of hot water.

16.1.12 For the purposes of the ES, it has been assumed that the heat pipe network

would extend to four principal locations from the Millerhill RERC, serving:

To the north / north east – the Queen Margaret University;

To the immediate West – the SNCD;

Further to the West – the Medical Quarter and the Royal Infirmary of

Edinburgh

To the north-west – the new developments within the Craigmillar

residential area.

Assessment Parameters

16.1.13 The following sections describe the potential grid connection and heat pipe

works in more detail and provide an assessment of potential environmental

impacts that may arise from the implementation of the routes that are under

consideration. The precise route of the grid connection and heat pipe network

would be subject to landowner negotiations and detailed design

considerations. As such, the following assessment provides an appraisal of

the likely environmental effects of the proposed grid connection option and

heat pipe network option in sufficient detail to identify any potential significant

effects and confirm the feasibility or otherwise of the proposed routes.

16.2 Description of Development

Electricity Connectivity – To Niddrie Primary Sub-station by Road

16.2.1 The Millerhill RERC development would generate electricity at 11kV. This

would be ‘stepped up’ to 33kV by an on-site transformer and exported from

the proposed site via an on-site substation. The construction of the on-site

substation which is located on the eastern boundary of the site, next to the

access road, has been considered within the main assessment in the

preceding Chapters of the ES.


16.2.2 The description of the development provided below, describes the cabling

infrastructure, the cable route and the construction methods required to

connect the Millerhill RERC development to the local electricity distribution

network.

Cable Route

16.2.3 The cable route would exit the Millerhill RERC site via the private access road

which connects to Whitehill Road. The cable would then run west along

Whitehill Road until it reaches the junction with the un-named road. The cable

would then follow the un-named road in a westerly direction to its junction with

the A6106 Millerhill Road, before turning north onto the A6106 – The Whisp

for the remaining 0.5km to the Niddrie primary sub-station. The distance to

the substation would be circa 3.1km in total.

Construction Methods

16.2.4 The electricity cable would be buried within a trench located within the

metalled roadway. The precise location would be subject to discussion with

the Midlothian Council and (if necessary) Edinburgh City Council Highways

Departments, other utilities companies and as a result of any local limitations

i.e. avoidance of damage to trees, adjacent structures or sensitive habitats.

16.2.5 Rigid corrugated cable ducts would be laid within a trench excavated to a

depth of circa 1m and to a width of circa 0.7m (the approximate width of an

excavating bucket) using a wheeled excavator or similar. Hardstandings would

be broken out using a hand operated or machine mounted pneumatic

breaking hammer and mechanical road saws. The cabling duct would be

placed on a blinding layer of sand or screened earth to prevent damage from

sharp objects. A further blinding layer would then be placed on the ducting.

For the purposes of Health and Safety a marking tape or tiles would be laid

circa 75mm above the duct to indicate its location. The trench would then be

backfilled with the previously excavated material. The road surface would then

be reinstated and surfaced to a specification required by the highways

authority. The electric cabling would be pulled through the ducting once it had

been laid and secured in position. A working area of circa 3m to 4m in width

would be required during the trenching and cable laying works for the


operation of machinery and temporary storage of excavated material prior to

backfilling. Traffic management (i.e. temporary traffic lights would need to be

put in place during the period of the construction works). The cabling would be

laid in short sections to minimise disruption to highways users.

16.2.6 It may be necessary for some sections of the cable route to be constructed

using directional drilling / micro-boring techniques as these methods would

avoid open excavations within the highway minimising traffic disruption. Such

works may be required where the cable crosses a main carriageway or at

major junctions where it would be desirable to avoid traffic management.

However, as no such junctions are in evidence on the proposed route, it is

highly unlikely that this technique would be necessary. Should these works be

required they would be carried out in accordance with the DMRB, ‘Guidance

on the trenchless installation of services beneath motorways and trunk

roads’37.

16.2.7 At the junction with the Niddrie sub-station the cable would be brought above

ground and connected into the transformers for onward distribution to the local

electricity network. There may be a requirement to upgrade some of the

equipment at the substation, but significant upgrades are considered unlikely.

Any upgrades would be undertaken within the boundary of the existing

substation. The contractor would implement best practice construction

methods throughout the period of the works to reduce potential environmental

impacts.

Description of the Heat Pipe Network and Installation Works

16.2.8 Given the types of heating requirements identified off-site to date as being

potentially available, heat could be supplied in the form of hot water to some

users subject to viable economics. The temperature of the water would be

supplied at up to 110oC depending on the end user’s requirements. Summer

supply temperatures would be lower to reduce energy losses.

37

DMRB, Volume 4, Section 1, HA120/08 Guidance on the trenchless installation of services beneath motorways and trunk roads. August 2008.


16.2.9 Heat would be distributed in buried pipework. Preinsulated steel pipes would

be used to supply pressurised hot water to the customer, and to return cooler

water. Where pipes are small, two pipes may be integrated within a single

insulation sleeve. However, single pipes are likely to be used to meet large

heat demands. This technology is well proven and provides an energy

distribution system with a 30 year design life. Additional pipe work can be

added in the future and it is a straightforward process to add branches to

serve new developments. It is estimated that 350mm internal diameter (i/d)

pipes would be installed for the flow and return pipes.

16.2.10 Heat would be supplied to a secondary heat exchanger on a consumer’s

premises. Typically, the hot water in the distribution system is supplied to one

side of a heat exchanger at the end user, with the other side arranged to heat

up the hot water required by the user. This heat exchanger can be arranged

upstream of any back up boiler plant, so that the heat from the facility can top

up any heat from the boiler.

16.2.11 Water would be pumped continuously around the system. Pumps are

operated with 100% standby capacity to maintain heat in the event of a pump

fault. The pumps would have variable speed drives to minimise energy usage.

Booster pumps can be installed within the distribution pipe network to increase

the distance over which the energy can be delivered. Providing the system

design pressure is not exceeded there is no limit as to the distance the water

can be pumped. Heat exchangers can be used to provide pressure breaks to

enable the network to be extended.

16.2.12 The potential heat pipe network route is shown in Figure 16.1.

16.2.13 The heat off-take pipes would be buried below ground within trenches located

within the confines of the public highway, private roads, or other areas of

hardstanding e.g. car parking areas. The trench would be excavated to a

depth of approximately 1m and would be approximately 1.35m in width.

16.2.14 Pipe supports would be installed within the bottom of the trench prior to the

placement of the steel pipe. The pipes would then be lifted and positioned in

the trench by an excavator. Once placed in the trench the pipes would be

welded and jointed. Following installation of the pipework the trench would be


backfilled with sand to cover the pipes, the trench would then be backfilled

with excavated material and the road surface or other hardstanding would be

reinstated.

16.2.15 During the trenching a working area of approximately 3-4 m in width would be

required for the operation of machinery and temporary storage of excavated

material prior to backfilling. As such appropriate traffic management (e.g.

temporary traffic lights) would need to be put in place along the affected

highways.

16.2.16 The indicative timetable for the construction of the plant and heat network is

provided in the Heat and Power Plan.

16.3 Approach to Assessment

16.3.1 As noted above the grid connection and heat pipe routes would need to be the

subject to refinement in order to take into account the requirements of affected

parties and any limitations identified along the proposed grid routes. This

assessment seeks to establish the likely significant environmental impacts

associated with the installation and operation of the grid connection works and

to determine if the routes are considered acceptable in relation to

environmental impacts. As such, the assessment identifies the nature of the

impacts that may arise from the connection works along or close to the

illustrated connection routes and defines the type of mitigation that would be

put in place to avoid or reduce impacts.

16.3.2 The assessments presented below utilise the baseline data gathered as part

of the main assessment. Where necessary this has been supplemented with

further environmental information gathered through desk study.

16.3.3 The assessment is based upon the methodologies used in the individual

Chapters of this ES, but seeks to summarise matters that are specific to the

proposed grid connection / heat pipe works. The findings are summarised in

Table 16.1 below.


Table 16.1: Assessment of Environmental Impacts Associated with the Grid Connection and Heat Pipe Installation Works

EIA Topic Description of Potential Impacts Mitigation

Traffic and Transport

The main traffic and transport effects that could arise as a result of the proposed grid connection / heat pipe installation route relate to:

Construction traffic on the local highways associated with staff movements, export of excavated material and general movement of construction plant along the proposed cabling route; and

Potential road closures during the construction works.

Only a small number of construction staff would be required to construct the routes. The numbers of construction staff would be insignificant in comparison to the staff numbers being employed on the main site. As such, there is not anticipated to be any significant traffic impacts from staff movements.

The volume of soil requiring export from the works would be limited due to the fact that much of the material would be used in reinstatement works. In relation to export of excavated materials, it is considered unlikely that the works would generate more than one or two HGV movements per day. As such, this would not represent a significant traffic impact.

Temporary traffic management would be required during the construction period. The requirement for traffic management would be avoided where possible. Traffic management measures are likely to involve the use of temporary traffic lights and / or lane closures.

Whilst some delays would inevitably result from the introduction of traffic management, access along the routes affected would be maintained throughout the construction period and as such, the impacts are not considered to be significant.

No significant impacts on traffic and transportation are considered likely once the construction works have been completed and the grid connection is ‘live’.

Construction vehicle movements would be managed to avoid peak traffic periods and temporary traffic management measures would be put in place and would be agreed in advance with the Midlothian Council and (if necessary) Edinburgh City Council, the Local Highways Authorities. In addition, appropriate signage would be installed in advance of the works to inform local road users of the planned date and duration of the works.

If deemed necessary during consultation with the local highways authority, directional drilling / micro-boring techniques would be used where the cable route crosses highways or key junctions. However, at this stage, it is not considered that such techniques would be required in relation to the proposed grid connection route.

Landscape and Visual

The works to install the proposed grid connection / heat pipe installation routes would, as described previously, involve underground cabling / trenching from the Application Site. On the basis that cabling would be underground, no permanent landscape or visual effects would occur and as such, the impact is considered to be negligible.

No mitigation is considered necessary.


Ecology and Nature Conservation

No statutory designated sites including SPAs, SACs, Ramsar Sites, SSSI, NNRs and LNRs are present along the proposed trenching routes.

Whilst the precise location of the trenching would be determined through consultation with the local highways authority, it is likely that the cable would be located under the metalled road. Thus, for the purposes of the assessment, it has been assumed that this would be the case with only limited works within the highway verges.

With regard to the aforementioned works within the highway, they would not result in the loss of any habitats of value. However, there are some mature and immature trees (and other vegetation) alongside the proposed trenching route. Whilst the impacts are unlikely to be significant and none of the trees would be lost as a result of the excavation works they could result in damage to roots. Accordingly, appropriate (standard) mitigation measures would need to be adopted during the construction of the trench to prevent any significant effects occurring.

Standard mitigation measures would be put in place regarding the protection of any tree roots. In the event that major structural roots are identified during excavation, hand digging should be undertaken to avoid damage to the roots.

Geology, Soils and Groundwater

With regard to the majority of the trenching, given the shallow nature of the excavations and the routine nature of the works proposed, no impacts associated with geology, soils or groundwater are predicted. It is possible that some isolated contaminated ground could be encountered in some parts of the proposed routes as a result of localised pollution events. However, standard construction working methods for the installation of utilities would be followed. This would include a health and safety risk assessment for site operatives. The assessment would identify the requirement for the use of personal protection equipment and would define operating procedures for working within areas of potentially contaminated ground.

It is considered that the adoption of these mitigation measures (which are based upon standard construction best practice) would prevent any significant effects occurring.

As described previously the contractor would undertake a health and safety risk assessment to identify any potential impacts on site operatives from contaminated material. The risk assessment would identify the requirement for the use of personal protective equipment by site operatives.

If any contaminated material was identified during the excavation works it would be disposed of at an appropriately permitted waste disposal facility.

Surface Waters and Flood Risk

The proposed grid connection / heat pipe installation route options are not considered likely to result in an increased flood risk as a result of the loss of floodplain, increased surface water run-off, or by affecting transmission of surface water flows during flood events.

The construction works would involve the excavation of soils and use of plant and machinery. As such, there is the potential for surface water pollution from suspended sediment, oils, lubricants or fuels.

The works would also not involve construction adjacent to any watercourses and standard best practice construction measures would be implemented to prevent pollution incidents occurring.

Best practice measures would be adopted during the excavation works in line with CIRIA C532 Control of Water Pollution from Construction Sites’.


Noise and Vibration

Sources of noise that may arise from the construction works include mechanical excavators, road breakers with air compressors, mechanical road saws, tipper trucks with grab buckets, other general site vehicles and portable power generators for traffic control signals.

Typical construction hours for these works would be between the hours of 07:00 to 19:00. The nature of the work is not dissimilar to those that would be expected from routine road maintenance or replacement / repair of other utilities.

The proposed works would be carried out in close proximity to a relatively small number of residential properties, but would be similar in nature to standard road maintenance activities or replacement / repair of other utilities and no abnormal noisy operations such as piling are proposed. The proposed works would be undertaken during the day time within areas with elevated background noise levels associated primarily with existing road traffic. Furthermore, the proposed works would only be temporary in nature.

The application of best practice attenuation measures in accordance with BS5228 (2009) would assist in significantly reducing any impact (i.e. using equipment that is regularly maintained and where practicable using equipment that is fitted with silencers and hoods).

On the basis that the construction works would be temporary, carried out during the daytime, within areas where receptors are likely to experience elevated noise levels and would be carried out in accordance with best practice in accordance with BS5228 (2009), it is considered that the effects would be minor. Thus, no significant effects are predicted in respect of noise disturbance to residential properties.

No significant sources of vibration are anticipated in association with the construction methods proposed.

Noise attenuation measures would be applied at all times to plant and equipment to follow industry best practice and conform to BS5228.

Air Quality

Excavation of the trenches would have the potential to give rise to the release of fugitive dust during dry and windy conditions. However, given the minor scale of the works such impacts would not be significant and are unlikely to have any significant adverse effects on residential or ecological receptors. As such, no mitigation is proposed or necessary.

No mitigation is considered necessary

Archaeology and Cultural Heritage

On the basis that the construction works would be temporary in duration and would only involve activities that are often experienced along road corridors, no indirect effects on setting of heritage features are considered likely to arise from the construction of the various trenches.

In addition, as the cable would be buried underground no permanent indirect setting impacts would result from the construction of the proposed cable route.

With regard to buried archaeology, as stated above, the trench would be positioned

It is proposed that in the event that unforeseen buried archaeology is encountered during the works, it would be adequately mitigated through a programme of archaeological works, recording and reporting to the Council’s Archaeologist.


within the existing highway boundary and the cabling works would take place at similar depths to other utility runs. The land within and immediately adjacent to the highway would have been previously disturbed as a result of the road construction. Whilst some potential for the disturbance of buried remains exists, this is considered highly unlikely and as such, the impacts associated with the construction of the trenching are considered to be negligible.

1488-01 / PLANNING APPLICATION DOCUMENT MILLERHILL RERC MARCH 2015 456

16.4 Residual Effects and Conclusion

16.4.1 The proposed grid connection works would involve the laying of

approximately 3.1km of underground cable within the footprint of existing

metalled highways and other areas of hardstanding. This would link the

Millerhill RERC development to the Niddrie primary sub-station and facilitate

the export of electricity. The heat pipe network installation is likely to

comprise of a trench excavation and the laying of a double pipe which would

convey hot water to potential heat users and provide for water to be returned.

Potential heat users include: future residents, commercial premises and

public buildings within the SNCD; the Queen Margaret University; the Royal

Infirmary of Edinburgh and existing and future residents within Craigmillar.

The heat pipe trench would also lie wholly within metalled highways and

other areas of hardstanding.

16.4.2 A CEMP would be prepared as part of the Millerhill RERC project and would

include the construction works associated with the grid connection and heat

pipe installation. The CEMP would include standard best practice measures

that would help to avoid or reduce impacts from the construction works.

16.4.3 The environmental impacts associated with the underground cabling and

heat pipe installation works would be temporary and as the development

activity would be limited to metalled highways or other hardstandings,

impacts are considered likely to be similar in nature to those that arise from

minor highways maintenance works. On this basis, implementation of

standard best practice construction methods is likely to avoid any significant

environmental impacts arising. A number of such methods have been

identified.

16.4.4 In considering the results of this assessment, it can be concluded that the

proposed grid connection and heat pipe installation works would not give rise

to any significant adverse residual environmental impacts


17.0 HUMAN HEALTH

17.1 Introduction

17.1.1 A Human Health Risk Assessment (HHRA) has been prepared in relation to

the Proposed Development (See Appendix 17-1) and provides information on

the likely impact on the health of local communities as a result of its

construction, operation and decommissioning.

17.1.2 As set out in Chapter 2.0 the assumed baseline position for the assessment

is that the AD Facility, SNCD and the Borders Railway are all built and

operational.

17.1.3 With regard to the assessment of human health, it is not considered that

either the SNCD or the Borders Railway would give rise to any significant

emissions of pollutants that would give rise to impact upon human health and

as such, they have not been modelled.

17.1.4 With regard to the AD Facility, the only emissions to air that are common with

the Proposed Development and would therefore need to be considered in this

Chapter are Oxides of Nitrogen, Sulphur Dioxide and Carbon Monoxide. The

emission of these pollutants in combination with those released by the

Proposed Development has already been assessed within the AQA (Chapter

12.0 and Appendix 12-1), which concludes that the effect of the

aforementioned pollutants on air quality would be insignificant. On this basis,

they would not give rise to any significant effects on Human Health.

17.1.5 Aside from the aforementioned pollutants all other remaining compounds of

potential concern (COPCs) to the assessment of Human Health would be

emitted by the Proposed Development. As a consequence, the remainder of

this ES Chapter focuses solely on the potential human health effects of the

other pollutants released by the Proposed Development (i.e. those listed in

Section 2.3.2 of the AQA in Appendix 12-1) and specifically Dioxins and

Furans as there are no air quality standards set for these COPCs.

17.1.6 HHRAs are applied to proposed developments in order to safeguard the

health of the local population. The assessment has been carried out in


accordance with guidance published by the Scotland and Northern Ireland

Forum for Environmental Research (SNIFFER). This guidance document

sets out six stages for a risk assessment study which are described fully in

Section 17.2.2.

17.1.7 The substances emitted from the stack - termed hereafter the COPCs, can

be considered under the following categories:

Substances for which any effects are more likely to be acute, and which

tend to occur shortly after exposure; these substances can be

subdivided into two groups:

o Acid gases, such as sulphur dioxide, nitrogen dioxide, hydrogen

chloride and hydrogen fluoride; and

o Other substances, such as carbon monoxide and fine particulate

matter.

Substances for which any effects are likely to be chronic, and which

tend to arise from prolonged exposure; these substances can also be

subdivided into two groups:

o Heavy metals; and

o Semi-volatile and non-volatile organic chemicals, specifically

dioxins and furans and dioxin-like PCBs.

17.1.8 Air quality standards (AQSs) for the protection of human health have been

assigned for the majority of the COPCs emitted from the Proposed

Development. Accordingly, the risks to human health from these have been

assessed as part of the atmospheric dispersion modelling study (see Chapter

12.0 and Appendix 12-1), therefore, no further assessment is considered

necessary. For those COPCs where AQSs have not been assigned, i.e.

dioxins and furans, further assessment has been undertaken using the

United States Environmental Protection Agency’s (USEPA) Human Health

Risk Assessment Protocol (HHRAP) methodology with is one of the methods

approved for use by the SEPA. The assessment has evaluated potential

impacts on human health from potential dioxin emissions, both in terms of the

long-term inhalation, and the overall long-term exposure through additional

viable routes such as the food chain.

17.1.9 The full HRRA can be found Appendix 17-1 and details the specific

methodologies of assessment and determination of significance.


17.1.10 It should be noted that the HHRA uses data obtained from the air quality

assessment and the results of that assessment have been used to inform the

HHRA. Consequently, there will be some duplication of information between

Chapter 12.0 and this Chapter, and reference will also be made to the AQA

contained in Appendix 12-1.

Previous Assessment

17.1.11 As discussed in Chapter 1.0 of this ES, the Application Site benefits from

PPiP (granted in 2012) for the ZWF, comprising:

An EfW Facility;

An AD Facility; and

A MBT Facility.

17.1.12 A HHRA was carried out for the ZWF. In order to address AMSC associated

with the ZWF, the air quality assessment submitted with the PPiP application

was revised in respect of the AD Facility, located immediately north of the

Application Site. Planning permission for the AD Facility was granted in June

2013, and construction was on-going at the time of writing.


EfW and MBT facilities. Given the difference in stack emission parameters

the impacts on human health are likely to be different to those assessed for

the ZWF and hence the current HHRA is required. .


17.1.14 A detailed description of the Proposed Development is provided Chapter 4.0

of this ES. Key aspects of the development that are of relevance to this

HHRA are the COPCs that are emitted from the 75m high RERC main

discharge stack. All discharge stack parameters are fully described in the

AQA in Appendix 12-1.

Legislation and Policy Context


an appraisal of effects on relevant human health policies, as set out in the


adopted statutory Development Plan and other material planning

considerations, are included in the PS (Part 3 of the PAD). Key legislation

and policies relevant to the HHRA are summarised below.


17.1.16 The NPF 3 (2014) highlights the responsibilities of planning authorities to

adhere to sustainable development; this includes the implementation of

policies on health. The document describes how environmental quality is:

“central to our health and wellbeing.”

17.1.17 National planning policy applicable to Scotland is set out in SPP (2014).

Policies of direct relevance to this HHRA include: “The planning system

should support the provision of infrastructure to allow Scotland’s waste and

secondary resources to be managed in one of the nearest installations by

means of the most appropriate methods and technologies, in order to protect

the environment and public health.” (Paragraph 182)

17.1.18 PANS provide advice on good practice and information. PAN 51: ‘Planning,

Environmental Protection and Regulatio’n is of most relevance which states

that: “any consideration of the quality of land, air or water and potential

impacts arising from development, possibly leading to a proven impact on

health, is capable of being a material consideration, insofar as it may arise

from any land use.” PAN 51 does, however, go on to state that: “the planning

authority should have regard to the impact of the proposal on air or water

quality although the regulation of emissions or discharges will fall to be dealt

with under other legislation.”

Industrial Emissions Directive (2010/75/EU)

17.1.19 The key legislation relating to discharges to air from the Application Site is

the IED. The IED prescribes measures relating to the control of emissions

to air and sets limits on emissions of a wide range of air pollutants, for both

normal and abnormal operation.

17.1.20 Chapter IV, Articles 42 to 55, of the IED: Special Provisions for Waste

Incineration Plants and Waste Co-incineration Plants sets out the


requirements that need to be met for the EfW activities that will be

undertaken at the Application Site and are described in Chapter 12.0.

17.1.21 Furthermore, Annex VI of the IED: Technical Provisions Relating to Waste

Incineration Plants and Waste Co-incineration Plants, in Part 3: Air

Emission Limit Values for Waste Incineration Plants; prescribes the limits

that releases to air must meet under both normal and abnormal operating

conditions.

Pollution Prevention and Control (Scotland) Regulations

17.1.22 The SEPAs role is to minimise the harm to human health and the

environment. For industry this is enacted through the Pollution Prevention

and Control (Scotland) Regulations 2000 (as amended). These regulations

implement the requirements of the IPPC Directive, which aims to provide an

integrated approach to pollution control preventing emissions into air, water

or soil wherever practicable. Where the prevention of pollutants is not

practicable, steps should be taken to minimise the emissions.

17.1.23 In order for the Proposed Development to operate it must obtain a permit to

operate under the Pollution Prevention and Control (Scotland) Regulations

2000 (as amended).

17.1.24 The main purpose of the permitting process as a whole is to prevent

emissions where practicable. Where this is not possible, a high level of

environmental protection should be demonstrated. This study aims to

demonstrate that the impact of emissions from the Proposed Development on

human health is acceptable.

17.1.25 As the SEPA does not prescribe any particular assessment for risk

estimation, methods for permit applications for these types of processes

typically follow either the approach developed by Her Majesty’s Inspectorate

of Pollution (HMIP): Risk Assessment of Dioxin releases from Municipal

Waste Incinerators (1996) approach or the USEPA: Human Health Risk

Assessment Protocol for Hazardous Waste Combustion Facilities (EAP530-

R-05-006, September 2005) approach. For this assessment the USEPA

HHRAP methodology has been used.


Regional and Local Policy

17.1.26 The Strategic Development Plan (2013) sets out strategic policies for south-

east Scotland. None of the policies contained therein have direct relevance to

this HHRA.

17.1.27 The Midlothian Local Plan 2008 states that where development proposal

affect any designated site or protected priority habitat or species or other

important non-statutory locations, an appropriate level of environmental or

biodiversity assessment should be carried out. It also notes that mitigation

measures should be included where appropriate.

Air Quality Standards for the Protection of Human Health

17.1.28 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland

(2007) details Air Quality Strategy Objectives for a range of pollutants,

including a number that are directly relevant to this study: Particulate Matter

(as both PM10 and PM2.5), Carbon Monoxide, Sulphur Dioxide, Nitrogen

Dioxide and Benzene.

17.1.29 In addition, the 4th AQDD details Target Values for arsenic, cadmium and

nickel. The EPAQS, which advises the UK Government on air quality, has set

recommended Guideline Values for: Arsenic, Chromium VI and Nickel; the

EPAQS Guideline Value for Nickel is the same as the AQDD Target Value,

but the EPAQS Guideline Value for Arsenic is half that of the AQDD value.

The lowest of these values have been taken into account in this study.

17.1.30 In the case of: Hydrogen Chloride, Hydrogen Fluoride, Chromium (VI) and

Arsenic, EPAQS has set recommended Guideline Values which have been

taken into account in this study.

17.1.31 EQS have been assigned by the SEPA to a number of the other pollutants

assessed in the modelling study; these are detailed (where assigned) in

Appendix D of SEPA Guidance Note H1. These have been derived from a

variety of published UK and international sources (including the WHO).


17.2 Methodology

17.2.1 This assessment evaluates the possible effects on the health of the local

human population likely to be exposed to emissions from the Proposed

Development. The geographic scope of the study is based on the same area

which covers all the sensitive receptors that were used in the air dispersion

modelling study, namely a 10km by 10km grid using the main discharge stack

as a central point.

17.2.2 Given that the assessment is related to exposure through the direct inhalation

of affected air and indirect exposure through ingestion of affected food and

locally grown produce on soil, which may be affected by the deposition and

accumulation of emissions from the proposed facility, the only emissions

relevant to the assessment are those arising from the facility’s main

discharge stack. Fugitive emissions are not considered relevant to this

assessment.

Current Guidance

17.2.3 The study has been carried out in accordance with guidance published by the

SNIFFER. This guidance document sets out six stages for a risk assessment

study namely:

Step 1: Define the legislative context;

Step 2: Hazard identification;

Step 3: Hazard assessment;

Step 4: Risk estimation;

Step 5: Risk evaluation; and

Step 6: Risk management.

17.2.4 In accordance with the recommended UK tiered approach to risk

assessment, the HHRA has considered worst-case scenarios for all receptors

in assuming multiple exposure conditions where all pathways of exposure in

each land use scenario were considered to be viable. Some of these

assumptions are both extremely conservative and also very unlikely, and,

therefore, the assessment is likely to over-estimate any potential impacts.


17.2.5 For the assessment and evaluation, detailed computer modelling has been

undertaken. The basis for the HHRA is predictive modelling using the

ADMS5 atmospheric dispersion model to estimate the likely ground level

concentrations of COPCs and deposition rates for dioxins and furans as a

result of emissions from the Proposed Development.

17.2.6 The methodology for the assessment of dioxin and furan is based on the

USEPA HHRAP which is fully discussed in the HHRA contained within

Appendix 17-1. The Industrial Risk Assessment Programme – Human Health

(IRAP-h View Version 4.1.87), which is based on the USEPA HHRAP, has

been used to calculate the transport and fate of dioxins and furans emitted

from the RERC main discharge stack.

The Study Area

17.2.7 The geographical area considered in the HHRA, together with the locations of

the various sources, is indicated in Figure 2154/F2 in Appendix 17-1.

Approach to Risk Assessment

17.2.8 The approach taken by the IRAP-h View software, which accords with that

set out in guidance, seeks to quantify the hazard faced by the receptor- the

exposure of the receptor to the substance identified as being a potential

hazard and then to assess the risk of exposure, as follows:

Quantification of the exposure – an exposure evaluation that

determines the dose and intake of key indicator chemicals for an

exposed person. The dose is defined as the amount of a substance

contacting the body (e.g. in the case of inhalation, the lungs) and intake

is the amount of the substance absorbed into the body. The evaluation

is based on, worst case, conservative scenarios, with respect to the

following:

o Location of the exposed individual and duration of exposure;

o Exposure rate; and

o Emission rate from the source.

Risk characterisation – following quantification of the exposure, the risk

is characterised by examining the toxicity of the substances to which


the individual has been exposed and evaluating the significance of the

calculated dose in the context of probabilistic risk.

Methodology for Estimating Exposure to COPCs

17.2.9 In order to estimate exposure from the emissions from the facilities

considered in the assessment, the following steps have been undertaken:

Measurement or estimation of emissions from the source - in the case

of the proposed facility, emissions have been based on the relevant

ELVs, and, therefore, are likely to be an overestimate of the actual

emissions;

Modelling the fate and transport of the emitted substances through the

atmosphere and through soil, water and biota following deposition onto

land;

Atmospheric dispersion modelling has been undertaken using ADMS5

(see Appendix 12-1). Concentrations of the COPCs in the

environmental media are estimated at the point of exposure, which may

be through inhalation or ingestion; and

Calculation of the uptake of the emitted substances into humans

coming into contact with the affected media and the subsequent

distribution in the body; this element of the assessment is undertaken

using IRAP-h View.


17.2.10 The purpose of the EIA is to determine the likely significant effects of a

development proposal. It is essential that the likely effects of the Proposed

Development are assessed thoroughly in order for determining authorities to

make an educated decision for the development of the proposal. Not all

emissions produced from the Proposed Development will have a significant

effect on human health, however they must all be assessed.

17.2.11 The Cancer Risk, Hazard Quotient (Non-cancer Risk) and Tolerable Daily

Intake (TDI) are needed to determine significance of effects from the

Proposed Development. These are calculated from the combing the

quantities and toxicology benchmarks for each pathway and receptor.


17.2.12 Cancer risk from exposure to emissions is the probability that a human

receptor will develop cancer, based on a unique set of exposure, model, and

toxicity assumptions. The current UK approach to HHRA utilises a range of

acceptable risk levels ranging from 0.00001 to 0.001 for the different

contaminants and pathways of exposure (for example, a risk of 0.00001 is

interpreted to mean that an individual has up to a one in 100,000 chance of

developing cancer during their lifetime from the evaluated exposure). In the

UK, a risk level of 0.00001 is used for all carcinogenic contaminants

considered in this assessment.

17.2.13 Non-cancer health risks can include acute, or short- term health problems

such as eye irritation, respiratory irritation, and headaches, and chronic, or

long-term problems such as permanent damage to organs, the central

nervous system, or reproductive functions, and developmental problems in

children. on-cancer health risk is defined by a Hazard Quotient (HQ). The

term HQ is used in the IRAP-h View model to describe the risk associated

with the potential for developing non-cancer health effects as a result of

exposure to COPC. The hazard quotient is not a probability but rather a

comparison of a receptor‘s potential exposure relative to a standard exposure

level. The standard exposure level is calculated over a similar exposure

period and is estimated to pose no unacceptable risk in terms of adverse

health effects to potential receptors. Standard risk assessment models

assume that, for most chemicals with non-cancer effects, the non-cancer

effects exhibit a threshold response. This means, there is a level of exposure

below which no adverse effects will be observed. A hazard quotient of less

than or equal to 1 is considered health-protective (USEPA Superfund). For

example, an HQ of 2 means the concentration of toxic substances in the air

at the point of exposure is predicted to be twice as high as is generally

thought to be safe, a HQ of 0.99 or below means the concentration of toxics

in the air at the point of exposure is thought to be safe. The levels defined as

‘safe’ are designed to protect the most sensitive individuals in a population.

17.2.14 The Committee of Toxicity (COT) sets out TDI levels for dioxins and furans

as 2pg TEQ/kg body weight / day. This is then compared with the predicted

total daily intake of dioxins and furans (averaged over a 70 year lifetime) at

each of the sensitive receptors of the Proposed Development.


17.2.15 The effects of the proposed development will be considered significant in the

context of this EIA if they exceed the stated thresholds for impacts upon

human health.

Consultation

17.2.16 The scope of the HHRA is in accordance with the SEPAs requirements and

the SEPA were consulted with reference to the sensitive human receptor

locations, and any other sites to be considered as part of the cumulative

assessment.

17.3 Baseline

17.3.1 The life expectancy of people living in Midlothian in 2008 – 2010 is higher

than the life expectancy of Scotland as a whole. For example the life

expectancy of women at birth in Midlothian is 81.4 whereas in Scotland the

equivalent is 80.9. For men the Scottish life expectancy at birth is 76.8 but in

Midlothian the life expectancy at birth is 76.6. Since 1998 there has been a

steady rise in life expectancy in Scotland and Midlothian. However, the rate

of increase in life expectancy is significantly greater in women than men.

17.3.2 The life expectancy at birth of Edinburgh can also be considered due to the

proximity of the Proposed Development to the city. For central Edinburgh the

life expectancy at birth between years 2009-2013 is 77.5 for men and 81.8 for

women, both of which are higher than the national average.


17.3.3 The PPiP future baseline scenario (refer to Chapter 2.0 for full details)

reflects the fact that a major development located at the Application Site has

been granted planning consent. The assessment of effects in this Scenario

seeks to set out in brief any additional human health effects that would derive

from the Proposed Development, over and above those deriving from the

consented ZWF development which it would effectively replace.






compensate for potential human health impacts.



specific environmental limitations imposed by the planning consent, as well

as relevant legislation, regulations and best practice guidance. The CEMP

would include detailed method statements for specific tasks where

necessary, as described in Chapter 4.0 of the ES. The CEMP would include

details of measures required mitigate the adverse effects of the construction

phase including:

Hard-surfaced haul roads;

Stockpiles of materials that have the potential to generate dust will be

securely sheeted;

Drop heights will be minimised;

Dust suppression, including measures to ensure the correct treatment

of disposal of run-off from dust suppression activities;

No-idling of vehicles;

Effective vehicle cleaning and wheel washing at site exit;

The covering of all loads which have the potential to generate dust;

No site run-off; and

All vehicles and plant will be well maintained.

17.4.3 A whole range of mitigation measures would be incorporated into the

Proposed Development to ensure that there are no unacceptable impacts on

air quality during its operational phase. These would comprise a combination

of design measures and management and operational procedures covering

both the Mechanical Treatment plant and the ERC plant, and would include

those measures detailed below.


Management and Staffing Arrangements

The Proposed Development will have an appropriate management

structure in place and will be suitably staffed; and

It is FCC’s intention that the an integrated management system (IMS)

will be developed at the proposed development; the IMS will be based

on the requirements of:

o The international quality management standard ISO9001; and

o The international environmental management standard

ISO14001, and the international occupational health and safety

management standard OHSAS18001.

17.4.4 These arrangements will ensure that the Proposed Development is managed

and operated to the highest standards at all times:

All operational procedures will be properly documented; this would help

to ensure that the plant is operated in an appropriate manner at all

times; and

All staff will be properly trained in their respective duties; again, this

would help to ensure that the plant is operated in an appropriate

manner at all times;

Operational Measures

General Arrangements

17.4.5 All aspects of the ERC would be controlled by a series of sophisticated

computer control systems which will provide feedback to the plant operators

on the operational status of the ERC at all times.

Mechanical Treatment Plant

All waste coming into the MT plant would be offloaded inside the Waste

Reception Building with the access doors closed;

All internal areas of the MT plant would be kept under negative

pressure; and

When the EFW is not operational (approximately 2 weeks per year) air

from inside the MT plant would not be under negative pressure and


accordingly air from this area will be ducted through a biofilter to control

odour emissions from the plant.

17.4.6 These arrangements will help to ensure that the potential for fugitive dust and

odour emissions form the MT plant would be minimised.

Energy from Waste Plant

All elements of the ERC plant have been designed to meet the


The ERC would incorporate a SNCR system to ensure that NOx are

reduced to a level that will ensure that the emissions meet the


The ERC would incorporate a flue gas treatment stage to remove acid

gases and particulate matter from the gas stream before discharge to

atmosphere; this comprises a lime and activated carbon injection

system and a high specification bag filtration system; again, these

arrangements will ensure that IED requirements will be met in relation

to emissions of particulate matter, sulphur dioxide, hydrogen chloride

and hydrogen fluoride;

The ERC would be equipped with a comprehensive range of

continuous monitoring devices to ensure that the plant operators are

fully aware of the status of the emissions from the plant at all times;

these devices will monitor particulate matter, carbon monoxide, oxides

of nitrogen (NO and NO2, Ammonia, Sulphur Dioxide, VOCs, expressed

as Total Organic Carbon TOC), Hydrogen Chloride, Oxygen, moisture,

temperature, pressure and velocity and flow; the continuous emissions

monitoring data generated by these devices will enable the operators to

adjust and / or shut down the plant if necessary;

The plant will be equipped with a comprehensive series of alarms and

interlock systems throughout; these would provide an indication of any

potential or actual system faults and would, if necessary, automatically

close the ERC down.

17.4.7 It is evident from the measures described above, that the Proposed

Development would benefit from extensive mitigation through a combination

of design, management procedures and operational procedures.


Construction Phase






likely to take place early, within the first 5 months. Erection of building

frames, plant and equipment, and then cladding would follow. Landscaping

and other external works would generally be amongst the last tasks to be

completed.


Application Site, and in the surrounding area, associated with the Borders

Railway, AD Facility and SNCD. The baseline for the HHRA assumes that

this construction activity is complete. The construction of Proposed

Development would introduce potential air quality effects from autumn-2015

until summer 2017 –There would be adverse effects of short-term duration

deriving from this construction activity.

17.4.10 The likely effect on human health from the construction phase would be from

dust (particulate matter) during construction and site clearance operations.

17.4.11 The main sources of dust from the Proposed Development will arise from the

following:

Material handling and removal,

Construction and road traffic passing over exposed soil surfaces and

vehicle exhaust emissions;

Site excavations for foundations and groundwork; and

Batching of concrete on site (if required).

17.4.12 The effects on construction dust are likely to be limited to areas downwind

within 200m of dust generating activities as particulate matter would drop out


of the air at distances less than this. Elevated concentrations of dust are most

likely to occur on dry windy days and areas downwind of the prevailing wind

direction will be affected more frequently.

17.4.13 Mobile plant used would also produce emissions which may temporarily

increase levels of pollutants within a localised area. However, these would be


17.4.14 The nearest sensitive receptors are immediately adjacent to the sites western

boundary (the housing proposed as part of the proposed Shawfair

development), with the measures implemented in the CEMP it is unlikely that

any significant dust emissions would arise.


17.4.15 The construction period for the ZWF development was proposed to occur

between 2013/2014 and 2015/2016 for a period of approximately 24 months.

The details regarding construction in the ES prepared in support of the

application for the ZWF, are limited, and as such, it seems reasonable to

assume construction would involve similar activities to those required for the

Proposed Development. The Air Quality Chapter prepared simply states that

dust emissions during the construction phase effects would be controlled

through formal agreement with the Local Authority, as would be the case with

this planning application.

17.4.16 The difference between the construction phase for the Proposed

Development, as compared with that for the ZWF Development, would be the

increased duration of construction activity. However, as the footprint of the

Proposed Development is smaller, the physical extent of the construction

area will be reduce. As such, the temporary adverse effects of the Proposed

Development would be for a longer duration, but would be of smaller physical

scale and are likely to be quantitatively less on a daily basis. It is not

considered that other aspects of the construction process would result in any

effect that is appreciably different from that would could be anticipated from

the PPiP Development. Accordingly, the effects of the Proposed

Development on human health during the construction phase would be

neutral when compared to the future bassline position.


Operational Phase


17.4.17 The potential effects of the Proposed Development on the health of the local

community have been considered in the context of the potential emissions

from the Proposed Development. Pollutants, excluding dioxins and furans

were subject to comparison with air quality objectives set for the protection of

human health; and dioxins and furans were subject to HHRA using the

methodology as described above.

Pollutants Assessment (excluding Dioxins and Furans)

17.4.18 The maximum pollutant GLC resulting from the emissions from the Proposed

Development have been predicted by the modelling undertaken for the AQA

(see Chapter 12.0). These have then been expressed as a percentage of

their AQSs. The modelling assessment concluded that none of the pollutants

in the releases from the proposed facility wouldl exceed either its short term

or long term AQSs.

17.4.19 In addition to the maximum GLC, the modelling study determines the impacts

at thirty-two potentially sensitive human receptors; the list of receptors

considered is provided in the HHRA report (see Appendix 17-1). The results

of the study indicate that at all of the sensitive receptors, the predicted

pollutant GLCs were significantly less than the maximum predicted pollutant

GLCs. As a consequence, the Proposed Development would not give rise to

any significant effects in this regard.

Dioxins and Furans Assessment

17.4.20 The results of the atmospheric dispersion modelling study were then used to

undertake a HHRA in relation to potential exposure to dioxins and furans.

The HHRA used Industrial Risk Assessment Program Human Health (IRAP-h

View) software, which is based on the USEPA methodology, to calculate the

transport and fate of dioxins and furans that could be in the discharge

exhaust stack gases from the Proposed Development. The full HHRA can be

found in Appendix 17-1.


17.4.21 The following pathways were considered as part of the assessment:

Inhalation (including acute inhalation);

Ingestion of soil;

Consumption of fruit and vegetables;

Consumption of poultry and eggs;

Consumption of meat (beef, pork and fish);

Consumption of cow’s milk and human breast milk; and

Consumption of drinking water.

17.4.22 Members of the local population are only likely to be exposed to significant

effects associated with emission of dioxins and from the Proposed

Development if:

They spend significant periods of time at locations where and when

emissions from the proposed installation increase the concentration of

dioxins / furans above the existing background concentration;

They consume food grown at locations where emissions increase the

concentration of dioxins / furans above the concentration normally

present in food from those locations;

They undertake activities likely to lead to ingestion of soils at locations

where emissions have increased the concentration of dioxins / furans in

the soil above background levels; and

They drink water from sources exposed to increased concentrations of

dioxins/furans above the levels normally present.

17.4.23 The extent of exposure that any person may experience would depend

directly on the degree to which they engage in any or all of the above

activities, and by how much the existing background concentration of dioxins

/ furans increases as a result of the operation of the Proposed Development.

The drinking water pathway is considered to be highly unlikely as very few

people are likely to collect and drink rainwater in the vicinity of the site.

17.4.24 Using the IRAP-h View model, a human health risk assessment for exposure

to dioxins and furans has been undertaken. The following calculations were

undertaken:

Estimates of the combined cancer risks and non-cancer (Hazard

Quotients) for all identified receptors;


Estimates of risk and hazards associated with pathways of exposure;

Evaluation of infant exposure via breast milk to COPCs with appropriate

bio-transfer factors; and

A comparison of the total daily intake of dioxins and furans and dioxin-

like PCBs with the the UK’s Committee on Toxicity of Chemicals in

Food, Consumer Products and the Environment COT* / TDI values.

* Note: The COT is an independent scientific committee that provides advice

to the Food Standards Agency, the Department of Health and other

Government Departments and Agencies on matters concerning the toxicity of

chemicals).

17.4.25 The total cancer risk estimated by the model, based on the air dispersion

modelling prediction of air concentrations and depositions by ADMS5, for the

worst case scenarios maximum emissions from the proposed installation

were calculated. It can be seen from the results in Table 4 of Appendix 12-1

that the highest identified cancer risk is for a Fisher Child at Stoneybank (R4)

- 5.18E-06 or 0.00000543. A risk level of 0.00001 (or 1.00E-05) is used as an

acceptable cancer risk, therefore based on the cancer risks calculated at all

sensitive receptor locations, the estimated cancer risk is well below the UK

acceptable risk of 0.00001. Consequently, it can be concluded that the

cancer risk from the proposed facility is well within acceptable limits, and, no

further assessment is considered necessary. As a consequence, the


regard.

17.4.26 The total hazard quotients estimated by the model, based on the air

dispersion modelling prediction of air concentrations and depositions by

ADMS5 for the worst case scenarios maximum emissions from the proposed

installation were calculated.

17.4.27 The results in Table 5 of Appendix 17-1 indicate that the highest hazard

quotient is for a Fisher Child at Stoneybank (R4) – 2.010E-03 or 0.00201. A

hazard quotient of less than or equal to 1 is considered health protective,

therefore based on the hazard quotients calculated at all sensitive receptor

locations, the hazard quotients are below the health protective value of 1.

Consequently, it can be concluded that the non-cancer risk from the


Proposed Development is well within acceptable limits, and, again, no further

assessment is considered necessary. In light of this, it can be concluded that

the Proposed Development would not give rise to any significant effects in

this regard.

17.4.28 There are no UK or USEPA target levels for acceptable infant exposure.

However, one approach that the USEPA has taken to evaluate whether

dioxins and furans are likely to cause significant health effects is to compare

estimated toxicity equivalency (TEQ) exposures to national average

background exposure levels. In the absence of any UK figures, the average

background exposure level for dioxins/furans in the US is 60pg TEQ kg-1 day-

1 for infants.

17.4.29 The Former Ministry of Agriculture, Forestry and Fisheries (MAFF) in its Food

Surveillance Information Sheet No 105, June 1997 stated that dietary intake

of dioxins/furans by breast-fed infants to be 170pg TEQ kg-1 day-1 at two

months, dropping to 39pg TEQ kg-1 day-1 at 10 months. It is interesting to

note that, despite the high intakes of dioxins/furans experienced by nursing

infants (intake of an adult being approximately 1pg TEQ kg-1 day-1), the

impact of breast-feeding on infant body burden of dioxins/furans is markedly

less dramatic. Peak infant body burdens are only around twice those of an

adult, a consequence of the infant’s rapidly expanding body weight and lipid

volume, as well as a possibly faster elimination rate.

17.4.30 The predicted average daily dose (ADD) associated with the Proposed

Development for each of the infant receptors has been compared with this

background level in order to assess the impact on breast-fed infants from

exposure to the sum of all dioxins via ingestion of their mother’s breast milk.

17.4.31 The data in Table 6 and 7 of Appendix 17-1 indicates that the highest ADDs

are calculated for Fisher Infant at Stoneybank (0.478pg COPC/kg/ body

weight/day), and equates to 0.80% of the USEPA criteria (i.e. 60pg/day

intake), 0.28% of a 2 month old infant (i.e. 170pg/day intake) and 1.23% of 10

month old infant (i.e. 39pg/day intake) respectively, based on the MAFF

criteria. Consequently, the Millerhill RERC will not pose a significant risk via

the ingestion of breast milk. In light of this, it can be concluded that the



regard.

17.4.32 The predicted total daily intake of dioxins and furans (averaged over a

lifetime (70 years)) has been compared against the COT total daily intake

value of 2pg TEQ/kg body weight/day at each of the sensitive receptors.

17.4.33 The total predicted total daily intake of dioxins and furans varies depending

on receptor type and location, ranges from 0.000043pg TEQ/kg body

weight/day for the resident child scenario at Dalkeith High School to

0.0905pg TEQ/kg body weight/day at Stoneybank. All values are less than

the COT total daily intake value of 2pg TEQ/kg body weight/day, and,

therefore, the Proposed Development would have negligible impact on

human health with regard to intake of dioxins and furans.

17.4.34 The background level of dioxins and furans within the area of assessment is

not known; therefore it is not practically feasible to quantify the total

concentration (i.e. the background plus the contribution from the Proposed

Development) at each receptor point. The highest estimated concentration of

dioxins and furans in soil due to the Proposed Development have been

calculated and compared to UK rural (4.7ng TEQ/kg) and urban (9.19ng

TEQ/kg) soil concentrations.

17.4.35 The highest predicted soil level is predicted to be 0.340ng TEQ/kg at Queen

Margret University Halls. This is less than 8% of the rural mean soil level, and

less than 4% of the urban soil level identified in the 2007 survey.

Consequently, it would not constitute a significant additional burden in the

context of the variability of soil levels of dioxins and furans.


17.4.36 The HRA for the ZWF was incorporated into the AQA. It concluded that the

predicted concentrations would be within the relevant air quality objective and

guidelines, as is the case with this application. In addition the PPiP dioxin and

furan assessment estimated that the highest forecast level of exposure would

be 5.5% of the tolerable daily intake. The highest forecast level of exposure

resulting from the Proposed Development would be 4.5% of the tolerable


daily intake. Consequently, it can be concluded that there effect on human

health would be lower using the Proposed Development compared to the

PPiP scheme.


17.4.37 The decommissioning stage of the project would be similar to the

construction phase. The main effects on human health will be from dust

(particulate matter) which would be generated during any demolition of

buildings and site clearance operations.

17.4.38 As with the construction phase, it is likely that the effects of dust would be

limited to areas downwind and within 200m of dust generating activities.

Elevated concentrations of dust are most likely to occur on dry windy days

and areas downwind of the prevailing wind direction would be affected more

frequently.

17.4.39 Mobile plant used will also produce emissions which may temporarily

increase levels of pollutants within a localised area. However these would be


17.4.40 The nearest sensitive receptors are directly adjacent to the western boundary

of the Application Site (associated with the SNCD). As part of the PPC Permit

the site would have to be decommissioned in accordance with a Site Closure

Report which would include dust control measures. Consequently, in the

event that emissions of dust arise they will be controlled in such a manner to

prevent a risk to human health. Accordingly, there will be no significant

effects during the decommissioning phase.



landscape and visual effects








Proposed Development would be as set out in Section 17.4 above

17.7 Conclusions

17.7.1 An assessment of the likely significant effects on the health of humans due to

emissions from the Proposed Development was undertaken. This was

focused on COPCs including acid gases, metals, and dioxins and furans for

which any effects are likely to be chronic arising from prolonged exposure.

17.7.2 The methodology for the assessment of all pollutants with the exception of

dioxins, furans, was based on a comparison of the predicted maximum

ground level concentrations, including background air quality levels, i.e. the

predicted environmental concentrations, with the relevant air quality

standards which are set for the protection of human health. This assessment

also included the agreed EIA baseline which includes emissions from the

ADFacility.

17.7.3 The results demonstrated that the process contributions from the Proposed

Development and the existing background combined with the relevant

emissions from the AD Facility would not result in any predicted

environmental concentration values that exceed air quality standards.

Consequently, it can be concluded that there would be no significant effect on

human health from these COPCs.

17.7.4 In the absence of UK protocols for the assessment of dioxin/furan effects on

human health, and further to consultation with the SEPA, the USEPA


methodology Human Health Risk Assessment Protocol 2005 was used

utilising the commercial software IRAP-h View.

17.7.5 A conceptual model was constructed for the site identifying all viable sources,

receptors and pathways of exposure relevant to each of the receptors.

17.7.6 COPC concentrations in the different receiving media were calculated from

the particle phase and vapour phase air concentrations and deposition to the

soil and surface water courses. The estimated concentrations were based on

a number of conservative assumptions to ensure that worst-case scenarios

were assessed.

17.7.7 To identify the level of potential risk from exposure to each COPC in all

relevant pathways of exposure, the hazard quotients for each medium were

calculated. Potential cancer risk was also estimated and compared with

relevant acceptable risk levels.

17.7.8 The modelling has demonstrated that the cancer risks and hazard quotients

for all receptors are below levels set for the protection of human health, and

the total dioxin intake is less than the health protective level of 2pg/day.

Consequently, the potential health impact on receptors in the vicinity of the

Proposed Development is not considered significant

17.7.9 It has also been concluded that there effect on human health would be lower

for the Proposed Development than the future baseline represented by the

ZWF.

17.7.10 It is, therefore, concluded that potential exposure to emissions from the

Proposed Development would not pose unacceptable risk to receptors

identified in the assessment area.

17.8 References

17.8.1 All references used can be found in the HHRA in Appendix 17-1.


18.0 SUMMARY OF EFFECTS

18.1 Introduction

18.1.1 This ES describes the Millerhill Recycling and Energy Recovery Centre

(Millerhill RERC) development and provides an assessment of the likely

environmental effects that may arise from the construction and operation of

the facility.

18.1.2 The Proposed Development would comprise a purpose built integrated waste

recycling and recovery plant situated on the former Millerhill Marshalling

Yards, Whitehill Road, Dalkeith. It would have an installed electricity

generating capacity of approximately 13.45 Megawatts (MW) and would

generate electricity by way of a steam turbine, which would be driven through

the combustion of 189,471 tonnes per annum (tpa) of non-hazardous residual

waste, the majority of which would be municipal waste. A proportion of the

waste treated at the facility would be commercial and industrial wastes similar

in composition to the municipal waste. The facility would be capable of

delivering Combined Heat and Power (CHP) with the turbine equipped with

steam extraction points enabling export of heat to local heat users, it would

also allow for the recycling of ferrous and non-ferrous metals.

18.1.3 The scope of the ES was agreed in consultation with Midlothian Council and

other relevant technical bodies. The potential effects of the proposals are

described fully within the Main Report (Volume 1) with supporting data for the

assessments bound separately within the Technical Appendices (Volume 2).

A Non-technical Summary (Volume 3) is also provided.

18.1.4 The potential effects of the proposals, as identified in the ES, are

summarised below.

18.2 Traffic and Transportation

18.2.1 Chapter 6.0 provides an assessment of the highways and transport related

environmental impact of the Proposed Development. The assessment relies

on the findings of the formal Transport Assessment (TA) that has been

submitted in support of the Planning Application.


18.2.2 The potential highways and transport related environmental impact of the

operation of the proposed facility has been assessed via reference to the

methodology set out in the Institution for Environmental Management &

Assessment (IEMA) document: Guidelines for the Environmental Assessment

of Road Traffic.

Construction Impacts

18.2.3 Traffic impacts associated with the construction of the site would be

temporary in nature and are likely to vary over the course of the construction

period dependent upon the nature of activities taking place. It is proposed

that a Construction Traffic Management Plan should be prepared (under the

control of a planning condition). This would form part of the Construction

Environmental Management Plan.

18.2.4 Construction of the Proposed Development would not generate a material

level of HGV demand. None of the construction phases are anticipated to

generate HGV levels in excess of those associated with the day to day

operation of the Proposed Development or indeed, those HGV thresholds

already established as being acceptable with respect to the Zero Waste

Facility (ZWF).

18.2.5 Appropriate levels of staff parking would be provided on site to avoid any

potential issues of overspill off-site parking on local routes, with the levels of

staff vehicle demand to be controlled by travel management initiatives such

as car sharing and off-site bus transfer where practical.

18.2.6 Maximum construction periods could result in the requirement for up to 288

staff to be based at the site. Such peak staff demand levels would not be

experienced across the full extent of the construction programme, being

typically related to the building fit out / installation phases. Indeed,

construction staffing levels of over 200 workers are only anticipated to occur

for approximately a quarter of the construction programme. Furthermore,

during these intensive staff demand periods, HGV construction traffic would

be at typically low levels (circa 20-30 HGV arrivals per day).


18.2.7 Such combined peak daily construction traffic demand including for maximum

predicted staffing levels has been demonstrated as falling well within industry

standard screening thresholds for the assessment of operational and traffic

related environmental effects. It can therefore only be concluded that the

traffic and transport related environmental effects associated with the

construction of the Proposed Development would not be significant.

Operational Impacts

18.2.8 The traffic levels associated with the extant waste management consent (for

the ZWF) have established an acceptable threshold for traffic volumes

associated with development at the proposal site, below which traffic demand

has been demonstrated via formal environmental assessment as not likely to

give rise to discernible network operational or traffic related environmental

concerns.

18.2.9 The combined operation of the Proposed Development and the currently

under-construction AD Facility would result in substantially less development

related traffic demand (both in terms of overall vehicle numbers and,

importantly, HGV trips), when compared to the consented ZWF. There can

therefore be a high degree of confidence that the day-to-day operation of the

Proposed Development would also not give rise to material traffic related

operational or environmental effects. Indeed, delivery of the Proposed

Development would result in an overall ‘net benefit’ in traffic and transport

effects when compared against the current reference planning position. In

light of this, it is concluded that the traffic related environmental effects of the

day to day operation of the Proposed Development would not be significant.

18.3 Landscape and Visual Impact

18.3.1 Chapter 7.0 provides an assessment of the landscape and visual impacts of

the Proposed Development. The methodology used to carry out the

assessment is based upon that set out in Guidelines for Landscape and

Visual Impact Assessment (3rd edition 2013, Landscape Institute and Institute

of Environmental Management and Assessment).



18.3.2 In overall terms, whilst there would undoubtedly be short term visual effects

during the construction phase, their temporary nature would not result in any

significant effect.

18.3.3 Effects upon landscape character would be set in the context of existing

development associated with the Borders railway, AD Facility and the

Shawfair New Community Development (SNCD). Current construction

activity is evidenced at several sites within the broader area. As such, whilst

the proposed development would introduce new construction activity the

construction activity is not unusual in the wider area and in that context; the

temporary and localised effects of the proposed development would not be

significant.

Operational Impacts

18.3.4 The overall effects upon the landscape fabric would not be significant. The

development would change the site from a vacant brownfield site with young

poor quality woodland, to an operational industrial facility with only a

proportion of the site covered in vegetation. The reduced amount of

vegetation cover within the site would be adverse, but the greater diversity of

vegetation and the enhanced management of the landscape fabric would be

beneficial.

18.3.5 Effects upon landscape character would not be significant in EIA terms. The

Proposed Development would be introduced into an urban fringe landscape

where the presence of built development, including electricity pylons and

road corridors is already strong, and will be even more so with the addition of

the new Borders railway, AD Facility and SNCD (all of which form part of the

LVIA baseline). Whilst the Proposed Development would be larger and more

visually apparent than other existing features the influence of the

development upon the wider character would nonetheless be limited, due to

the very strong influence of built features in the baseline landscape.

18.3.6 Significant visual effects (in EIA terms) would be experienced from only one

of the sixteen viewpoints assessed (at the western edge of Old Craighall).


The ES for the consented ZWF development also found that there would be

significant effects from this location. Whilst effects would be significant,

views from the majority of the residential properties would be oblique or

obscured by other properties. It must also be noted that the parcels of land

situated between Old Craighall and the existing marshalling yards (to the

immediate east of the Application Site) have been allocated for mixed-use

development in the emerging East Lothian Local Development Plan. As

such, whilst it cannot be guaranteed that development will come forward,

there is a strong likelihood that the view will change significantly in the short

to medium term, with much of the foreground likely to take on an urbanised

character and with the Proposed Development becoming partially screened

and a much less conspicuous component of the view as a result.

18.3.7 More generally, visual effects would not be significant. Views available are

defined by the presence of built development, including large-scale urban

settlement, industrial / commercial buildings, major trunk roads and

prominent embankments (particularly the A1). The presence of the Shawfair

New Community development will increase the visual influence of built

development and will restrict views of the Proposed Development from

nearby locations. In this context, the Proposed Development, whilst

generally visible over a wide area, would have only a limited influence upon

the views available, which would remain characterised by the presence of

built development and road traffic.

Assessment against Future Baseline Scenario

18.3.8 When contrasted with the landscape and visual effects identified for the

consented ZWF development, the significant effects of the Proposed

Development would be less extensive, due to the on-going changes in the

surrounding area and the spread of built development, including the AD

Plant, Borders Railway and Shawfair New Community Development. The

presence of these developments changes the context of the receiving

landscape and greatly increases the influence of buildings and other

structures upon it. Hence whilst the Proposed Development would be a

larger structure than the PPiP development, it would have a lesser effect

upon its surroundings.


18.4 Ecology and Nature Conservation

18.4.1 Chapter 8.0 provides an assessment of the ecological impacts of the

Proposed Development. The ecological assessment is based on evaluation

of local nature conservation records and the results of surveys carried out in

support of the application for the ZWF (Phase 1 Habitat and Invasive Plants

Survey, Lower Plants Survey, Breeding Bird Survey, Bat Survey Reptile

Survey Badger Survey), update surveys carried out in 2013 (vegetation

survey, Invasive Species Search, Bat Survey, Breeding Bird Survey and

Badger Survey); surveys commissioned in connection with the AD plant in

2012 and an extended Phase 1 Habitat Survey undertaken specifically for the


18.4.2 This impact assessment follows the methodology set out by the Institute of

Ecology and Environmental Management (IEEM 2006).


18.4.3 Construction works would result in loss of habitats including the loss of 2.3ha

of lowland mixed deciduous woodland habitat; the degradation of bat foraging

habitat over the site (albeit in an area with relatively low bat activity); the

displacement and loss of nesting habitat for up to 14 territories of five

woodland breeding bird species, including seven territories of an Amber List

species, willow warbler; and the displacement of common lizard from the site

and its surroundings. Without mitigation these impacts would vary between

moderate and minor adverse significance.

18.4.4 It is considered that the impacts during the construction phase would be

compensated through the implementation of the landscape scheme,

supported by a long term management plan targeted at key species and

habitats including birds and the creation of habitat for common lizard.

Measures would also need to be incorporated in the Construction

Environmental Management Plan to protect common lizard and breeding

birds in accordance with species protection legislation and policy.


18.4.5 Following implementation of these measures the development would only

give rise to minor residual effect that would not be classed as significant in

ecological terms.

Operational Impacts

18.4.6 The operational phase of the Proposed Development would not result in any

additional direct impacts in terms of land-take and consequent habitat loss.

Potential indirect adverse impacts during the operational phase may arise

due to the ecological effects of lighting, noise, human disturbance and

emissions to air and water.

18.4.7 A detailed assessment of air quality impacts has demonstrated that the

development can proceed without a likely significant effect on European

conservation sites. This has been determined both by dispersion modelling

and by the assessment of the ecological status and sensitivity of Firth of

Forth SPA / Ramsar site / SSSI. No significant effects were identified in

relation to other interest features during the operation of the Proposed

Development.


18.4.8 The ecological assessment for the ZWF (Chapter 9 of the ES) reached

broadly similar conclusions on impact significance despite some differences

in assessment methodology. Impacts on woodland habitats and breeding

birds were assessed as slight / moderate adverse significance, based on a

matrix approach which valued the features as having ‘low’ value and the

impact magnitude as ‘moderate’. Given the greater scale of impact on these

features (e.g. loss of 39 breeding bird territories), the impacts of the ZWF

could be regarded as having a higher ecological significance than the


18.5 Geology and Hydrogeology

18.5.1 Chapter 9.0 provides an assessment of the geology, hydrogeology and

ground conditions impacts of the Proposed Development. As part of the

consideration of ground conditions the assessment considers the geological


setting, designated geological sites, contaminated land, hydrogeology, geo-

hazards and geotechnical issues associated with the Proposed Development

and the Application Site.

18.5.2 The assessment has been based on the information gathered from a number

of desk study and ground investigation reports undertaken at the Application

Site and on the adjacent areas.

18.5.3 The only historical land uses that have been identified at the Application Site

are those associated with the construction, operation and removal of the

marshalling yards. No remediation measures have been carried out.


18.5.4 No significant impacts were identified by the assessment. However, there

remains the potential for some contamination to be present. As such, it is

recommended that standard best practice construction methods are

employed to ensure that site operatives are not exposed to contaminants that

may remain at the Application Site.

18.5.5 Measures to prevent the contamination of soils or groundwater during the

construction phase are recommended e.g. procedures for dealing with

accidental oil and fuel spillage and dust suppression. These measures would

be fully detailed within the Construction Environmental Management Plan.

Operational Impacts

18.5.6 With the implementation of mitigation measures during the construction of the

Proposed Development, no significant operational impacts have been

identified.


18.5.7 No additional impact or risks will be associated with the Proposed

Development compared to those identified in the ZWF development. Thus,

the development would have a neutral impact when compared with the future

baseline position.


18.6 Surface Waters and Flood Risk

18.6.1 Chapter 10.0 provides an assessment of the surface water and flooding

impacts of the Proposed Development. The assessment has been based on

the information gathered from the ground investigation desk study,

topographic survey, the SEPA data and previous flood risk assessments

undertaken at the Application Site.


18.6.2 Potential adverse impacts associated with the construction phase include the

potential for pollution of the drainage ditch from suspended solids, oils and

hydrocarbons, cement and concrete products, heavy metals and metalloids,

bentonite and solvents/paints among others. Standard best practice

construction methods would be implemented at site to ensure that no water

quality impacts result from the construction works. These would be

documented in the Construction Environmental Management Plan and would

include measures such as storage of fuel, oils and chemicals in bunded

areas and use of settlement lagoons.

Operational Impacts

18.6.3 The proposed development does not lie within an identified area of flood plain

and the assessment has shown that there is ‘low risk’ of flooding from all

sources. As such the risks posed to the development from fluvial and

groundwater flooding sources are considered to be negligible.

18.6.4 The infrastructure serving the proposed development has been designed

using criteria, pre-agreed as part of the ZWF development, to ensure that the

resulting flows do not exceed those envisaged during the design of the off-

site infrastructure. Given that runoff from the site will be restricted to a pre-

agreed peak flow rate that cannot be exceeded, irrespective of the statistical

infrequency of storm events, it has been concluded that the residual effect

upon downstream properties is minor beneficial.

18.6.5 The proposed development would not affect the water quality of the

surrounding area as a result of the infrastructure that would be installed to


service the site e.g. appropriately designed storage areas for fuels, chemicals

and oils and provision of interceptor tanks within the surface water drainage

system.


18.6.6 When assessed against the Future Baseline conditions, which assume that

the proposal site has been developed for the approved alternative waste

management facilities, it is evident that there would be very little difference

between, the scale of the facilities; the construction practises that would be

employed; and the drainage infrastructure that would be installed to serve

each development scenario. As a consequence, it is considered that the

Proposed Development would have a neutral effect in terms of flood risk and

surface water impacts.

18.7 Noise and Vibration

18.7.1 Chapter 11.0 provides an assessment of the noise and vibration impacts of

the Proposed Development. To establish any likely impact from noise a

baseline noise survey was undertaken to establish the existing noise climate

at the site. Relevant and appropriate noise guidance and standards have

been used to determine the potential noise impact from the proposal. Impacts

from both the plant operations and vehicle movements have been assessed.

Observations undertaken during the monitoring indicate that the local noise

climate is influenced by road traffic movements and intermittent aircraft noise.


18.7.2 The assessment of potential noise effects during the construction phase has

shown that there is a potential for construction noise to cause moderate

adverse effects at the nearest noise sensitive receptor to the development

site (Shawfair Area D). However, it should be noted, that this assessment

assumes (in accordance with the baseline for assessment) that development

would be implemented and occupied as a sensitive receptor prior to the

commencement of construction works. The reality is that the development

within Shawfair area D is not expected to commence until after the Proposed


Development has been constructed. Accordingly, the predicted impact for

construction is deemed to be robust and pessimistic.

18.7.3 An assessment of potential vibration effects has indicated that receptors in

the vicinity of the site would not be adversely affected by vibration inducing

construction activities and therefore would not result in a significant impact.

Operational Impacts

18.7.4 During the operation of the site it is concluded that with the implementation of

appropriate mitigation within the detailed design, there would be no

significant effects from the facility.

18.7.5 The assessment has shown that the facility would be within appropriate

guidance, standards and the limits Midlothian Council intend to impose

through a planning condition. Accordingly, the predicted noise levels are not

expected to cause a significant impact to the current noise climate at

surrounding residential and commercial receptors.

18.7.6 The assessment of noise change due to variation in traffic flows on the local

road network has shown that the noise levels would not result in a significant

impact. In addition, ground-borne vibration from the operation of the site or

from HGVs, would also not result in a significant impact.


18.7.7 The noise impacts predicted for the ZWF development indicate that the noise

levels from the site would not exceed background sound levels +5dB and the

combined effect of the AD Facility, EfW and MBT Facility would not exceed a

design limit of background sound +5dB. The assessment concludes that, in

terms of residual noise, the ZWF development would give rise to

environmental effects of negligible to minor adverse significance. The noise

predictions from the Proposed Development show noise levels to be below

existing background sound levels and based on a worst case assessment,

would only give rise to a negligible to minor impact. In light of this, it can be

concluded that the Proposed Development would only give rise to a ‘neutral’

impact when compared to the future baseline scenario.


18.8 Air Quality and Human Health

18.8.1 Chapter 12.0 provides an assessment of the air quality impacts of the

Proposed Development. The assessment has identified that the operation of

the facility would give rise to a number of substances that would be emitted to

the atmosphere. As a result, the potential environmental effects of these

emissions have been assessed using detailed dispersion modelling. The

results of the modelling have been assessed against relevant air quality

objectives and guidelines identified from national legislation and the SEPA’s

guidance documents.

18.8.2 The assumptions that have been adopted to determine the predicted

emission levels from the plant, maximum ground level concentrations and

background levels in the vicinity of the plant have been based on a ‘worst-

case’ scenario.


18.8.3 During the construction there would be the potential for short-term effects to

occur, mainly in the form of dust emissions generated by earthmoving

activities.

18.8.4 Standard best practice construction methods would be implemented at site to

reduce emissions to the air. These would be documented in the Construction

Environmental Management Plan and would include measures such as use

of water mists during dry periods, closed sheeting of vehicles and washing of

road surfaces leading to the construction site. With the implementation of

these measures no significant construction impacts are anticipated.

Operational Impacts

18.8.5 The results of the modelling have indicated that the proposed stack would

provide more than adequate dispersion to atmosphere and that the operation

of the facility is predicted to have a negligible impact on local air quality or

sensitive habitats. As a result, no significant effects on air quality are

predicted.



18.8.6 An assessment has also been carried out of the Proposed Development

against the future baseline position associated with the ZWF development.

The assessment concluded that in relation to air quality the effects of the

Proposed Development during its construction, and operation would be

‘neutral’.

18.9 Cultural Heritage

18.9.1 Chapter 13.0 provides an assessment of the cultural heritage impacts of the

Proposed Development. The assessment includes an appraisal of cultural

heritage resources in a study area of 2km (for all cultural heritage features

recorded on the Historic Environment Gazetteer) and 5km (all World Heritage

Sites, Scheduled Monuments, Grade I and Grade II* Listed Buildings and

Registered Parks and Gardens, excluding Historic Environment Record

data).


18.9.2 Due to past development of the Application Site from the mid-20th century

onwards, it is likely that any archaeological remains that may have been

present have been removed. As such, it is considered that the construction of

the Proposed Development would have no direct or indirect impact on known

or potential cultural heritage receptors within the Application Site

Operational Impacts

18.9.3 A number of cultural heritage receptors were identified in the surrounding

landscape, these included Grade A listed buildings and Scheduled

Monuments. The operation of the facility would not result in any direct

impacts on the identified cultural heritage receptors but the facility does give

rise to potential indirect impacts on setting.

18.9.4 The assessment has concluded that the facility would result in minor-

moderate residual impacts on the setting of seven cultural heritage receptors

in the area surrounding the site and minor residual impacts on the setting of


twenty-one cultural heritage receptors, these impacts are not considered to

be significant.


18.9.5 There would be no material difference between residual effects for the ZWF

development and the Proposed Development and the difference between the

effects resulting from the two developments is considered to be neutral.

18.10 Socio-Economic Effects

18.10.1 Chapter 14.0 of the ES considered the socio-economic and community

effects of the Proposed Development. It identified background information

from Edinburgh, Midlothian and its districts and wards, in particular Dalkieth

Ward, within which the Application Site is located. It then identified the main

socio-economic and community effects of the Proposed Development.

18.10.2 The key issue addressed in the assessment was to understand the existing

situation and consider whether the proposed development would result in any

adverse socio-economic impacts.


18.10.3 The construction of the facility would take circa 28 months to complete and

would provide up to 300 temporary jobs with an average of circa 180-200

over the entire construction period. It is expected that a large proportion of

these temporary jobs would be locally sourced.

18.10.4 The assessment estimates that of these jobs approximately 50 could be

secured during the construction period by local contractors and workers. In

addition there could also be further benefits locally for some businesses (food

and drink, accommodation providers) that may ultimately benefit as a result

of any temporary visiting workforce.

18.10.5 The socio-economic effects of the construction phase of the Proposed

Development are judged to have moderate beneficial effects in the impact

area.


Operational Impacts

18.10.6 During the operational phase the facility would create 39 new permanent

jobs. The majority of the employees would be skilled operatives

(electricians/fitters/crane operatives) or technical engineers (control and

plant), with a small number of low skilled jobs also created. It is anticipated

that a new apprenticeships would be provided through FCCs apprenticeship

scheme.

18.10.7 Once indirect and induced employment impacts are also considered, it is

estimated that the energy centre could support 50 permanent FTE jobs within

the area. This has the potential to lead to an annual GVA impact of circa

£3.8M per annum. The development would also offer local supply chain

opportunities for local businesses.

18.10.8 Community benefit would also be provided as a result of the integrated visitor

and education centre within the facility. The centre would be a valuable

education resource and would provide local residents with information on the

operation of the facility and educate school children on sustainable waste

management and taking responsibility for their own waste. The visitor centre

would also available for use by other local groups as a meeting space.

18.10.9 In addition the plant would provide a local sustainable renewable source of

energy that would meet the domestic needs of circa 26,000 homes and

produce saleable by-products, in the form of recycled metals and bottom ash

which would be taken off site and re-processed as a secondary aggregate. It

would also offer significant potential to form the primary source of heat for a

district heating network.

18.10.10 The proposal would not have any significant adverse impact further to the

existing situation. The proposal would in fact create a number of social and

economic benefits for Edinburgh and Midlothian and its residents.


18.10.11 The ES prepared in support of the ZWF development concludes that it would

give rise to a number of beneficial socio-economic effects. The anticipated


residual socio-economic effects associated with the Proposed Development

have also been assessed as being of beneficial significance. Accordingly,

when compared to the future baseline scenario, the Proposed Development,

as a minimum, result in a neutral impact.

18.11 Cumulative Effects

18.11.1 Chapter 15.0 of the ES considered the potential cumulative effects of the

Proposed Development. Two projects were identified that could have the

potential to result in material cumulative effects with the proposed

development. The assessments undertaken conclude that significant

cumulative environmental effects are unlikely to result from either the

construction or operation of the Proposed Development.

18.12 Energy Export Connection

18.12.1 Chapter 16.0 of the ES considered the potential effects associated with the

export of energy (electricity and heat) from the Proposed Development.

18.12.2 The Proposed Development would generate electricity for export to the local

electricity distribution network and it would also have the potential to

distribute heat to a District heating network. Neither the grid connection works

nor heat distribution network form part of the Planning Application. However,

on the basis that export of both electricity and heat is an integral part of the

scheme, it is considered appropriate that the potential environmental impacts

associated with the connection to the local electricity grid and district heating

network are assessed within the ES.

18.12.3 A potential grid connection route has been identified by Scottish Power

Networks and this has been the subject of assessment. A potential route has

also been identified for the distribution of heat within the heat and power plan

(contained within Part 6 of the Planning Application Document). The

potentially significant effects of both route options have been assessed.

18.12.4 The assessment concludes that no significant residual adverse impacts are

likely to arise from the construction or operation of either route option. Some

very minor adverse impacts have been identified and mitigation measures


have been proposed to avoid or reduce these impacts. The development of

these energy export connections is not considered to give rise to significant

effects.

18.13 Human Health

18.13.1 Chapter 17.0 provides an assessment of the human health impacts of the

Proposed Development. The assessment has identified that the operation of

the facility would give rise to a number of substances that would be emitted to

the atmosphere and that these substances have the potential to accumulate

in the environment and have an impact on human health. As a result, the risk

to human health of these emissions has been assessed.

18.13.2 A detailed health risk assessment has been carried out using the Industrial

Risk Assessment Program-Human Health (IRAP-h View – Version 4.1.87).

The programme, created by Lakes Environmental is based on the United

States Environment Protection Agency (USEPA) Human Health Risk

Assessment Protocol. In addition an assessment was undertaken to consider

the impacts of on agriculture in the area.

Operational Impacts

18.13.3 Advice from human health specialists such as the Health Protection Scotland

(HPS) is that there is lack of a consistent or conclusive evidence of an

association between (non-occupational) human health effects and waste

incineration. However HPS do note that there will remain a need to take

account of background ambient air quality in assessing the potential impact

of a new facility.

18.13.4 The results of the modelling have indicated that the emissions from the

facility would not have any significant effect on human health, soils or

watercourses.

18.13.5 It is recognised that there is the potential for the proposal result in anxiety

and concern in the local population due to the perception of health effects

from emissions. However, on the basis of the health assessment there is no

evidence to suggest that the health of the local population would be at risk


and consultation activities have been undertaken in order to keep local

residents informed of the project and its potential effects.


18.13.6 The human health risk assessment carried out in support of the ZWF

development (contained within the Air Quality Assessment) concluded that

the predicted concentrations would be within the relevant air quality objective

and guidelines, as is the case with the Proposed Development. In addition

the dioxin and furan assessment carried out for the ZWF estimated that the

highest forecast level of exposure would be 5.5% of the tolerable daily intake.

The highest forecast level of exposure resulting from the Proposed

Development would be 4.5% of the tolerable daily intake. Consequently, it

can be concluded that there effect on human health would be lower / more

beneficial than the ZWF development.

18.14 Summary

18.14.1 In considering the results of this ES, it can be concluded that the Proposed

Development would provide a sustainable waste management solution for

Edinburgh and Midlothian’s residual non-hazardous waste. The project would

assist in diverting waste from landfill, provide a source of low carbon and

renewable energy, create local job opportunities and provide a local

community resource in terms of a visitor centre.

18.14.2 The assessments contained in this ES have demonstrated that the only

potentially significant effects relate to visual impacts on a single viewpoint

located approximately 1km to the east of the site, where there are 30

residential properties. The assessments have shown that the proposal would

not result in a significant impact on local landscape character. No other

significant residual adverse environmental impacts have been identified.

FIGURES