EIA for multiple S.73 applications
- Resource extraction ,
- Energy ,
- Construction ,
- Consultancy ,
Alison Carroll from Nicholas Pearson Associates reflects on the challenges posed by an environmental impact assessment (EIA) relating to the Wytch Farm, Wareham and Kimmeridge oilfields
In 2011/12, Nicholas Pearson Associates coordinated the EIA for a proposal to extend the planning consents relating to the Wytch Farm, Wareham and Kimmeridge oilfields in Dorset. At the outset, a few fundamental questions had to be answered.
What planning consents were required?
The planning history of the oilfields is extremely long and complex. The Kimmeridge Oilfield, for instance, was first discovered back in 1959. The oilfields have been developed incrementally since then.
By 2011, when Perenco UK took over as operator of the oilfields, there were more than 50 live planning consents relating to the three oilfields. These covered a range of sites, including: a gathering station, an access road, offices, a sea water pumping station, a causeway, 12 well sites and numerous infield pipelines.
The majority of consents included a planning condition requiring restoration to be completed in 2016, although some ended in 2019 or 2020, and some were not time limited at all.
It was established that 39 planning applications would need to be submitted under section 37 of the Town and Country Planning Act 1990 (as amended). Thirty-five planning applications would seek extensions to 2037, two to 2032 and two to 2027.
Was EIA required?
Yes! While many of the individual planning applications could have been subject to screening and would not have exceeded any EIA thresholds, it was clear that collectively they sought to extend the operation of all three oilfields by more than 20 years. The potential for this to give rise to significant environmental effects was obvious, especially given that the oilfields are located within a very environmentally sensitive area.
Collectively the sites fall either within or adjacent to an area of outstanding natural beauty, heritage coast, a world heritage site and several special areas of conservation, special protection areas, Ramsar sites and sites of special scientific interest.
What would the scope of the EIA be?
The scope of the EIA had to be broad ranging, both geographically and in terms of topic areas. The EIA could not, for example, simply consider those elements that were subject to the 39 planning applications, but had to consider the impacts of the whole development as extended.
The EIA also included consideration of the Purbeck to Southampton pipeline, which was not subject to consent from the Mineral Planning Authority and did not require a time extension.
The EIA had to consider impacts against two different baselines:
- the conditions present in 2011 with all sites operating as they did at that time; and
- the conditions that, based on available restoration proposals, could have prevailed in the future had the sites been restored in 2016. For ease, a 2016 end-point was adopted for all sites.
It soon became apparent that if only the existing baseline was used then the impacts of retaining the sites would be negligible. All of the sites were already in place and operating, and there were no plans to physically extend the sites or do anything radically different within them – in the future it was largely going to be “business as usual”.
Assessing only against the existing baseline would miss the fact that the proposals delayed restoration to heathland, woodland or agriculture, and maintained hydrocarbon extraction and processing over the extended period.
Establishing the 2011 baseline was straightforward, the real challenge was to work out what might have happened post-2016 if the oilfield consents were not extended.
How would the environmental statement be structured?
Environmental statements (ES) are often criticised for their length and unwieldy nature, but could a concise ES be written to cover all of the sites, access roads and pipelines and meet the requirements of 39 separate planning applications?The honest answer is: no. However, the ES was structured as logically as possible.
One overarching volume was produced that provided an overview of all of the impacts cumulatively across the development. Seventeen additional volumes of varying length then acted as “mini-ESs” for each location.
This was my most challenging ES to coordinate to date and an experience that I have learned a great deal from. Some of the lessons learned from the process will be the subject of a future article.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Alison Carroll, MIEMA CEnv, is an associate environmental planner at Nicholas Pearson Associates, and a registered EIA practitioner.
The input of the client and all of the consultants who contributed to the ES is acknowledged, including Savills who are also IEMA EIA Quality Mark registrants.
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