Practitioners from LUC describe applying the new Scottish planning advice note on environmental impact assessment (EIA) to the Neart na Gaoithe offshore windfarm development
Planning advice notes (PANs) provide advice and information from the Scottish government on technical planning matters. PAN 1/2013: EIA supersedes PAN 58, which was published in 1999, and is underpinned by three key principles:
- Integration: This covers a number of themes including the integration of EIA into the overall development management process and ensuring that the benefits of EIA are realised through the early consideration of environmental issues, which can lead to improvements in design, including the integration of mitigation measures, which can lead to cost savings. A further key message is that the assessment of cumulative impacts provides an important opportunity to consider the impacts of the development as a whole.
- Proportionality: The PAN emphasises that EIAs should be “fit for purpose” and that excessively long, repetitive and poorly coordinated environmental statements can prove a barrier to informed decision making. Proportionality can best be achieved by seeking information from the planning authority and consultation bodies on the scope of the assessment and by focusing the EIA on the significant environmental effects of the proposed development.
- Efficiency: The Scottish government is seeking more efficient and effective EIA. Again, a number of themes are addressed here including the use of strategic environmental assessment (SEA) to streamline project level EIA and coordinating any information requirements where both an EIA and a Habitats Regulations appraisal is required. Furthermore, some projects may require more than one consent which must be subject to EIA (a “multi-regime consent”) and in these cases, early and effective engagement with the consenting bodies should minimise duplication while ensuring that the requirements of the individual EIA regulatory regimes are met. .
Neart na Gaoithe offshore windfarm
Neart na Gaoithe (a gaelic phrase meaning “might of the wind”) offshore windfarm is being proposed by Mainstream Renewable Power and is located to the north-east of the Firth of Forth in Scotland.
LUC was appointed in 2009 to undertake preliminary routeing work for the associated onshore cable and substation, with a further appointment in 2011 to undertake the EIA, following identification of a proposed cable route (approximately 12.5km) to a substation location within an existing onshore windfarm. The onshore works are located entirely within East Lothian.
The EIA process was integrated in that early consideration of environmental issues led to careful selection of the cable landfall location on the beach and the selection of a route corridor for the cable that was considered to minimise potential environmental effects. This included avoiding sensitive habitats, important landscape features, protected cultural heritage features, sensitive watercourses and proximity to residential properties where possible.
Three types of potential cumulative impact were also considered:
- cumulative impacts arising with other schemes, including other windfarm projects;
- cumulative impacts arising from the potential for the onshore works to lead to significant inter-related effects on a single receptor, such as noise, dust and traffic impacts on a particular residential property; and
- cumulative impacts of the onshore works in combination with the offshore works, particularly in the vicinity of the landing point for the cable.
The EIA process was proportional in that considerable effort was invested upfront in considering the potential impacts of the development, in terms of its nature (largely underground, with a number of effects limited to the construction phase), size and location – the cable route starting in a sensitive coastal environment popular for recreation, and ending at a proposed substation location within an existing windfarm where impacts were anticipated to be limited.
This fed through into a request for a scoping opinion which sought to proactively scope-out a number of potential impacts; an approach which was supported by East Lothian Council. For example, the majority of potential operational impacts were scoped-out, including:
- impacts on habitats, breeding or wintering bird populations;
- pollution of surface and groundwater; and
- the impacts of operational and maintenance vehicles on existing traffic flows and the local road network.
The EIA and wider decision-making processes were efficient in that the EIA requirements for this multi-regime project were established at an early stage in the development process, which was particularly challenging given the limited number of precedents and the involvement of bodies still in their infancy, including Marine Scotland.
Furthermore, full planning permission for the onshore works was granted by East Lothian Council only 18 months after the request for a scoping opinion was submitted by LUC. This arguably demonstrates an efficient EIA and decision-making process in accordance with Scottish government objectives.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.