South London energy recovery facility - a complex future baseline

28th January 2016


Related Topics

Related tags

  • Business & Industry ,
  • Built environment ,
  • Planning ,
  • Management

Author

Brian Morgan

Emma Robinson, associate director at Terence O'Rourke, highlights the difficulty of assessing future impacts of a development

In July 2012 Terence O’Rourke (TOR) submitted a detailed planning application, including a comprehensive EIA for the South London Energy Recovery Facility (ERF) at Beddington Farmlands landfill site in the London Borough of Sutton (LBS) on behalf of Viridor. Under the landfill consent, the whole site was subject to restoration proposals which would have resulted in habitat creation, management of the site for nature conservation and some public access, subject to operational considerations regarding the aftercare of the landfill.

The council’s scoping opinion included a requirement that the landscape and visual assessment and natural heritage assessment within the environmental statement (ES) must compare the predicted impacts of the proposed ERF against the future baseline post-2023 after the site was restored, rather than against current conditions.

There are considerable difficulties in making meaningful predictions about what the baseline conditions at a future point will be. For example, which species will be present on the site and in what numbers; how many local residents will be using the site; and how the restored site will look from the surrounding area. Given that the future baseline cannot be accurately measured, any assessment includes a significant degree of speculation and professional judgement.

The standard approach is for an ES to include consideration of the implications of the proposals on a detailed, measurable and current baseline. The future baseline is then usually considered in very general descriptive terms, except for topics that can quantifiably be more accurately predicted, such as background air quality or traffic flow, where a more detailed analysis is possible.

With regard to the council’s scoping opinion, it was felt that an assessment of potential impacts purely against a future baseline (that could not be measured) as opposed to a detailed assessment against a measurable baseline, was not a robust approach.

Professional experience and best practice suggest that conclusions in an ES need to be factual and quantifiable in order to be considered robust for use in determining the planning application. While it was accepted than an element of impact assessment is based on professional judgement, it was considered that the likely highly subjective nature of detailed future baseline work could provide a weakness or point of challenge to the EIA.

In March 2012, TOR wrote to the London Borough of Sutton to highlight the difficulties in assessing future baselines beyond a basic descriptive consideration. We proposed assessing the ES against current conditions as required by the EIA regulations. We also proposed a more detailed assessment of the future baseline as required in the EIA scoping opinion, but in a separate document to the ES.

The ES submitted in July 2012 therefore included an assessment of the potential impacts of the proposals against a robust 2012 baseline, and a basic assessment of the future baseline as it would be once the site was restored. A separate document assessed the proposed development against the 2023 restored baseline, which was based purely on professional projections of what the future restored site was likely to be.

However, LBS subsequently issued a regulation 22 request for the transfer of the text and figures from the separate future baseline document to a dedicated chapter within the ES. A new chapter was prepared and submitted in February 2013 as an addendum to the July 2012 ES. The findings and conclusions of this chapter were exactly as reported in the original separate document and did not alter the conclusions of the original ES.

In the author’s view, it is likely that consideration of the acceptability of the proposal, which received permission in May 2013, was best gleaned from the findings of the original main ES which looked at the impact of the proposed development on a detailed, measurable and robust existing baseline, rather than the future baseline, which, while constructed as accurately as possible, was inevitably more speculative and imprecise.

Subscribe

Subscribe to IEMA's newsletters to receive timely articles, expert opinions, event announcements, and much more, directly in your inbox.


Transform articles

Advice note on health impact assessments

An advice note on health impact assessments and health in environmental assessments is set to be published by IEMA soon.

31st May 2024

Read more

IEMA’s Impact Assessment Network is delighted to have published A Roadmap to Digital Environmental Assessment.

2nd April 2024

Read more

Lisa Pool on how IEMA is shaping a sustainable future with impact assessment

27th November 2023

Read more

IEMA responded in September to the UK government’s consultation on the details of the operational reforms it is looking to make to the Nationally Significant Infrastructure Projects (NSIP) consenting process as put forward in the NSIP reform action plan (February 2023).

24th November 2023

Read more

Members of IEMA’s Impact Assessment Network Steering Group have published the 17th edition of the Impact Assessment Outlook Journal, which provides a series of thought pieces on the policy and practice of habitats regulations assessment (HRA).

26th September 2023

Read more

In July, we published the long-awaited update and replacement of one of IEMA’s first published impact assessment guidance documents from 1993, Guidelines for the Environmental Assessment of Road Traffic.

1st August 2023

Read more

Are we losing sight of its intended purpose and what does the future hold for EIA? Jo Beech, Tiziana Bartolini and Jessamy Funnell report.

15th June 2023

Read more

Luke Barrows and Alfie Byron-Grange look at the barriers to adoption of digital environmental impacts assessments

1st June 2023

Read more

Media enquires

Looking for an expert to speak at an event or comment on an item in the news?

Find an expert

IEMA Cookie Notice

Clicking the ‘Accept all’ button means you are accepting analytics and third-party cookies. Our website uses necessary cookies which are required in order to make our website work. In addition to these, we use analytics and third-party cookies to optimise site functionality and give you the best possible experience. To control which cookies are set, click ‘Settings’. To learn more about cookies, how we use them on our website and how to change your cookie settings please view our cookie policy.

Manage cookie settings

Our use of cookies

You can learn more detailed information in our cookie policy.

Some cookies are essential, but non-essential cookies help us to improve the experience on our site by providing insights into how the site is being used. To maintain privacy management, this relies on cookie identifiers. Resetting or deleting your browser cookies will reset these preferences.

Essential cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

Analytics cookies

These cookies allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.

Advertising cookies

These cookies allow us to tailor advertising to you based on your interests. If you do not accept these cookies, you will still see adverts, but these will be more generic.

Save and close