Using parameters in planning applications
Paul Burgess explains how WYG is using a parameters-based approach in environmental impact assessment (EIA) of the Liverpool Waters development
It used to be the case that if an application for outline planning permission was determined then an additional EIA was not required at the application for approval of reserved matters.
However, as a result of a series of court decisions (specifically the TEW and Milne cases and Commission v UK, C-508/3) it is now accepted that it may be appropriate to seek an EIA at the approval of reserved matters. When developing an outline planning application sufficient information should be developed to allow a meaningful environmental assessment to be carried out, which obviously creates a challenge on large projects with long-term phased programmes.
This article outlines how WYG put into place a clear strategy at the outset of the EIA of Peel’s Liverpool Waters project in support of the outline planning application. This helped to ensure that sufficient information was available for the assessment team which resulted in a meaningful environmental assessment.
Liverpool Waters is one of the largest urban regeneration projects in the UK, extending across more than 150 acres of derelict dockland. The £5.5 billion mixed-use development will include offices and commercial areas alongside new homes, visitor attractions, local shops and services and is planned to be built over 30 years.
Considering the scale of the project and its phased duration, it was essential for its successful delivery to ensure that it could be designed to allow for flexibility and innovation throughout the implementation process, to be able respond to design and technological advancements as well as changes in needs, social attitudes and future baseline conditions.
WYG’s EIA and planning team, as the EIA coordinators of the project, realised the need to provide specific boundaries or ranges of development within the project’s design, subsequently referred to as “key principles” and “parameters”.
The key principles and parameters were derived following extensive consultation with stakeholders and through testing within the preliminary stages of the EIA (using indicative masterplans and visualisations).
Apart from assisting with the provision of sufficient development information to enable meaningful environmental assessment and mitigation design, the level of detail and stakeholder engagement ensured the proposals were designed carefully to protect and conserve the historic features of the docks. This was especially important because part of the site lies in Liverpool’s world heritage site.
The key development parameters considered to have the greatest bearing in terms of environmental effects were:
- Heights – specified as maximum and minimum per plot.
- Footprint and massing – the footprints of each neighbourhood boundary were defined and fixed.
- Floorspace – the total square footage was set, and within this the maximum of each development type was set.
- Access points – specified in terms of location and number.
- Parking – specified in terms of total parking spaces per neighbourhood.
- Programming of construction and opening year for each neighbourhood phase.
These formed the fundamental development parameters on which EIA was undertaken and are considered to be the minimum required to undertake landscape and visual impact assessments and above-and-below-ground cultural heritage assessments – which require certain fixed details of heights, massing and spatial layout.
The direct design detail outlined above allowed estimations to be calculated in terms of the likely energy demand, greenhouse gas emissions, water demand, water emissions, waste generation, traffic generation, noise and air emissions, and microclimate changes based on various assumptions considering the 30-year implementation programme.
It would have been tempting to stop with these parameters, but we realised the provision of further detail, albeit indicative, was essential to provide sufficient information for the assessment team to provide the most robust assessments possible at this stage of the project’s design and, therefore, enable the consenting authorities to make an informed decision.
The key items of indicative detail included:
- Building plot locations within fixed neighbourhood boundaries.
- Internal access.
- Visualisations (photomontages) which were prepared on maximum heights.
It was important to recognise that the submitted Liverpool Waters masterplan represents only one solution of how development could come forward in accordance with the development’s key principles and parameters.
Topic assessments were then based on the most relevant parameters stated above, which allowed a meaningful assessment to be undertaken (for example, within the landscape and visual assessment the maximum heights were used as a robust reference).
It was very important that the assumptions and the limitations of each impact assessment were clearly stated so the forecasting methods and confidence in the individual assessments could be verified by the stakeholders and the consenting authority. This also forms a transparent point of reference so that potential significant changes can be identified in future reserved matters applications, which would trigger the need for further EIA.
Furthermore, the project’s mitigation strategy required that in each EIA topic area where assumptions or estimations could be subject to error or future changes in baseline, a further EIA at reserved matters would be required, and this was specified as mitigation to be conditioned.
Planning permission for the site, if granted, will be controlled by planning conditions to ensure any reserved matters application (or any application for other approvals required under the planning permission sought) that falls outside the defined development’s key principles and parameters is screened to ensure any adverse environmental effects are no greater than those assessed in the current environmental statement. This would trigger the requirement for further EIA to be undertaken and reported in a subsequent environmental statement.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Paul Burgess is an Associate Environmental Consultant, WYG.