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ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED
1-1
1 INTRODUCTION
1.1 TERMS OF REFERENCE FOR THIS ENVIRONMENTAL IMPACT ASSESSMENT REPORT
This Environmental Impact Assessment Report (EIA Report) has been
prepared by Environmental Resources Management Ltd (ERM) on behalf of
Keadby Developments Limited (the Company). This EIA Report has been
prepared to support an application under section 36C of The Electricity Act
1989 in accordance with the requirements of The Electricity Generating
Stations (Variation of Consents) (England and Wales) Regulations 2013 (‘the
2013 Regulations’).
1.2 APPLICATION HISTORY OF THE KEADBY II PROJECT
On 10 September 1993, the Company were granted consent pursuant to
section 36 of the Electricity Act 1989 and a Direction under section 90 of the
Town and Country Planning Act 1990 providing for the construction and
subsequent operation of a 710 MW combined cycle gas turbine generating
station at Keadby, North Lincolnshire.
The section 36 consent was subsequently varied on 3 November 2016
pursuant to section 36C of the Electricity Act 1989 (and the 2013 Regulations)
and section 90(2ZA) of the Town and Country Planning Act 1990 (2016
Consent) to accommodate an increase in the electrical output of the plant, up
to 820 MW (the Consented Development).
1.3 THIS APPLICATION
The Company now seeks a further variation pursuant to section 36C of the
Electricity Act 1989 (and the 2013 Regulations) and section 90 (2ZA) of the
Town and Country Planning Act 1990, to increase the electrical output of the
Consented Development, up to 910 MW and to deliver a higher efficiency in
electricity generation (the Proposed Development). The Proposed
Development is also known as Keadby II; its location is shown on Figure 1.1.
It is anticipated that the design changes for the Proposed Development will not
result in the need for any material changes to the existing consent conditions.
The application submitted in relation to the 2016 Consent was supported by
an Environmental Statement (ES) that was prepared in accordance with The
Electricity Works (Environmental Impact Assessment) (England and Wales)
Regulations 2000 (‘the 2000 EIA Regulations’). An Environmental Impact
Assessment (EIA) has been undertaken to determine the likely significant
effects of the Proposed Development to the extent these differ from those
previously assessed in the ES. The EIA has been undertaken in accordance
with The Electricity Works (Environmental Impact Assessment) (England and
Wales) Regulations 2017 (the ‘2017 Regulations’) which have come into force
since the 2016 Consent. The 2017 Regulations introduce several changes
from the 2000 Regulations and these are identified and discussed in Table
1.2.
Site Location
±0 2 4 6 8 10Kilometres
Path: \\UKEDIDC01\Data\Edinburgh\Projects\0280278_KeadbyGIS_GB_KM\MAPS\EIA 2017\0280278_SiteLocation_A02.mxd
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PROJECT: 0280278
SCALE: As scale bar VERSION:SIZE: A4
DATE: 06/07/2017
A01
Figure 1.1Site Location Plan
SOURCE: Service Layer Credits: © OpenStreetMap (and) contributors, CC-BY-SA
PROJ
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N: Br
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ation
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id
Site Location
ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED
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In addition Regulation 17 of the 2017 Regulations requires:
(e) where the application is for a section 36 variation, the main respects
in which the developer thinks that the likely significant effects on the
environment of the development, as varied, will differ from those set out
in—
(i) any EIA report or environmental statement prepared in
connection with the application for the section 36 consent that it is
proposed be varied; and
(ii) if the section 36 consent has previously been varied by a
section 36 variation, any EIA report or environmental statement
prepared in connection with the application for that variation;
(f) a non-technical summary of the information referred to in sub-
paragraphs (a) to (e).
This EIA Report focusses on the design changes to the Consented
Development and on receptors and resources that will be potentially affected
(see Table 1.1 for the key design changes). It also addresses matters arising
from changes in legislation (most notably the introduction of the 2017
Regulations implementing the 2014 EIA Directive), updates the baseline
where appropriate and reviews other schemes that have emerged from the
planning process in terms of the potential for cumulative effects. In order for
the EIA Report to be proportionate it clearly sets out (Chapter 3) where the
assessment of effects relating to the Consented Development remains valid.
A copy of the ES can be found in Annex D.
Table 1.1 Comparison of Key Design Changes between the Consented
Development and the Proposed Development
Consented Development Proposed Development
Output Capacity
820 MW 910 MW
Dimensions of Main Structures of the Proposed Development
Multishaft configuration presented
Note: The corresponding building sizes
presented in the ES contained some minor
errors corrected here. The nature of the error
was by omission and labelling and not in the
dimensions actually used in the assessment.
Multishaft configuration presented
Note: the locations of some of the buildings
have changed slightly within the application
boundary.
Building appearance
The Consented Development gas turbine hall
and steam turbine hall were to be constructed
of clad steel with brickwork to the lower level.
The Proposed Development gas turbine hall
and steam turbine hall are to be constructed
of clad steel down to ground level.
ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED
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Consented Development Proposed Development
Supplementary firing
The Consented development included
supplementary firing i.e. combustion of natural
gas directly into the boiler inlet duct to provide
additional steam.
The Proposed Development will not use
supplementary firing as part of the power
generation process.
Commissioning duration
The commissioning phase for the Consented
Development was approximately 26 weeks.
The commissioning phase for the Proposed
Development has increased to 12 months.
Abnormal Indivisible Loads (AILs)
A maximum of 10 AILs will be required for the
Consented Development and will route
through the village of Ealand.
A higher number of AIL will be required for the
Proposed Development, although the number
routed through the village of Ealand over the
construction phase will remain the same (i.e.
10 AIL deliveries). All additional AIL deliveries
will take an alternative route.
1.4 POLICY AND LEGISLATION OVERVIEW
A comprehensive overview of the planning policy context relevant to the
Proposed Development is provided in Chapter 3 of the Consented
Development ES (see Annex D).
Since issue of the 2016 Consent, the principle legislative change of relevance
to the given application is the implementation of the 2017 EIA Regulations
which came into force transposing Directive 2014/52/EU (the ‘2014 Directive’)
into UK law. The 2017 Regulations were brought into force on the 16th May
2017. Although on the face of it the 2014 Directive introduced a number of
new matters to be addressed within an EIA, many aspects of these had been
routine elements of EIA in the UK for a number of years.
Table 1.2 sets out the new requirements and comments on them in the
context of this EIA Report.
Table 1.2 Implications of the 2014 Directive
EIA Directive 2014 Comment
Scoping Opinion
Where a scoping opinion is requested from
the decision maker the EIA Report will need to
be based on the response (Art.5 (1)).
A scoping opinion was sought and provided
for within the ES. Although this preceded the
implementation of the 2017 Regulations, the
ES was based on the response.
A scoping opinion has not been sought
specifically in relation to this EIA Report;
however the information contained herein is
based on the original Scoping Opinion, the
consultation comments in relation to the ES
and comments received from the pre-
application consultations undertaken with the
Council, BEIS, local communities and the
statutory consultees with specific regard to
this EIA Report.
Content
The 2014 Directive includes clear
requirements for content on a number of
areas, including (Annex IV):
impacts on biodiversity, climate change,
landscape and human health;
vulnerability to accidents and disasters
All these matters were fully addressed in the
ES and are supplemented as necessary within
this EIA Report
ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED
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EIA Directive 2014 Comment
and the environmental consequences of
such.
Alternatives
The 2014 Directive requires at Art.5 (1): “a
description of the reasonable alternatives
studied by the developer”. Alternatives
include: project design, technology, location,
size and scale (Annex IV, para.2).
Reasonable alternatives were considered to
the extent appropriate in the ES for the
Consented Development and those
alternatives apply equally to the Proposed
Development. See Section 2.7 for an overview
of the alternatives.
Uncertainty
The main uncertainties associated with
forecasting methods must be described.
The role of uncertainty in assessment was
addressed in the ES and also applied to this
EIA Report.
Cumulative effects
These have been defined as those arising
from the development with other existing and
approved developments.
The ES identifies cumulative schemes
following consultation with North Lincolnshire
Council and assesses their cumulative effects
with the Consented Development. This
assessment is updated for the purposes of the
Proposed Development.
Environmental management and
monitoring
In the event of consent for EIA development,
the 2014 Directive now includes requirements
for monitoring of implementation of mitigation
measures (Art.8a (4)).
Monitoring measures for the construction
phase are set out in the draft Construction
Environmental Management Plan (CEMP) in
the ES. Similar provisions will apply to the
Proposed Development along with operational
monitoring requirements to be set out in the
Environmental Permit and to be agreed with
the local planning authority regarding the
consent conditions.
Baseline, validity of data and evolution
The decision-maker must be satisfied that the
ES is “up to date” before determining the
application (Art.8a). There is also a new
requirement to outline the likely evolution of
the baseline scenario in the absence of the
development, as far as this can be assessed
‘with reasonable effort’ on the basis of
available information and scientific knowledge.
Data sources are set out in the ES and have
been updated to the extent necessary for this
EIA Report. Natural evolution of the baseline
where relevant is addressed in Table 3.2.
EIA and HRA
Authorities must choose whether to combine
the EIA process with ‘appropriate
assessments’ under the European Habitats
Directives or simply co-ordinate the
assessments (Art.2 (a) (3)).
The ES and this EIA Report contain an
ecological impact assessment and a Habitat
Regulations Assessment.
Competence of Practitioners
The 2014 Directive introduces a need for EIAs
to be produced by ‘competent experts’.
The ES and this EIA Report have been
prepared by Environmental Resources
Management (ERM). ERM is a member of the
Institute of Environmental Management and
Assessment’s (IEMA’s) EIA Quality Mark, a
scheme which allows organisations to make a
commitment to excellence in their EIA
activities, and have this commitment
independently reviewed.
1.5 REPORT CONTENT AND STRUCTURE
This EIA Report presents the outcome of the EIA in respect of the Proposed
Development building on the desktop studies, field surveys and assessments
conducted for the Consented Development. It is a summary of the EIA studies
carried out and is presented to accompany the given Section 36C variation
application.
ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED
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This EIA Report objectively records the assessment of likely significant effects
of the Proposed Development on the environment, including direct effects and
any indirect, secondary, cumulative, short, medium and long-term, permanent
and temporary, positive and negative effects (1), resulting from:
the existence of the Proposed Development;
the use of natural resources; and
the emission of pollutants, creation of nuisances and waste.
Table 1.3 shows the location within this EIA Report and the ES of pertinent information to satisfy the requirements set out in Schedule 4 of the 2017 Regulations. The general approach to the EIA is described in Section 1.6. The EIA Report
scope, including where the ES remains valid or supplementary information is
provided in the EIA Report, is presented in Chapter 3.
1.6 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMENT
This section provides an overview of the broad principles of the methodology
adopted within this EIA Report. A comprehensive description of the approach
to the EIA can be found in Chapter 4 of the ES (see Annex D).
This EIA Report presents a comparison of the Proposed Development and its
likely significant effects, when compared to those attributable to the
Consented Development. An informal scoping exercise has been undertaken
in the preparation of this ES Report and is set out in Chapter 3. In addition
Chapter 3 highlights topics where the likely significant effects have been
reassessed due to changes in the project design. For those topics where no
further assessment is required justification is provided and an overview of
impacts and effects as presented in the Consented Development ES is
provided. For those topics where additional assessment is required a full and
thorough assessment has been carried out.
Figure 1.2 sets out the approach to assessment of likely significant effects that
may arise from the Proposed Development. This approach has been applied
in undertaking the EIA for the Consented Development as well as the
Proposed Development, as part of the Section 36C variation application.
(1) Transboundary effects are scoped out.
Table 1.3 Contents of the EIA Report
Relevant
Paragraph of
Schedule 4 to
the EIA
Regulations
Required Information Report Reference
[Paragraph 1]
Description of the proposed development, including in particular:
a description of the location of the proposed development;
a description of the physical characteristics of the whole development
including, where relevant, requisite demolition works, and the land-use
requirements during the construction and operational phases;
a description of the main characteristics of the operational phase (in
particular any production processes), for instance, energy demand and
energy used, nature and quality of the materials used and natural
resources; and
an estimate, by type and quantity, of expected residues and emissions
(such as water, air and soil and subsoil pollution, noise, vibration, light, heat,
radiation) and quantities and types of waste produced during the
construction and operation phases of the proposed development.
This EIA Report provides a description of the location of the Proposed
Development (Figure 1.1) alongside a description of the physical
characteristics of the whole development and main characteristics of the
operational phase (see Chapter 2: Project Description). Types and
quantities of waste are also addressed in Chapter 2: Project Description.
The changes in project design and how these may affect the estimates
of various emissions have been considered in detail in Table 3.1. There
are no material changes to the project design during construction and so
construction emissions remain reported in the ES (see Annex D),
however, operational emissions to air are reassessed in this EIA Report
(see Chapter 4). See Table 3.1 for further detail on the EIA Report
Scope.
[Paragraph 2] A description of the reasonable alternatives (for example in terms of
development design, technology, location, size and scale) studied by the
developer, which are relevant to the proposed development and its specific
characteristics, and an indication of the main reasons for selecting the chosen
option, including a comparison of the environmental effects.
This EIA Report provides a description of the alternatives considered
and the main reasons for selection of the chosen option. See Section
2.7 for a description of the alternatives.
[Paragraph 3]
A description of the relevant aspects of the current state of the environment
(baseline scenario) and an outline of the likely evolution thereof without
implementation of the proposed development as far as natural changes from the
baseline scenario can be assessed with reasonable effort on the basis of the
availability of environmental information and scientific knowledge.
The ES provides a comprehensive description of the baseline scenario
for all topics that may be affected by the Project. However, this EIA
Report provides updated baselines, where appropriate, to those topics
that are being reassessed (see Table 3.1 for EIA Report Scope and
Chapters 4 and 5).
An outline of the likely natural evolution of the baseline without
implementation of the Proposed Development, where possible, is
provided in Table 3.2.
[Paragraph 4] A description of the factors specified in regulation 4(2) likely to be significantly affected by the development: population, human health, biodiversity (for example fauna and flora), land (for example land take), soil (for example organic matter, erosion, compaction, sealing), water (for example hydromorphological changes, quantity and quality), air, climate (for example greenhouse gas emissions, impacts relevant to adaptation), material assets, cultural heritage, including
The ES provides a comprehensive description of the baseline scenario.
See the following chapters in Annex D:
Chapter 6 - Land and water (including soils);
Chapter 7 - Ecology and nature conservation (including fauna and flora);
Chapter 8 - Noise and vibration;
Relevant
Paragraph of
Schedule 4 to
the EIA
Regulations
Required Information Report Reference
architectural and archaeological aspects, and landscape.
Chapter 9 - Air quality;
Chapter 10 - Archaeology and cultural heritage;
Chapter 11 - Traffic and transport;
Chapter 12 - Socio-economic characteristics;
Chapter 13 - Landscape and visual.
However, this EIA Report provides updated baselines, where
appropriate, to those topics that are being reassessed (see Table 3.1 for
EIA Report Scope and Chapters 4 and 5). Additional information on
landscape and visual impacts are provided in Figure 3.1. Land take is
shown in Figure 2.1.
[Paragraph 5] A description of the likely significant effects of the proposed development on the environment, resulting from, inter alia: (a) the construction and existence of the development, including, where relevant, demolition works; (b) the use of natural resources, in particular land, soil, water and biodiversity, considering as far as possible the sustainable availability of these resources; (c) the emission of pollutants, noise, vibration, light, heat and radiation, the creation of nuisances, and the disposal and recovery of waste; (d) the risks to human health, cultural heritage or the environment (for example due to accidents or disasters); (e) the cumulation of effects with other existing and/or approved projects, taking into account any existing environmental problems relating to areas of particular environmental importance likely to be affected or the use of natural resources; (f) the impact of the project on climate (for example the nature and magnitude of greenhouse gas emissions) and the vulnerability of the project to climate change; (g) the technologies and the substances used.
The description of the likely significant effects on the factors specified in
regulation 4(2) should cover the direct effects and any indirect, secondary,
cumulative, transboundary, short-term, medium-term and long-term, permanent
and temporary, positive and negative effects of the development. This
description should take into account the environmental protection objectives
established at Union or Member State level which are relevant to the project,
including in particular those established under Council Directive 92/43/EEC(a)
and Directive 2009/147/EC(b).
The ES provides a comprehensive description of the likely significant
effects of the Consented Development on the environment. Table 3.1 in
this EIA Report assesses the validity of the findings of the ES in relation
to the changes in project design presented in the EIA Report. For many
topics there are no material changes that would affect the significance of
the assessment in the ES and as such the ES remains valid. Where the
assessment of likely significant effects may be different to that assessed
in the ES, new information is presented in this EIA Report (see Chapter
4: Air quality and Chapter 5: Ecology and Nature Conservation).
Table 3.1 also provides supplementary information to fulfil the
requirements of the 2017 EIA regulations, as indicated within the table.
[Paragraph 6] A description of the forecasting methods or evidence, used to identify and assess the significant effects on the environment, including details of difficulties
The ES provides a comprehensive description of the approach to the
EIA (see Chapter 4 of the ES – Annex D). Further topic specific details
Relevant
Paragraph of
Schedule 4 to
the EIA
Regulations
Required Information Report Reference
(for example technical deficiencies or lack of knowledge) encountered compiling the required information and the main uncertainties involved.
are provided in ES Chapters 6 to 13 and Chapters 4 and 5 of this EIA
Report. A summary of the approach is provided in Figure 1.2 below.
Uncertainty, where relevant, is dealt with within the topic assessment
chapters of the ES and this EIA Report.
[Paragraph 7]
A description of the measures envisaged to avoid, prevent, reduce or, if
possible, offset any identified significant adverse effects on the environment and,
where appropriate, of any proposed monitoring arrangements (for example the
preparation of a post-project analysis). That description should explain the
extent, to which significant adverse effects on the environment are avoided,
prevented, reduced or offset, and should cover both the construction and
operational phases.
A description of the measures proposed to avoid, prevent and reduce
any identified significant adverse effects as well as monitoring and the
effect of implementing the proposed mitigation measures are provided in
the topic assessment chapters of the ES. A summary is provided in
Chapter 15 of the ES (See Annex D to this EIA Report). Where these
measures have been updated due to changes in project design
considered in this variation they are presented in Chapter 4: Air quality
and, Chapter 5: Ecology and Nature Conservation as well as Chapter 7,
which provides a summary of the updated mitigation measures.
[Paragraph 8] A description of the expected significant adverse effects of the development on the environment deriving from the vulnerability of the development to risks of major accidents and/or disasters which are relevant to the Proposed Development. Relevant information available and obtained through risk assessments pursuant to EU legislation such as Directive 2012/18/EU(c) of the
European Parliament and of the Council or Council Directive 2009/71/Euratom(d) or UK environmental assessments may be used for this
purpose provided that the requirements of this Directive are met. Where appropriate, this description should include measures envisaged to prevent or mitigate the significant adverse effects of such events on the environment and details of the preparedness for and proposed response to such emergencies.
The Proposed Development is not within the consultation zone for any
COMAH site and therefore is not at risk of being affected by a major
accident at one of these sites.
Flood risk has been addressed in the design levels of critical operational
infrastructure and the Proposed Development will be provided with a
sustainable drainage system sized to cope with future changes due to
climate change (see Chapter 3 and Annex D).
An emergency situation and response plan will be developed for the
Proposed Development prior to construction and updated for operation.
A Hazard and Operability Study and Process Hazard Review (HAZOP)
will also be conducted prior to construction to consider sources of major
accidents as part of preparing such a plan.
[Paragraph 9]
[A non-technical summary of the information provided under paragraphs 1 to 8] A Non-technical Summary of all relevant information, including
information presented in the ES, is provided with this EIA Report.
[Paragraph 10] A reference list detailing the sources used for the descriptions and assessments
included in the environmental statement.
References are provided as footnotes in each chapter of the ES and EIA
Report, as relevant.
Predict Magnitude
A project’s impacts are quantified in terms of eg:
landtake area or habitat loss;
proportion of an ecological population exposed to impact;
change in noise levels at a residence;
pollutant exposure at a receptor; and
numbers of jobs generated in the local economy.
In predicting magnitude the effect of all the project mitigation in place (ie
committed to by the applicant) is taken into account.
For some impacts, especially noise, air and water pollution, significance is
assessed directly against numerical criteria and standards. For
exceedances, further mitigation must be incorporated by a project to
reduce the magnitude of the impact (and the significance of its effect).
For other impacts nominal levels of magnitude (eg small, medium, large)
may be adopted based on widely recognised factors such as: the nature
of a change (what is affected and how); its size, scale or intensity; its
geographical extent and distribution; its duration, frequency, reversibility
and, for unplanned events, likelihood of occurrence.
Some activities will result in changes to the environment that may be
immeasurable or undetectable or within the range of normal natural
variation. Such changes are assessed as having no impact or to be of
negligible magnitude and will not lead to significant effects.
Predict
Magnitude
Evaluate
Significance
Report
Effects
Identify
Impacts
Describe Baseline
Baseline data are collected to better understand the potentially most
important impacts and effects identified in scoping. Baseline data may
quantify existing exposure levels (eg for noise, air and water pollution),
identify vulnerable populations of animals or people, more clearly delineate
valued cultural property and ecosystem services etc.
Where a baseline aspect cannot be quantified then nominal levels of
importance, quality or value (low, medium, high) are assigned based on
widely accepted criteria in fields such as ecology, cultural heritage, landscape
and socioeconomic assessment. Inter-relationships between elements of the
baseline are identified.
Interact with Project Design
The EIA process interacts with a project design team to develop a basis for the
assessment (for example quantities of emissions, noise levels of equipment,
sizes of structures). The EIA process also interacts with design to assess
alternatives, ‘best available technology’ and mitigation options, especially
when after initial assessment some impacts may need to be further reduced.
Consult Stakeholders
Ongoing stakeholder consultation, post-scoping, is good practice in EIA and is
undertaken to refine the assessment and present preliminary findings to
stakeholders to elicit early responses and help make the Environmental
Statement as fit for purpose as possible.
Informed by high
level baseline,
project infor-
mation and con-
sultation with key
stakeholders
Project as
currently planned
with mitigation
incorporated
Compared
against standards
or looking at
magnitude in
combination with
affected re-
source/receptor
Increasing interaction with baseline studies, project design and stakeholders Identify Impact
The scoping process identifies the potentially most important/significant
impacts and effects (including secondary, indirect and cumulative) for the
assessment to address. This is done through a combination of:
looking at the nature of a project’s activities and the impacts they will
give rise to;
looking at a project’s environmental and social settings and their
aspects which are likely to be most sensitive/vulnerable to impacts
from the project;
applying professional understanding gained from the evidence base;
and
considering inputs from stakeholders through consultation.
Decisions are then made on which impacts and effects to assess or to
prioritise in the assessment (scoping in and scoping out) and how to
assess them (proposed methodology).
Evaluate Significance
In evaluating significance, the EIA process is seeking to inform regulators and stakeholders about the effects of
a project in a way that helps them make decisions on whether to approve it and allows them to develop
suitable conditions to attach to an approval. The evaluation of significance ideally demonstrates legal
compliance at least (eg compliance with quantified standards, avoidance of effects on legally protected
resources).
In the absence of quantified standards, significance can be evaluated through considering the magnitude of an
impact in combination with the importance/quality/value of the receptor or resource that is affected, also
considering the response (or sensitivity) of a resource or a receptor to a particular impact. Impacts/effects of
more than minor significance may warrant re-examination to see if an impact magnitude can be reduced
further. Different mitigation options may be examined and the reasons for selecting one and rejecting others
explained. Some impacts/effects that cannot be adequately mitigated may need to be addressed through the
consideration of offsets or compensation.
The evaluation process may go through more than one iteration of working with project design to develop
suitable mitigation and re-evaluating impacts and effects.
For some impacts and
effects further or
different mitigation
may need to be con-
sidered and the effect
re-evaluated
While the above provides a general framework for identifying impacts and assessing the significance of their effects, in practice the approaches and criteria applied vary across
different environmental and socio-economic topics.
Magnitude of Impact
Small Medium Large
High
Medium
Low
Sen
siti
vity
/Qu
alit
y/Im
po
rtan
ce o
f R
ece
pto
r/R
eso
urc
e
Not significant
Minor
Moderate
Major
Figure 1.2 Overview of the EIA Process
ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED
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1.7 COMPARISON BETWEEN THE PROPOSED DEVELOPMENT AND THE CONSENTED
DEVELOPMENT
In accordance with Regulation 17 paragraph (e) of the 2017 Regulations, one
purpose of the EIA is to provide information on the main respects in which the
Company considers that the likely significant effects on the environment of the
Proposed Development will differ from those described in the ES. The
conclusions of this comparison are presented in Chapter 8 of this EIA Report.