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GP PLANNING LTD EIA SCOPING REPORT

C025-01 / Môr Hafren ERF Scoping Report/ MD August 2019

Request for a Scoping Direction Môr Hafren Energy Recovery

Facility Môr Hafren Bio Power C025-01

Revision Comments Author Date 3 For Internal Review MD 27th August

2019

4 External Release MD 30th August 2019


C025-01/Môr Hafren ERF Scoping Report/ MD August 2019 1

Contents

1 INTRODUCTION ......................................................................................................................... 4

1.1 The Applicant .................................................................................................................................... 4

1.2 Background ....................................................................................................................................... 4

1.3 Development of National Significance ............................................................................................. 4

1.4 The EIA Scoping Process – Extant Planning Permission.................................................................... 6

1.5 Guidance on Developments of National Significance and EIA ......................................................... 7

2 THE SITE AND ITS SURROUNDINGS .......................................................................................... 11

2.1 Introduction .................................................................................................................................... 11

3 THE PROPOSED DEVELOPMENT ............................................................................................... 12

4 PLANNING POLICY CONTEXT .................................................................................................... 18

4.1 Introduction .................................................................................................................................... 18

5 SCOPE OF THE ENVIRONMENTAL IMPACT ASSESSMENT........................................................... 23

5.1 Introduction .................................................................................................................................... 23

5.2 The Environmental Statement ........................................................................................................ 25

6 THE ENVIRONMENTAL STATEMENT AND ASSESSMENTS .......................................................... 28

6.9 Environmental Topics ..................................................................................................................... 29

7 AIR QUALITY ASSESSMENT ...................................................................................................... 30

7.1 Introduction .................................................................................................................................... 30

7.2 ADMS Modelling ............................................................................................................................. 30

7.3 Modelling Uncertainty .................................................................................................................... 30

7.4 Modelling Input Data ...................................................................................................................... 31

7.5 Plant Details .................................................................................................................................... 35

7.6 Emissions Data ................................................................................................................................ 36

7.7 Atmospheric Chemistry .................................................................................................................. 36

7.8 Meteorological Data ....................................................................................................................... 36

7.9 Local Environmental Conditions ..................................................................................................... 37

7.10 Background Air Quality ................................................................................................................... 38

7.11 Stack Height Calculation ................................................................................................................. 39

7.12 Detailed Modelling ......................................................................................................................... 39

7.13 Residual Effects ............................................................................................................................... 41

7.14 Cumulative Effects .......................................................................................................................... 41

8 NOISE AND VIBRATION ASSESSMENT ...................................................................................... 42



8.1 Introduction .................................................................................................................................... 42

8.2 Scope ............................................................................................................................................... 42

8.3 Baseline Assessment ....................................................................................................................... 42

8.4 Modelling ........................................................................................................................................ 43

8.5 Consultation .................................................................................................................................... 43

8.6 Noise Sensitive Receptors ............................................................................................................... 44

8.7 Final Assessment ............................................................................................................................. 46



9 ECOLOGICAL ASSESSMENT ...................................................................................................... 48

9.1 Introduction .................................................................................................................................... 48

9.2 Methodology................................................................................................................................... 48

9.3 Context and Baseline ...................................................................................................................... 48

9.4 Preliminary Ecological Appraisal ..................................................................................................... 50

9.5 Extended Phase 1 Habitat Survey ................................................................................................... 51

9.6 Impact Assessment Methodology .................................................................................................. 51

9.8 Survey Findings ............................................................................................................................... 53



10 LANDSCAPE AND VISUAL IMPACT ASSESSMENT ....................................................................... 55

10.1 Introduction .................................................................................................................................... 55

10.2 Methodology................................................................................................................................... 55

10.3 Visual Baseline ................................................................................................................................ 56

10.4 Zone of Theoretical Visibility .......................................................................................................... 59



11 TRANSPORT ASSESSMENT ....................................................................................................... 60

11.1 Introduction .................................................................................................................................... 60

11.2 Scope ............................................................................................................................................... 60

11.3 Context and Baseline Conditions .................................................................................................... 60

11.4 Methodology................................................................................................................................... 62

11.5 Assessment of Effects ..................................................................................................................... 62





12 HISTORIC ENVIRONMENT ASSESSMENT ................................................................................... 65

12.1 Introduction .................................................................................................................................... 65

12.2 Scope ............................................................................................................................................... 65

12.3 Assessment ..................................................................................................................................... 65



13 FLOOD CONSEQUENCES ASSESSMENT ..................................................................................... 67

13.1 Introduction .................................................................................................................................... 67

13.2 Context ............................................................................................................................................ 67

13.3 Objectives ....................................................................................................................................... 67

13.4 Baseline Conditions......................................................................................................................... 68

13.5 Methodology................................................................................................................................... 69



14 TOPICS TO BE SCOPED OUT OF THE EIA .................................................................................... 70

14.2 Arboricultural Assessment .............................................................................................................. 70

14.3 Ground Conditions .......................................................................................................................... 70

15 OTHER SUPPORTING DOCUMENTATION .................................................................................. 71

15.2 Consultation .................................................................................................................................... 71

16 SUMMARY AND CONCLUSIONS ............................................................................................... 72

Appendices

APPENDIX 1: SITE CONTEXT PLAN APPENDIX 2: SITE LAYOUT PLANS APPENDIX 3: LAYOUT SUGGESTION APPENDIX 4: ELEVATIONS APPENDIX 5: VISUAL REPRESENTATIONS APPENDIX 6: VIEWPOINT LOCATIONS



1 INTRODUCTION

1.1 The Applicant

1.1.1 Môr Hafren Bio Power is the Applicant. The Company has been established specifically to promote and

build an Energy Recovery Facility on land at Newlands Road, Cardiff.

1.1.2 The Applicant has chosen to work with a German engineering company and technology provider,

Standardkessel Baumgarte, who have successfully delivered similar projects around the world.

1.2 Background

1.2.1 The Applicant intends to apply for planning permission for the construction and operation of an energy

recovery facility on land located off Newlands Road in Cardiff. The proposed development site is located

at Grid Reference X 323618 and Y 179468, with the nearest postcode being CF3 2EU. The site’s context

is shown on Site Context Plan: GPP/CoG/WC/19/01 Revision 1, attached as Appendix 1. Site Location

Plans: GPP/CoG/WC/19/01 Revision 2 (at scales 1:1,250 and 1:2,500) are attached as Appendix 2 and

show the proposed boundary of the prospective application site.

1.2.2 The final form and design of the building has been informed by an ‘optioneering exercise’ in conjunction

with Cardiff Council. The basic form and design principles have been ‘fixed’ and are described in Section

3 of this Report.

1.2.3 The proposed development comprises an energy recovery facility (ERF) that will use residual waste (i.e.

that remaining after material that can be re-used or recycled has been recovered) to generate electricity

that that will be exported to the National Grid. The proposed ERF will process up to 200,000 tonnes of

mainly commercial and industrial waste per annum to export around 15Mw of electricity. The plant will

be classified as a recovery facility and will be designed with the ability to export heat, as well as

electricity, should local off-take be identified.

1.3 Development of National Significance

1.3.1 The proposed scale of the development (above 10Mw and below 50Mw) means that it constitutes

development of national significance (DNS). As a consequence, the determination of the prospective

application is determined by Welsh Ministers. The procedural elements relating to the application are

administered through the Planning Inspectorate for Wales (PINS) where the application is considered by



an Independent Planning Inspector through Hearing Sessions or Public Inquiry should that prove

necessary. The Planning Inspector will prepare a Report for the Welsh Ministers based on an

assessment of the merits of the proposed development and will present a recommendation for the

consideration of Ministers.

1.3.2 The statutory basis for the DNS process is set out in Part 5 of the Planning (Wales) Act 2015, which

amends the Town and Country Planning Act 1990, the Developments of National Significance

(Procedure) (Wales) Order 2016 and subsequent regulations.

The EIA Regulations

1.3.3 The Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017 (the EIA

Regulations, as hereafter referred to), implement the requirements of the EIA Directive in Wales,

defined in the Regulations as meaning Directive 2011/92/EU of the European Parliament and of the

Council on the assessment of the effects of certain public and private projects on the environment.

1.3.4 EIA development, as defined, means that which falls under Schedule 1 of the Regulations (Schedule 1

development); or that which falls under Schedule 2 and is likely to have significant effects on the

environment by virtue of factors such as its nature, size or location.

1.3.5 The proposed development will fall under Schedule 1 (10) of the Regulations: Waste disposal

installations for the incineration or chemical treatment (as defined in Annex IIA to Council Directive

75/442/EEC under heading D9) of non-hazardous waste with a capacity exceeding 100 tonnes per day.

1.3.6 As the proposal falls within Schedule 1 of the Regulations, EIA is mandatory. Accordingly, the Applicant

is obliged to carry out an EIA and confirms that an Environmental Statement (ES) setting out the findings

of the EIA will be submitted with the forthcoming planning application. As a consequence, it is not

considered necessary to seek a formal screening request to establish the need for EIA from PINS (under

Part 2 of the EIA Regulations).

1.3.7 However, a formal request for a Scoping Direction is sought under Regulation 15(1) 30 of the Town and

Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017 (the 2017 Regulations).

The purpose of this Scoping Report is to set out the details of the proposed development, the site and

the surrounding area, and to highlight the assessment areas and approach considered appropriate for

inclusion within the EIA.



1.4 The EIA Scoping Process – Extant Planning Permission

1.4.1 The land currently has the benefit of planning permission for the construction of an integrated waste

management facility incorporating autoclave technology, materials recycling and combined heat and

power generation, ancillary offices and weighbridge office, and associated roads, car parking and

landscaping (planning reference 09/00246/E).

1.4.2 Permission was granted subject to 32 planning conditions. There was an associated legal agreement

under Section 106 of the Town and County Planning Act 1990, as amended.

1.4.3 Planning permission was subsequently granted for an extension of time for the commencement of

development (14/0251/MJR). This allows the development to be commenced, under the terms of the

extant permission, to 30th April 2020.

1.4.4 The key controls on the permission related to:

• Flood risk and drainage

• Archaeology

• Gas monitoring

• Contamination

• Noise environment

• Landscaping and tree protection

• Ecological protection

• Site lighting

1.4.5 The application was accompanied by an Environmental Statement assessing a suite of specialist topics

covering land use and ground conditions, contamination, water resources, ecology, landscape, cultural

heritage, traffic, air quality, noise and socio-economic impacts.

1.4.6 The request for a Scoping Opinion and Cardiff City Council’s formal Scoping Opinion was attached to the

submitted Environmental Statement. The key issues ‘scoped-in’ by the Council were flood risk,



groundwater and contaminated land and waste pollution/prevention issues (reference

SE/2008/106971/01-L01).

1.4.7 This Scoping Report sets out: -

• Details of the proposed development;

• Details of the site and its surroundings;

• Proposed consultation; and

• Proposed content of the EIA - consideration of the relevant environmental issues pertinent to

the proposed development.

1.5 Guidance on Developments of National Significance and EIA

1.5.1 PINS has prepared a suite of guidance for the DNS process. Appendix 3 to that Guidance covers matters

pertaining to EIA.

1.5.2 Applications which are EIA development, such as this prospective application, must be accompanied by

an Environmental Statement (ES) that reports on the likely impacts on the environment. The ES must

comply with Schedule 4 of the EIA Regulations to be deemed adequate.

1.5.3 The ES should clearly set out and explain the processes followed, the forecasting methods used and the

measures envisaged to prevent, reduce and where possible offset any significant adverse effects. The

EIA process is an iterative one and must include public participation.

1.5.4 The Guidance clearly states that ‘effort in the pre-application stage to agree the scope, methodology and

baseline information relied upon for assessment should assist a smooth examination process.’

1.5.5 Regulation 8 of The Developments of National Significance (Wales) Regulations 2016 places a duty on

PINS to provide pre-application advice to prospective applicants where that advice has been sought.

1.5.6 In this case, pre-application advice was initially sought from Cardiff City Council. Preliminary advice has

been sought from PINS on the need to engage PINS directly in further ‘formal’ pre-application advice.

Given the fact that PINS will rely on the advice of its technical advisers, including Cardiff City Council and

other bodies, PINS do not consider formal pre-application engagement is necessary. As a consequence,



direct engagement with Cardiff City Council and other bodies is ongoing.

1.5.7 This Report constitutes a formal request for a Scoping Direction from PINS on the information to be

included in the ES. PINS must adopt a Scoping Direction within 8 weeks of receiving such a request of

longer period as may be reasonably required.

1.5.8 The DNS Guidance strongly advises prospective Applicants to seek a Scoping Direction, although it is not

mandatory to do so. In order to gain the most benefit from the process it is advised that a request is

submitted when:

• There is sufficient certainty about the description of the proposed development, and

• Sufficient understanding of the main elements of the proposed development likely to have a

significant environmental effect.

1.5.9 It is considered that the description of the development, the site layout, building design and baseline

assessments are sufficiently advanced.

1.5.10 Furthermore, the Guidance advises applicants to undertake their own informal consultation to inform

the scoping request. The prospective Applicant and its advisers have undertaken informal consultation

with Cardiff City Council and the Planning Inspectorate in advance of this submission.

1.5.11 Baseline information obtained has been gathered at the appropriate time of the year.

1.5.12 The DNS Guidance assists in setting out the minimum information to be provided with a scoping

request.

1.5.13 In accordance with the requirements of Regulation 30, the following information is included in this

request for a Scoping Direction:

• Plans sufficient to identify the land, the proposed DNS boundary (defined by a red line);

• A brief description of the nature of the proposed development and its possible effects on the

environment;

• Features including designated areas on and around the site, and

• Relevant other information.



1.5.14 In dealing with the description of the development and its possible effects on the environment regard is

given to Schedule 3 of the EIA Regulations.

1.5.15 The Scoping Report also includes the information cited in Appendix 3 of PINS Guidance:

• an outline of the main alternatives considered and the reasons for selecting a preferred option;

• results of desktop and baseline studies where available;

• a record of consultation undertaken with relevant bodies (including any public engagement) to

date;

• referenced plans presented at an appropriate scale to convey clearly the information and all

known aspects associated with the proposal;

• guidance and best practice to be relied upon, and whether this has been agreed with the

relevant bodies (for example the statutory nature conservation bodies or local authorities)

together with copies of correspondence to support these agreements;

• methods used or proposed to be used to assess impacts and the significance criteria framework

used;

• any mitigation proposed and the extent to which these are likely to reduce impacts;

• where impacts from consequential or cumulative development have been identified, how

applicants intend to assess these impacts in the ES (for example, a high-level assessment of the

grid connection where this does not form part of the proposed development for a power

station);

• an indication of any European designated nature conservation sites that are likely to be

significantly affected by the proposed development and the nature of the likely significant

impacts on these sites;

• key topics covered as part of applicants’ scoping exercise; and

• an outline of the structure of the proposed ES.



1.5.16 This Scoping Report sets out:

• A description of the proposed development site and context;

• A description of the proposed development;

• The planning policy context;

• A description of the EIA process, methodology, the EIA Scoping process and the proposed

structure of the Environmental Statement;

• The methodology to be employed for each of the specialist areas scoped into the EIA. Each

topic area will include the extent of the study area, the baseline information that has been

gathered to date, outcomes from pre-scoping meetings/consultation to date that assist in

informing the EIA; relevant guidance and methodologies, identification of potential for

significant effects and approach to dealing with mitigation;

• The approach to covering any other assessments that must be undertaken as part of the EIA;

• Summary of Scope of the EIA, and

• An overview of other information that will accompany the planning application.



2 THE SITE AND ITS SURROUNDINGS

2.1 Introduction

2.1.1 The site lies within the Trowbridge area of Cardiff, approximately 6 kilometres to the north east of

Cardiff City Centre. The residential suburb of Runmey lies approximately 1.5 kilometres to the west of

the site and the suburb of Llanrumney is about 0.6 kilometres to the north.

2.1.2 The site is situated immediately to the south of the main South Wales railway line and to the north of

the B4239 Wentloog Avenue / Wentloog Road.

2.1.3 The site is situated in the Gwent Levels – Rumney and Peterstone Site of Special Scientific Interest (SSSI).

2.1.4 The Severn Estuary RAMSAR and SPA lie approximately 1.4km to the southeast. There are 2 Sites of

Importance for Nature Conservation (SINCS) within 500m of the site.

2.1.5 There are no scheduled ancient monuments, conservation areas, registered landscapes parks and

gardens of special historical interest or world heritage sites within 1 km of the site. The nearest listed

building is at a distance of 200m to the south of the site.

2.1.6 The site lies adjacent to an historic landscape area.

2.1.7 The site is located within Zone C1/Flood Zone 3.

2.1.8 The site is situated to the north of Newlands Road within the Wentloog Industrial Area. Surrounding

uses are predominantly industrial in character. To the west and east of the site are large industrial /

warehousing uses.

2.1.9 Newlands Farm is the nearest residential individual residential property, some 14om to the south east of

the development site boundary. The nearest residential estate is located off Trowbridge Road, about

515m to the north east of the development site boundary.

2.1.10 Shirenewton Travellers Site is located about 380m south east of the development site boundary.

2.1.11 Access to the site is via Newlands Road, which lies approximately 400m north of the junction with

Wentloog Avenue.



3 THE PROPOSED DEVELOPMENT

3.1 Overview

3.1.1 The Applicant (Môr Hafren Bio Power Limited) intends to seek planning permission for an energy

recovery facility (ERF) on land at Newlands Road, Cardiff.

3.1.2 Planning permission was granted in 2009 on the same site for the construction of an (200,000tpa)

integrated waste management facility incorporating autoclave technology, materials recycling and

combined heat and power generation, ancillary offices and weighbridge office, and associated roads, car

parking and landscaping (planning reference 09/00246/E). That permission remains extant and is

described previously in this Report at Section 1.4.

3.2 Scheme Description

3.2.1 The proposed development comprises an ERF, fuelled by residual waste (i.e. that commercial and

industrial waste remaining post treatment and destined for landfill), to provide electricity to the local

area via the National Grid and has the potential to provide heat to adjacent developments.

3.2.2 The proposed ERF would use a traditional moving grate technology with a steam raising heat recovery

boiler. Steam would drive a condensing steam turbine generator set with turbine pass out steam

capable of being used to provide heat to the site and a wider heat network if viable.

3.2.3 The ERF would be a recovery operation under the Waste Framework Directive and is designed to

achieve R1 Recovery Status

3.2.4 Feedstock would be sourced from within a 30-mile catchment area of the site from sources in and

around Cardiff, with up to 200,000 tonnes per year being delivered by road. Road access would be from

Newlands Road and direct access routes from the strategic highway network, with the exception of

locally sourced material.

3.2.5 The feedstock would comprise treated and commercial waste, generally considered to have minimum

50% biogenic content and potentially up to 70%. The proposed plant is designed for the generic

category of feedstock, which is composed entirely of residual waste which is suitable for combustion

and has a theoretical calorific value in the range of 9 – 16 MJ/kg. The plant would contribute to Wales’s

carbon reduction targets. The plant would contribute to sustainable waste management through using



residual waste as feedstock and ensuring that waste is diverted from landfill and managed further up

the waste hierarchy.

3.2.6 The proposed ERF would have an approximate output rating comprising approximately 15MW electrical.

The facility would operate continuously, 24 hours per day, with an approximate average of 8,000 hours

of operation per year, being offline for approximately 10% of the year for maintenance purposes.

3.3 Proposed Development Details

3.3.1 The development plot is 1.67 ha of previously developed land. The indicative site layout is shown on

Drawing 5071-18, Revision 01 – Layout Suggestion GSDA Edit 11/12/2018, attached as Appendix 3.

3.3.2 The proposed built components within the development plot would comprise:

• The tipping hall, fuel bunker, process buildings (boiler and turbine halls, and stack);

• Air-cooled condensers;

• Flue gas treatment plant;

• Residue silos;

• Firewater tanks;

• Office and weighbridge.

3.3.3 Provision is included for 15 car parking spaces and 2 accessible spaces, in the northern part of the site,

to the south of the railway line.

3.3.4 The heights of the key components of the built development would be:

• Turbine : 20m

• Air-cooled Condensers: 20.74m

• Waste Bunker: 37.5m

• Boiler Parapet: 46.45m



• Stack: 70m

3.3.5 As the final design is yet to be determined, it is possible that the built form will vary in height, although

it is not considered that such variance would be considered significantly different from the above. The

final design of the building will be determined with regard to form, function, scale, massing, landscape

and visual impact and the building’s environmental context.

3.4 Built Form and Design

3.4.1 Various built form and design options have been considered and consulted upon with Cardiff Council,

through a pre-application engagement process.

3.4.2 The ES, in the section considering alternatives, will explain the optioneering exercise and rationale

behind the preferred built form and design.

3.4.3 The design process was informed by the following:

• A recognition that a functional ERF requires a large building to accommodate the necessary

plant and a desire to not want to make the building physically bigger than it needs to be;

• A desire to not increase the built form as result of ‘design’ e.g. by the introduction of ‘non-

functional wraps or cladding, and

• A desire to create a well-designed building, that sits well in its environmental context.

3.4.4 The design process commenced with a coherent development of form from a simple approach of

horizontally and fractured blocks and evolved through the application of bands, sculpted abstraction

and rectilinear cladding.

3.4.5 The design evolution was undertaken in consultation with Cardiff Council.

3.4.6 The favoured design, in elevational and visual representations, are attached as Appendix 4 and Appendix

5 and adopts the form of a ‘bird’s nest’.

3.4.7 The elevations are shown in Appendix 4.

3.4.8 Visual representations of the building are attached as Appendix 5. The visual representations are shown

from viewpoint 2,15 and 18 on the Viewpoint Location Plans attached as Appendix 6. The ‘Test’ view

point is taken from Caer Castell Place (viewpoint 12).



3.4.9 The use of fractured and coloured panels, taking a triangular form, provides the appearance of a ‘bird’s

nest’ grounded in its context. The use of colour and design assists in breaking up the mass of the

building and is designed to blend with the predominant colour palette of its surroundings.

3.4.10 At a higher level the colouring is blended to predominant colouring of the sky and estuary in the

background which assists in drawing the eye downwards and reducing the perceived scale of the

building.

3.4.11 This is the favoured design for the following reasons:

• It fulfils the brief of providing a building that celebrates its context through its ‘iconic

camouflage’. The careful use of colour palettes and fractured design assists in presenting a

statement, while also providing mitigation through the breaking up of the massing.

• The ‘bird’s nest’ option best achieves the basic premise of the design process as set out

above. It works with the requisite elements of the ERF form and provides a functional

building of no greater scale or appearance than that required.

• The ‘’ bird’s nest’ option also presents opportunities to vary the design around the building –

allowing each elevation and interface to be developed in response to its visual context which

differs around the 360 degrees.

• The ‘bird’s nest’ option achieves a respectful balance between logic and flare.

3.5 Ancillary Infrastructure

3.5.1 HGV feedstock deliveries would enter the site in an-clockwise direction, passing over the incoming

weighbridge to be located to the west of the main buildings, before reversing in to the Tipping Hall, and

then exiting across the exit weighbridge to be located near to the car parking area, before leaving the

site in the northern corner and exiting via an existing access road. Residue Silo Tanker Deliveries would

pass over the entrance weighbridge and enter the site in a clockwise direction to the silo location, and

after delivery would exit in a clockwise direction.

3.5.2 A 15-bay car park would be provided along with a further two accessible spaces.

3.5.3 The land and water protection strategy would include such measures as sensitive construction

techniques, piling risk assessment, full impermeable bundling of bulk liquid storage, and concrete or

other impermeable hardstanding with sealed drainage systems. The surface water run-off from the site



would be treated before discharge, in accordance with limits set out in the future Environmental Permit.

3.5.4 Security fencing would be erected around the site boundaries.

3.6 Site Operations

3.6.1 The ERF would employ approximately 25 staff, on a 3-shift system such that the maximum number on

site at any one time will be 12.

3.6.2 The ERF would be operational 24 hours per day and 7 days per week, except for maintenance shutdown

periods. There are expected to be two planned shutdowns per year, one for one week and one for two

weeks; and on average there can be expected to be 10-15 days per year of unscheduled short-term

shutdowns.

3.6.3 Feedstock deliveries and materials removal would be restricted to times between 6:00am and 6:00pm.

3.6.4 The proposed plant is designed for generic feedstock, which is composed entirely of residual waste

suitable for combustion and has a theoretical calorific value in the range of 9 – 16 MJ/kg. However, the

expected average CV range is between 10 and 12. To generate a realistic worst-case, assuming an

annual average CV of 9 MJ/kg, (the low point of the theoretical range) the plant throughput would be 23

tonnes per hour. Below this CV value the plant itself becomes limiting and the tonnage would not

increase, instead the thermal throughput would decrease. At an average annual operational period of

90%, this would equate to 184,000 tonnes per year of feedstock.

3.6.5 A reasonable maximum throughput of 200,000 tonnes per year has been derived to determine the

number of feedstock deliveries. Based on this high-end throughput of 200,000 tonnes per year, a truck

payload of 20t and over 250 days per year, some 40 deliveries per day would be expected. As a

sensitivity check, should the plant be operational for up to 93% of hours in any single year, the

additional 3,675 tonnes of feedstock would require one extra truck delivery on 4 days of the week. This

would be a negligible implication for road traffic movements in and around Cardiff and the associated

environmental effects.

3.6.6 In addition to the feedstock it is anticipated that there would be approximately 40,000 tonnes of bottom

ash produced by the proposed facility per year, and some 12,000 tonnes of fly ash and flue gas

treatment residue, which would be removed from the site by road, the former in 10 tonne payloads, the

latter in 20 tonne payloads. Assuming an operation of 250 days per year, there would be some 21



additional HGV two-way movements per day. Adding together feedstock, ash and residue and car

movements, the ERF would generate a total of 116 two- way movements (i.e. 88 in and 88 out). This is a

realistic worst-case average per day.



4 PLANNING POLICY CONTEXT

4.1 Introduction

4.1.1 This section provides an indication of the planning policies that will be considered in the preparation of

the planning application and supporting ES. The development and its impact will be assessed against

national policy, local planning policy and waste policies and strategies.

4.2 National Policy

Planning Policy Wales Edition 10

4.2.1 Planning Policy Wales (PPW) published in December 2018, sets out the land use planning policies of the

Welsh Government. It is supplemented by a series of Technical Advice Notes (TANs), Welsh Government

Circulars, and policy clarification letters, which together with PPW provide the national planning policy

framework for Wales.

4.2.2 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of

sustainable development and improves the social, economic, environmental and cultural well-being of

Wales, as required by the Planning (Wales) Act 2015, the Well-being of Future Generations (Wales) Act

2015 and other key legislation.

4.2.3 PPW and the National Development Framework (NDF) set out how the planning system at a national,

regional and local level can assist in delivering these requirements through Strategic Development Plans

(SDPs) and Local Development Plans (LDPs). Planning procedural advice is given in the Development

Plans Manual and Development Management Manual as well as Welsh Government circulars and

letters.

4.2.4 PPW should be read as a whole, as aspects of policy and their application to a particular development

proposal could occur in several parts of the document. Where ‘must’ is used in the document it reflects

a legislative requirement or indicates where action is needed now to make changes in practice over the

long term to achieve strategic outcomes. Where ‘should’ is used it reflects Welsh Government

expectations of an efficient and effective planning system.

4.2.5 The Key Planning Principles in PPW are:



• Growing our economy in a sustainable manner

• Making best use of resources

• Facilitating accessible and healthy environments

• Creating & sustaining communities

• Maximising environmental protection and limiting environmental impact

4.2.6 Section 5.13 addresses Sustainable Waste Management Facilities:

The planning system has an important role to play in facilitating sustainable waste management by providing a framework for decision making which recognises the social, economic and environmental benefits that can be realised from the management of waste as a resource to meet the needs of society and businesses, …

4.2.7 At paragraph 5.13.4 PPW states:

The Welsh Government’s policy for waste management is contained in Towards Zero Waste and associated sector plans. Planning authorities should, in principle, be supportive of facilities which fit with the aspirations of these documents and in doing so reflect the priority order of the waste hierarchy as far as possible.

4.2.8 In respect of waste infrastructure PPW advises at para 5.1.3.10:

Planning authorities must support the provision and suitable location of a wide ranging and diverse waste infrastructure which includes facilities for the recovery of mixed municipal waste and may include disposal facilities for any residual waste which cannot be dealt with higher up the waste hierarchy. The extent to which a proposal demonstrates a contribution to the waste management objectives, policy, targets and assessments contained in national waste policy will be a material planning consideration.

The Collections, Infrastructure and Markets (CIM) Sector Plan (2012)

4.2.9 The Collections, Infrastructure and Markets (CIM) Sector Plan describes the waste management

framework to provide the best solutions to meet social, economic and environmental needs to 2050. It

indicates a move towards the reduction of disposal and recovery options for treating waste in favour of

high volume source segregated collection followed by reprocessing as well as preparation for re-use and

prevention.

4.2.10 At paragraph 2.3.4.4 the Plan states that;



There is a need across Wales to develop more residual waste treatment and recovery facility capacity. The future needs for residual mixed waste treatment and recovery cannot be predicted with any complete certainty due to the variety of factors that will affect future tonnages and a variety of factors that affect actual existing capacity.

Towards Zero Waste (June 2010)

4.2.11 Towards Zero Waste sets out, at a high level, how the Welsh Assembly Government will build on the

successes achieved through Wise About Waste - The National Waste Strategy for Wales (2002). It

describes a long term framework for resource efficiency and waste management between now and

2050. Towards Zero Waste is an overarching waste strategy document; it is not a detailed action plan.

TAN 21 Waste (February 2014)

4.2.12 TAN 21 provides advice on how the land use planning system should contribute towards sustainable

waste management and resource efficiency, reflecting the new waste management drivers at a

European Union and Wales level. Planning Policy Wales and TAN 21 set out a framework for facilitating

the delivery of sustainable waste management infrastructure through the planning process.

4.2.13 At paragraph 2.7.4 the TAN states:

Where wastes cannot be recycled, other waste recovery operations should be encouraged. Waste recovery operations result in waste that can serve a useful purpose by replacing primary fossil fuel materials (i.e. coal or gas) which would otherwise have been used to fulfil a particular function in the plant or in the wider economy..

The recovery of energy from mixed municipal waste in high efficiency facilities is considered by Welsh Government to be a vital component of the waste management system in Wales. Such facilities are currently considered to represent the most sustainable outcome for mixed municipal waste.

4.3 Local Planning Policy

4.3.1 The Council adopted a Local Development Plan (LDP) for Cardiff on 28th January 2016 The LDP became

operative on its adoption and now forms the development plan and will be the basis for decisions on

land use planning in Cardiff.

4.3.2 The development plan for Cardiff therefore consists of:

• The Cardiff Local Development Plan 2006-2026, adopted in January 2016.

4.3.3 The site sits within an allocated employment area (EC1.4). Policy EC1 relates to existing employment



land. The site is protected for B1, B2 and B8 uses.

4.3.4 The LDP has two waste related policies, only one of which is relevant to the proposal, Policy W1.

4.3.5 Policy W1, Sites for Waste Management Facilities, states:

Proposals for the development of waste management facilities will be permitted

where:

i. There is a demonstrable need assessed against regional requirements;

ii. They conform with the waste hierarchy and the principles contained in

the Waste Framework Directive of An Integrated and Adequate Network;

Nearest Appropriate Installation; Self Sufficiency and Protection of Human

Health and the Environment;

iii. They would not cause unacceptable harm to the environment, built

heritage or to human health;

iv. They include acceptable proposals for restoration, aftercare and after-use,

including the beneficial after-use of by-products;

v. They would not endanger aviation safety;

vi. They include acceptable proposals for the protection of adjoining and

nearby land from landfill gas and leachate migration or contamination;

vii. They are not located within an area at risk from flooding;

viii. They would not cause unacceptable air, noise or light pollution, dust,

vibration or odours, or attract excessive vermin;

ix. They provide safe means of access to the highway and adequate on-site

parking and turning facilities; and

x. They are accompanied by a Waste Planning Assessment containing

sufficient information to enable an assessment of the proposal.

Facilities for the handling, treatment and transfer of waste will generally be

encouraged towards existing use class B2 general industrial land.

4.3.6 It is clear that W1 directs development of the type proposed to B2 general industrial land.

Cardiff Well Being Plan 2018-2023.

4.3.7 The Well-being of Future Generations (Wales) Act is about improving the social, economic,

environmental and cultural well-being of Wales. It requires public services to work together through

Public Services Boards to improve the well-being of each Local Authority area and contribute to the 7

national well-being goals.



4.3.8 The Cardiff Well Being Plan sets out the Cardiff Public Services Board (PSB) priorities for action over the

next 5 years, and beyond.

4.3.9 The plan focusses on the areas of public service delivery which fundamentally require partnership

working between the city’s public and community services, and with the citizens of Cardiff.

4.3.10 The Plan contains 7 objectives. However, none are directly relevant to the proposed development. One

of the sub-objectives is managing population growth and climate change. Objective 2, however, does

refer to levels of Nitrogen Dioxide and Particulate Matter pollution levels.



5 SCOPE OF THE ENVIRONMENTAL IMPACT ASSESSMENT

5.1 Introduction

5.1.1 Regulation 17 of the EIA Regulations states that an Environmental Statement is a statement which

includes at least:

(a) a description of the proposed development comprising information on the site, design, size

and other relevant features of the development;

(b) a description of the likely significant effects of the proposed development on the

environment;

(c) a description of any features of the proposed development, or measures envisaged in order

to avoid, prevent or reduce and, if possible, offset likely significant adverse effects on the

environment;

(d) a description of the reasonable alternatives studied by the applicant or appellant, which are

relevant to the proposed development and its specific characteristics, and an indication of

the main reasons for the option chosen, taking into account the significant effects of the

development on the environment;

(e) a non-technical summary of the information referred to in sub-paragraphs (a) to (d); and

(f) any additional information specified in Schedule 4 relevant to the specific characteristics of

the particular development or type of development and to the environmental features likely

to be significantly affected.

5.1.2 Schedule 4 of the Regulations specifically requires:

• a description of the development including;

- a description of the physical characteristics of the whole development;

- a description of the main characteristics of the operational phase of the development (in

particular any production process);

- an estimate, by type and quantity, of expected residues and emissions; -

• a description of the reasonable alternatives (for example in terms of development design,



technology, location, size and scale); -

• a description of the relevant aspects of the current state of the environment (baseline

scenario); -

• a description of the factors specified in regulation 4(2) likely to be significantly affected by the

development: population, human health, biodiversity, land, soil, water, air, climate, material

assets, cultural heritage, including architectural and archaeological aspects, and landscape; -

• a description of the likely significant effects of the development on the environment resulting

from e.g. the use of natural resources, the emission of pollutants and the risks to human

health; -

• a description of the forecasting methods or evidence used to identify and assess the effects

on the environment; -

• a description of the measures envisaged to avoid, prevent, reduce or, if possible, offset any

identified significant adverse effects on the environment; -

• a description of the expected significant adverse effects of the development on the

environment deriving from risks of major accidents and/or disasters which are relevant to the

project concerned;

• a non-technical summary of the above information; and

• a reference list detailing sources used in the ES.

5.1.3 As stated in Section 1, EIA is an iterative process comprising a number of integral parts culminating in

the preparation of an ES that will accompany the application for a DNS.

5.1.4 The EIA process is summarised as comprising the following key stages:

• Scoping - this stage, seeking formal views on the scope of work to be assessed;

• Baseline studies – a series of baseline assessments will be conducted in respect of the

specialist areas. These will comprise both desktop and site-based reconnaissance studies to

establish the existing environmental conditions against which the impact of the proposed

development can be benchmarked and assessed;

• Assessment of Effects and their Significance – an assessment of the effects will be conducted

for each of the disciplines, recording the level of significance;

• Mitigation – measures necessary to reduce the potential impact, and

• Residual Effects – residual effects will be identified after mitigation is taken into account.

5.1.5 It will be necessary to ensure that a design “freeze” is applied once the baseline assessment work has



been concluded and the key receptors have been identified. This will ensure an appropriate and

consistent approach to the assessment work across the disciplines.

5.1.6 The intention of this Scoping Report is to set the scope of the EIA with regard to those specialist areas

and issues that are considered to have the potential for significant effects. Where a particular issue is

not referenced that does not mean that it will not be further considered in the DNS application; it means

that is not considered that there is potential for significant effects.

5.1.7 Baseline assessment work has been carried out across the relevant disciplines. Once the scope is

formally agreed, a Scoping Direction received and any necessary survey work concluded, potential

effects of the development will be identified and assessed according to the magnitude of change against

the sensitivity of the identified receptors.

5.1.8 The assessment will use a standard matrix and terminology, as appropriate. This will identify significant

effects and the level of significance (slight, moderate, substantial or very substantial) and whether the

effects are considered to be direct, indirect, secondary, cumulative, shirt, medium and long-term,

permanent and temporary, positive and negative.

5.1.9 The EIA and assessment of effects will consider all phases of the development and, where appropriate

take account of cumulative effects. Cumulative impacts can occur as a result of the combination of

effects arising from more than one development. Cumulative effects will be considered on a topic basis

and will address committed and consented projects. Regard will be had to known projects at the

planning stage. However, the effects of these projects may be much less certain.

5.1.10 Mitigation will also be recorded for each topic area and the level of significance of effect will be

recorded pre and post mitigation. Residual effects (i.e. those remaining post mitigation or other

environmental controls) will also be reported in the ES.

5.1.11 On the basis of the guidance set out in the 2017 Regulations, this section of the Report sets out the

proposed scope of the EIA. In terms of environmental topics, it identifies both the topics that will be the

focus of the assessment of significant effects and also those topics that are considered to have impacts

of ‘little or no significance’ and will therefore receive ‘only very brief treatment’.

5.2 The Environmental Statement

5.2.1 While the Regulations set out the matters that need to be included in the ES, there is no prescribed



format.

5.2.2 The ES for the proposed ERF will comprise:

• Non-technical Summary

• Chapter 1 - Introduction, Background, and Context

• Chapter 2 - Statement of Competency

• Chapter 3 - The Site and its Setting

• Chapter 4 - Design and Consideration of Alternatives

• Chapter 5 - Proposed Development

• Chapter 6 - Methodology

• Chapter 7 - Planning History and Planning Policy Context

• Chapter 8 - Air Quality Assessment

• Chapter 9 - Noise/Vibration Assessment

• Chapter 10 - Ecological Assessment

• Chapter 11 - Landscape and Visual Impact Assessment

• Chapter 12 - Transport/Traffic Assessment

• Chapter 13 - Cultural Heritage Assessment (above and below ground archaeology)

• Chapter 14 – Flood Consequences Assessment

• Chapter 15 - Socio-economic

• Chapter 16 - Summary of Effects and Conclusions

5.2.3 Each topic chapter will be presented in a consistent manner.

5.2.4 Together, these subjects will be presented as the ES document. Liaison between consultants will take

place where necessary to ensure that where issues may cross over subjects, they are dealt with in the

most appropriate way. This reflects the iterative nature of EIA work. Where necessary, the proposed

development will be amended to reflect the outcomes of the EIA. The outcomes will be summarised in

the ES.

5.2.5 Each assessment of the main environmental topics will consider the impacts during both the

construction of the ERF and the operational development. Each specialist subject will be presented in a

separate report within which the following matters will be addressed, where relevant: -



• Introduction

• Planning Context Summary

• Assessment Methodology

• Baseline Conditions

• Identification and Evaluation of Significant Effects

• Mitigation

• Residual Effects

• Conclusions



6 THE ENVIRONMENTAL STATEMENT AND ASSESSMENTS

6.1.1 The following sections describe the context of each topic area based upon information currently

available and the proposed scope of each topic assessment to assist consultees in assessing its

adequacy.

6.2 Introduction, Background and Context

6.2.1 This section will include narrative on the format and content of the ES and the statutory background to

the EIA process. It will also include information regarding the applicant, the assessment team, the scope

of assessment and the organisation of the ES.

6.3 The Site and Its Setting

6.3.1 This part of the ES will describe the general physical and environmental characteristics of the application

site and its surrounding environs. Other chapters of the ES will provide detailed descriptions of the site

in relation to particular environmental topics, providing “baseline” surveys against which the effects of

the proposals may be evaluated.

6.5 Description of Development

6.5.1 This section will describe the development for which planning permission is sought including the layout

of the proposed facility together with the description of the waste and energy recovery processes to be

undertaken on site. It will also set out the basis against which the EIA has been conducted.

6.6 Planning History and Planning Policy Context

6.6.1 This section will include information regarding the planning history of the site and a summary of the

policy context at the European, National, and Local level. The relevant policies will be reviewed and the

key points of relevance summarised. This will set the context for the more detailed topic analysis that

will be included in the specific chapters of the ES.

6.7 Need

6.7.1 In respect of applications for new waste infrastructure TAN 21 advises that it will be necessary for

applicants to carry out a Waste Planning Assessment and provide a Waste Policy Statement (WPS). The



WPS should include, amongst other things:

• A calculation of existing and projected future demand.

• Identify the markets that will be served by the proposed development.

• A calculation to identify the current shortfall in treatment capacity.

6.7.2 The above information will effectively provide the “need” justification for the development.

6.8 Alternatives

6.8.1 The EIA Regulations Schedule 4(2) states:

“A description of the reasonable alternatives (for example in terms of development design, technology,

location, size and scale) studied by the applicant or appellant 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.

6.8.2 The alternatives section will deal with the alternatives considered in terms of alternative technologies,

alternative scheme design and building form and scale.

6.9 Environmental Topics

6.9.1 The following Sections of the Report set out each of the environmental topics that will be assessed and

the approach to each of the assessments.

6.9.2 Where baseline data has already been collated, the methodology applied to that data collection and any

relevant baseline data is presented.



7 AIR QUALITY ASSESSMENT

7.1 Introduction

7.1.1 An Air Quality Assessment will consider the potential impacts of the development associated with the

delivery and operation of the ERF development. In doing so it will consider the potential impact of the

full range of air emissions.

7.2 ADMS Modelling

7.2.1 The modelling software used in the detailed atmospheric dispersion modelling is ADMS Version 5.2.

This is the preferred software and is one of a range of models available for assessing the impact on local

air quality of pollutant emissions to atmosphere. Those used routinely in the UK for this sort of

modelling included United States Environmental Protection Agency (US-EPA) models such as AEROMOD,

and the ADMS modelling developed in the UK by Cambridge Environmental Research Consultants

(CERC).

7.2.2 The ADMS model can be used to assess ambient pollutant concentrations arising from a wide variety of

emission sources associated with an industrial process. It can be used for initial screening or more

refined determination of ground level pollutant concentrations on either a short-term basis (up to 24-

hour averages) or longer term (monthly, quarterly or annual averages).

7.3 Modelling Uncertainty

7.3.1 Atmospheric dispersion modelling is not a precise science and results can be impacted by a variety of

factors such as:

• Model uncertainty - due to limitations in the dispersion algorithms incorporated into the

model and their ability to replicate “real life” situations;

• Data uncertainty - due to potential errors associated with emission estimates, discharge

characteristics, land use characteristics and the relevance of the meteorological data to a

particular location; and,

• Variability - randomness of measurements used.

7.3.2 CERC models are continually validated against available measured data obtained from real world

situations, field campaigns and wind tunnel experiments. Validation of the ADMS dispersion models has



been performed using many experimental datasets that test different aspects of the models, for

instance: ground/high level sources, passive and buoyant releases, buildings, complex terrain, chemistry

and plume visibility. These studies are both short-term as well as annual, and involve tracer gases or

specific pollutants of interest.

7.3.3 Potential uncertainties in the model results have been minimised so far as practicable, and a suite of

worst-case assumptions have been applied and will continue to be applied to the input data in order to

provide a robust assessment.

7.3.4 The worst-case assumptions for include the following:

• Selection of dispersion model itself – ADMS 5.2 is commonly used and results have been

verified through a number of inter-comparison studies;

• Meteorological data – modelling was undertaken using hourly average meteorological data

from Cardiff Airport which is considered to be the most representative of local conditions;

• ERF Operating Conditions – detailed design has yet to finalised and, as a consequence,

operating conditions were based upon process information for a similar ERF facility by the

same plant supplier;

• Receptor Locations – a 4km x 4km Cartesian Grid (20 metre grid spacing) was utilised in the

model in order to calculate maximum predicted concentrations in the vicinity of the proposed

ERF. Specific receptor locations are also included in the model to provide detailed

assessment at these sensitive locations (as shown below), noting that the location of sensitive

ecological receptors has yet to be determined, and

• Variability – all model inputs are as accurate as possible and worst-case conditions are

considered as necessary in order to ensure a robust assessment of potential odour

concentrations.

7.3.5 Emissions are to be assessed in line with Welsh Air Quality Regulations and their objective limits (where

applicable) or against specific pollutant Environmental Assessment Limits (EALs) detailed in NRW and

Environment Agency Guidance.

7.4 Modelling Input Data

7.4.1 The ERF is proposed to be located on a brownfield site at Ordnance Survey Coordinates ST 23628 79471.

Figure 1 below shows the proposed location of the facility, its local setting and the location of what are



considered to be the nearest sensitive receptors, in air quality terms. The specific locations are set out

in Table 1.

7.4.2 The specific receptors are denoted by blue circles and represent locations where members of the

general public may be present for significant periods of time, either through residing in that location or

through occupation.

7.4.3 Twenty-three receptors are considered to be representative of residential properties or locations where

members of the general public may be present for significant periods of time. These are shown on

Figure 1.



Figure 1: The Local Setting Showing the Location of the Proposed ERF Development Site

7.4.4 Table 1 sets out each receptor number, X and Y co-ordinates, distance from the site and receptor name.



Table 1: Specific Sensitive Receptors

7.4.5 As well as the above, it is also considered appropriate to include representative locations where Cardiff

Council undertakes NO2 monitoring. It is considered that there are twenty-six representative points, as

shown in Table 2.

Table 2: Receptor Locations - NO2 Monitoring

NO2 Monitoring Receptors X Y Distance from Site (m) Receptor Name

164 321405 179345 2,217 725 Newport Road

169 321586 177414 2,906 43 Clos Hector

170 320973 177721 3,183 11 Pengam Green

159 320709 177918 3,307 IMO façade replacement

107 320356 177618 3,762 Lynx Hotel

171 320750 177053 3,765 23 Tweedsmuir Road

97 319955 177546 4,147 Newport Road (premises)

81 319387 176980 4,920 Stephenson Court

172 320544 175613 4,950 Ocean Way 1

129 319349 176963 4,962 Stephenson Court 2

130 319326 176949 4,988 Burgess Court

131 319292 176932 5,026 Dragon Court

173 320395 175623 5,036 Ocean Way 2

44 319086 177097 5,126 City Road

45 318722 177788 5,183 Mackintosh Place

182 319162 176827 5,192 Admiral House, Newport Road

86 318452 178805 5,211 19 Fairoak Road



141 318438 178742 5,233 Fairoak Road 2

153 319491 176183 5,290 Magic Roundabout

180 318929 176681 5,467 Fitzalan Court, Newport Road

181 318712 176749 5,620 Windsor House, Windsor Lane

183 318765 176623 5,637 Station Terrace

158 318093 177716 5,803 64/66 Cathays Terrace

101 318416 176525 5,988 Cardiff Centre AURN



7.4.6 Reference is made earlier in this section to the location of ecological habitat and the need to consider

the potential air quality impacts on those receptors.

7.4.7 Internal discussions have taken place on this matter and it is considered that a total of 22 ecological

receptors are found within a 10km radius of the site. The co-ordinates of these receptors (X and Y),

distance from the proposed development site and the receptor names are set out in Table 3.

Table 3: Ecological Receptors

7.5 Plant Details

7.5.1 For the purposes of the Air Quality Assessment it is assumed that the proposed ERF will be operational

for approximately 8,000 hours per annum (i.e. 91% of the time). The remainder of the time the plant

would be off-line for routine maintenance. However, the model will be set to run on a worst-case basis

to calculate annual process contributions from the facility (8760 or 8784 hours per annum).



7.6 Emissions Data

7.6.1 The operation of the ERF would be regulated by NRW in line with conditions imposed on an

Environmental Permit (a separate regulatory regime to the DNS process). The operation of the facility

would be regulated under the Environmental Permitting Regulations (England and Wales) 2016, and

subsequent amendments. The proposed plant would be operated in accordance with conditions in the

Industrial Emission Directive (European Community Directive 2010/75/EU) (IED). It is expected that by

the time the proposed plant would be operational, the emission limit values in the EIPPC Draft BREF

Note will have been included into the IED and Environmental Permitting Regulations. The Air Quality

Assessment will take these emission limit values into consideration.

7.7 Atmospheric Chemistry

7.7.1 The Environment Agency’s recommended procedure for calculating predicted ground -level

concentrations of Nitrogen Dioxide (NO2) will be used to calculate annual average and hourly average

NO2 ground-level concentrations.

7.7.2 This procedure is based upon the following formulae:

7.8 Meteorological Data

7.8.1 Hourly averaged meteorological data from the Cardiff Airport measurement station, located

approximately 20km to the west of the proposed ERF development will be applied to the models. Data

for 2012-2016 is proposed to be used.

7.8.2 The windrose for the Cardiff Airport measurement station is shown in Figure 2. It shows a

predominance of winds from a westerly and easterly to north-easterly direction.



Figure 2: Windrose for the Cardiff Airport Measurement Station

7.8.3 The data includes nine parameters, as set out in Table 4.

Table 4: Modelled Meteorological Parameters

7.9 Local Environmental Conditions

7.9.1 Local environmental conditions describe the factors that might influence the dispersion process (such as

nearby structures, terrain rises etc) and also describe the locations at which pollution concentrations are

to be predicted.

7.9.2 These included:

• Surface roughness: this defines the amount of near-ground turbulence that occurs as a result

of surface features. Agricultural areas may have a surface roughness of approximately 0.2m



to 0.3m whereas large cities may have a roughness of 1 to 1.5m. Land use in the immediate

vicinity of the proposed development site is predominantly industrial and commercial,

surrounded by open scrub land. A roughness of 0.2m is considered appropriate.

• Nearby buildings and structures: the proximity of solid structures can affect the dispersion of

a plume. The potential impact of this occurring will be assessed on the basis of the proposed

heights of the built components of the development.

• Local terrain: this can affect wind flow patterns, and, consequently, can affect the dispersion

of atmospheric pollutants. The effects of terrain are not normally noticeable where the

gradient is less than 10%. OS mapping shows the absence of significant terrain in the vicinity

of the proposed ERF development site. For that reason, terrain effects will be excluded from

the detailed modelling.

7.10 Background Air Quality

7.10.1 Estimates of background concentrations for NOX, NO2, PM10 and PM2.5 are provided by DEFRA at a

resolution of 1km x 1km grid spacing. The development site is located within an area under the

jurisdiction of Cardiff Council. Data has been obtained for 2020 for the locality around the

proposed ERF development site. The data show that future estimates for background

concentrations of the above pollutants, without any Process Contribution from the proposed

development, are below their respective Welsh Air Quality Standards.

7.10.2 Data for the grid square immediately adjacent to the ERF development site will be used to provide

the basis for assessment for the general area around the site, relative to existing background

concentrations. The air quality assessment for the proposed ERF will be based upon the estimated

background concentrations for 2020, when the background concentration for Nitrogen Dioxide was

estimated to be 12.2 µg m-3, and this value will be used to determine the Predicted Environmental

Concentration from the model predictions for NO2.

7.10.3 Table 5 shows the background air quality data in the vicinity of the proposed development site.

Table 5: Background Air Quality Data in the Vicinity of the Development Site (2020)

Pollutant Annual Average Concentration (µg m-3)*

NO2 12.2 NOX 16.8 PM10 11.7 PM2.5 7.7 * Average of concentrations at grid point 323500,179500 and 323500,178500



7.10.4 Cardiff Council has declared four Air Quality Management Areas (AQMAs) and undertakes air quality

monitoring. Locations where air quality monitoring is undertaken are included in as specific receptors

and will be assessed.

7.11 Stack Height Calculation

7.11.1 The methodology defined in Her Majesty’s Inspectorate of Pollution (HMIP, now the Environment

Agency) guidance note D1 will be used to calculate the appropriate height of the stack proposed for the

ERF. As a minimum the guidance recommends that a stack is at least 3m taller than the height of the

building on which the stack is to be located, or near to. In this instance, the minimum stack height

would be approximately 50 metres.

7.11.2 The full stack height calculation will be included within the air quality assessment. Preliminary

assessments, and iterative modelling, indicate that a stack height of 70 metres results in more than a

four-fold reduction in the maximum annual average Process Contribution and an approximately three-

fold reduction in the maximum hourly average process contribution.

7.11.3 The detailed air dispersion modelling will be carried out on the basis that the stack will be 70 metres in

height.

7.12 Detailed Modelling

7.12.1 Detailed atmospheric modelling will be carried out in accordance with the modelled parameters set out

above.

7.12.2 Emissions of NOX, SO2, CO, Particles (PM10), VOCs, HCl, HF, Mercury, Cadmium, Other Metals and

Dioxins & Furans, will be assessed in line with the Welsh Air Quality Regulations and their objective

limits (where applicable), or against specific pollutant Environmental Assessment Limits (EALs)

detailed in NRW and Environment Agency guidance.

Determining Significance

7.12.3 The descriptive terms for the impact significance for NO2 and PM10 are based on those published in

Land Use Planning and Development Control: Planning for Air Quality (2017 Update) prepared by

the Institute of Air Quality Management (IAQM) and Environmental Protection UK (EPUK)9. Impact

description involves expressing the “magnitude of incremental change as a proportion of a relevant



assessment level and then examining this change in the context of the new total concentration and

its relationship with the assessment criterion”. The EPUK/IAQM descriptor matrix is shown in Table

6 below.

Table 6: Definition of Impact Magnitude for Changes in Annual Mean Nitrogen Dioxide and PM10

Concentration

7.12.4 The EPUK/IAQM guidance states that impacts on air quality, whether adverse or beneficial, will

have an effect on human health that can be judged as “significant” or “not significant”. The

EPUK/IAQM guidance will be followed for determining the impact descriptor for increases in annual

average NO2 and PM10 concentrations at sensitive receptors in the vicinity of the development site

7.12.5 The above assessment criteria will apply to increases in annual average NO2 and PM10

concentrations due to the operation of the ERF.

Other Assessment Criteria

7.12.6 The UK Government provides guidance for screening the significance of air quality impacts

associated with the operation of industrial processes, which is applied in England by the

Environment Agency, and which is assumed to be acceptable to NRW for environmental permit

applications in Wales. For long term impacts, the guidance recommends a 1% insignificance

threshold relative to a long term AQS or environmental assessment level, with a corresponding 10%

insignificance threshold for the assessment of short-term impacts.



7.12.7 Accordingly, the above criteria will be applied in the assessment of air quality impacts.

7.13 Residual Effects

7.13.1 Residual effects will be considered after the mitigation measures have been designed into the scheme,

should the assessment of impacts identify the need.

7.14 Cumulative Effects

7.14.1 Cumulative effects will consider the phased delivery of the development and the potential successive

and simultaneous effects of other similar development in proximity to the proposed development.



8 NOISE AND VIBRATION ASSESSMENT

8.1 Introduction

8.1.1 An Environmental Noise and Vibration Impact Assessment will be carried out to assess potential noise

implications of the ERF and associated HGV movements.

8.2 Scope

8.2.1 The scope of the assessment and precise requirements will be agreed with the relevant technical

representatives in the determining authority or advisers. Through discussion, the precise requirements

and methodology will be established for the assessment at all noise sensitive receptors (NSRs) in the

vicinity of the proposed development.

8.3 Baseline Assessment

8.3.1 The assessment will also consider the potential noise impact on ecological designations and associated

receptors, where deemed appropriate.

8.3.2 A baseline environmental noise survey will be undertaken. This will comprise unmanned weekday and

weekend daytime and night—time background and ambient noise surveys at up to three separate

locations, in order to ascertain the pre-existing environmental noise climate expected at the agreed

NSRs, for benchmarking and subsequent acoustic assessment purposes. Where it is not possible to

leave equipment unattended, representative short-term attended benchmark environmental noise

measurements shall be conducted during the weekday daytime, late-evening and night-time periods, as

deemed necessary.

8.3.3 The noise survey will be carried out using Type 1 Precision Grade noise monitoring equipment.

Meteorological data will also be recorded.

8.3.4 Based upon the results of the baseline environmental noise survey and assessment methodology,

acceptable noise levels will be determined at existing sensitive receptors during both construction and

operational phases of the development.

8.3.5 A Construction Phase Noise Impact Assessment will be undertaken.



8.3.6 Information will be obtained on the likely programme, timescales and relating to construction. This will

include phasing, ground conditions and engineering, vehicle movements and other acoustic

components. Specific acoustic data will be attained for each component. Where specific data is not

available it will be sourced from a database and referenced accordingly.

8.4 Modelling

8.4.1 A 3D computer model will be constructed of the site for the purpose of predicting the environmental

noise impact of the construction work at the NSRs. This will determine the predicted level of effects and

the need for remedial measures/mitigation to achieve the specified noise level limits.

8.4.2 The Construction Phase Noise Impact Assessment will also assess the significance in the likely change in

noise due to additional construction vehicles.

8.4.3 Thereafter, an Operational Phase Noise Impact Assessment will be carried out.

8.4.4 A 3D computer model will be constructed of the site for the purpose of predicting the significance of

noise impact from all identified significant noise sources on the site at the identified and agreed NSRs.

8.4.5 This will enable the maximum allowable sound pressure level at sensitive receptors to be identified at

the NSRs during the operational phase of the development, in line with the requirements of

BS4142:2014 and any other requirements emerging through the Scoping process.

8.4.6 The Operational Phase Noise Impact Assessment will identify the significance of effects and the need for

any mitigation to limit the noise levels.

8.4.7 The Operational Phase Noise Impact Assessment will also assess the significance in the likely change in

noise due to changes in traffic flow.

8.4.8 Both Assessments will consider the significance of effects on ecological receptors and any necessary

mitigation.

8.5 Consultation

8.5.1 Consultation to date has been in the form of a request for Pre-application Advice from Cardiff City

Council.



8.5.2 In response to that request, advice was received from Vale of Glamorgan Council (shared service). It

stated that the acoustic report should consider the following:

• The existing daytime and night-time noise levels from the nearby roads;

• An assessment of the expected impact the noise will have upon the future occupiers of the

proposed building;

• Details of any mitigation measures that may be required as a result of the impact assessment;

• Plant noise (BS:4142) for existing plant and surrounding areas and proposed noise levels for

any plant associated with the proposed accommodation.

• Given that noise is a material consideration by paragraph 13.15.1 (Edition 7) of Planning

Policy Wales, it is expected that the acoustic report is submitted for consideration and

approval by the Pollution Control team prior to determination of the application.

8.5.3 It is confirmed that the Environmental Noise Impact Assessment will include the above referenced

requirements.

8.6 Noise Sensitive Receptors

8.6.1 Prior to completing the baseline assessment, further views have been sought from Vale of Glamorgan

Council (through Cardiff City) on the agreed NSRs and other relevant matters. Formal response is

awaited.

8.6.2 The nearest identified existing residential noise sensitive premises (NSRs) to the development site are

identified as follows:

• Newlands Farm residential dwelling located c.140m to the south east of the development site

boundary

• Shirenewton Travellers Site located c.380m to the south east of the development site

boundary.

• Residential estate as located off Trowbridge Road c.515m to the north west of the

development site boundary.

8.6.3 These are shown on Figure 3 below.



Figure 3: Identified Noise Sensitive Reeptors

8.6.4 The following specific questions have been posed to Vale of Glamorgan Council, in advance of

undertaking the ENIA:

1. Could you please confirm whether there are any other existing residential receptors we need

to consider?

2. Could you please confirm whether there any proposed (either approved or pending approval)

new residential premises located in the vicinity of the Development which are required to be

considered?

3. Do we need to consider any non-residential receptors such as ecological receptors, SSSI,

public footpaths etc. in the vicinity of the development which are deemed to be acoustically

sensitive by the EHO?

8.6.5 In respect of the background assessment, it is proposed to conduct the survey during a typical 24-hour



weekday period acceptable (likely to consist of continuous unmanned measurements and limited

attended measurements).

8.6.6 Notwithstanding agreement on the identified NSRs, it is proposed to adopt 2 noise measurement

positions to determine the existing environmental noise climate at:

1) the Newlands Farm residential dwelling, and

2) at the residential estate off Trowbridge Road.

8.6.7 These are considered to be representative receptors from which the baseline noise assessment can be

modelled and the predicted noise levels at other NSRs can be identified.

8.6.8 The identified Travellers Site is located further away from the site than the identified Newlands Farm

residential dwelling and is expected to be exposed to a lower noise level impact when compared to the

Newlands Farm dwelling. The noise impact on this receptor shall still be assessed, adopting the

background noise levels as measured at Newlands Farm.

8.6.9 There is the potential for noise to be generated during construction. As part of the consultation

request, Vale of Glamorgan were also asked to confirm/comment on the following points.

1. Do we need to assess construction and operational phase generated road traffic on the local

road network on the surrounding NSRs?

2. In reference to the Vale of Glamorgan memo ref. JH4-5025/19 (attached), do we need to

consider the potential noise impact from the existing road traffic and rail traffic noise impact

on the Development proposals as part of the assessment? The development itself is not

considered to be noise sensitive.

3. Could you please confirm whether you have any specific assessment criteria to be achieved,

such as maximum permissible Rating Level relative to the Background Sound Level,

appropriate assessment criteria for non-residential receptors etc.?

8.7 Final Assessment

8.7.1 Once the NSRs and the above matters have been agreed, the baseline noise climate will be measured

and the impact of the proposed plant will be modelled for those receptor locations. The noise maps



derived from the modelling will present the expected noise levels within the wider modelled area.

8.7.2 BS4142 will be used to assess noise of an industrial nature. The procedure for assessing the impact is to

compare the measured or predicted noise level from the source in question, the ‘Specific Sound Level’

immediately outside the noise sensitive premises, with the Background Sound Level. Where the noise

contains attention attracting characteristics such as tonal, impulsive, intermittent levels, it may be

appropriate to obtain the ‘Rating Level’.

8.7.3 BS4142 states that the significance of sound of an industrial and/or commercial nature depends upon both the

margin by which the Rating Level of the specific sound source exceeds the background sound level and the context

in which the sound occurs:

• • Typically, the greater this difference, the greater the greater the magnitude of the impact.

• • A difference of around +10dB or more is likely to be an indication of a significant adverse

impact, depending on the context.

• • A difference of around +5dB is likely to be an indication of an adverse impact, depending on

the context.

• • The lower the Rating Level is relative to the measured background sound level, the less

likely it is that the specific sound source will have an adverse impact or a significant adverse

impact. Where the Rating Level does not exceed the background sound level, this is an

indication of the specific sound source having a low impact, depending on the context.

8.7.4 It is important to note from the above that the predicted magnitude of the noise impact, as based upon

the difference between the Rating Level and the existing Backgrounds Sound Level, is stated as being

dependant on the context in which the sound occurs.









9 ECOLOGICAL ASSESSMENT

9.1 Introduction

9.1.1 An Ecological Impact Assessment will be carried out to consider impacts of the proposed ERF.

9.2 Methodology

9.2.1 The assessment will be undertaken in accordance with to the Institute of Environmental Assessment’s

‘Guidelines for Baseline Ecological Assessment’ (1995), Chartered Institute of Ecology and Environmental

Management (CIEEM) ‘Guidelines for Preliminary Ecological Appraisal’ (2013) and BS 42020: 2013

‘Biodiversity - Code of practice for planning and development.

9.3 Context and Baseline

9.3.1 Planning permission has previously been granted on site (App. Number: 09/00246/E) on the 23rd

November 2009. The design proposals included the creation of an advanced waste treatment process

which utilised autoclave technology for the management of household, commercial and industrial

waste. An Ecology Chapter of an Environmental Impact Assessment (EIA) was prepared in February 2009

by Ardeola Environmental Services. An assessment of the habitats on site and their potential for use by

protected species was undertaken in February 2008. As a consequence, water vole (Arvicola terrestris),

otter (Lutra lutra), breeding birds, reptiles, amphibians (specifically great crested newt), invertebrates,

vascular and lower plants, and fungi were identified as possible constraints and relevant surveys were

undertaken during 2008.

9.3.2 An updated walkover survey was undertaken in 2014 by Godler Associates (14514190588.502/B.1)

which concluded that: “Based on the site visit and data review undertaken, there has been little change

to the nature of the site or the ecological impacts associated with the development of the site”. As such,

the findings of the original EcIA remain valid and the recommended mitigation measures should be

implemented as agreed in the extant planning consent via planning condition.

Vascular and Lower Plants

9.3.3 During the survey, three main types of vegetation were identified, including common reed (Phragmites

australis) and fat duckweed (Lemna gibba) along the ditch of the western boundary, a line of grey willow

(Salix cinerea) with some silver birch (Betula pendula) along the northern boundary and tall marshy



grassland with ruderals and brambles (Rubus sp.). Furthermore, ruderal vegetation was found on the

disturbed ground to the south and east of the site. The habitats on site (except the tree line and ditch)

were found to be of low conservation value.

Mammals

9.3.4 Evidence of foxes (Vulpes vulpes) and rabbits (Oryctolagus cuniculus), in the form of burrows and faeces,

were found on site. No observation of otter or water voles or their field signs were recorded during the

surveys even though the habitat on site was deemed to be suitable. It was recommended that the tree

line and ditch were retained.

Breeding Birds

9.3.5 Whitethroat (Sylvia communis), dunnock (Prunella modularis), wren (Troglodytes troglodytes),

woodpigeon (Columba palumbus) and possibly reed warbler (Acrocephalus scirpaceus) were observed

breeding on site during the 2008 surveys. Territories of breeding chiffchaff (Phylloscoupus collybita),

goldfinch (Carduelis carduelis), great tit (Parus major), greenfinch (Carduelis chloris), song thrush (Tardus

philomelos) and willow warbler (Phylloscopus trochilus) overlapped at least part of the site.

Furthermore, a range of birds were seen using the area during the breeding season, including bullfinch

(Pyrrhyla pyrrhula), buzzard (Buteo buteo), kestrel (Falco tinnunculus), raven (Corvus corax), swallow

(Hirundo rusticola) and swift (Apus apus). A range of additional bird species were said to use the site

outside of the breeding season.

9.3.6 No birds of conservation concern were deemed to be dependent on the habitats on site, with the

habitat potential for breeding birds and the bird assemblage on site deemed to be of no regional

significance. It was recommended that any works should be conducted outside of the breeding bird

season with a 5 m buffer implemented along the ditch and line of trees along the northern boundary.

Reptiles

9.3.7 A peak-count of three adult grass snake (Natrix natrix) were observed on 19th August 2008. Juvenile

grass snake were also observed on site which suggested that they were breeding locally. The population

density on site was deemed to be ‘low’ and a reptile translocation mitigation strategy was

recommended.



Amphibians

9.3.8 No amphibians (including great crested newt) were observed on site at the time of survey, and the site

contained no water bodies suitable for breeding amphibians. Surveys of the surrounding ponds

recorded a population of smooth newts (Lissotriton vulgaris), however no great crested newt were

observed. The site was considered to be suitable for the terrestrial stage of their lifecycle, but it was

deemed unlikely that populations were dependent on the site.

Invertebrates

9.3.9 The site contained a range of habitats in a mosaic format that were deemed to be suitable for a range of

invertebrate species, and which would provide opportunities for different parts of the life-cycle.

Coleoptera was selected as the taxonomic order which would strongly represent the assessment of

invertebrates on site. In total, 44 species of beetle were recorded on site, with grassland and scrub

matrix the dominant habitat. These species were mostly widespread species of no conservation

concern, but several species were of local significance. The site was not deemed to be of entomological

interest and no further mitigation was suggested.

Fungi

9.3.10 At the time of survey, the species found on site were typically from the bracket family (Polypores) which

live on trees and those associated with the silver birch trees along the northern boundary. The site was

not deemed to be important for fungi conservation as a limited number of species were recorded.

9.4 Preliminary Ecological Appraisal

9.4.1 A Preliminary Ecological Appraisal has been carried out. The purpose of which was to identify:

• the major habitat types present on the site and within the surrounding area;

• evidence/potential for legally protected and notable species to be present;

• potential ecological constraints associated with the proposals;

• whether additional ecological surveys are likely to be required;

• the need for mitigation and compensation; and,

• opportunities for enhancement of the natural features identified on the site and habitat

creation.

9.4.2 A desk study was completed involving database searches for statutory and non-statutory designated



sites within a 2km search area. A search for statutory European designated sites for ecology was

conducted within a 10km search area. A number of reference sources were used.

9.5 Extended Phase 1 Habitat Survey

9.5.1 An extended Phase 1 Habitat Survey of the site was carried out in March 2019. This enables the habitat

to be evaluated in accordance with the following rankings.

Table 7: Habitat Evaluation

Rank Evaluation

Negligible

While presence cannot be absolutely discounted, the site includes sub-optimal or unsuitable habitat for a particular species or species group. There may be no local returns from a data search and the surrounding habitats are considered unlikely to support wider populations of a species/species group. The site may also be outside or peripheral to the known natural range for a species/species group.

Low

Habitats within the site are of poor to moderate quality for a given species/species group. There are few or no returns from the data search, but presence cannot be discounted on the basis of national distribution, the nature of surrounding habitats, habitat fragmentation or recent on-site disturbance, etc.

Moderate

Habitats within the site are of moderate quality providing opportunities for a given species/species group. Desk study reveals local occurrence or site is within the national distribution and with suitable surrounding habitat. Factors limiting the likelihood of occurrence may include small habitat area, habitat isolation, and/or disturbance.

High Habitats within the site are of high quality for a given species/species group. Desk study provides evidence of local occurrence. The site is within/peripheral to a national or regional stronghold and/or has good quality surrounding habitat and good connectivity.

Confirmed Presence

Presence confirmed from the current survey or by recent, confirmed records.

9.6 Impact Assessment Methodology

9.6.1 The CIEEM Ecological Impact Assessment (EcIA) guidelines (2018) recommend that the value or

potential value of an ecological resource or feature should be determined within a defined geographical

context. They recommend that the following frame of reference be used (or adapted to meet local

circumstances):



• international and European;

• national;

• regional;

• county (or metropolitan);

• local; and

• site.

9.6.2 The purpose of this assessment is to identify whether sufficient information is available to accurately

assess the nature conservation value of a site for a given protected species or habitat, or whether more

comprehensive surveys are necessary.

9.6.3 The assessment of ecological impacts will follow the process described by CIEEM (2018), which can be

summarised as:

• identification of the range of potential impacts that may arise resulting from the proposed

development;

• consideration of the systems and processes in place to avoid, reduce or mitigate the possible

effects of these impacts;

• assessment of the residual impacts, following consideration of the success of avoidance and

mitigation;

• where necessary, identification of compensation required to offset any significant residual

effects; and,

• identification of the opportunity for ecological enhancement/habitat creation associated with

the proposals.

9.7 Limitations

9.7.1 Ecological surveys are limited by a variety of factors which affect the presence of flora and fauna (e.g.

climatic variation, season and species behaviour). A lack of evidence of a protected species during a

survey does not mean that the species is absent; hence, the survey also records and assesses the

suitability of habitats to support such species. The time frame in which the survey is implemented

provides a snapshot of activity within the survey area and cannot necessarily detect all evidence of use

by a species. The survey was completed in March 2019. The timings of the habitat surveys did not

present any issues when classifying habitats in this circumstance. The surveyor undertaking the habitat



surveys was suitably skilled at classifying habitats and identifying plants outside of the core flowering

season.

9.7.2 It should be noted that whilst every effort will be made to provide a comprehensive description of the

site, no investigation can ensure the complete characterisation of the natural environment. The

extended Phase 1 Habitat Survey does not constitute a full botanical survey. Plant species may have

been under-recorded, unidentifiable or not visible due to a number of factors including the time of year

the survey was carried out.

9.7.3 The protected species assessment will provide a preliminary view of the likelihood of protected species

occurring on the site. This is based on the suitability of the habitat, known distribution of the species in

the local area and any direct evidence within the survey area. It should not be taken as providing a full

and definitive survey of any protected species group. It is only representative of the time the survey was

carried out. Desk study data is not likely to be exhaustive and it is therefore possible that protected

species not identified during the data search do in fact occur within the vicinity of the site.

9.8 Survey Findings

9.8.1 Survey findings will be presented in the assessment, in full, along with recommended mitigation and the

Assessment will consider the proposed development in relation to the established baseline. Existing

knowledge of the ecological assets and value means that focus will be placed on the potential impact

upon the following assets:

• Mammals

• Birds

• Amphibians and Retiles

• Invertebrates

• Vascular Plants

• Lower plants

• Fungi

9.8.2 In addition to the above, any other protected flora or fauna assets identified in the field surveys and

supporting baseline work will be considered.











10 LANDSCAPE AND VISUAL IMPACT ASSESSMENT

10.1 Introduction

10.1.1 A Landscape and Visual Impact Assessment (LVIA) concentrates on key landscape and visual issues,

including impacts of development on the landscape resource and impacts on visual amenity. Landscape

impacts are those that occur upon the landscape character and resource, whereas visual impacts are

those that arise from changes in the appearance of the landscape and have a resulting impact on visual

amenity.

10.2 Methodology

10.2.1 A LVIA will be carried out in line with the Landscape Institutes ‘Guidelines for Landscape and Visual

Impact Assessment (GLVIA3)’ document.

10.2.2 The assessment will aim to:

• Define the existing landscape environment.

• Identify the existing visual resource and sensitive viewpoint locations.

• Indicate the sensitivity to change of the existing landscape and visual resource.

• Describe the key landscape and visually related aspects of the development.

• Describe the nature of the impact of the development on the landscape environment and

visual resource.

• Indicate the order of magnitude of the impacts of the development and set out a range of

mitigation measures to reduce the magnitude of the impact.

• Consider residual impacts of the development following mitigation.

10.2.3 The existing landscape environment will be defined through considering the following:

• International and National Landscape Designations

• Local Landscape Designations, comprising Conservation Areas, Public Rights of Ways, Listed

Buildings, Listed Parks and Garden, Local Nature reserves, Local and County Level Wildlife

Sites, Country Parks and Registered Common Land

• National, County and Local Landscape Character Area Appraisals



10.3 Visual Baseline

10.3.1 The Visual Baseline Methodology relies upon an initial study of Ordnance Survey Map 171 Cardiff and

Newport (1:25,000), to identify potential viewpoints and areas for investigation based on the following

criteria:

• Distance from the scheme to the receptor;

• The proportion of the development visible as well as the absolute visibility of the scheme;

• The height of the development relative to the receptor with reference also to the scale of

other features in the view;

• The number and character of elements which would be lost from or added to the view;

• High concentrations of viewers, such as settlements, local recreational facilities, PROWs etc.;

• Views illustrating the visual character of the surrounding area.

10.3.2 Viewpoints will be selected on the basis of which points provide the clearest views of the site and are

also the most accessible to the public.

10.3.3 Site survey work has identified 19 receptor locations, as set out below (X and Y co-ordinates and AOD,

using hand held GPS device at camera level):



Table 8: Viewpoint Locations





10.3.4 Plan showing the location of each viewpoint are attached as Appendix 6.

10.4 Zone of Theoretical Visibility

10.4.1 A Zone of Theoretical Visibility will be established for the various elements of the scheme to show the

extent of visibility. Analysis of the ZTV will form a key part of the assessment of impact.

10.4.2 The LVIA will consider the impact of the construction and operational phases of the ERF development. In

visual terms, the impact will be considered with respects to the identified viewpoints.

10.4.3 Where required, mitigation measures will be suggested for incorporation into the development scheme.

These will be suggested for both the construction and operational phases of the development.









11 TRANSPORT ASSESSMENT

11.1 Introduction

11.1.1 A Transport Assessment (TA) will be undertaken that considers the impact of the proposed development

in terms of transport accessibility, highway capacity, safety and traffic routeing.

11.2 Scope

11.2.1 The scope of the Transport Statement (TS) has been defined with reference to the highway network

along which development traffic will travel. The westerly extent of the site is defined by the

A4232/Lamby Way/River Way junction. Beyond this junction, due to the high volume of existing vehicle

flows on the highway network, the impact of the development traffic associated with the site is not

considered to be material.

11.2.2 The baseline conditions have been determined through both-desk based and field survey.

11.3 Context and Baseline Conditions

11.3.1 The site is situated approximately 6 kms to the northeast of Cardiff City Centre within the Wentloog

Industrial area. It is located to the north of Newlands Road and to the south of the Cardiff/Newport

railway line. The site is presently undeveloped although it is known to have been previously used for

storage.

11.3.2 Planning permission was granted in 2009 for the construction of a 200,000 tpa integrated waste

management facility incorporating autoclave technology, materials recycling and combined heat and

power generation, ancillary offices, weighbridge office, associated roads, car parking and landscaping

(planning reference 09/00246/E). A further planning application, submitted in 2014 (14/02521/MJR), for

the extension of time period for the commencement of work was granted permission in June 2015.

11.3.3 The site is predominantly surrounded by large industrial units towards the east and south, Pinewood

Studios and other industrial units towards west and the railway line to the north.

11.3.4 Access into the application site is currently at the north-eastern corner of the site via an unnamed

service road. This road is 8.6m wide and connects to Newlands Road approximately 400m north of the



junction with Wentloog Avenue (B4239).

11.3.5 Newlands Road is subject to a 30mph speed limit and runs from the roundabout junction with the B4239

Wentloog Avenue to the Freightliner Depot to the east of the site. The general carriageway width of

Newlands Road is approximately 8.9m, whereas in the vicinity of the site Newlands Road is 9.3m wide.

11.3.6 Newlands Road has a 2m wide footways on both sides of the carriageway. It was observed during the

site visit that the footway on the northern side of Newlands Road is not currently continuous due to the

patches of overgrown vegetation.

11.3.7 Wentloog Avenue is approximately 8.4m wide in the vicinity of the site with a 2m wide footway and 2m

wide verge on both the northern and the southern side. Wentloog Avenue becomes Lamby Way

adjacent to the landfill site access. Lamby Way connects with the A4232 at a roundabout junction with

Rover Way. The A4232 connects to the A48 via a gyratory and the A48 joins the M4 at Junction 29, to

the east of the site.

11.3.8 Newlands Road, Wentloog Avenue west of the site and Lamby Way all benefit from existing street

lighting. Wentloog Avenue, west of the site, has a speed limit of 30mh, whereas Lamby Way is subject to

a speed limit of 40mph.

11.3.9 A Public footpath approximately 2.5m wide runs along the western boundary of the site and connects

Newlands Road with the Trowbridge residential area north of the site via a pedestrian and cycle bridge

over the railway line.

11.3.10 The nearest bus stops (Flagpole) are located approximately 370m west of the site on both sides of

Wentloog Avenue (Inbound/outbound). Service 10 runs between Cardiff City Centre and Wentloog

Industrial area during the morning and evening peak hours. The weekday service is every hour between

06:00 and 09:00 in the morning and every hour between 15:00 and 18:00 in the evenings. There is no

service during weekends and bank holidays.

11.3.11 Annual average daily flows between the junctions of the A4232/Lamby way /Rover Way and

A4232/A4161 will be taken into account to examine the impact of the development traffic on the

principal highway network. This information has been obtained from the Department for Transport

(DfT) traffic statistics for the year 2018 and was recorded approximately 270m north of the A4232/

Lamby Way/Rover Way Roundabout junction.



11.4 Methodology

11.4.1 The Transport Assessment (TA) will be undertaken in accordance with the Guidelines for the

Environmental Assessment of Road Traffic prepared by the Institute of Environmental Assessment. The

document sets out two rules to be considered when assessing the impact of development traffic on a

highway link:

• Include highway links where traffic flows will increase by more than 30% or the number of heavy

goods vehicles will increase by more than 30%, and

• Include any other specifically sensitive area where traffic flows have increased by 10% or more.

11.4.2 This is based on the assumption that an increase in traffic of less than 30% is likely to have an

imperceptible environmental impact, and that the increase of less than 10% will have no discernible

environmental impact.

11.5 Assessment of Effects

11.5.1 The environmental effects specified in the Guidance will be considered:

• Severance

The guidance suggests that severance effects are considered ‘slight’ in cases that included

changes of traffic flow of less than 30%.

However, guidance related to potential severance formed due to new routes is not relevant

in respect of this development.

• Driver Delay

New development has the potential to increase the number of vehicles using the main routes

and junctions and thereby create delay in the network. However, the extent of such delays on

the network will be based on a number of factors including the existing operation of the

route or the junction, levels of background traffic and the traffic generated by the

development.



• Pedestrian Delay and Amenity

This is defined as the relative ‘pleasantness’ of journeys and can be affected by a number of

factors. Pedestrian delay and pedestrian amenity both derive from a consideration of the

ability of the pedestrians to cross individual routes. This is further dependent on the extent of

this change in crossing these routes as a consequence of the additional traffic on that route.

The guidance suggests a threshold for significance where traffic flow, or its HGV component,

is halved or doubled.

• Fear and intimidation

Fear and intimidation are another problem caused to pedestrians and cyclists by the close

proximity of vehicular movements. This impact is further dependent on the closeness of the

footway to the carriageway edge, volume and type of traffic and the width of the footway.

However, there are no commonly agreed thresholds for the assessment of this impact.

• Accidents and Safety

The assessment of highway safety and the risk of accidents occurring is based on the existing

knowledge and information on the existing accident rates in the local area, to identify any

specific circumstances and accident clusters.

11.5.2 For a number of effects there are no ready thresholds of significance or magnitude of impact. In such

cases, interpretation and judgement is applied based on experience. Potential effects will therefore be

described as:

• Adverse: Detrimental or negative effect to an environmental resource or receptor;

• Negligible: No significant effect to an environmental resource or receptor; and

• Beneficial: Advantageous or positive effect to an environmental resource or receptor.

11.5.3 The Guidelines for Environmental Assessment of Road Traffic identify that the most discernible

environmental effects of traffic are noise, severance, pedestrian delay and intimidation, with severance

and intimidation being the most sensitive to changes in traffic volumes.

11.5.4 The following contextual scale will be used to define the magnitude of change to traffic in the



assessment:

• Less Slight: less than 30% increase in traffic

• Slight: 30% increase in traffic

• Moderate: 60% increase in traffic, and

• Substantial : 90% increase in traffic

11.5.5 The significance of the effect is a combination of the magnitude of change and the capacity of the

receptor to absorb change. Professional judgement is exercised in ascribing significance having regard to

the magnitude of change, and the spare capacity of the existing transport network. Impacts are

characterised as:

• Negligible: Impact beneath level of perception or within margin of forecasting error;

• Minor: Slight impacts, very short or highly localised impact of no significant consequence;

• Moderate: Limited impact (by extent, duration or magnitude) which may be considered

significant and

• Major: Considerable impact (by extent, duration or magnitude) of more than local

significance or in breach of recognised acceptability, legislation, policy or standards.

11.5.6 Mitigation measures, including a Travel Plan, will be considered as appropriate.









12 HISTORIC ENVIRONMENT ASSESSMENT

12.1 Introduction

12.1.1 An assessment will be conducted of the impact of the proposed development on heritage assets (above

and below ground).

12.2 Scope

12.2.1 A desk-based Heritage Assessment will be carried out to assess potential buried archaeological interest.

The assessment will also consider the impact of the proposed ERF on the setting of designated and no-

designated historic assets.

12.2.2 The purpose of the assessment will be to address 'historic assets' of the site as defined in PPW.

12.3 Assessment

12.3.1 The assessment of potential impact on historic assets will focus on the setting and significance of

historic/listed buildings in particular and any other designated assets as well as non-designated heritage

assets identified by Cardiff City Council. The assessment will follow the best practice guidance

recommended by Cadw and assess the significance of the assets, identify their settings and the

contribution setting makes to their significance and assess the impact of the proposed development.

The relevant provisions of the Historic Environment (Wales) Act 2016 will also be taken into account.

12.3.2 The height of the building and proposed stack are such that the proposed development may have

impacts on the settings of historic assets.

12.3.3 In particular the development will be visible from the Registered Gwent Levels Landscape of

Outstanding Historic Interest to the east, although the proposed development site is not situated within

the designated area.

12.3.4 A review of the extant planning permission for waste uses on the site, and supporting information,

reveals that the original proposal was not considered to require an AISDOHL2 Assessment (Assessment

of the significance of the impact of development on historic landscape) to quantify the impact the

development might have on Landscape Character areas within the landscape.



12.3.5 It is considered that such an assessment may be required given the scale of the built development and

its potential visual impact.

12.3.6 The Heritage Assessment will be informed by the ZTV and the Landscape and Visual Impact Assessment.

12.3.7 Formal advice on the scope of the assessment is sought through the submission of this Scoping Report.

12.3.8 A previous desk based archaeological assessment was conducted at the site, suggesting it was

predominantly farmland before being used as a railway sidings and timber yard. The site lies within the

Gwent Levels and, as a consequence, there is potential for deeply buried archaeological deposits of

Prehistoric, Roman and Medieval date.

12.3.9 This potential will be considered and assessed.

12.3.10 Where required, the scope of any mitigation measures that might be required or design iteration which

can contribute to mitigating the effect of development on significance will be proposed.









13 FLOOD CONSEQUENCES ASSESSMENT

13.1 Introduction

13.1.1 A Flood Consequences Assessment will be carried out along with a drainage strategy that is appropriate

for the site’s location.

13.2 Context

13.2.1 The entire site is located within Zone C1/Flood Zone 3 with the risk of flooding being from

predominantly tidal sources. The area is classified as an Area Benefitting from Defences and a review of

mapping produced by NRW for Surface Water flood risk indicates there is an isolated area at low risk of

surface water flooding and solely contained within the drainage ditch channel itself. These areas are less

than 300mm in depth and have a low risk or negligible hazard risk.

13.2.2 The site is currently defended along the River Severn and the associated tidal frontage by an earth

embankment running parallel to the Severn Estuary from Rumney Sea Wall in the west to Tredegar Pill

in the east. A 2013 survey undertaken by NRW identified the crest levels of the defences and

subsequent further assessment identified that only the section at Peterstone Gout has a Standard of

Protection (SoP) against tidal flooding of less than 1 in 1000 years (0.01%). Consideration is being given

to improvements in flood risk management measures in the Wentloog levels as part of the Environment

Agency’s Severn Estuary Flood Risk Management Strategy (SEFRMS).

13.2.3 Within Zone C1 Less Vulnerable development can take place subject to application of the justification

test, including acceptability of consequences. Where development is justified a flood consequences

assessment (FCA) can be used to establish whether suitable mitigation measures can be incorporated

within the design to ensure that development is as safe as possible.

13.3 Objectives

13.3.1 The main objectives of the FCA will be to develop a full appreciation of :

• The consequences of flooding on the development;

• The overall impacts of the development on flood risk elsewhere within the catchment for a

range of potential flooding scenarios up to that flood having a probability of 0.1%;

• The FCA can then be used to establish whether appropriate mitigation measures can be



incorporated within the design of the development to ensure that development minimises

risk to life, damage to property and disruption to people living and working on the site or

elsewhere in the floodplain.

13.4 Baseline Conditions

13.4.1 The anticipated ground conditions for the majority of the site are based on available information from

BGS which indicates the site is underlain by sedimentary Mudstone from the Mercia Mudstone Group.

The dominant superficial deposits in the area are Tidal Flat Deposits – Clay, Silt and Sand. A review of

LandIS soils guide suggests the site is underlain by loamy and clayey soils of coastal flats with naturally

high groundwater.

13.4.2 April 2019 received 125% of the long term average rainfall (LTA) for Wales. River flows in the area were

predominantly ‘normal’ (24 out of 29 indicator sites) with 2 sites classed as ‘above normal’ and the

remaining 3 sites as ‘below normal’. Soil moisture deficit reduced across the month with the differences

between SMD values and the LTA across Wales varying from -16.3 to 12.0mm and soils generally wetter

than the LTA across the Area. The cumulative reservoir storage for 14 out of 18 indicator reservoirs was

greater than 95% at the end of April. All reservoirs were within normal operating ranges for the time of

year.

13.4.3 The BGS/NRW GeoIndex mapping suggests the site is underlain by a Secondary B Bedrock aquifer and a

Secondary Undifferentiated superficial aquifer and is within a Groundwater Vulnerability Zone classed as

high vulnerability, secondary aquifer. The site is not situated within a Groundwater Source Protection

Zone.

13.4.4 The Planning Policy Wales, via TAN15 Development and Flood Risk, sets out a precautionary principle to

guide planning decisions defined by Development Advice Zones. The site is within Zone C1 and served

by significant infrastructure including flood defences which lower the potential flood risk.

13.4.5 The site is predominantly greenfield and exhibits natural drainage to ground and there are no surface

water features, formal drainage or built structures with drainage provision other than a minor drainage

ditch which runs parallel to the south western boundary separating the site from the adjacent footpath.

13.4.6 The site does not currently have a requirement for foul drainage.

13.4.7 Given the site’s location in Zone C1, the FCA will include a justification test in accordance with the



requirements of TAN15. It is considered that the wider sustainability benefits of the proposal will satisfy

the justification test and this will be set out in full.

13.4.8 National policy and local development and flood risk policy will be considered in full.

13.5 Methodology

13.5.1 A full flood consequences assessment will be undertaken with reference to available data from NRW

mapping and modelled data. This will include modelled levels for tidal events from the Caldicot and

Wentlooge Coastal Modelling Study (JBA 2016) and the predicted effects of climate change as set out in

Flood and Coastal Defence Appraisal guidance FCDPAG3.

13.5.2 Surface water flooding, drainage and infrastructure flood risk, groundwater flood risk and other sources

of flood risk will be assessed along with historical flooding. Wave action will also be considered.

13.5.3 The effect the existing flood defences will be taken into account in the assessment.

13.5.4 A Flood Management Plan will be produced for the site.

13.5.5 The flood risk implications will be fully assessed and a sustainable drainage system will be developed as

suitable surface water mitigation.

13.5.6 The risks to the water environment from surface water discharges will be assessed based upon the

expected risk classification onsite in accordance with the Simple Index Approach recommended in both

C753 The SuDS Manual V3 and the SuDS Standards for Wales 2018.

13.5.7 The significance of effects will be recorded along with any mitigation required.









14 TOPICS TO BE SCOPED OUT OF THE EIA

14.1.1 The following section details the topic areas that will not be assessed under the Environmental Impact

Assessment (Wales) Regulations 2017, and will not therefore support the Environmental Statement.

Justification for the ‘scoping-out’ of the topic areas is provided below.

• Arboricultural Assessment

• Ground Conditions

14.2 Arboricultural Assessment

14.2.1 There are existing trees/shrubs along the western boundary of the site. Their respective value will be

assessed outside the scope of the ES and the findings and recommendations recorded in the Planning

Statement.

14.3 Ground Conditions

14.3.1 Due to the historic nature use of the site as a railway sidings and timber pit-prop stocking area, site

investigations were undertaken both in the late 1990’s and more recently in 2008. Contamination tests

of the samples that were taken identify low concentrations of potential contaminants at levels below

the risk to human health or to the environment. The risk of groundwater contamination is also very low

given the low permeability of deposits underlying the site. No significant concentrations of ground

gases were recorded.

14.3.2 The recorded ground conditions will be set out in the Planning Statement.

14.3.3 Prior to construction works commencing, detailed method statements; health, safety and

environmental management plans; and safe systems of work will be put in place. All construction

activities at the site will also be undertaken in accordance with best management practices including

Guidance for Pollution Prevention (GPP) produced by Natural Resources Wales.



15 OTHER SUPPORTING DOCUMENTATION

15.1.1 The Planning Application will be supported by the following, supporting documents and other

documents deemed necessary through scoping or wider consultation:

• Travel Plan

• Arboricultural Assessement

• Drainage Strategy

• Planning Statement

15.2 Consultation

15.2.1 Under Article 11 of the Developments of National Significance (Procedure)(Wales) Order 2016, a DNS

application must be accompanied by a Pre-application Consultation Report (PAC).

15.2.2 The application will be accompanied by a PAC Report that will include a full account of the consultation

undertaken, responses received and how the proposed development has responded to particular issues

raised.

15.2.3 The PAC Report will include the information set out in section 61Z of the Act including copies of all

relevant notices and publications used, appropriate Declarations, addresses of those given notice of the

proposed application, the particulars of all responses received from persons consulted and copies of the

responses.



16 SUMMARY AND CONCLUSIONS

16.1.1 This Scoping Report seeks a formal Scoping Direction for the proposed 200,000 tonnes per annum, Môr

Hafren Energy Recovery Facility on land at Newlands Road, Cardiff and sets out the details of the

proposed development, the site and its surroundings and the proposed content and extent of the EIA.

16.1.2 The intention of this Scoping Report is to set the scope of EIA with regard to those specialist areas and

issues that are considered to have the potential for significant effects.

16.1.3 The EIA will include assessments of:

• Air quality

• Noise and Vibration

• Ecology

• Landscape and Visual Impact

• Transport

• The Historic Environment

• Flood Consequences

16.1.4 Advice and guidance are sought on the proposed scope and, in particular, agreement on receptors and

the need for additional survey work to inform the EIA and subsequent ES.

16.1.5 This Report is submitted to PINS in association with a request for a formal Scoping Direction for this

Development of National Significance.


C025-01/Môr Hafren ERF Scoping Report/MD August 2019 Appendix

APPENDIX 1: SITE CONTEXT PLAN



APPENDIX 2: SITE LOCATION PLANS



APPENDIX 3: LAYOUT SUGGESTION



APPENDIX 4: ELEVATIONS



APPENDIX 5: VISUAL REPRESENTATIONS



APPENDIX 6: VIEWPOINT LOCATIONS

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Documents

GP Planning Ltd. · GP PLANNING LTD EIA SCOPING REPORT C025-01/Môr Hafren ERF Scoping Report/ MD August 2019 4 1 INTRODUCTION 1.1 The Applicant 1.1.1 Môr Hafren Bio Power is the