Scottish Government EIA Workshop October 2014 Scoping for

Scottish Government EIA Workshop
October 2014
Scoping for Efficiency
Jim Mackay and Katherine Lakeman, SEPA
Kieron Hansen and Harry Driscoll, Hydroplan
General introduction and EIA scoping background – 15 min – Jim
Hydroplan experience and case study – 25 min – Kieron and Harry
SEPA scoping case study – 25 min – Jim and Katherine
Main scoping findings from session overall – 5 min - Katherine
Scoping is the process of determining the content and extent of
matters to be covered by the EIA and the resulting Environmental
Statement (ES). The purpose of scoping is to:
• identify the key issues to be considered
• identify those matters which can either be scoped out or which
need not be addressed in detail
• discuss and agree appropriate methods of impact assessment,
including survey methodology where relevant.
The scoping process should also be used to identify any other
project level assessment or survey obligations which may apply.
No statutory requirement for a developer to consult planning
authority or Consultation Bodies at scoping stage, but strongly
encouraged to do so
National or major developments require pre-application
consultation with the public – will inform EIA content
Where developer requests formal scoping opinion from planning
authority, planning authority must consult Consultation Bodies
Benefits of efficient, effective scoping
• More concise, targeted ESs
• Robust, if audit trail provided
• Less wasted resource in ES preparation and
EIA process
• Speedier ES preparation and EIA process
• Speedier planning process
• Efficiencies all round!
• New focus on significant effects (EIA Directive
Scoping Concise
Some EIA developments that went badly wrong…
effective and efficient scoping would have helped
SEPA’s new pilot – new EIA Scoping approach being
trialled initially on hydros
Much more map based
Much less discursive
More emphasis on schedule of mitigation
Sharp and to the point
Extract from a SEPA scoping response (2010) in relation to peat:
Disruption to peatlands
If there are peatland or mire systems present, the ES should demonstrate how the layout and design of the
proposal, including any associated borrow pits, hard standing and roads, avoid impact on such areas where
possible. For areas where avoidance is impossible details of how impact is minimised and mitigated should be
provided, including a detailed map of peat depth for all construction elements that affect peatland habitats.
Peatland impacts that should be considered include those from waste management, drainage, dewatering,
excavation and pollution.
By adopting an approach of minimising disruption to peatland, the volume of excavated peat can be minimised
and the commonly experienced difficulties in dealing with surplus peat waste reduced. The generation of surplus
peat waste is a difficult area which needs to be addressed from the outset given the limited scope for re-use.
Landscaping with waste peat (or soil) may not be of ecological benefit and consequently a waste management
exemption may not apply, and the position regarding disposal of waste peat within borrow pits can be very difficult.
Early discussion of proposals with us is essential, and an overall approach of minimisation of peatland disruption
should be adopted.
The disposal of surplus peat waste to borrow pits is not encouraged as experience has shown that peat used as
cover can suffer from significant drying and oxidation, and that peat redeposited at depth can lose structure and
create a hazard when the stability of the material deteriorates. This creates a risk to people who may enter such
areas or through the possibility of peat slide and we are aware that barbed-wire fencing has been erected around
some sites in response to such risks. There are important waste management implications of measures to deal
with surplus peat, including the possibility that peat disposed at depth must be considered in the context of waste
being landfilled, requiring a PPC permit, and may not be consentable under our regulatory regimes. It is therefore
essential that the scope for minimising the extraction of peat is explored and alternative options identified that
minimise risk in terms of carbon release, human health and environmental impact. It is also important to discuss
options with us at an early stage.
So much advice and so generalised… was it picked up by the developer?
Extract from the subsequent scoping section of the Environmental Statement
So, having received copious scoping advice, SEPA’s requests regarding peat
were not included as a topic requiring further investigation
Revisiting benefits of efficient,
effective scoping
• New focus on significant effects (EIA Directive
• More concise, targeted ESs
• Robust, if audit trail provided
• Less wasted resource in ES preparation and
EIA process
• Speedier ES preparation and EIA process
• Speedier planning process
• Improved environmental outcomes
• Efficiencies all round!
Scoping Workshop
New streamlined SEPA hydro EIA scoping response – a pilot
New, alternative approach now being trialled in SEPA’s hydro EIA planning
responses. Our entire scoping request is now shorter than a single descriptive
request in our previous scoping requests.
Information provision is now dominated by provision of overlaid maps and
schedule of mitigation
These requests are supported by detail on how to prepare the maps or carry
out the surveys. Will the new “Scoping for Efficiency” approach work?
Example provided for discussion
We consider that the following key issues must be addressed. To avoid delay
and potential objection, the following information must be submitted:
[Delete any not applicable]
a) Details of any related CAR application or authorisations;
b) Each of the maps below must detail all proposed upgraded, temporary and
permanent site infrastructure. This includes all tracks, excavations,
buildings, borrow pits, pipelines, cabling, site compounds, laydown areas,
storage areas and any other built elements;
c) Map and assessment of all engineering works within and near the water
environment including buffers;
d) Map and assessment of impacts upon Groundwater Dependant Terrestrial
Ecosystems and buffers;
e) Map and assessment of impacts upon groundwater abstractions and buffers;
f) Peat depth survey and table detailing re-use proposals;
g) Map and table detailing forest removal;
h) Map and site layout of borrow pits;
i) Schedule of mitigation including pollution prevention measures.
That is our entire list of requests – and even then some may
be scoped out as not significant effects
Example of map we expect to see…
Example of map we expect to see - GWDTEs…
Further enhancement – if
the nature of an area of
the site ruled out
development options, was
there need to survey?
Could more effective
scoping have ruled out
surveys to the east of the
burn in this case?
Information on the wrong scale and form to allow us to assess
significant impact on sensitive features - we cannot see what’s
happening at the powerhouse (far east). There is good information
in the supporting report but it is not presented at the best scale.
Our new scoping approach is clearer on requirements.
Route of
Good map-based information on peat depth in
relation to infrastructure, as per scoping request