Alternatives, Mitigation and

Environmental Management
Plans
 Types of alternatives
• No action
• Locations
• Scales of project
• Processes or equipment
• Site layouts & designs
• Operating conditions
(may be limited by commercial considerations; and
should be developed in consultation with
stakeholders)
 Dibden Terminal Alternatives
Outline:
• The primary use of the Terminal will be the import,
export and distribution of unitised freight in
containers. The Terminal will also be used for the
import of aggregates, for roll-on/roll-off (ro-ro) cargo
(vehicles) and lift-on/lift-off (lo-lo) cargo.
• Operational area: 202 hectares.
• Environmental measures: 185 hectares (including
planting, landscaping and nature conservation
enhancements) and agriculture.
Principal land uses within the Terminal :
• Approximately 1.8 kilometres of quay providing 6
deepwater berths; cranes, storage areas, railway yards,
offices, parking, landscaping
 Dibden Alternatives

Increase existing capacity- decking, change of use, efficiency

Extend existing docks- little space or scope for reclamation
Develop elsewhere- none viable- reclamation and transprt links
needed
Do nothing- see ‘need’
 Alternative Designs and Sight
Layouts: Southampton Biomass
Power project
http://www.thisishampshire.net/news/8856144.Public_meeting_on_po
wer_plant/
 Landscape and design issues
• Initial design was very badly received by
the local community
• http://nosouthamptonbiomass.co.uk/a
ction_needed.html
 Redesigns proposed with
consultation
Generally-
• Smaller stack, buildings etc
• More sensitive alternative designs
• Further consultation with community and
statutory consultees
“Marine Design”
•Mimicking a container ship
•Sloping profiles
•External features echoing masts or
containers
•http://www.southamptonbiomasspower.com/design.aspx
“Wave Design ”
•Curves soften appearance from a distance
•Flows between components
•Use of blocks of colour to break up visuals
“High-tech Design ”
•inspired by the language of modern high
technical equipment
•highlights the industrial nature of the plant
whilst providing an idea of the processes
that take place (e.g. red for boiler house)
• Further Community Consultation sought
the local community's views on the
alternative design approaches for the
scheme.
• Those local community respondents, and
the statutory consultees, who selected a
preferred design approach demonstrated a
clear preference for the 'Marine' design
approach (52% for Marine, 35% Wave,
13% High Tech).
Stonehenge- A303 improvement-
Alternative routes
Options for alternatives:
• 2.1 km bored tunnel- rejected because of costs (£510m)
• Northern route (£283m)
• Southern Route (£246m)
• Cut & Cover tunnel(£389m)
• “Partial solution” (£159million)
 Stonehenge alternatives:
• “Published scheme”- expensive
• Northern & Southern routes- impacts on
monuments, landscape, biodiversity,
residences
• Cut & Cover- cheaper- potential damage
on landscape & heritage; 9m high
embankment
• Partial solution-some traffic improvements
and improvements to setting
• 2009: Visitors Centre to be relocated to
Airman’s Corner- now open
• A344 now closed; grassland being restored

http://www.engli
sh-
heritage.org.uk/
daysout/propert
ies/stonehenge/
our-plans/our-
proposals/
Now- further proposal for
tunnel
http://www.bbc.co.uk/news/u
k-england-wiltshire-
30267403
Normanton
Down Barrows
at western End
of cutting: calls
to further
redesign

Guardian
8/2/2017
 Alternatives- changes in 2014
Directive
Requirements should be clearer:
• 'a description of the reasonable
alternatives studied by the developer,
which are relevant to the project and its
specific characteristics',
instead of
• 'an outline of the main alternatives studied
by the developer'.
• -See more at: http://www.bdb-law.co.uk/news-and-views/blogs/planning-act-
2008/2014/june/555-new-environmental-impact-assessment-directive-comes-into-
force/#sthash.OU9wBFZa.dpuf
 Mitigation approaches
“measures envisaged to avoid, reduce, and,
if possible, remedy significant adverse
effects” From Directive 97/11
The significance spectrum

• From Ehrlich & Ross 2014

Mitigation Strategies- a hierarchy

• Avoid the impact by not taking certain

action
• Reduce/Minimise the impact over time by
maintenance or preservation
• Restore/Remedy the impact by repair or
restoration
• Compensate by replacing resources
• (plus Enhance: positive changes)
General elements of mitigation,
from http://eia.unu.edu/course/index.html%3Fpage_id=118.html
 Avoid:
• In the extreme, don’t build or avoid land-
take
• Change site layout, for example to avoid
destruction of hedgerows
• Schedule lorry movements to avoid traffic
congestion or late night noise
 Reduce:
• Reduce visual impact by reducing height
of large structures, planting barriers of
trees, building earth banks, or designing to
fit in with existing landscape
• Reduce area of greenfield with housing to
protect nature conservation or amenity
• (generally better to abate at source rather
than abate at receptor)
 Restore/Remedy:
• Repair or reseed a meadow used for
temporary storage of construction
materials
• Resurface access roads damaged by
heavy vehicle use
 Compensate:
• Create replacement habitat
• Provide sound insulation for local
residents
• Provide financial compensation for loss of
amenity
 Enhance
Projects can have positive effects as well as
negative’ These could be further advanced,
e.g.
• by innovative design (e.g. Stonehenge
Visitor Centre)
• By net gain in habitat (e.g. Dibden)
• Or generate local improvements that
support the project and the local area; e.g.
road or other infrastructure improvements
• Practice and effectiveness varies- see Glasson
for more information
• look in environmental statements for real
examples
• Mitigation now usually included as a ‘planning
condition’ or ‘Section 106 agreement’
• Actual implementation still not always monitored
or effectiveness established
• Environmental management planning is now
becoming more widespread, as a planning
condition
Environmental Management
Plans
(see IEMA 2008)

World Bank Definition:

An EMP outlines the mitigation, monitoring
and institutional measures to be taken
during project implementation and
operation to avoid or control adverse
environmental impacts, and the actions
needed to implement these measures
• Mitigation measures identified in the pre-
consent phase or during the consenting
process…
• May be subject to planning conditions or
obligations
• The EMP should be a structured plan for
ensuring mitigation measures are
actually implemented ‘on the ground’
(because often they are overlooked)
• “a vehicle to ensure the commitments or
promises made at the design stage are
carried through…it’s about locking in the
benefits”
(David Hinde, Highways Agency, in IEMA
2008)
 Links to Environmental
Management Systems (EMS)
• EMS: a structured and documented system to
manage a company’s overall environmental
performance and responsibilities
• Includes company commitments on managing
environmental impacts of activities, use of
resources, management of specific aspects such
as waste, energy and water
• Is often accredited to a standard such as
ISO14001
 Links between EIA, EMS and EMP
Contractor
EMS

Pre-decision:
Project Consent/ Post- Operation:
preparation Decision: Decision: EMS
EIA, including for project
EMP
identification Planning operation
of mitigation application Construction,
and and ES mitigation EMP may still
monitoring and apply for long
monitoring term monitoring

Client/proponent EMS

Adapted from IEMA 2008 p 3

 EMP, however:
• Focuses on the project itself
• Includes all contractors, consultants etc if
they have a role
• Can incude construction and operation
phases
• Includes (e.g.) protection, restoration,
monitoring
Preparing the EMP: key parties
• Project proponent (developer, design
team, environmental consultants,
contractors)
• Regulators (planning authority, statutory
consultees)
• Stakeholders (community, interest groups)
 Do we have to do this….?
• In the UK: no statutory requirement (unlike, e.g.,
Netherlands, Australia, Hong Kong)
• Planning authorities may request EMP to secure
mitigation measures included via planning conditions
• Little guidance from government; other than DoE
Circular 11/95 “allows planning authorities to require a
scheme of mitigation covering matters of planning
concern….”
• EMP allows the conditions set to be framed
effectively and, with clarity on, for example , monitoring
and reporting
• May overlap with other related consents or licences-
these would usually be integrated into the EMP
 Structure of an EMP
• Contents
• Introduction
• Project team- roles and responsibilities
• Emergency procedures (e.g. in case of breach of consent)
• Consents and permissions
• Environmentally significant changes (& responsibilities)
• Generic environmental actions (e.g. legal requirements, EMS
documents)
• Register of site specific environmental actions
• Liaison and consultation
• Register of variations
• Technical schedules (e.g. monitoring methodologies)
• Appendices
 London Array Phase One
Facts and Figures:
• An offshore area of 100km2
• 175 wind turbines
• Two offshore substations
• Nearly 450km of offshore cabling
• One onshore substation
• 630MW of electricity- enough power for around 480,000
homes a year – two thirds of the homes in Kent
• CO2 savings of 925,000 tonnes a year
• Phase One completed end of 2012
(see http://www.londonarray.com)
 EMP in action- the London Array
• Offshore wind farm in Thames
Estuary
• Connection to National Grid at
Cleve Hill, Kent: substation,
cabling, onshore works
compounds, realignment of
overhead power lines
• An ecological mitigation and Image:
Mott
management plan was produced McDonald

to address the ecological impacts

of onshore works
Onshore impacts
 EMP in action- the London Array:
example issues
• Clearance of vegetation
• Onshore bird monitoring methodology
• Works in pits and ditches
• Great Crested Newt mitigation strategy
• Reptile surveys and habitat clearance
• Pre-construction water vole surveys
Each had its own schedule (or section)
within the EMP
• Each schedule includes a description of
habitat/species and locations, mitigation
strategy, proposed monitoring and
reporting
• LPA consulted stakeholders, including
Natural England & wildlife groups
• Schedules used as reference point for
contractors and specialist ecologists
throughout construction work
 What you need to know
• Different types of alternatives, and
examples
• A mitigation hierarchy, with examples
• What is an EMP, what are the benefits to
those involved in EIA?

Find your own real examples!