Vol. 1 Main Text Final - Stroud District Council · Eco Park – Revised Scheme, Land at M5 Junction 13, West of Stonehouse | Environmental Statement Vol. 1 Main Text December 2017

Eco Park – Revised Scheme, Land at M5 Junction 13, West of Stonehouse | Environmental Statement Vol. 1 Main Text

December 2017

Page | 1

Report Control

Document: Environmental Statement Vol. 1 – Main Text

Project: Forest Green Rovers Football Club Stadium, Stroud

Client: Ecotricity

Job No: 15_149

File storage: Client files\15-112 to 15-189\15-149_Eco Park, Stroud_Ecotricity\7.

Stadium Only Submission\4. ES\Vol 1 Main Text

Document Checking

Primary Author: Daniel Hughes Initialled: DH

Contributor: Initialled:

Reviewer: Initialled:

Revision Status

Issue Date Status Checked for issue

1 06.11.17 Draft DH

2 15.11.17 Final Draft DH

3

4


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FOREWORD

INSPECTION OF THE AMENDED PLANNING APPLICATION,

ENVIRONMENTAL STATEMENT AND

SUPPORTING DOCUMENTS

Copies of the ES documentation are available for viewing at Stroud District Council during their normal

office hours. The ES may also be viewed at Ecotricity's Offices at Unicorn House, 7 Russell St, Stroud,

Gloucestershire, GL5 3AX. Copies of the Non-Technical Summary (NTS) are also freely available from this

address.

Hard copies of the ES may be purchased from the above Ecotricity address at a cost of up to £500 for the

entire documentation (lower charges may apply for specific documents). The complete ES documentation

may also be obtained on a CD free of charge (limited to one per person).

Printed on FSC

paper from

responsible sources


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VOLUME 1 MAIN TEXT – CONTENTS

1 INTRODUCTION 8

2 APPROACH TO EIA 18

3 DESCRIPTION OF THE SITE AND SURROUNDING AREA 31

4 CONSIDERATION OF ALTERNATIVES 34

5 DESCRIPTION OF THE REVISED SCHEME 39

6 PLANNING POLICY CONTEXT 50

7 ARCHAEOLOGY AND CULTURAL HERITAGE 53

8 ECOLOGY AND NATURE CONSERVATION 74

9 FLOOD RISK, HYDROLOGY AND DRAINAGE 123

10 LANDSCAPE AND VISUAL 164

11 SOCIO-ECONOMICS 238

12 TRANSPORT AND ACCESS 256

13 AIR QUALITY AND DUST 292

14 LIGHTING 320

15 NOISE AND VIBRATION 342

16 CLIMATE CHANGE 366

17 MAJOR ACCIDENTS AND DISASTERS 385

18 CUMULATIVE EFFECTS 414

19 SUMMARY OF EFFECTS AND MITIGATION 424

20 GLOSSARY 431


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RS FIGURES (VOLUME 2)

Chapter 1 - Introduction

RS Figure 1.1 Concept Plan

RS Figure 1.2 Local Context Plan

RS Figure 1.3 Site Context Plan

Chapter 4 – Consideration of Alternatives

RS Figure 4.1 Site search area for the Revised Scheme

Chapter 5 – Description of the Revised Scheme

RS Figure 5.1. Building Height Parameter Plan

RS Figure 5.2 Land Use Parameter Plan

RS Figure 5.3 Indicative Green Infrastructure Parameter Plan

RS Figure 5.4 Indicative Construction Compound Locations

RS Figure 5.5 Site Plan and Sections

RS Figure 5.6 Cross section at Grove Lane

Chapter 7 – Archaeology and Cultural Heritage

RS Figure 7.1 Designated Heritage Assets

RS Figure 7.2 Non-designated heritage assets

Chapter 8 – Ecology and Nature Conservation

RS Figure 8.1 Arboricultural Survey

RS Figure 8.2 Trees and Hedgerows Balance

RS Figure 8.3 Ecological Survey Area

RS Figure 8.4 Potential Zones of Influence

RS Figure 8.5 Bat Survey Static Locations 2015-16

RS Figure 8.6 Ecological Designations (Statutory and non-Statutory)

RS Figure 8.7 Protected Species Records Mammals (other than bats), Amphibians and Reptiles

RS Figure 8.8 Confidential Protected Species Records- Badgers - NOT FOR PUBLIC RELEASE

RS Figure 8.9 Protected Species Records Birds Directive Annex I

RS Figure 8.10 Protected Species Records WACA Schedule 1 - Birds

RS Figure 8.11 Protected Species Records BOCC Red List - Birds

RS Figure 8.12 Protected Species Records Bats

RS Figure 8.13 Protected Species Records Bat Roosts

RS Figure 8.14 Baseline Survey

RS Figure 8.15 National Vegetation Classification

RS Figure 8.16 Reptile and Amphibian Survey

RS Figure 8.17 Tree Endoscope Survey for Bats

RS Figure 8.18 Bat Survey Tree Emergence and Dawn Re-entry Locations

RS Figure 8.19 Bat Survey Transect Routes 2015-16

RS Figure 8.20 Visual Summary of Bat Passes 2015-2016

RS Figure 8.21 Static Bat Passes Common Pipistrelle

RS Figure 8.22 Static Bat Passes Soprano Pipistrelle

RS Figure 8.23 Static Bat Passes Myotis


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RS Figure 8.24 Static Bat Passes Noctule

RS Figure 8.25 Static Bat Passes Lesser Horseshoe

RS Figure 8.26 Static Bat Passes Greater Horseshoe

RS Figure 8.27 Breeding Bird Territory Locations 2015

RS Figure 8.28 Breeding Bird Territory Locations 2016

RS Figure 8.29 Confidential Badger Setts - NOT FOR PUBLIC RELEASE

RS Figure 8.30 Confidential Badger Survey 2016 - NOT FOR PUBLIC RELEASE

Chapter 9 – Flood Risk, Hydrology and Drainage

RS Figure 9.1 Watercourses within the vicinity of the Revised Scheme

Chapter 10 – Landscape and Visual

RS Figure 10.1 Site Location, Study Area and Viewpoint Location

RS Figure 10.2 Aerial Photograph and Site Layout with PRoW

RS Figure 10.3 Topography Plan and Cross-Section

RS Figure 10.4 Zone of Theoretical Visibility (ZTV) and Viewpoint Locations

RS Figure 10.5a Landscape Character with ZTV (SDC and National) (Study Area)

RS Figure 10.5b Landscape Character with ZTV (Gloucestershire and Cotswolds AONB) (Study Area)

RS Figure 10.5c Industrial Heritage Conservation Area (IHCA) Character Areas (Study Area)

RS Figure 10.5d Relationship between Landscape Character Types and Areas in Study Area

RS Figure 10.6 Landscape Designations and Public Access / Recreational Resources with ZTV (Study Area)

RS Figure 10.7a Key Landscape and Visual Receptors with ZTV

RS Figure 10.7b Key Landscape and Visual Receptors with ZTV including PRoW and Residential (Detail)

RS Figure 10.8a SALA Assessment of Onsite Landscape Sensitivity with Project Components (SDC)

RS Figure 10.8b Landscape Sensitivity of Stroud District Landscape Character Types (Ecotricity)

RS Figure 10.9a 1st Edition OS Map 1842-1852

RS Figure 10.9b 1st Edition OS Map 1842-1852 with Project Components

RS Figure 10.10a Cotswolds AONB Light Pollution Map

RS Figure 10.10b Night-time Baseline / Existing Light Sources / Lighting Levels (Study Area)

RS Figure 10.10c Night-time Baseline / Existing Light Sources / Lighting Levels (Detailed Area)

RS Figure 10.11a Off Site Constraints and Opportunities Plan

RS Figure 10.11b On Site Constraints and Opportunities Plan

RS Figure 10.11c Landscape Strategy

RS Figure 10.11d Landscape Mitigation

RS Figure 10.12a Cumulative Schemes and Landscape Character (SDC and National)

RS Figure 10.12b Cumulative Schemes and Landscape Character (Gloucestershire and Cotswolds AONB)

RS Figure 10.13 Baseline Photographs (including Night-time)

RS Figure 10.14 Enhanced Wireframe Visualisations

RS Figure 10.15 Additional Residential Visual Amenity Assessment Visualisations

Chapter 11 – Socio-Economics

RS Figure 11.1 Stroud District Context Plan

RS Figure 11.2 Index of Multiple Deprivation Plan

Chapter 12 – Transport and Access

RS Figure 12.1 Two-Way Link Flows Saturday Matchday Arrival Period (14:00 - 15:00)

RS Figure 12.2 Two-Way Link Flows Saturday Matchday Departure Period (17:00 - 18:00)


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RS Figure 12.3 Two-Way Link Flows Weekday Matchday Arrival Period (18:00 - 19:00)

RS Figure 12.4 A419 Junctions Assessed for Capacity

RS Figure 12.5 Percentage difference between Two-Way Link Flows Saturday Matchday

RS Figure 12.6 Percentage difference between Two-Way Link Flows Weekday Matchday

Chapter 13 – Air Quality and Dust

RS Figure 13.1 Air Roads and Receptors

RS Figure 13.2 Air Construction Activities

RS Figure 13.3 Air Trackout Activities

RS Figure 13.4 Air N02 Concentrations

RS Figure 13.5 Air PM10 Concentrations

RS Figure 13.6 Air PM25 Concentrations

Chapter 14 - Lighting

RS Figure 14.1 Baseline

RS Figure 14.2 Provisional Task Area

RS Figure 14.3 Lighting with Mitigation

RS Figure 14.4 Road Lighting

RS Figure 14.5 Entire Site and Road Lighting

RS Figure 14.6 Worst Case Light Spill

RS Figure 14.7 Worst Case Light Spill with Enhancement

RS Figure 14.8 Intrusive Lighting on Dwellings

RS Figure 14.9 Intrusive Lighting on Dwellings with Enhancements

Chapter 15 – Noise and Vibration

RS Figure 15.1 Survey Locations

RS Figure 15.2 Stadium LAeq30secs First Floor

RS Figure 15.3 Stadium Lmax First Floor

RS Figure 15.4 Training Pitches LAeq2h First Floor

RS Figure 15.5 Training Pitches Lmax First Floor

RS Figure 15.6 Car Park LAeq30min First Floor

RS Figure 15.7 Traffic Noise 2017 - Baseline

RS Figure 15.8 Traffic Noise 2036 - Difference between with and without development scenario

Chapter 18 – Cumulative Effects

RS Figure 18.1 Cumulative Schemes


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RS APPENDICES (VOLUME 3)

RS Appendix 1.1 Competent Expert CVs

RS Appendix 1.2 Scoping Opinion

RS Appendix 1.3 Scoping Report

RS Appendix 2.1 Schedule 4 of 2017 EIA Regulations

RS Appendix 6.1 Relevant Planning Policy

RS Appendix 6.2 Draft Planning Conditions

RS Appendix 7.1 Heritage Assessment

RS Appendix 7.2 Geophysics Report

RS Appendix 7.3 Evaluation

RS Appendix 7.4 Written Scheme of Investigation for Evaluation

RS Appendix 7.5 Consultation

RS Appendix 8.1 Baseline Survey

RS Appendix 8 2 Fauna Surveys

RS Appendix 8.3 Arboricultural Survey

RS Appendix 8.4 Confidential Badger Report - NOT FOR PUBLIC RELEASE

RS Appendix 8.5 Green Infrastructure Plan

RS Appendix 8.6 Principles of Environmental Enhancements

RS Appendix 8.7 Consultation responses

RS Appendix 8.8 Further Consultation J13_M5 Eco Park EPR

RS Appendix 8.9 Planning Policy and Guidance

RS Appendix 9.1 Flood Risk Assessment

RS Appendix 9.2 Water Framework Directive Watercourses

RS Appendix 9.3 Assessment of Non-Significant Effects

RS Appendix 10.1 Landscape and Visual Impact Assessment Methodology

RS Appendix 10.2 Baseline Assessment

RS Appendix 10.3 Landscape Assessment Schedules

RS Appendix 10.4 Visual assessment schedules

RS Appendix 10.5 Cumulative Landscape and Visual assessment Schedules

RS Appendix 10.6 Cotswolds AONB Position Statements

RS Appendix 10.7 Landscape Strategy

RS Appendix 10.8 Non-Significant Landscape and Visual Effects

RS Appendix 10.9 Planning Policy

RS Appendix 10.10 Bareground ZTV out to 25km to include Wye Valley AONB

RS Appendix 12.1 Transport Assessment

RS Appendix 12.2 S-Paramics Traffic Model – Forecasting Report

RS Appendix 12.3 Outline Travel Plan

RS Appendix 13.1 Detailed Air Quality Assessment Report

RS Appendix 14.1 Calibration Certificate

RS Appendix 14.2 Schedule of Luminaries

RS Appendix 15.1 Glossary

RS Appendix 15.2 Survey Equipment Details

RS Appendix 15.3 Noise Survey Data

RS Appendix 15.4 Assessment of Non-Significant Effects

RS Appendix 15.5 Assumed Construction Plant

RS Appendix 15.6 Arup Stadium Internal Noise Survey


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1 INTRODUCTION

Introduction

1.1 PWA Planning is retained by Ecotricity Group Limited (‘the Applicant’) to assist with the

preparation of an Environmental Statement (ES) in respect of Land at M5 Junction 13 West of

Stonehouse (‘the Site’), which is within the ownership of the Applicant, for a sports complex that

will provide replacement sports facilities for Forest Green Rovers (FGR) Football Club (FC). The

complex will include a centrepiece stadium and additional training pitches to serve FGR (the

‘Revised Scheme’). The Revised Scheme represents an amendment to planning application ref.

S.16/0043/OUT, which sought permission for an ‘Eco Park’ that included some of the sports

facilities proposed as part of the Revised Scheme, a Green Technology Hub (B1/B2/B8 uses),

additional indoor and outdoor pitches, transport hub and nature conservation area.

1.2 As this is an amendment to the previously submitted and larger Eco Park application, the Redline

Boundary remains unchanged. It includes the area south of the A419 and east of the M5

(formerly the Sports Complex), the area north of the A419 and east of the M5 (formerly the

Green Technology Hub) and the area south of the A419 and west of the M5 (formerly the Nature

Conservation Area). However, only the area north of the A419 and east of the M5 is being

proposed for development (‘Development Footprint’) as part of this Revised Scheme.

1.3 The ES supports an outline planning application with all matters reserved save for access, with

detailed permission being sought for:

• Signalised site access off the A419 (as previously) with full dualling of the A419 from the

M5 Junction 13 to Chipmans Platt.

• A signal controlled pedestrian and cycle crossing of the A419, with a combined footway/

cycleway on the south side of the A419 which will link to National Cycle Route 45 (NCN45)

at Grove Lane.

1.4 Planning permission for internal access is not sought by the application. This will be finalised

through Reserved Matters as determined by the final site layout. However, an indicative internal

access has been illustrated as part of RS Figure 1.1 Indicative Concept Plan.

1.5 This Chapter outlines the background to the Applicant, development and the project team, along

with the legal framework and structure of the ES.

About the Applicant

1.6 Ecotricity was founded in 1995 as the world’s first green energy company and now supplies over

200,000 customers across the UK from a growing fleet of wind and sun parks. More recently

Ecotricity has introduced green gas to Britain and built and run Britain’s first national network of

electric vehicle charge points, the Electric Highway.

About Forest Green Rovers

1.7 FGRFC was founded in 1889. The club is currently the joint-highest ranked football side from

Gloucestershire in the football pyramid. Attendances at FGR games has grown 73% over the last

four seasons. The urgency of the amended Revised Scheme has been increased as a result of


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FGRs promotion into the Football League (League 2), for the first time in its history at the end of

the 2016/ 17 Season, and consequently a further increase in attendances.

About the Development

1.8 The Revised Scheme seeks to provide replacement sports facilities for FGR. In order to meet the

club’s requirements moving forward, a sports complex is proposed which includes an innovative

centrepiece 5,000 capacity stadium designed by world-renowned architects Zaha Hadid, as well

as two additional full-size training pitches and goalkeeping training area to serve FGR. The pitches

will be grass and none will be flood lit. The Revised Scheme is illustrated on RS Figure 1.1

Indicative Concept Plan.

1.9 The training pitches will be used primarily by the FGR first team who currently train at Stanley

Park, Chippenham, which is approximately 24 miles from the New Lawn. The proposals will allow

FGR to centralise its operations and will provide a ‘hub’ of activity.

1.10 The Redline Boundary remains the same as for the previous application submitted. However, all

development will now take place on land north of A419 and east of the M5 within the

Development Footprint only (on land previously allocated for the Green Technology Hub in the

initial submission). No development will take place to the south of the A419, however,

translocation of a hedge will occur on this land (as a result of road widening) as discussed in both

Chapter 5 and Chapter 8.

1.11 The Redline Boundary is approximately 39.5ha. The area that will form the new FGR site is

approximately 18.9ha with the highways improvement works 2.5ha. The Site is approximately

centred on National Grid Reference SO 77965 206584. RS Figure 1.2 shows the Site’s local

context and RS Figure 1.3 shows the Site’s context. The key components of the Revised Scheme

are listed in Table 1.1 (final amounts to be determined at Reserved Matters based on the

parameters set out in RS Figures 5.1, 5.2 and 5.3).

Table 1.1: Key Components of the Revised Scheme

Use Use

Class

Indicative Amount Based on Indicative

Concept Plan (RS Figure 1.3)

Sports Complex 18.9ha

Stadium including ancillary facilities

designed for a capacity of 5,000

D2 To be determined at Reserved Matters. Form

and design of stadium is set out in the Design

and Access Statement.

Two full-sized grass pitches and a goal

practice area

D2 To be determined at Reserved Matters.

Car parking and associated infrastructure N/A To be determined at Reserved Matters.

Parking will be provided for 1,700 vehicles (lit

to previous arrangements, LED luminaries

complete with street optics and including

sensors).

Access Works 2.5ha


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Use Use

Class



Including: signalised site access off the A419;

full dualling of the A419 from M5 J13 to

Chipmans Platt; a signal controlled

pedestrian and cycle crossing of the A419

with a combined footway/ cycleway on the

south side of the A419 (which will link to

National Cycle Route 45 at Grove Lane).

N/A 2.5ha

1.12 FGR are currently based at The New Lawn in Nailsworth, Gloucestershire. The New Lawn was

built in 2006 and has a capacity for a crowd of just under 5,000. The ability of FGR to operate

sustainably is hindered by the location of The New Lawn, which is not readily accessible.

Nailsworth has no railway station (Stroud is the nearest) and is some nine miles from the Stroud

junction of the motorway. There is also a chronic lack of parking and facilities for fans.

1.13 As part of identifying the need for FGR to relocate, an automatic traffic survey took place on

Nympsfield Road, Nailsworth (ST 84159 99977) from 22nd September 2015 to 6th October 2015

whilst the FGR were still playing in the National League. This period was selected for a survey as

it covered two FGR homes matches, Cheltenham on Tuesday 22nd September 2015 and

Gateshead on 26th September 2015, therefore covering a Tuesday and Saturday home match but

also a Tuesday and Saturday where no match took place. On the day of a match there can be a

significant increase in traffic within the residential areas in the vicinity of the existing New Lawn

ground, in some cases, the increase in traffic was over 150%.

1.14 As such, it is clear that as the club progresses, and attendances increase, the number of vehicles

in association with FGR, particularly in relation to the limited transport options in proximity of

The New Lawn, are also anticipated to increase. Therefore, the relocation of FGR to a more

accessible site would be of significant benefit.

1.15 In this respect, the average attendance for FGR during the 2016/ 2017 season prior to attaining

promotion to the League 2 was 1,753. Since attaining promotion, up to 25 November 2017,

attendances at home games at the New Lawn this season have been substantially higher (as

obtained from the FGRFC website) averaging at 2,234 per game (an increase of approximately

27% when compared to the 2016/2017 season) (see Table 12.9)

1.16 Additionally, car parking at The New Lawn is limited – there are just 228 spaces onsite and the

Club regularly uses overflow car parking at Nailsworth Primary School and operates a Park and

Ride from local company Renishaw’s for bigger games. In any event, fans invariably park

in adjacent residential areas, causing significant congestion. This has led to parking restrictions

being implemented on match days. A more accessible location, with more on-site car parking

and better public transport links will enable the club to grow its support to sustainable levels for

the league it plays in now, and for those above.

1.17 The existing FGR stadium (The New Lawn, Nailsworth) was subject to recent planning application

(S.17/0850/OUT), for the demolition of the stadium and re-development to provide the erection

of up to 95 dwellings, up to 0.11 hectares of community uses (which may include D1/D2/A3/B1


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uses), landscaping, open space, associated access, parking and infrastructure. Whilst this

application has been withdrawn, a resubmission is due imminently, and this will be dependent

(and conditioned) upon the replacement sporting facilities being provided as part of the Revised

Scheme.

The Project Team

1.18 PWA Planning has been commissioned by the Applicant to assist with an Environmental Impact

Assessment (EIA) in support of the outline planning application for the Revised Scheme. This has

incorporated technical input from a number of consultants, as outlined in Table 1.2 below. A

copy of the relevant CVs for each competent expert is included within RS Appendix 1.1, and

within each chapter a brief overview of the author’s experience has been provided.

Table 1.2: Project Team

Project Team Contribution

PWA Planning Ltd. and Ecotricity

Group Ltd.

EIA Co-ordination and other project management inputs

Zaha Hadid Ltd. Project Architects and Concept Design

Cotswold Archaeology Ltd. Archaeology and Cultural Heritage

Gavin David CMLI

Chartered Landscape Architect

(lead input) and Ecotricity Group

Ltd.

Landscape and Visual Impact Assessment

Ecotricity Group Ltd. Ecology and Nature Conservation (Biodiversity)

RSK Environment Ltd. Flood Risk, Hydrology and Drainage & Air Quality and Dust

Hopkin Coats Associates Lighting

Hoare Lea LLP. Noise and Vibration

Regeneris Consulting Ltd. Socio-Economics

PFA Consulting Ltd. Transport and Access

Hunter Page Planning Ltd. Planning Statement

Consult QRD Ltd. Sports and Pitches Statement

LUC Ltd. Major Accidents and Disasters & Climate Change

The Environmental Statement (ES)

1.19 This Environmental Statement (ES) on the Revised Scheme is the output of the EIA process which

has been undertaken in accordance with the Town and Country Planning (Environmental Impact

Assessment) Regulations 20111, as amended in 20152 (hereafter referred to as the ‘2011 EIA

Regulations’).

1.20 Since the submission of the original scheme in January 2016, the Town and Country Planning

(Environmental Impact Assessment Regulations 20173 came into force on 16th May 2017

(hereafter referred to as the ‘EIA Regulations 2017’). Regulation 76 of the EIA Regulations 2017

contains provisions for the revocation of the 2011 EIA Regulations and transitional

arrangements. Relevant parts of Regulation 76 are as follows;

1 Town and Country Planning (Environmental Impact Assessment) Regulations 2011 available from

http://www.legislation.gov.uk/uksi/2011/1824/contents/made accessed on 8th December 2015. 2 Town and Country Planning (Environmental Impact Assessment) Amendments 2015 available from

http://www.legislation.gov.uk/uksi/2015/660/contents/made accessed on 8th December 2015. 3 Town and Country Planning (Environmental Impact Assessment) Amendments 2017 available from

http://www.legislation.gov.uk/uksi/2017/571/contents/made accessed on 22nd November 2017.


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’76. – Revocation and transitional provisions

(1) Subjection to paragraphs (2) to (4), the 2011 Regulations are revoked.

(2) Notwithstanding the revocation in paragraph (1), the 2011 Regulations continue to apply

where before the commencement of these Regulations –

(a) An applicant, appellant or qualifying body, as the case may be, has submitted an

environmental statement or requested a scoping opinion; or

(b) In respect of local development orders, the local planning authority has in connection with

that order prepared an environmental statement or a scoping opinion or requested a scoping

direction’

1.21 Accordingly, the 2011 EIA Regulations will continue to govern the determination of extant

planning applications where an Environmental Statement has been submitted before 16th May

2017, or alternatively, where a request for a scoping opinion had been made before that date,

both of which are relevant in this instance.

1.22 Therefore, this EIA has been carried out in accordance with the 2011 EIA Regulations. However,

it should be noted that the 2017 Regulations now contain additional matters which were not

required to be assessed in the 2011 Regulations. As these matters are clearly important, whilst

this ES will be determined in line with the 2011 Regulations, the additional matters which would

have been required under the 2017 Regulations have also been assessed, and the scope of this

work is explained in more detail within Chapter 2.

Legal Framework for the ES

1.23 The EIA Regulations require that prior to consent being granted for certain types of development,

an EIA must be undertaken. The 2011 EIA Regulations set out the type of development which

must always be subject to an EIA (Schedule 1 development) and other developments which may

require an assessment if they are likely to have a significant effect on the environment by virtue

of factors such as its nature, size or location (Schedule 2 developments).

1.24 The Revised Scheme falls under Paragraph 10(b) of Schedule 2 of the EIA Regulations which

relates to Infrastructure Projects. Specifically, Paragraph 10(b) relates to Urban development

projects, including the construction of shopping centres and car parks, sports stadiums, leisure

centres and multiplex cinemas and sets the following thresholds for when a development should

be screened (Table 1.3 below).

Table 1.3: Extract of Paragraph 10(b) of Schedule 2 of the 2011 EIA Regulations (as amended in

2015)

10. Infrastructure projects Threshold

(b) Urban development projects,

including the construction of

shopping centres and car parks,

sports stadiums, leisure centres and

multiplex cinemas;

(i) The development includes more than 1 hectare of urban

development which is not development; or

(ii) the development includes more than 150 dwellings; or

(iii) the overall area of the development exceeds 5 hectares.


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1.25 In this instance, the Revised Scheme exceeds the thresholds set by both parts (i) and (iii). It has

been agreed in consultation with Stroud District Council (SDC) that the Revised Scheme may have

‘significant’ environmental effects, and as such a voluntary ES should be submitted.

1.26 The EIA process identifies likely ‘significant’ environmental effects of proposed developments,

by comparing the existing situation, that which pertains before development is carried out

(baseline) with the situation once the proposals (including any embedded mitigation) are in

place. Likely significant effects during construction are also considered.

1.27 The first stage of the EIA process is to identify the issues which should be addressed in the ES;

this is termed ‘scoping’ and the results are presented as a Scoping Report. This Scoping Report

sets out the views of the Applicant, as to the proposed scope of the environmental issues to be

considered in the EIA and as to the method by which assessment will be undertaken. A Scoping

Report (RS Appendix 1.3) was submitted to accompany a request for a Scoping Opinion in

relation to the original Eco Park scheme from SDC under Regulation 13 of the EIA Regulations in

2015. The Scoping Opinion from SDC identified all issues to be addressed in the ES and is included

in RS Appendix 1.2. As discussed, this new ES accompanies an amendment to the existing

planning application, the Revised Scheme. A further Scoping Opinion has not been sought,

rather, further on-going discussions with statutory and non-statutory consultees from before

and during the planning process have been engaged in order to ensure environmental effects

associated with the Revised Scheme can be fully taken into account within this new ES.

Structure of the ES and Documentation submitted with this Revised Scheme

1.28 The ES is provided in four parts:

• Non-Technical Summary – contains, in non-technical language, a summary of the main

text as a separate self-contained document.

• Volume 1: Main Text – contains a detailed description of the proposal. It evaluates the

existing environmental baseline conditions and identifies and addresses the predicted

environmental effects that could occur as a result of the development. It provides detailed

analysis of the design procedure and how mitigation measures have been embedded into

the design, where possible, to prevent, reduce or offset any environmental effects

identified. Where this is not possible, mitigation has been proposed to ameliorate those

effects which cannot be dealt with through embedded mitigation.

• Volume 2: RS Figures – contains all the illustrative material referred to in the Main Text

(Volume 1). RS refers to the Revised Scheme.

• Volume 3: RS Appendices – contains details of assessment methodologies, assessment

data, technical details and background information.

1.29 Table 1.4 below outlines the structure and content of this document, Volume 1: Main Text.

Table 1.4: Structure of Volume 1: Main Text

Chapter

Number

Chapter Title Content

1 Introduction This Chapter outlines the Project Team, along with the legal

framework and structure of the ES.

2 Approach to the

EIA

This Chapter outlines the approach to the Environmental Impact

Assessment (EIA) in order to meet the information required in an ES

under the EIA Regulations


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Chapter

Number

Chapter Title Content

3 Description of

the Site and its

surround area

This Chapter provides a description of both the Site location, defined

by the Redline Boundary, and the surrounding area.

4 Consideration of

Alternatives

This Chapter outlines the description of the alternatives to the

Revised Scheme in terms of both alternative site locations and

alternative site layouts during the evolution of the Concept Design.

5 Description of

the Revised

Scheme

This Chapter provides a description of the Revised Scheme in

accordance with the amended application for planning permission.

6 Planning and

Environment

Context

This Chapter summarises the land-use planning policy framework

against which the Revised Scheme has been considered.

7 – 17 Technical

Chapters

These Chapters provide a description of the existing baseline

environment, the specific methods used to assess the potential

effects of the Revised Scheme, an assessment of these effects and

mitigation measures proposed to remove/reduce adverse effects for

each receptor on a chapter-by-chapter basis.

18 Cumulative

Effects

This Chapter assesses the potential for significant cumulative

environmental effects associated with the Revised Scheme.

19 Summary of

Effects and

Mitigation

This Chapter provides a summary of effects table for each of the

technical assessment chapters of the ES. A summary of all proposed

mitigation measures is also included.

1.30 Table 1.5 below provides a breakdown of the information required in an ES under the 2011 EIA

Regulations, and where this information can be located in this ES. As discussed, this ES is

submitted in accordance with the 2011 EIA Regulations. Additional matters identified within the

2017 EIA Regulations have also been included within this new ES. These additional matters are

discussed within Chapter 2.

Table 1.5: Location of Required Information within the ES

Schedule

No 1.

Required Information Location within ES

1 Description of the development, including in particular

a) Description of the physical characteristics of the whole

development and land-use requirements during the

construction and operation phases.

Chapter 5 –

Description of the

Revised Scheme

b) Description of the production processes, for instance, the

nature and quantity of materials used.

Chapter 5 –

Description of the

Revised Scheme

c) An estimate, by type and quantity, of expected residues and

emissions (water, air and soil pollution, noise, vibration, light,

heat, radiation etc.) resulting from the operation of the Revised

Scheme.

Technical Chapters 7 -

17

2 An outline of the main alternatives studies by an applicant or

appellant and an indication of the main reasons for this choice,

taking into account the environmental effects.

Chapter 4 –

Consideration of

Alternatives

3 A description of the aspects of the environment likely to be

significantly affected by the development, including in

particular, population, fauna, flora, soil, water, air, climate

factors, material assets including architectural and

archaeological heritage, landscape and the interrelationship

between the above factors.

Technical Chapters 7-

17

4 A description of the likely significant effects of the development

on the environment, which should cover the direct effects and

any indirect, secondary, cumulative, short, medium and long


17


December 2017

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Schedule

No 1.

Required Information Location within ES

term, permanent and temporary, positive and negative effects

of the development, resulting from:

• The existence of the development;

• The use of natural resources; and

• The emissions of pollutants, the creation of nuisances,

and the elimination of waste

5 A description of the measures envisaged to prevent, reduce

and where possible, offset any significant adverse effects on

the environment.


17

6 A non-technical summary of the information provided. Non-Technical

Summary

7 An indication of any difficulties (technical deficiencies of lack-

of-know-how) encountered by the applicant in compiling the

required information.

Chapter 2 – Approach

to the EIA and the

relevant Technical

Chapters 7-17.

1.31 The purpose of this ES is to provide a description of the Revised Scheme, to identify and assess

potential significant environmental effects and, where necessary, propose mitigation to offset

those affects. Enhancement measures are also proposed in addition to mitigation where

appropriate.

1.32 The ES is one of the supporting documents submitted to the determining planning authority, SDC

in support of the amended planning application. Volume 3 of the ES contains the Arboricultural

Report (RS Appendix 8.3), Flood Risk Assessment (including Drainage Strategy) (RS Appendix 9.1)

and Transport Assessment (RS Appendix 12.1) which are required as part of SDC’s planning

application local validation requirements. The ES should also be read in conjunction with the

other documents submitted as part of the amended planning application, comprising:

• Design and Access Statement

• Desk Based Utility Report

• Environmental Statement (Volumes 1 to 3) and Non-Technical Summary

• Planning Drawings (Location Plan, Existing Site Plan)

• Planning Statement

• Preliminary Risk Assessment

• Statement of Community Involvement

1.33 It should be noted that the suit of documents submitted as part of this amended planning

application (the Revised Scheme), including the ES and associated documents, replaces all

previous submissions for this Site in their entirety. This includes the original planning application

and ES (submitted January 2016), Further Environmental Information (FEI) 1 (submitted

September 2016), FEI 2 (submitted February 2017), and FEI 3 (submitted August 2017).

Definition of Key Terms

1.34 The following provides the definition of some of the key terms included within the Environmental

Statement. A full glossary is included at the end of this document.


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Table 1.6: Definition of Key Terms

Key Term Definition

Assessment Process by which information about effects of the Revised Scheme is collected,

assessed and used to inform decision making.

Baseline

Conditions

Environment as it appears (or would appear) immediately prior to the

implementation of the project together with any known or foreseeable future

changes that will take place before completion of the project.

Cumulative

Effect

Effects that result from incremental changes caused by other past, present or

reasonably foreseeable actions together with the project.

A cumulative effect may arise as the result of (a) the combined effect of a number of

different environmental topic-specific effects from a single environmental impact

assessment project on a single receptor/ resource or (b) the combined effect of a

number of different projects within the vicinity (in combination with the

environmental impact assessment project) on a single receptor/resource.

Development

Footprint

Development on land north of A419 and east of the motorway subject of the

amended application.

Effect Term used to express the consequence of an impact (expressed as the ‘significance

of effect’), which is determined by correlating the magnitude of the impact with the

importance (or sensitivity) of the receptor or resource in accordance with defined

significance criteria. For example, land clearing during construction results in

habitat loss, the effect of which is the significance of the habitat loss on the

ecological resource.

Embedded

Mitigation

Mitigation that has been embedded into the design of the Revised Scheme.

Environmental

Impact

Assessment

(EIA)

Statutory process by which certain planned projects must be assessed before a

formal decision to proceed can be made. Involves the collection and consideration

of environmental information, which fulfils the assessment requirements of the EIA

Directive, including the publication of an environmental statement.

Environmental

Statement

Document produced in accordance with the EIA Directive (as transposed into UK

law by the EIA Regulations) that reports the outcomes of the EIA process.

Mitigation Measures that are necessary to avoid, minimise, or offset anticipated adverse

impacts and, where appropriate, to incorporate these into an environmental

management plan or system.

Receptor Defined individual environmental feature usually associated with population, fauna

and flora with the potential to be affected by a project.

Redline

Boundary

Application area as indicated on RS Figure 1.2 Local Context Plan. This includes the

area south of the A419 and east of the M5 (formerly the Sports Complex), the area

north of the A419 and east of the M5 (formerly the Green Technology Hub) and the

area south of the A419 and west of the M5 (formerly the Nature Conservation

Area).

Revised

Scheme

Development on land north of A419 and east of the motorway subject of the

amended application (the Development Footprint)

Scoping Process of identifying the issues to be addressed by the environmental impact

assessment process. It is a method of ensuring that an assessment focuses on the

important issues and avoids those that are considered not significant.

Scoping

Opinion

Opinion provided by a competent authority that indicates the issues an

environmental impact assessment of a proposed development should consider.

Screening Formal process undertaken to determine whether it is necessary to carry out a

statutory environmental impact assessment and publish an Environmental

Statement in accordance with the EIA Regulations.


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Significant

Effect

Environmental effect considered material to the decision-making process.

Significance of

Effect

Measure of the importance or gravity of the environmental effect, defined by either

generic significance criteria or criteria specific to the environmental topic

Site Land at M5 Junction 13 West of Stonehouse.

Study Area Spatial area within which a particular environmental effect has been assessed.


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2 APPROACH TO EIA

Introduction

2.1 This Chapter outlines the approach to the Environmental Impact Assessment (EIA) in order to

meet the information required in an ES under the 2011 EIA Regulations as outlined in Table 1.5.

A request for a Scoping Opinion for the previous Eco Park application was made in 2015 and SDC

confirmed the scope for the ES. The Scoping Opinion is provided in RS Appendix 1.2. For the

Revised Scheme consultation has continued with stakeholders engaged both within and outside

the planning process for the previous Eco Park application. The details of these discussions have

been included within the technical chapters that form part of the ES.

2.2 Since the submission of the original scheme, the Town and Country Planning (Environmental

Impact Assessment Regulations 20174 came into force on 16th May 2017. Regulation 76 of the

2017 contains provisions for the revocation of the 2011 EIA Regulations. Relevant parts of

Regulation 76 are as follows;

’76. – Revocation and transitional provisions

(3) Subjection to paragraphs (2) to (4), the 2011 Regulations are revoked.

(4) Notwithstanding the revocation in paragraph (1), the 2011 Regulations continue to apply

where before the commencement of these Regulations –

(c) An applicant, appellant or qualifying body, as the case may be, has submitted an

environmental statement or requested a scoping opinion; or

(d) In respect of local development orders, the local planning authority has in connection with

that order prepared an environmental statement or a scoping opinion or requested a scoping

direction’

2.3 Accordingly, the 2011 EIA Regulations will continue to govern the determination of extant

planning applications where an Environmental Statement has been submitted before 16th May

2017, or alternatively, where a request for a scoping opinion had been made before that date,

both of which are relevant in this instance.

2.4 Therefore, this EIA has been carried out in accordance with the 2011 EIA Regulations. However,

it should be noted that the 2017 Regulations now contain additional matters which were not

required to be assessed in the 2011 Regulations. As these matters are clearly important, whilst

this ES will be determined in line with the 2011 Regulations, the additional matters which would

have been required under the 2017 Regulations have also been assessed.

2.5 The key objectives of the EIA are as follows:

• Set the legal framework;

• Consider the main alternatives to the Revised Scheme;

• Identify potentially significant effects during the design process so that some effects can

be prevented or reduced through design changes and embedded mitigation prior to the

4 Town and Country Planning (Environmental Impact Assessment) Amendments 2017 available from

http://www.legislation.gov.uk/uksi/2017/571/contents/made accessed on 22nd November 2017.


December 2017

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assessments within the Environmental Statement (ES), i.e. demonstrating an iterative

approach to EIA;

• Identify, predict and assess the significance of environmental effects associated with the

Revised Scheme: positive and negative; permanent and temporary; direct and indirect and

short/medium/long term. These include environmental effects associated with the

following topic areas: archaeology and cultural heritage; ecology and nature conservation;

flood risk, hydrology and drainage; landscape and visual; socio-economics; transport and

access; air quality and dust; noise and vibration; lighting; major accidents and disasters;

climate change and any interactions between these;

• Identify, predict and qualitatively assess the cumulative effects of the Revised Scheme,

including those associated with other developments in the vicinity (cumulative effects);

• Identify suitable mitigation and monitoring measures to prevent, reduce or remedy

significant negative environmental effects and identify the residual effects following the

implementation of these measures.

EIA Strategy

2.6 The ES will clearly outline that the assessment of effects is based on the Revised Scheme

description and supporting plans outlined within Chapter 5 – Description of the Revised Scheme.

These will be based on the worst-case scenario to ensure all potential effects are considered in

the ES.

Approach to Baseline Conditions

2.7 The baseline conditions for the purpose of the ES will be as at the time of the surveys for each

individual topic as noted in the Technical Chapters 7-17. These were initially conducted between

approximately July to December 2015 for all technical topics. However, many chapters have

benefitted from update work during both 2016 and 2017. There are slight variances across the

ES depending on the use of existing data obtained through other external sources as well as more

recent surveys. A summary of the baseline environment is also provided in Chapter 3 –

Description of the Site and Surroundings.

2.8 Table 2.5 details the developments that have been taken into account as part of the cumulative

assessment for the technical assessments. For certain chapters, including Chapter 12 – Transport

and Access, Land West of Stonehouse (planning application S.14/0810/OUT) has formed part of

the baseline (rather than being assessed cumulatively). This is because of Land West of

Stonehouse’s existing allocation within SDC’s Local Plan5, the recent approval of Reserved

Matters and commencement of development on site in summer 2017. As such, given Chapter

13 – Air Quality and Dust and Chapter 15 – Noise and Vibration utilise the data from the traffic

assessment, these topics have also included Land West of Stonehouse as part of the baseline to

their assessments.

Design Parameters

5 Stroud District Council’s Local Plan available from

http://www.stroud.gov.uk/info/plan_strat/newlocalplan/PLAIN_TEXT_Local%20Plan_Adopted_November_2015.pd

f accessed on 8th December 2015.


December 2017

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2.9 The Revised Scheme is assessed against parameter plans as detailed in Chapter 5 – Description

of the Revised Scheme. There will be a degree of flexibility within some of the parameter plans

to allow the Revised Scheme to evolve through the detailed design stages and Reserved Matters

Applications, however the finalised design will be within the identified parameters, as set out in

the following parameter plans:

• Building Height Parameter Plan (RS Figure 5.1)

• Lane Use Parameter Plan (RS Figure 5.2)

• Indicative Green Infrastructure Parameter Plan (RS Figure 5.3)

• Indicative Construction Compound Locations (RS Figure 5.4)

• Site Plan and Sections (RS Figure 5.5)

• Cross section at Grove Lane (RS Figure 5.6)

2.10 The assessments undertaken have led to design changes, but also now utilise these parameter

plans in combination with RS Figure 1.1 Indicative Concept Plan and the details provided in

Chapter 5 – Description of the Revised Scheme.

Design Iterations

2.11 Details of the design iterations are provided in Chapter 4 – Consideration of Alternatives and

Design and Access Statement, with design evolution specific to the various disciplines described

in Technical Chapters 7 – 17. The assessment of pre-mitigation effects of the Revised Scheme

has been based on the information contained within Chapter 5 – Description of Revised Scheme.

2.12 As a result of embedded mitigation via design iterations, a number of potentially significant

effects have been reduced in severity. Consequently, the number of specific mitigation measures

proposed to reduce potential significant effects is also reduced.

Screening (Regulation 5)

2.13 The EIA Regulations require that prior to consent being granted for certain types of development,

there must be consideration, by the relevant planning authority, of environmental information.

The EIA Regulations set out the type of development which must always be subject to an EIA

(Schedule 1 development) and other developments which may require an assessment if they are

likely to have significant effects on the environment (Schedule 2 development). In this instance,

as described in Chapter 1, the Revised Scheme is a Schedule 2 development and should be

screened. It has been agreed in consultation with SDC that the Revised Scheme may have

‘significant’ environmental effects, and as such a voluntary ES is submitted.

Scoping (Regulation 13)

2.14 An EIA Scoping Report for the original Eco Park scheme was submitted to SDC on 17th July 2015

alongside a request for a formal Scoping Opinion in accordance with Regulation 13 of the EA

Regulations. The Scoping Report identifies likely ‘significant’ environmental effects of the

Scheme, by comparing the existing situation (that which pertains before development is carried

out (baseline)), with the situation once the proposals are in place. The report also took into

account significance of effects during construction. The Scoping Report is provided in RS

Appendix 1.3 and the Scoping Opinion in RS Appendix 1.2. The effects outlined in the Scoping

Opinion have been taken forward and assessed within this ES as presented in Chapters 7 – 17.


December 2017

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2.15 The scoping exercise identified that the original Eco Park scheme would not give rise to significant

environmental effects on either a temporary (construction) and / or permanent (constructed)

basis to some of the environmental disciplines discussed. Consequently, some of the

environmental disciplines were scoped out of any further assessment. Table 2.1 below provides

a summary of what was scoped in and out of the original ES, full details are in the Scoping Opinion

(RS Appendix 1.2).

Table 2.1: Environmental Disciplines Scoped In and Out of the ES

Discipline Scoped

In / Out

Summary of Scoping Opinion

Agriculture Out The Site is Grade 3 and as such its loss is not considered to be significant

in EIA terms.

Air Quality and

Emissions

(Chapter 13)

In The proposal could generate substantial traffic unless alternative

sustainable transport is established. There is the potential for an

increase in car borne pollutants and bearing in mind the surrounding

residents it is considered that this should be included in the scope. This

may affect on ecology and the aquatic environment.

Archaeology

and Cultural

Heritage

(Chapter 7)

In There are numerous heritage assets within the area, the development

may have a significant effect on them. Archaeology should be included.

There is high potential for significance which may be masked by the

agricultural soils.

Ecology and

Nature

Conservations

(Chapter 8)

In Given the ecological activity on site, there is potential for significant

environmental effects. Ecology will be interrelated to other sections of

the ES, which should use clear cross-referencing. The ecological

strategy must aim for ecological enhancement.

Flood Risk,

Hydrology and

Drainage

(Chapter 9)

In The Site partially falls within Flood Zone 3, therefore there is potential

for a significant effect. Existing local surface water flow paths should be

identified and there should be an assessment of how these flow paths

will be affected by the development. The SUDS water/run off

implications must be considered. Water quality and the need to filter

run off could be important and impinge on ecology.

Ground

Conditions,

Contamination

Out There is no history of land instability in this vicinity. The topography

does not suggest much re-engineering would be required. The Site is

not likely to have any significant land contamination. The proposal

should not cause contamination.

Landscape and

Visual

(Chapter 10)

In Given the scale of the development and proximity of receptors, it is

considered that there is a potential for significant effects. The Site is

very prominent from public viewpoints including the M5, A38, A419, as

well as various roads. These views are close by and short range, which

are therefore likely to be affected considerably by the proposal.

Lighting

(Chapter 14)

In Lighting should be included in the scope due to its relationship with

other factors. A lighting strategy will be required. The lighting need of

the development must be assessed and the height; direction; intensity;

hooding; orientation and position within the development will have to

be assessed. Guidance from the Institute of Lighting Engineers should

be referenced and the Bat Conservation Trust guidance on lighting

should be used where relevant.

Noise and

Vibration

(Chapter 15)

In The noise implications may compound other issues. They should be

included in the scope of the ES. The methodology set out in the scoping

report is broadly acceptable.

Socio-

Economics

In The development is anticipated to create numerous jobs in the area, as

such there is the potential for a significant effect. Health benefits of the

proposal should be explained. As the proposal involves the relocation


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Discipline Scoped

In / Out

Summary of Scoping Opinion

(Chapter 11) of FGR, the effect of this relocation must be considered, both on the

effect of the new development on the surrounding area, and the loss

of the use on the Site in Nailsworth. The effect of the development on

the redevelopment of other sites within the area must be undertaken.

Transport and

Access

(Chapter 12)

In The Site is located adjacent to the Junction 13 of the M5, therefore

there is the potential for significant effects. The Site is adjacent to the

M5, and its junction with the A419. The A38 major road is close by.

Effectively these roads form major arteries north-south but also

eastwards. The capacity of the roads and junctions in particular at peak

time needs to be considered as well as the safety of all users of the

highway.

2.16 The Revised Scheme now proposed is much reduced from the proposals which were scoped

above. Therefore, it is considered that following the Scoping Opinion outlined above will ensure

the worst case is now assessed as part of this Revised Scheme. In addition, further matters raised

since this Scoping Opinion of 2015 have been taken on board. Where relevant, responses to pre-

and post- application discussions and details of further technical consultations with respective

consultees have been included within the respective technical chapters of the ES.

2017 EIA Regulations

2.17 Additionally, to respond to the 2017 EIA Regulations, although not required for this ES under the

2011 Regulations, two additional chapters have now been produced. These two new chapters

are; Climate Change (Chapter 16); and Major Accidents and Disasters (Chapter 17). In this

respect, Regulation 18(3) of the 2017 EIA Regulations sets out the requirements for

environmental statements in the following terms;

‘(3) 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 developer, 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 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.’

2.18 Accordingly, insofar as the requirements of Regulation 18(3)(a) to (e) are concerned, there has

not been any fundamental change in requirements of the EIA Regulations when compared with

the requirements of Part 2, of Schedule 4 to the 2011 EIA Regulations. Those requirements were

directed at:


December 2017

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• a description of the development (comprising information on the site, design and size of

development),

• a description of measures to avoid, reduce and, if possible, remedy significant adverse

effects,

• data required to identify and assess the main effects on the environment,

• an outline of the main alternatives studied and indication of the reasons for the choice

made (taking into account environmental effects), and,

• a non-technical summary.

2.19 Given that the previously prepared Environmental Statement adequately addressed those

requirements, there would not be any substantive changes to any subsequent Environmental

Statement in order to address the demands of Regulation 18(3)(a) to (e) of the 2017 EIA

Regulations.

2.20 However, as set out above in by Regulation 18(3)(f) of the 2017 EIA Regulations, there is a

requirement for an Environmental Statement to include, ‘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’.

2.21 Schedule 4 of the 2017 EIA Regulations contains some different requirements when compared

with Part 1 of Schedule 4 to the 2011 EIA Regulations. The list of requirements has become more

detailed. Amongst other things, Schedule 4 of the 2017 EIA Regulations contains specific

reference to:

• energy demand and use for a development’s operational phase (paragraph 1),

• ‘reasonable alternatives’ as opposed to ‘main alternatives’ in the 2011 EIA Regulations

(paragraph 2),

• the evolution of the baseline scenario in the event that the proposed development does

not occur (paragraph 3),

• human health as a potential factor for consideration (paragraphs 4 and 5, and Regulation

4(2) of the 2017 EIA Regulations),

• ‘the impact of the project on climate (for example the nature and magnitude of

greenhouse gas emissions) and the vulnerability of the project to climate change’

(paragraph 5),

• ‘A description of the forecasting methods or evidence, used to identify and assess the

significant effects on the environment, including details of difficulties (for example

technical deficiencies or lack of knowledge) encountered compiling the required

information and the main uncertainties involved’ (paragraph 6).

2.22 A copy of Schedule 4 of the 2017 EIA Regulations has been included in RS Appendix 2.1. However,

it is considered these additional matters have either already been addressed within the scope of

the ES, or through the additional chapters included as part of this new ES. For the avoidance of

doubt, although this ES is prepared to be compliant with the 2017 Regulations, it is submitted

under the 2011 Regulations.

Public Consultation


December 2017

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2.23 As part of the planning process for the original Eco Park scheme, the Applicant made every effort

to engage with a range of stakeholders in advance of the submission of the planning application.

This allowed concerns raised through consultation to be addressed. Consultation was

undertaken with both the public and the various stakeholders potentially affected, this is

detailed fully within the Statement of Community Involvement submitted as part of the planning

application.

2.24 In total five public exhibitions took place prior to the submission of the original Eco Park

application, a summary of these are provided in Table 2.2 below. At the exhibitions information

displayed included site location and concept plans with a newsletter, comments form, survey

postcards and FGR advantages sheets also available for completion or taking away.

Table 2.2: Summary of Public Exhibitions

Public Exhibition Summary

31st August 2015:

The New Lawn,

Forest Green

Rovers,

Nailsworth, 12 to

2.45pm (pre-

match).

Attended by 235

people.

The response was broadly positive with regards to employment and recreational

benefits.

The general points of interest discussed revolved around: parking charges and

costs associated with season and match day tickets; footpath links from

Whitminster; the use of the stadium as a concert venue; a family fun park on

match days and disability access.

Concerns raised about the Proposed Development were in relation to: the all

seater ruining the match day atmosphere (with strong support for an all standing

stand); the traffic effects associated with the development; that public transport

is not an option in rural Gloucestershire and further to travel for local (Nailsworth

based) fans.

2nd September

2015: The New

Lawn, Forest

Green Rovers

Football Club,

Nailsworth, 12 to

7.30pm.

Attended by 24

people.

The response was broadly positive.

The general points of interest discussed revolved around: will the community be

able to access the facilities; the local community having a say on the future use of

The New Lawn; sustainable transport needs to be considered within the proposal

and The New Lawn to accommodate conference facilities or after school club.

Concerns raised about the Proposed Development were in relation to: the traffic

effect of the proposal; the loss of gym/facilities from FGR and the potential for

increased traffic if housing is delivered on The New Lawn site and that young

supporters will find the new location hard to get to.

3rd September

2015: Village Hall,

Eastington, 12 to

7.30pm.

Attended 115

people.

The response was a mixture of positive and negative feedback, with the greatest

concern being the traffic along the A419 and through Eastington.

The general points of interest discussed revolved around: the proposed use being

better than for housing; too much emphasis on ball games and not enough on

racquet sports; the athletic facility should be indoors; the effect on existing public

rights of ways; runoff and sewerage needs attention as houses on Grove Lane have

no main sewerage; facilities on canal need to attract boat owners; survey should

be undertaken to see how FGR would access the new stadium and that high speed

internet would be needed for the area.


December 2017

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Concerns raised about the Proposed Development were in relation to: traffic

effect relating to congestion of A419 and knock-on use of Spring Hill / Eastington

Road; the nature reserve would not be accessible; the proposal is in contradiction

to Ecotricity’s green ethos and that the cumulative effect of the development

would lead to conjoining of Stroud with Stonehouse.

8th September

2015: Unicorn

House, Stroud, 12

to 7.30pm.

Attended by 26

people.

The majority of the responses were broadly positive.

The general point of interest discussed revolved around: requests for a swimming

pool and other sports to be considered; the canal trust being interested in office

space; the towpath being wide enough for pedestrians and cyclists and that the

use of the Site for the proposal is better than as a housing development.

Concerns raised about the Proposed Development were in relation to; traffic

concerns; not good to lose farmland and the loss of community facilities at The

New Lawn.

30th September

2015: Town Hall,

Stonehouse, 3 to

8.30pm

Attended by 44

people.

The response was a mixture of positive and negative feedback, with the greatest

concern being the traffic along the A419 and the use of green land.

The general points of interest discussed revolved around: the benefit of high

quality sporting facilities and improved transport links.

There also much discussion on how the proposal may assist with the reopening of

the Bristol Road Station in Stonehouse, along the Birmingham to Bristol railway

line.

2.25 A summary of the further consultations which took place after the original submission in January

2016 is summarised in Table 2.3 below.

Table 2.3: Summary of Public Exhibitions and Consultation following submission of the Eco Park

Planning Application in January 2016


Saturday 30 January 2016

Before and after match at

Forest Green Rovers FC, The

New Lawn, Nailsworth

Public Exhibition. Very well attended with overwhelmingly positive

support for the proposals. A few fans were concerned about the loss

of the ground in Nailsworth to which they could currently walk.

Thursday 4 February 2016

Eastington Village Hall,

Eastington

Public Exhibition. Well attended exhibition where a wide range of

questions and comments were raised by members of the public, the

majority of which were subsequently stated in consultation responses

on the application. Main issues were traffic and parking, through-

traffic in Eastington, lighting and noise, as well as clarification on what

kind of community access/ facilities would be available.

Saturday 6 February 2016

Stonehouse Town Hall,

Stonehouse

Very poor weather was likely to be a factor in a lower than expected

turnout. Again, from those that attended a wide range of issues were

raised.

Saturday 13 February 2016

The Ale House, 9 John Street,

Stroud, GL5 2HA

Well attended and generally positive response to Eco Park.

Saturday 16th April 2016

SGS College, Berkeley Green,

Berkeley

Berkeley Green Open Day was for companies and organisations that

have expressed an interest in the development of the former nuclear

site at Berkeley.

Wednesday 29th June 2016

Growing Gloucestershire

Conference, University of

Gloucestershire, Longlevens,

GL2 9HW

The Growing Gloucestershire Conference is an annual event which

brings together delegates from the business community to discuss

interesting developments in the county. Eco Park was the subject of

the Keynote Address on ‘Delivering the Eco Park and a new home for

Forest Green Rovers at Junction 13’. Over 200 delegates attended


December 2017

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the Conference from across the Gloucestershire Business

Community.

Thursday 17th November

2016

Eastington Village Hall,

Eastington

As previously, a well-attended exhibition. Main issues were again

traffic and parking, through-traffic in Eastington, lighting and noise, as

well as clarification on what kind of community access/ facilities would

be available.

Saturday 17 December 2017

Before and after match at

Forest Green Rovers FC, The

New Lawn, Nailsworth

Public Exhibition. Again, well attended with overwhelmingly positive

support for the proposals, including the new ZHA Stadium design.

Wednesday 5th April 2017

Eco Park Business Breakfast

Event

Over one hundred businesses attended a Business Breakfast Event,

which featured ZHAs design for FGR’s new stadium, and opportunities

presented in the proposed new Green Technology Hub.

2.26 In addition to public consultation, numerous meetings with stakeholders have continued

throughout the process, and included stakeholder engagement and meetings with Eastington

Parish Council and an exhibition/ open day, William Morris College, Stagecoach, FGR, Hitchens

(related to overlapping issues with West of Stonehouse), the Cotswold Conservation Board, and

discussions over the feasibility of re-opening Stonehouse Bristol Road Train Station.

2.27 The technical chapters also provide further detail with regards to the consultation that has been

undertaken with both statutory and non-statutory consultees. Discussions with stakeholders are

ongoing and the Applicant will continue these throughout the application and consultation

process.

Approach to the Assessment of the Revised Scheme

2.28 The assessment of potential effects resulting from the Revised Scheme has taken into account

the construction and operational phases. The significance level attributed to each effect

identified has been assessed on the magnitude of change due to the Revised Scheme and the

sensitivity of the affected receptor/ receiving environment to change/ effect as well as a number

of other factors that are outlined below in more detail. The determination of the significance of

residual effects has been assessed with regard to the extent to which mitigation measures will

reduce or reverse significant negative effects. Whether these residual effects are significant or

not is also stated.

Assessment Criteria

2.29 The assessment of potential effects for each of the technical topic areas are presented in

Technical Chapters 7 – 17 and have taken into account a number of criteria to determine

whether or not the potential effects are ‘significant’. Wherever possible and appropriate, the

effects will be assessed quantitatively. The following criteria have been taken into account when

determining the significance of potential effects.

• Relevant legislation and planning policy;

• International, national, regional and local standards;

• Geographical extent;


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• Magnitude and complexity of effect;

• Sensitivity / value of affected receptor or receiving environment;

• Duration (short, medium or long-term), frequency and reversibility of effect;

• Inter-relationship between different effects (both cumulatively and in terms of potential

effect interactions);

• The outcomes of consultations.

2.30 Unless specified in the Technical Chapters 7 – 17 the following criteria will be used to determine

the magnitude of change and the sensitivity of the receptor/ receiving environment.

Magnitude of Change

2.31 The magnitude (scale) of change for each effect has been identified and predicted as a deviation

from the established baseline conditions, for the construction and operational phases of the

Revised Scheme. The scale used (high, medium, low, and negligible) is shown in Table 2.4 below.

Sensitivity of Receptors

2.32 The sensitivity of receptors/ receiving environments considered within the ES are defined within

Chapters 7 – 17. The sensitivity/ value of receptors/ receiving environments to change have been

determined by quantifiable data (where applicable), the consideration of existing and proposed

designations and professional judgement. The scale used (high, medium, low, and negligible) is

also shown in Table 2.4.

Assessment Effect Significance

2.33 The level of effects has been assessed using appropriate national and international standards or

limits (WHO Limits, EU Quality Standards etc.). Where no such standards exist, the assessments

in each individual subject area describe the professional judgements (assumptions and value

systems) that underpin the attribution of significance.

2.34 Each effect has been assessed against the change of magnitude and the sensitivity of the receptor

as shown in Table 2.4.

Table 2.4: Matrix for determining the level of effects

Sensitivity of receptor/ Receiving Environment to Change/ Effect

High Medium Low Negligible

Ma

gn

itu

de

of

Ch

an

ge

/ e

ffe

ct Substantial Major Moderate Minor Negligible

Medium Moderate Moderate Minor Negligible

Minor Minor Minor Minor Negligible

Negligible Negligible Negligible Negligible Negligible

2.35 While effects are considered to fall into one of four effect categories ranging from ‘negligible’,

‘minor’, ‘moderate’, ‘major’ in the effects matrix presented in Table 2.4, it is only those effects

that fall into the ‘moderate’ or ‘major’ category (as shaded above) that are considered to be the

significant environmental effects arising from the construction and operation of the Revised


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Scheme. It should however be noted that different specialist topics within the ES may use a

different approach to identify which level of effects are significant. A summary of effects table is

contained within each technical assessment chapter clearly stating for each effect identified

whether it has been found to be ‘significant’ or ‘not significant’.

2.36 Whilst the ES provides a full factual description of the development, as emphasised by Schedule

4 of the 2011 EIA Regulations 6, and clearly stated in Planning Practice Guidance (PPG)7, the ES

needs to be proportionate and not any longer than is necessary to assess properly those effects

which are considered significant. In this instance, effects considered significant have been

assessed within the main technical chapters, with supporting appendices clearly identified in

these chapters providing details of the assessments undertaken on the effects considered not

significant.

2.37 The terms as used within the table have been defined below:

• Major positive or negative effect: where the development would cause significant

improvement (or deterioration) to the existing environment.

• Moderate positive or negative effect: where the development would cause noticeable


• Minor positive or negative effect: where the development would cause perceptible


• Negligible: no discernible improvement or deterioration to the existing environment.

2.38 In addition to the assessment structure set out above, specific criteria have been developed for

certain technical studies and are detailed in the respective chapters of the ES. The inter-

relationship between environmental effects and residual effects following implementation of

mitigation measures has also been discussed.

2.39 In terms of the duration of an effect, short-term has been considered as 1 year (or below), a

medium-term effect has been considered to be between 1 and 10 years in duration and a long-

term effect has been considered to be greater than 10 years in duration. If variation on these

timeframes is necessary, this is stated and explained in Technical Chapters 7 to 17.

Cumulative Effects

2.40 Schedule 4 of the EIA Regulations requires that cumulative effects of a development are

considered within an EIA. There is no widely accepted methodology or best practice for the

assessment of cumulative effects, although various guidance documents exist. The following

approach has been adopted for the assessment of cumulative effects, based on previous

experience, the types of receptors being assessed, the nature of the Revised Scheme, the

committed developments under consideration and the information available to inform the

assessment.

6 Schedule 4 of the EIA Regulations available from http://www.legislation.gov.uk/uksi/2011/1824/schedule/4/made

accessed on 8th December 2015. 7 Planning Practice Guidance, Paragraph: 035 Reference ID: 4-035-20140306 available from

http://planningguidance.communities.gov.uk/blog/guidance/environmental-impact-assessment/preparing-an-

environmental-statement/ accessed on 8th December 2015.


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2.41 With regards to cumulative effects, they have been considered within the technical assessments

as both cumulative effects from different committed developments and cumulative effects from

different environmental features. Table 2.5 lists the committed developments that have been

identified as part of this assessment. RS Figure 18.1 illustrates the locations of these sites. As

such, each consultant has reviewed the respective planning submission (and ES chapters where

these exist) to ensure any cumulative effect has been fully assessed within the respective

technical chapters.

2.42 As detailed above and within Chapter 12 – Transport and Access, Land West of Stonehouse has

formed part of the baseline for the assessment undertaken as opposed to the cumulative

assessment. This is because all the traffic modelling has included West of Stonehouse (and

associated A419 junction improvements) as part of the baseline traffic flows in order to assess

worst case. Given Chapter 13 – Air Quality and Dust and Chapter 15 – Noise and Vibration rely

on data from the traffic assessment, these have also included Land West of Stonehouse and the

A419 junction improvements as part of the baseline to their assessments.

2.43 Further details regarding the scope of the assessment of cumulative effects are provided within

Chapter 18 – Cumulative Effects.


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Table 2.5: List of committed developments that have been identified for cumulative assessment

Reference Address Development Status Co-ordinates Distance from site

(km)

S.14/0810/OUT Land West of

Stonehouse, Nastend

Lane, Nastend,

Stonehouse,

Gloucestershire

A mixed-use development comprising up to 1,350 dwellings and 9.3 hectares of employment land

for use classes B1, B2 and B8; a mixed use local centre comprising use classes A1, A2, A3, A4, A5,

D1, D2 and B1; primary school, open space and landscaping, parking and supporting infrastructure

and utilities; and the creation of new vehicular accesses from Grove Lane, Oldends Lane and Brunel

Way. Reserved Matters now approved under S.17/0095/REM.

Application

Permitted

379312,

206558

0.1

S.12/0763/FUL Bonds Mill, Unit 27,

Bristol Road, Stonehouse

Demolition of part of an existing warehouse including a hoist on the adjacent building, renovation

of the remainder as office space and erection of a two-storey extension.

Application

Permitted

379344,

205327

1.51

S.15/1088/FUL Westend Courtyard,

Grove Lane, Westend,

Stonehouse,

Gloucestershire

Proposed extension to Westend courtyard to provide 10 additional offices (B1 use). Application

Permitted

378312,

207018

0.1

N/A Infilled canal to the south

of the Site

Canal restoration and realignment scheme subject to successful Lottery bid funding from Cotswold

Canals Trust

No planning history. Directly to the

south of

Redline

Boundary.

Directly to the south

of Redline Boundary.

13/0001/INQUIR Land at Javelin Park Proposed Development of an Energy from Waste (EfW) facility for the combustion of non-

hazardous waste and the generation of energy

Appeal Allowed 380040,

210430

3.92

S.15/2089/OUT Land Adjacent To

Eastington Trading Estate

Churchend, Eastington,

Gloucestershire.

Erection of three industrial employment buildings with associated access, car parking and service

yards (Outline application - Access, Layout and Scale included).

Application

Permitted

378000,

206050

0.1

S.17/0563/OUT Land Off School Lane,

Whitminster,

Gloucestershire

Residential development for up to 60 dwellings including infrastructure, ancillary facilities, open

space and landscaping. Construction of a new vehicular access from School Lane.

Application Refused 377106,

208403

1.5

S.17/1133/FUL Former Standish Hospital

and Former Westridge

Hospital Standish,

Stonehouse,

Gloucestershire

Conversion and refurbishment of the former Standish Hospital complex, including Standish House

(Building A), Stable Block (Building B), Ward Blocks (Buildings C & G), Standish Lodge (Building L),

Building I, and demolition and works to associated out-buildings and gatehouse to form 50

dwellings; demolition of Westridge Hospital and associated building. Development of 98 new build

homes within the grounds; conversion; associated surface vehicle and cycle car parking, pedestrian

and vehicular access and associated ancillary development, landscaping, ancillary storage and plant

and ecological bat housing; and all associated engineering works and operations

Pending

Consideration

381646,

206566

3.0

S.16/0922/REM Land Adjoining Station

Road Bristol Road,

Stonehouse,

Gloucestershire, GL10

3RB

Approval of Reserved Matters Appearance and Landscaping from appeal

APP/C1625/A/13/2195656 (S.12/2538/OUT) - residential development for 49 units, new access

way and associated works.

Application

Permitted

379900,

205480

1.8

S.17/2331/OUT

Land Adjoining Oldbury

Lodge Pike Lock Lane

Eastington

Gloucestershire

Erection of new buildings for uses within use class C1 (Hotel) up to 1,908 Sqm (56 Beds), and use

classes A3 / A4 Pub (Pub/Restaurant) up to 711 Sqm (Including ancillary manager's apartment) and

associated access, servicing, parking, drainage and landscaping (outline application: all matters

reserved except for access and scale)

Awaiting Decision 378500,

206100

0.3


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3 DESCRIPTION OF THE SITE AND SURROUNDING AREA

Introduction

3.1 This Chapter provides a description of both the Site location, defined by the Redline Boundary

(RS Figure 1.3), and the surrounding area. Further detailed site descriptions along with the Study

Areas in relation to the technical assessments undertaken are provided within Chapters 7 – 17.

Site Location and Surrounding Area

3.2 The Site is approximately centred on National Grid Reference SO 77965 206584. RS Figure 1.2

shows the Site’s local context and RS Figure 1.3 shows the Site context. As noted under scoping

in Chapter 2 above, the Site is Grade 3 agricultural land. It consists of relatively species poor

agricultural land throughout with fields currently used for cattle grazing and cutting of hay. The

Site is bisected by the A419, running in a north-west, south-east direction, and the M5 in a north-

east to south-west direction. The Site is fairly flat with a slight fall south across the Site from 20m

AOD to 15m AOD.

3.3 The southern land parcel of the Site (formerly the Sports Complex) is approximately 13.5ha in

size and is bounded to the south-east by residential properties and warehouses, and to the south

by the flood plain of the River Frome which lies in Flood Zone 3 of the Environment Agency Flood

Map. It is comprised of mixed agricultural fields.

3.4 The south-western land parcel of the Site (formerly the Nature Conservation Area) is

approximately 4.6ha and is bounded to the east by the M5, River Frome to the south, mature

hedgerow and trees to the west and the Eastington Maintenance Compound associated with the

motorway to the north. It comprises two agricultural fields with belts of trees and mature

hedgerow with a line of scrub bordering the river to the south. It is located within Flood Zone 3.

3.5 The area where the Revised Scheme is located is approximately 18.9ha in size and is bounded by

properties and Grove Lane to the north, a tree lined agricultural track to the east, the A419 to

the south and the M5 to the west. It is comprised of mixed agricultural fields with belts of trees

and hedgerows.

3.6 As the land use at the Site is predominantly agricultural (grazing land), it is understood that

potable water supply and foul drainage services are not currently present on-site. However, the

nearest foul water drainage and water supply are within close proximity to the Site at properties

directly to the east of the southern parcel of land at Chipmans Platt, and properties located off

Grove Lane adjacent to the Revised Scheme. The existing landscape context is a combination of

built development and major infrastructure and rural land use – a dynamic rural landscape with

urban fringe qualities including the hustle and bustle (both aural and visual) of an urban

environment.

3.7 The highways improvement works covers an area approximately 2.5ha in size. It comprises the

A419 which forms the main road corridor into Stonehouse and Stroud from the west. To the

west the A419 has a grade separated roundabout junction with the M5 (Junction 13) and, beyond

the M5, a roundabout junction with the A38 south of Whitminster. The section of the A419


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located to the south of the area subject of the Revised Scheme, between the M5 and Chipmans

Platt Roundabout is a single carriageway road subject to the national speed limit. There is no

street lighting and no footway along this section.

3.8 Chipmans Platt roundabout to the south east of the Site forms the junction between the A419,

Spring Hill to the south and Grove Lane to the north, and is street lit. A service area is located at

this junction, and includes a filling station, a coffee shop and a hotel. Entrance is from the

roundabout, with exit on to Grove Lane to the north. It should be noted that this service area

junction onto Grove Lane is currently the subject of works associated with the West of

Stonehouse development. Construction commenced in summer 2017, and works to the site

access are now well underway.

3.9 North of Chipmans Platt, Grove Lane leads north and west to join the A38 at Whitminster. The

southern section is a two-lane single carriageway, with a footway on the eastern side, and subject

to a 50mph speed limit (and currently the subject to West of Stonehouse access works as

described above). The footway stops to the north of the service area exit, and a 40mph speed

limit commences on the approach to the settlement of Westend, returning to 50mph to the

south east of the bridge over the M5. South of Chipmans Platt, Spring Hill / Alkerton Road leads

south west to the village of Eastington where it has a roundabout junction with Bath Road.

3.10 There is currently no footway or cycleway along the A419 bisecting the Site and no formal

pedestrian crossing of the A419 is provided, even though a Public Right of Way crosses from the

southern parcel of land into the northern parcel of land where the Revised Scheme is located.

There is an underpass approximately 100m long which could be made suitable for use on foot

(subject to some refurbishment) under the M5 south of Junction 13. The local public rights of

way network through the Site includes a footpath running south-west to north-east through the

southern parcel of land, and a footpath that runs south-west to north-east and then splits into

two separate footpaths through the Revised Scheme. These two footpaths in the southern parcel

of land and the Revised Scheme to the north are linked across the A419 (but without a pedestrian

crossing as noted above). Evidence on the ground indicates generally infrequent use near the

A419 crossing, with slightly greater levels or use near Grove Lane and William Morris College.

3.11 National Route 45 of the NCN, which links Chester with Salisbury via Gloucester, Cirencester and

Swindon, runs along Grove Lane to the north of the Revised Scheme, and then south along Spring

Hill south of Chipmans Platt for a short distance.

3.12 The noise environment at the Site is dominated by road traffic noise from both the M5 and A419.

Other noise sources include agricultural plant, livestock and potentially the operation of the

Highways Agency Maintenance Compound. The baseline air quality estimated at the Revised

Scheme site does not exceed the relevant air quality objectives for NOx, NO2, PM10 and PM2.5.

3.13 No Scheduled Monuments, Registered Parks and Gardens or Registered Battlefields are present

within or in the vicinity of the Site. The southern part of the Site lies partially within the Stroud

Industrial Heritage Conservation Area. No Listed buildings are present within the Redline

Boundary.


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3.14 There are no ecological designations within the Site. However, the land holding adjacent to the

southern parcel of land adjoins, and is partly included in, the River Frome Key Wildlife Site (KWS)

and the River Frome mainstream and Tributaries KWS. A desk study within 5km of the Site

identified two internationally important sites, four nationally important sites, and 18 Key Wildlife

Sites. Fourteen species of bats have been recorded within 10km of the Site centre. Otter, badger,

hare, water vole, reptiles and amphibians were recorded within 5km of the Site centre. A large

number of bird records were returned due to the proximity of the Site to the Severn Estuary

Special Protection Area.

3.15 The Site is currently unlit with no existing sources of artificial lighting within the Redline

Boundary. Existing light emissions are associated with the M5, A419 and the junction which

connects these two roads. While the sections of these roads immediately adjacent to the Site are

unlit, there are light emissions associated with traffic traversing these roads at night, the

Highways Agency maintenance compound, the service station to the southeast of the Revised

Scheme, and residential dwellings along Grove Lane and associated with Chipmans Platt. Light

intrusion is also observed from the Eastington Trading Estate which adjoins the Redline Boundary

of the southern parcel.

3.16 Committed development in the surrounding area is illustrated in RS Figure 18.1 and listed in

Table 2.5. Directly to the south west of the Redline Boundary is the proposed canal realignment

scheme by the CCT. To the east of the Revised Scheme is Land West of Stonehouse. This is a

strategic site allocation within the recently adopted Local Plan, has outline planning permission,

and has recently been granted Reserved Matter approvals with work now commencing on the

site access from Grove Lane as noted above. It is a mixed-use development with permission for

up to 1,350 dwellings and 9.3 hectares of employment land.

3.17 Another committed development to the north of the Revised Scheme, located on the north side

of Grove Lane, is Westend Courtyard. This is an approved permission for 10 additional offices.


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4 CONSIDERATION OF ALTERNATIVES

Introduction

4.1 This Chapter outlines the description of the main alternatives to the Revised Scheme which have

been considered by the Applicant and the principal reasons for proceeding with the current

planning application. It firstly looks at alternative sites and then discusses alternative site layouts.

Requirement of the Consideration of Alternatives

4.2 Schedule 4, Part 1 of the 2011 EIA Regulations states that an ES should include ‘an outline of the

main alternatives studied by the applicant or appellant and an indication of the main reasons for

the choice made, taking into account the environmental effects’.

Alternative Sites

4.3 A number of options have been considered in relation to the future location of the FGR, but also

the concept of Eco Park that formed part of the original planning submission. In the initial stage

of the project appraisal the Site options were considered against FGR’s requirements and

aspirations for relocation. These were (as per Chapter 1):

• Provide a location easily accessed by supporters being well served by public transport and

with adequate onsite parking provision;

• Remove parking congestion on match days from Nailsworth;

• Provide adequate facilities in one location for the youth, academy, first and ladies teams,

helping to ensure sustainability in sport by supporting and encouraging local talent;

• Be an educational resource for local further education establishments, enabling more

sports related courses to be run and an increase in student numbers;

• Deliver an all-weather pitch together with training pitches, gym, state of the art sports

science and medical facilities;

• Create a centre of excellence for sports medicine, rehabilitation, fitness and health,

working with local health and education providers.

• Be of benefit to the residents and Sports Clubs of Stroud District and beyond who will have

access to the FGR facilities for a range of sports;

• Provide additional sports facilities which will be developed and could include, for example,

an athletics track and a rugby pitch;

• Be the focal point of Eco Park, which offers FGR the prospect of a long-term home, set

within a traffic free parkland and designed to show case sustainable construction

practices.

4.4 In order to identify an area of search for the Revised Scheme, a GIS mapping exercise was carried

out to identify potential available land for Eco Park. The methodology used for the area of search

was as follows:

1. Land located within the AONB, existing built up areas and land already allocated for

housing was removed from the area of search.

2. Land located within the Flood Zones 2 and 3 according to the Environment Agency

mapping was then subsequently removed from the area of the search.


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3. From the existing stadium development an area of search of 10km was identified. Given

FGR’s location within Nailsworth, it was important when looking for a new location that

the club did not relocate too far and lose its local association.

4. The proposed Stonehouse Cluster (strategic site SA2 from the Local Plan) was then

subsequently removed from the area of search.

5. Further constraints such as common land, National Trust land and both national and

international designated ecological sites were identified on the plan.

6. Finally, an area of search from the junctions of the M5 motorway were added to the plan.

4.5 The output from was RS Figure 4.1 Site search area for the Revised Scheme. From these

requirements, a number of available sites within Stroud District were considered. The search was

limited to the District given FGR’s association with the area, current fan base and the need to

avoid this fan base from travelling longer distances in order to maintain their support for the

club. The following alternative options have been considered:

• Option 1: The ‘Do Nothing’ Scenario: FGR stays at The New Lawn and the Site remains as

agricultural land

• Option 2: Redevelopment of The New Lawn

• Option 3: Relocation Alternative Sites

• Option 4: Relocation to Land at Junction 13 M5 ‘Eco-Park’, West of Stonehouse

• Option 5: Relocation to Land at Junction 13 M5 ‘Revised Scheme’, West of Stonehouse

Option 1 - Do Nothing

4.6 The ‘do nothing’ scenario would mean that the Site would continue to remain Greenfield

agricultural land. A number of important effects would derive from this ‘do nothing’ scenario and

largely relate to lost opportunities for improvement / enhancement. These include:

• The loss of opportunity for significant investment in Stroud District in a difficult economic

climate;

• The loss of provision of employment opportunities on-site during construction and

operation and in the surrounding area through supply chain services;

• The loss of improved traffic and transportation implications associated with match days at

The New Lawn;

• The missed opportunity of a landmark building providing a gateway into Stroud District;

• The missed opportunity to deliver the dualling of the A419 between the Junction 13 of the

M5 and Chipmans Platt roundabout which will deliver traffic flow improvements towards

Stroud.

• The missed opportunity to deliver the biodiversity enhancements sought by the Revised

Scheme.

4.7 There are, however, a number of positive effects resulting from the ‘do nothing’ scenario,

including the following:

• The increased noise, dust and visual intrusion associated with the construction phase

would be avoided;

• The increased traffic, noise, lighting and air quality effects associated with the operational

phase would be avoided;


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• Existing ecology (species and habitats, albeit limited) and agricultural land would not be

disturbed and would remain unaffected;

• Preservation of the existing landscape character and existing views from the surrounding

features and properties.

Option 2: Redevelopment of The New Lawn

4.8 One option considered was to redevelop the stadium on The New Lawn site. This was ruled out

fairly early in the process due to the technical difficulties that would be encountered

redeveloping the current stadium. Issues such as the size of the pitch, the orientation logistics of

working around the current buildings and the current and future access to the Site were all

constraints that were considered and caused this option to be discounted. Furthermore, part of

the reason for the relocation is to allow future expansion of the stadium as the ambition is to

progress up the Football League, and therefore the alleviation of traffic effect on the local

community associated with higher attendances – which are already being experienced since

FGR’s promotion to League 2 this season.

Option 3 - Relocation Alternative Sites

4.9 As part of an initial search for sites, three alternative sites to land at M5 Junction 13 were

considered, these were Aston Down Industrial Estate, Javelin Park, Oldends Lane Industrial Estate

and the Stonehouse Area. These sites have been assessed below.

4.10 Oldends Lane Industrial Estate and the Stonehouse Area: The Site allocations at the Stroudwater

Business Park previously comprise of 18.6ha of land within three allocations (EA9, EA10 and EA11

of Saved Policy EM5). However, the residual allocations of these have now been reallocated to

form part of Policy SA2 of the adopted Local Plan. The Site is one of the primary employment

allocations within the District having good access to the A419 and M5. The location is within the

M5 growth corridor. The previous allocation EA9 has been partially developed with new

applications coming forward on behalf of Schlumberger in the form of “buildings A and F”.

Allocation EA10 also benefits from a recent planning permission (S.14/0353/FUL) for Stroud

Metals. In addition to the Site allocations, a further development of 1.83ha by Ashville

Developments Finance Limited was permitted in July 2015 adding a further 1.83ha to the

employment land supply here. The remaining area of land available at this site is 10.4ha in the

residual allocation from EA9 and EA11, which like EA10 are now formally revoked. The Stroud

Local Plan reallocates the residual part of allocation EA9 from the previous Local Plan and

accordingly there is no increase of employment land at this location from the previous local plan

despite it being in the optimum location for business growth. However, as is clear from scale and

need of the Revised Scheme, a site of 10.5 ha will not be sufficient to deliver the Revised Scheme

which covers some 18.9ha.

4.11 Aston Down Industrial Estate: The Site is identified as a key employment site within the Local

Plan (Policy El1 site EK21). It is located within the AONB and this, coupled with the distance from

the motorway, would make it unacceptable in the scale and form of the Revised Scheme and also

unlikely to be found acceptable in planning terms.

4.12 Javelin Park: The Site is identified a Key Employment Site and is a Waste Core Strategy Allocation

within the Local Plan, it has also recently been subject to a successful appeal for an Energy from


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Waste Plant. As such, through the implementation of that development it would not allow the

form and scale of the Revised Scheme that would be required. Furthermore, the Site falls outside

the area of search in terms of distance from the area of search.

4.13 All four sites following an assessment were not considered to be suitable for the Revised Scheme

in its current scale and form.

Options 4 and 5: Relocation to Land at M5 Junction 13, West of Stonehouse

4.14 A further option discussed (and which formed the Eco Park Application), was the relocation to

Land at M5 Junction 13 West of Stonehouse. The original planning application was larger, and

included the area south of the A419 and east of the M5 (the Sports Complex), the area north of

the A419 and east of the M5 (the Green Technology Hub) and the area south of the A419 and

west of the M5 (the Nature Conservation Area). Since submission of this application in January

2016, the Applicant and their advisors have been in on-going discussions with both SDC and

statutory consultees, and this has given rise to this Revised Scheme. Only the area north of the

A419 and east of the M5 is being proposed for development (the ‘Development Footprint’) as

part of this Revised Scheme, to provide a stadium and ancillary facilities, together with training

pitches for FGRFC.

4.15 A full description of the Revised Scheme is included in Chapter 5 – Description of the Revised

Scheme.

Alternative Site Layouts

4.16 Following the selection of the Site, environmental constraints have been identified and

subsequently addressed through alteration of the concept design to minimise or avoid adverse

significant environmental effects. As a result of embedded mitigation via design iterations, a

number of potentially significant effects have been reduced in severity. Consequently, the

number of specific mitigation measures proposed to reduce potential significant effects is also

reduced.

4.17 The Design and Access Statement submitted as part of the planning submission also provides

further details of the design evolution of the Revised Scheme. These are provided in more detail

within that statement, however the key design iteration changes can be summarised in Table

4.1.

Table 4.1: Design Iterations

Iteration Changes

1 • Concept Design: was prepared to assess the preliminary viability of the Site and to

establish whether the development could be accommodated within the Site.

• Environmental Constraints: were taken into account in order to build embedded

mitigation into the Revised Scheme.

• William Morris College: was identified as key receptor at the outset and ways to reduce

the effect upon them were considered.

• Access: a new access point was built in due to both proximity of the M5 and existing

congestion issues along the A419.

2 • Concept Plan: was broadly translated to the submitted outline parameter plans

submitted as part of this ES (RS Figures 5.1, 5.2 ad 5.3). The layout in the Indicative


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Iteration Changes

Concept Plan was developed as feedback became available from members of the

consultant team as their assessments were carried out.

• Access: the Concept Design was adjusted to accommodate the introduction of a signalised

junction as opposed to a roundabout, along with a separate access off Grove Lane for

busses to utilise on matchdays via the Stonehouse development.

• Pedestrian Access: various options were considered, including the location of footways.

The signalised junction was considered the most appropriate means of accessing the Site

from the A419.

• Footpath / Cycle Link: was built in to be delivered on the A419 between the new junction

and Chipmans Platt roundabout improving the Site’s sustainability credentials and

reducing the potential traffic effect.

4 • Topographic Data: was overlaid to further inform the detailed positioning of the new and

maintained green infrastructure. This included incorporating the Arboricultural Report

(RS Appendix 8.4) ensuring certain hedgerows and trees identified for retaining were

incorporated.

• Access: the most notable change was the relocation of the junction slightly further east

along the A419 to reduce the effect on surrounding trees. As part of this two hedgerows

to the south of the A419 will be affected by the widening of the A419. Prior to the

carriageway widening, the hedgerows will be translocated 40m to the south of the original

alignment.

6 • Concept Design: the design was altered so the pitches to be delivered by the Revised

Scheme would be located solely for the use of FGR. This avoids the need for flood lighting,

and potential for effects on surrounding receptors such as residential properties and the

identified bat corridors (see RS Figure 5.3).

• Landscape Bund: a bund was introduced as illustrated on RS Figure 5.3 to reduce

potential effects in relation to noise, lighting and visual intrusion on neighbouring

properties but also ecological receptors. In particular this will allow for a bat commuting

corridor to provide commuting and foraging opportunities for bats while preventing light

spill.

• Parking: an increase of car parking spaces to 1,700 was made to comply with

Gloucestershire County Council Highways requirements. Capacity for 100 cycle spaces

will also be provided.

4.18 Through the key design iterations discussed in Table 4.1, RS Figure 1.1 the Indicative Concept

Plan has been developed. It includes the embedded mitigation within the design required to

reduce potential significant effects. However, the Concept Plan is still draft, and the final Revised

Scheme may still be subject to change at the Reserved Matters stage (within the parameters that

have been applied for).


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5 DESCRIPTION OF THE REVISED SCHEME

Introduction

5.1 This Chapter provides a description of the Revised Scheme. An indicative description of how the

Revised Scheme will be constructed and construction principles has also been provided. It is upon

this description, information and the supporting spatial plans that the technical assessments in

Chapter 7 – 17 are based.

Revised Scheme

5.2 The Revised Scheme seeks to provide replacement sports facilities for FGR. In order to meet the

club’s requirements moving forward, a sports complex is proposed which includes an innovative

centrepiece 5,000 capacity stadium designed by world-renowned architects Zaha Hadid, as well

as two additional full-size training pitches and goalkeeping training area to serve FGR. The pitches

will be grass, and none will be flood lit. The Revised Scheme is illustrated on RS Figure 1.1

Indicative Concept Plan.

5.3 The training pitches will be used primarily by the FGR first team who currently train at Stanley

Park, Chippenham, which is approximately 24 miles from the New Lawn. The proposals will allow

FGR to centralise its operations and will provide a ‘hub’ of activity.

5.4 The Redline Boundary remains the same as for the previous application submitted. However, all

development will now take place on land north of A419 and east of the M5 within the

Development Footprint only (on land previously allocated for the Green Technology Hub in the

initial submission). No development will take place to the south of the A419, however,

translocation of a hedge will occur on this land (as a result of road widening).

5.5 The Redline Boundary is approximately 39.5ha. The area that will form the new FGR site is

approximately 18.9ha with the highways improvement works 2.5ha. The Site is approximately

centred on National Grid Reference SO 77965 206584. RS Figure 1.2 shows the Site’s local

context and RS Figure 1.3 shows the Site’s context. The key components of the Revised Scheme

are listed in Table 5.1 (final amounts to be determined at Reserved Matters based on the

parameters set out in RS Figures 5.1, 5.2 and 5.3).

Table 5.1: Key Components of the Revised Scheme

Use Use

Class



Sports Complex 18.9ha

Stadium including ancillary facilities

designed for a capacity of 5,000

D2 To be determined at Reserved Matters. Form

and design of stadium is set out in the Design

and Access Statement.

Two full-sized grass pitches and a goal

practice area

D2 To be determined at Reserved Matters.

Car parking and associated infrastructure N/A To be determined at Reserved Matters.

Parking will be provided for 1,700 vehicles (lit

to previous arrangements, LED luminaries


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Use Use

Class



complete with street optics and including

sensors).

Access Works 2.5ha

Including: signalised site access off the A419;

full dualling of the A419 from M5 J13 to

Chipmans Platt; a signal controlled

pedestrian and cycle crossing of the A419

with a combined footway/ cycleway on the

south side of the A419 (which will link to

National Cycle Route 45 at Grove Lane).

N/A 2.5ha

5.6 FGR are currently based at The New Lawn in Nailsworth, Gloucestershire. The New Lawn was

built in 2006 and has a capacity for a crowd of just under 5,000. The ability of FGR to operate

sustainably is hindered by the location of The New Lawn, which is not readily accessible.

Nailsworth has no railway station (Stroud is the nearest) and is some nine miles from the Stroud

junction of the motorway. There is also a chronic lack of parking and facilities for fans.

Design Principles

5.7 The Revised Scheme aspires to be a green low carbon development, employing the very best,

innovative and most recent practices in;

• Sustainable construction;

• Innovative sustainable building design, orientation and landscape works, which have

excellent thermal performance, exceptional air-tightness with mechanical ventilation to

minimise heating/ energy demand, and unadopted highways to be constructed of KWS

Infra sustainable plastic roads;

• Sustainable operation through, for example, a site layout which creates a parkland

setting around the stadium itself.

• Creating a sustainable development by providing facilities for accessing the Site by public

transport, walking, cycling and the use of electric vehicles.

• Use of Green Infrastructure within the Revised Scheme and the retention and ecological

enhancements of woodlands and mature hedgerows wherever possible;

• Integration of species rich grassland into non-sporting areas throughout the site;

• Use of SuDs where practicable throughout the development;

• The adoption of best practice ecological management and enhancement for green

corridors.

5.8 Specific detailed design proposals will emerge from the evolution of the outline planning Concept

Design, and will be subject to Reserved Matters. The principal considerations for the Revised

Scheme design are outlined below. The principal benchmark used for the Revised Scheme will

be BREEAM with the aspiration for achieving the ‘outstanding’ standard. “BREEAM sets the

standard for best practice in sustainable building design, construction and operation and has

become one of the most comprehensive and widely recognised measures of a building's

environmental performance. It encourages designers, clients and others to think about low


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carbon and low effect design, minimising the energy demands created by a building before

considering energy efficiency and low carbon technologies.”8

5.9 It is anticipated that the finalised Revised Scheme will incorporate the following principal design

considerations (Table 5.2) set out through any subsequent Reserved Matters Applications.

Considerations are set out in relation to sustainable construction; sustainable building design

and landscape works; green travel plan (see Outline Travel Plan, RS Appendix 12.3); sustainable

operation; and best practice ecological creation, management and enhancement.

Table 5.2: Principal Design Considerations

Principal Design Considerations

Sustainable Construction

• Monitoring, recording and reporting energy, water and transport consumption data resulting from

all construction processes;

• The use of responsible sourcing for construction materials with a low environmental impact

(including embodied carbon) over the full life cycle of the building (e.g. source materials such as

timber from sustainable/ certified sources);

• The provision of a Site Waste Management Plans to design out waste, reduce waste generated on

site and implement procedures to sort and reuse/recycle construction waste on and off site;

• The use of re-used materials where possible, such as the use of recycled and secondary aggregates,

and the construction of unadopted roads with sustainable waste plastic;

• The use of thermal insulation which has a low embodied environmental impact relative to its

thermal properties and has been responsibly sourced;

• Sustainable procurement and the use local contractors where possible;

• Construction site operative awareness and training in sustainable practices;

• A detailed Construction Management Plan including a Pollution Prevention Plan, and the use of an

Environmental and /or Ecological Clerk of Works to maintain best practice procedures;

• Measures to protect ecological habitats including all important hedgerows and trees, and

establishment of a suitable buffer around identified protected species (such as the main badger

sett);

Sustainable Building Design and Landscape Works

• The Revised Scheme aspires be carbon neutral or carbon negative, by including measures such as

the provision of on-site renewable energy generation;

• Design of buildings to minimise operational energy demand, consumption and CO2 emissions (such

as use of appropriate insulation and meeting Passivhaus standards);

• Building design to ensure maximum use of natural daylight, limited use of artificial lighting (both

internal and external), utilise energy efficient lighting technology (such as the use of LEDs) and

sustainable occupant controls to minimise energy consumption;

• External lighting will be controlled through a combination of movement sensors, time switches

and daylight sensors to prevent operation during daylight hours. It will be concentrated in the

appropriate areas, and upward lighting will be minimised, reducing unnecessary light pollution,

energy consumption and nuisance to neighbouring properties. In addition, external lighting will: -

o Be designed to minimise horizontal spill of light to hedgerows and areas of restored

species-rich grassland;

o Avoid use of white- and ultra-violet light;

o Implement a dark period, when there is no lighting.

• Design buildings for robustness, recognising and encouraging adequate protection of exposed

elements of the building and landscape, therefore minimising the frequency of replacement and

maximising materials optimisation;

• Enhancement of areas around the buildings for ecological mitigation and enhancement (see

separate section below);

8 BREEAM’s on line resource available at http://www.breeam.org/about.jsp?id=66. Accessed on 30/09/15.


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• The proper integration, design and maintenance of SUDs throughout, which could include a

combination of: -

o Attenuation features and infiltration devices;

o Swales to store and/or convey runoff and remove pollutants;

o Infiltration basins/ vegetated depressions;

o Modular storage such as soakaways beneath communal parking areas and footpaths;

o Permeable paving for all parking areas and footpaths;

o Other inlets, outlets and control structures, including landscaped pipes, perforated pipes,

weirs, orifices, vortex control devices and spillways.

Green Travel Plan (see Outline Travel Plan, RS Appendix 12.3)

• The provision and compliance with a Green Travel Plan which will have examined all options for

sustainable travel to and from the Site. These might include: -

o Information and promotion of alternative green travel choices;

o Dedicated bus services;

o Minimisation of vehicular movements within the Site, and the incorporation of

pedestrian priority throughout the development (as noted on the Concept Design);

o Provision of electric charging points for electric vehicles including electric motorbikes and

bicycles;

o Safe dedicated priority cycle lanes, and plentiful, safe, sheltered, secure storage for

bicycles in proximity to destination, with supporting facilities such as lockers, changing

and showering;

o Footpaths to provide direct access to the stadium throughout, connect to PROW off site,

and link to local transport and other off-site amenities.

Sustainable Operation

• Life-cycle costing and service life planning in order to improve design, specification and through-

life maintenance and operation;

• Source energy from renewable energy sources, including the provision of on-site renewable

energy production (see above);

• Reduce the consumption of potable water for sanitary use in the stadium from all sources

through the use of water efficient components and water recycling systems, and ensure water

consumption can be monitored and managed. Leak detection systems will also be installed;

• Encourage procurement of energy-efficient equipment;

• Utilise the supply of heat from a system that minimises NOx emissions, and therefore reduces

pollution of the local environment;

• Provision of dedicated operational-related recyclable waste streams, so that this waste is

diverted from landfill or incineration;

• Encourage utilisation and participation in the EMAS (Eco-Management and Audit Scheme), a

voluntary initiative designed to improve companies’ environmental performance. The scheme

recognises organisations that go beyond minimum legal compliance and continuously strive to

improve their environmental performance, with requirement to produce publicly available

statements.

Best Practice Ecological Creation, Management and Enhancement – including integral Green

Infrastructure

• Development of a full Biodiversity Management Plan including avoiding clearance/works at key

times of the year (e.g. breeding seasons)

• Minimisation of the loss of ecological habitats (hedgerows, trees etc.);

• Ecological enhancement of existing habitat;

• Protection and enhancement for bats including bat friendly lighting throughout the Site, and the

creation of bat corridors;

• The creation of species rich parkland grassland using seed of local provenance;

• Planting of new native hedgerow and native trees throughout;

• Creation of linear orchards with local apple, pear and perry pear trees;

• Creation of flower-rich verges from locally sourced seed;

• Enhancement of the Site for invertebrates, particularly butterflies and bees;


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• Potential creation of new artificial badger sett (with cameras);

• Use of sustainable drainage throughout (see above);

• Creation of new ponds throughout the Site for birds, bats and invertebrates;

• Stock-proof fencing adjacent to A419 and cattle grids on the Site entrances to minimise deer

movement onto A419;

• On-going programme of monitoring and management, which will include conservation

management;

• The adoption of horticultural good practice (e.g. no, or low, use of residual pesticides);

• The installation of insect boxes at appropriate locations;

• Installation of nest boxes for Little Owl, Barn Owl and Swifts, and artificial Sand Martin nesting

towers;

• Installation of bat boxes and other bird nesting boxes on suitable trees throughout;

• Suitable interpretation throughout the Site.

Access

5.10 The principal vehicle access will be from a new traffic signal junction on the A419 east of the M5

Junction 13. The proposed layout for the access junction is shown in RS Figure 12.6 (Drawing

No. E191/04 Rev A). This includes the dualling of the A419 between the M5 J13 and Chipmans

Platt roundabout.

5.11 The provision of the access will result in the loss of the existing laybys on this section of the A419.

However, it has been agreed with Gloucestershire County Council that the laybys can be re-

provided on the A419 to the west of the M5 – on land under the ownership of the Highways

Authority.

5.12 The existing public footpath (Eastington Footpath 37) which crosses the A419 to the east of the

proposed access will be incorporated into a signalised pedestrian crossing, as part of the

signalised Site access, as indicated in RS Figure 12.6.

5.13 The proposed improvements also include a footway on the south side of the A419 from the

proposed Site access to Chipmans Platt, providing a link to Stonehouse, and on to Stroud via the

canal towpath.

5.14 A second vehicular access for buses/ coaches and emergency vehicles only is proposed from

Grove Lane, as indicated on the Concept Plan (RS Figure 1.1). This entrance will be gated when

not in use. It will enable buses serving the west of Stonehouse development to divert through

the Site on match days, without joining the main flow of traffic entering via the main entrance.

Coach parking will be provided on site for away coaches. Bus shelters will be provided within the

Site as required.

5.15 A pedestrian and cycle access will be provided adjacent to the bus access from Grove Lane, and

will be kept open to allow continued use of Eastington Footpath 38 as well as access to the

Stadium from the West of Stonehouse development. A footway will be continued along Grove

Lane to connect with the West of Stonehouse proposals. Crossing points will be located to the

north of the proposed entrance on Grove Lane, and at Nupend.

5.16 Within the Site, the area around the Stadium will be vehicle free during matches, as indicated on

the Concept Plan (RS Figure 1.1).


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5.17 Following discussions with Gloucestershire County Council regarding the Revised Scheme, a total

of 1,700 parking spaces are included to cater for the 5,000 capacity Stadium. Electric vehicle

charging points will be provided within the parking area.

5.18 Up to 100 cycle parking spaces will be available initially, with scope to increase this number if

demand requires.

Parameter Plans

5.19 RS Figures 5.1 to 5.3 provide details of the elements in Table 5.1 for which outline planning

permission is sought. Specifically, RS Figure 5.1 Building Height Parameter Plan takes into

account the varying needs of the surrounding local environment and has been largely governed

by the assessments undertaken from both the cultural heritage and landscape and visual

chapters of the EIA submitted with the application.

5.20 With regards to the Revised Scheme, the RS Figure 5.1 indicates that the maximum height of any

built development in the area will be up to 19.5m. This is largely a result of the scale of the

stadium, although given that the application is currently in outline form, the actual location is

not yet finalised. However, within the ES, the assessments have been undertaken based on RS

Figure 1.1 Indicative Concept Plan, and the parameters set within RS Figure 5.1.

5.21 RS Figure 5.2 Land Use Parameter Plan illustrates the information presented in Table 5.1, whilst

RS Figure 5.3 Indicative Green Infrastructure Parameter Plan illustrates the proposed Green

Infrastructure strategy for the Site. Further details are also provided in RS Appendix 8.5.

Indicative cross sections of the Site are provided in RS Figure 5.5.

Construction

5.22 The planning application is in outline form with all matters reserved save for access. The

necessary access works for the Revised Scheme as discussed at the beginning of this chapter are

being applied for in full. As such, the future development of the Site will be dependent on

subsequent Reserved Matters Applications. It is anticipated that should planning permission be

granted, Reserved Matters Applications would be submitted within two years and construction

starting within a year following approval. For the purpose of the ES the following sequence has

been assumed.

• Phase A: Highways improvements.

• Phase B: Stadium, outdoor training pitches, landscape works

Pre-construction Phase

5.23 Prior to the main construction contract commencing, a number of enabling works will be

undertaken, including geotechnical investigations of the Site, sufficient to facilitate the

development of detailed designs, and the production of a detailed Construction Environmental

Management Plan. There are further details in relation to construction that will require pre-

construction work, and these are outlined within the Technical Chapters 7-17 as they are

considered important mitigation for reducing the residual effect of the Revised Scheme.


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Construction Phase

5.24 A series of assumptions have been made to the construction proposals including the following:

• Anticipated construction activities;

• Haulage routes;

• Construction traffic timings and frequency;

• Traffic management requirements (including the sourcing of local construction materials);

• Construction compound location;

• Temporary drainage solution;

• Foundation solutions;

• Site working hours and days;

• Construction employment (including the sourcing of local labour);

• Site Management Plan;

• Trees within the Redline Boundary.

Anticipated construction activities

5.25 The following provides an outline timetable of the expected aspects of construction and when

they will be completed in relation to the Revised Scheme.

Table 5.3 Anticipated Construction Activities

Sequence Activities

1 - Site activities; site set up fencing and gates; site compound set up; start on site; dualling

to commence.

- Plant anticipated; minimal plant anticipated.

2 - Substructure; Site Strip; Top soil strip and store; Drainage Works; Form site

infrastructure, roads and services; Piling / Vibro compaction Operations; Excavate,

Concrete Bases / footings; Services Ducts and drainage.

- Plant anticipated; Large Rotary Bored Piling Rig; Dumpers, Earth Moving Plant;

Compressor Generators; Tracked Excavators; Dozer; Dump Truck; Tracked Mobile Crane;

Water Pump.

3 - Superstructure works; Structural Steel installation; In situ concrete; Roof/ Wall Cladding;

Brick / Block walling; Rainwater Goods; Internal Services installation; Secondary

Steelwork; PCC Installation and Barriers; Spectator Seating; Roof Sheeting / Cladding;

Internal Walls; Windows / Curtain Walling / Doors; Rainwater goods / Signage; dualling

anticipated to be completed.

- Plant anticipated; Tracked Mobile Crane; Dumpers, Earth Moving Plant; Compressor

Generators; Cement Mixers; Concrete Mixer Truck; Lifting Platforms; Mobile Telescopic

Crane.

4 - Superstructure works; Structural Steel installation; In situ concrete; Roof/ Wall Cladding;

Brick / Block walling; Rainwater Goods; Internal Services installation; Secondary

Steelwork; PCC Installation and Barriers; Spectator Seating; Roof Sheeting / Cladding; -

the main super structure is proposed to be in Glue – laminated timber. There will be

minimal steel at the superstructure level probably in terms of secondary steel work and

joints. The roof is stretched fabric. Minimal block work. Currently no brickwork

anticipated. Internal Walls; Windows / Curtain Walling / Doors; Rainwater goods /

Signage. Plant anticipated; Lifting Platforms; Mobile Telescopic Crane; Compressor

Generators.


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Sequence Activities

5 - External works; Drainage; Service Trenches; Car Parks and Access Roads; Landscaping.

External fittings & fixtures in terms of bollards / lights.

- Plant anticipated; Dumpers Earth Moving Plant; Tracked Excavators; Compressor

Generators; Tarmac Machinery.

5.26 Indicative construction activities are anticipated to be as per Table 5.3. Final timescales and

construction activities are likely to be agreed pending Reserved Matters Applications.

Haulage routes

5.27 The majority of construction traffic is expected to be routed via the A419, M5 and A38 to the

west of the Site, identified for HGV traffic on the Gloucestershire Advisory Freight Route Map

(See Appendix O within the TA which forms RS Appendix 12.1 of this ES).

Construction traffic timings and frequency

5.28 The selection of construction vehicles and the numbers of vehicular trips which are required will

depend on the size and number of vehicles operated by the contractor. Appropriate controls will

be implemented to ensure the safety of other road users and to protect the environment.

5.29 When considering possible size restrictions for vehicles which would be in daily use, the key

vehicles would be the tipper trucks used for moving materials arising from preparation of the

Site and, in the later stages of construction, the delivery of bulky items by articulated lorry.

Specialised items such as low-loaders to deliver construction plant and other machinery would

need to be considered on an individual basis and would be dependent on both the form of

construction to be adopted and the programme.

5.30 It has been assumed that the majority of construction deliveries and collections to the Site will

occur outside the prevailing traffic peak periods on a weekday and weekend. However, for the

purpose of assessing a worst-case scenario, the following traffic flows have been assumed for

peak periods:

• 260 car movements daily (i.e. 130 in, 130 out).

• 100 HGV movements daily (i.e. 50 in, 50 out). This equals 4.5 HGV’s in and out per hour

into the Site assuming an 11-hour day or 1 every 15 minutes.

Traffic management requirements

5.31 Mitigation of the effects of construction will be achieved through controls imposed by planning

conditions, health and safety requirements and good construction site practices. The mitigation

measures to address the transport effects associated with the construction of the Revised

Scheme will be co-ordinated and implemented by means of a Construction Traffic Management

Plan which can be secured by a planning condition. Measures are likely to include:

• Appropriate signing of the delivery route to ensure vehicles use the approved route to and

from the Site

• Warning signs for vehicles and pedestrians as appropriate

• Co-ordination of delivery times to ensure that as far as possible deliveries take place

outside peak periods


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• Layout of site to allow adequate space for goods vehicle manoeuvring and ensure that

vehicles are not required to wait on the public highway

• Temporary traffic management for short periods if delivery of oversized loads may cause

obstruction to the public highway

• Design of the Site access to ensure that vehicles have appropriate visibility upon leaving

the Site

• Wheel washing facilities for vehicles leaving the Site, and road sweeping when necessary

5.32 During construction, particular restrictions in relation to Public Rights of Ways may be required

for pedestrians in the vicinity of the Site in order to ensure their safety. When such restrictions

are needed the correct legal process will be followed as necessary.

5.33 In relation to on-site access, a traffic system will be designed and detailed in a Traffic

Management Plan (within the Construction Environmental Management Plan). It will also detail

the maximum size of vehicles, appropriate routes, and appropriate delivery timings in line with

the text above. Appropriate controls will be implemented to ensure the safety of other road

users and to protect the environment.

5.34 It is anticipated that where required, material will be attempted to be sourced locally. No

material will be moved off site as it will be used as part of the landscape works.

Construction Compound location

5.35 During the construction period, a temporary construction compound will be required. At this

point in time, it is not known exactly where the compound will be located on site given the outline

nature of this application. Prior to construction starting a plan will be provided to the Local

Planning Authority (LPA) as to where the compound will be located for their approval. This can

be secured via a planning condition and the Construction Environmental Management Plan.

However, RS Figure 5.4 Indicative Construction Compound Locations indicates areas of the Site

where a construction compound could be located. This plan has been taken into account within

each of the technical assessments in relation to potential construction effects.

5.36 The compound will be surrounded by hoarding to reduce any potential visual effects and security

lighting will be designed in accordance with a lighting design strategy in conjunction with the

ecologists to ensure suitable bat mitigation is incorporated. It will be in use for the duration of

the works and will require an area of approximately 0.3 ha. This will be confirmed when a plan

of the location of the construction compound is submitted for LPA approval.

5.37 It is anticipated that the compound will comprise of a hardstanding area and will provide space

for:

• Temporary porta cabins/ parking for site offices and welfare facilities for contractors;

• Containers used for tool and equipment storage;

• Storage of construction vehicles when not in use;

• Storage of components and material including fuels, lubricants and oils.

Temporary drainage solution


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5.38 Surface water management during the Site preparation, earthworks and construction phase will

include measures to remove silt, sediment and debris and to attenuate surface water runoff prior

to controlled discharge to the drain network. This is discussed further within both Chapter 8 and

Chapter 9 of the ES. As part of the construction phase, mitigation is proposed to ensure no

significant effect.

Foundation solutions

5.39 For the purposes of the ES it has been assumed that surcharge may be required across the Site.

This is the temporary process by which additional material is added to the Site and existing

moisture levels are reduced. A piling foundation solution has been assumed across the Site within

the area of built development. The piles will be driven to the required depth using conventional

pile driving equipment.

Site working hours and days

5.40 It has been assumed for the purposes of this ES that working hours for site construction activities

will be as follows:

• 07:00 and 18:00hrs Monday to Friday;

• 08:00 and 13:00 on Saturdays;

• Other hours by exception and with the prior agreement of the LPA.

Construction employment

5.41 It is estimated that the Revised Scheme will result in approximately 120 full time equivalent jobs

within the construction sector during a 12-month construction period (see Chapter 11 for further

information). Where possible, labour will be sourced locally.

Site Management Plan

5.42 Detailed Site Management Plans will be prepared as part of the Construction Environmental

Management Plan (CEMP) by the Contractor in advance of construction. Task specific risk

assessment will be carried out for each work activity and detailed method statements prepared

to control the operation and to ensure that all concerned are aware of safety and environmental

hazards associated with the work and the precautions to be taken. These will refer to:

• Details on working boundaries for the work activity;

• Details on the order and method of construction for the work activity with reference to

work procedures;

• The planned measures to reduce the risk identified;

• Information on material being used, plant, labour and any temporary works requirements;

• Site constraints that affect the works activity and how they will be dealt with e.g. pollution

prevention methods, noise, by-pass channels, over pumping etc.;

• The quality requirements for the item of work;

• Focus on protected species: otters, water vole, great crested newt, etc.

• Compliance with all legal frameworks in force at the time.

Trees within Redline Boundary

5.43 An Arboricultural Report has been undertaken as part of the planning application submission,

showing tree locations, canopy sizes and classification with an accompanying tree schedule


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within the Redline Boundary. A Tree Constraints Plan has also been included as part of the

planning submission and this ES (see RS Appendix 8.3).

Post-construction Phase

5.44 All reinstatement works, landscape mitigation and enhancement measures including grass

seeding, native tree planting and shrub planting will be carried out upon completion of

construction. The Principal Contractor will be responsible for the reinstatement works arising

from construction operations.


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6 PLANNING POLICY CONTEXT

Introduction

6.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 places a requirement upon

Authorities when determining planning applications to do so in accordance with the adopted

Development Plan unless material considerations indicate otherwise.

6.2 The Development Plan relevant to the Site comprises the Stroud District Local Plan9 (adopted

November 2015) and the Eastington Neighbourhood Development Plan 2015-203110 (made in

October 2016). Material considerations include the National Planning Policy Framework (NPPF)11

and the associated National Planning Practice Guidance (PPG)12, as well as the Stroud Local Plan

Review13.

6.3 This chapter considers the planning policies from the Development Plan, along with any material

considerations relevant to the determination of the application, before summarising the

planning balance as set out within the Planning Statement (submitted as part of the suite of

documentation supporting the Revised Scheme). RS Appendix 6.1 provides full details of the

relevant planning policies to the Revised Scheme, whilst RS Appendix 6.2 provides a list of

proposed draft planning conditions for the Revised Scheme.

Development Plan

Stroud District Local Plan

6.4 The Local Plan relates to the whole District and provides a strategy for delivering growth for

Stroud District up to 2031. The document provides the vision, objectives and strategic policies

for delivering new homes, jobs, services, facilities and infrastructure. Section 1 of RS Appendix

6.1 provides the policies of the Local Plan considered most relevant to the determination of the

Revised Scheme.

Eastington Neighbourhood Development Plan

6.5 The Neighbourhood Plan has been designed to closely follow and be in conformity with the

Stroud District Local Plan. The settlement boundaries in the Neighbourhood Plan are closely

aligned to those defined in the Local Plan. These reflect the strategic growth options in the Local

Plan. Section 2 of RS Appendix 6.1 provides the policies of the Neighbourhood Plan considered

most relevant to the determination of the Revised Scheme.

9 The Stroud District Local Plan available from https://www.stroud.gov.uk/media/1455/stroud-district-local-

plan_november-2015_low-res_for-web.pdf accessed on 27th November 2017. 10 Eastington Neighbourhood Development Plan available from http://eastington-pc.gov.uk/wp-

content/uploads/2016/08/Eastington-NDP-Adopted-Version-Oct-2016.pdf accessed on 27th November 2017. 11 National Planning Policy Framework (2012) available from

http://www.stroud.gov.uk/info/plan_strat/newlocalplan/PLAIN_TEXT_Local%20Plan_Adopted_November_2015.pd

f accessed on 12th December 2015. 12 Planning Practice Guidance (2014) available from http://planningguidance.communities.gov.uk/blog/guidance/

accessed on 12th December 2015. 13 Stroud Local Plan Review available from https://www.stroud.gov.uk/environment/planning-and-building-

control/planning-strategy/stroud-district-local-plan-review accessed on 27th November 2017.


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Planning policy documents that comprise ‘material considerations’

National Planning Policy Framework (NPPF)

6.6 The NPPF sets out Government planning policies for England and how these are expected to be

applied. Paragraph 14 of the NPPF states that the purpose of the planning system is to contribute

to the achievement of sustainable development and that a presumption in favour of sustainable

development is at the heart of the NPPF. For decision taking this means:

• Approving development proposals that accord with the development plan without delay;

and

• Where the development plan is absent, silent or relevant policies are out of date, grant

planning permission unless:

o Any adverse effects of doing so would be significant and demonstrably outweigh

the benefits, when assessed against the policies in the framework as a whole; or

o Specific policies in the framework indicate development should be restricted.

6.7 Furthermore, Paragraph 7 of the NPPF sets out the three dimensions to sustainable

development; economic, social and environmental. With regards to the economic dimension it

states that the planning system is required to ‘contribute to building a strong, responsive and

competitive economy, by ensuring that sufficient land of the right type is available in the right

places at the right time to support growth and innovation’.

6.8 It is considered that the Revised Scheme will meet the dimensions of sustainable development

as set out by the NPPF. Section 3 of RS Appendix 6.1 provides a summary of the sections and

paragraphs considered most relevant to the determination of the Revised Scheme.

National Planning Practice Guidance (PPG)

6.9 PPG acknowledges that open space, which includes all open space of public value, can take many

forms, from formal sports pitches to open areas within a development, linear corridors and

country parks. It can provide health and recreation benefits to people living and working nearby;

have an ecological value and contribute to green infrastructure, as well as being an important

part of the landscape and setting of built development, and an important component in the

achievement of sustainable development (Paragraph: 001 Reference ID: 37-001-20140306).

Stroud Local Plan Review

6.10 The District Council is now starting the process of reviewing the current Stroud District Local Plan.

The first stage is the Issues and Options, which is currently going through consultation. Given

the early stage of the review, very limited weight can be given to the Issues and Options at this

stage; however, it indicates possible directions of travel for the Local Plan.

6.11 The site, as well as land to the south of the A419, has been identified as a potential ‘broad

location for future growth’ (reference STO D) for employment, open space and community

uses.

Planning Balance


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6.12 The key policies relating to the principle of development within the adopted Development Plan

are Core Policy 15 and Delivery Policy EI11. There are no policies relating to sports provision

within the Neighbourhood Plan.

6.13 Core Policy CP15 generally seeks to restrict all new developments outside of identified

settlement boundaries. It is considered that the application proposal is consistent with the two

criteria and all other qualifying criteria of the policy. Therefore, whilst the Revised Scheme falls

outside of an identified settlement boundary, it is considered to be consistent with the policy

when read as a whole. The Revised Scheme does not conflict with the purposes of the policy

which is designed at protecting the separate identity of settlements, avoiding coalescence and

ensuring that new development is located sustainably.

6.14 Despite this minor conflict (being outside of a settlement boundary), there is a need for Forest

Green Rovers (FGR) to improve its facilities to enable it to continue to develop. There are no

alternative sites available within the District where this can be achieved; Chapter 4 of this ES,

along with the supporting Planning Statement provide further information over the search for

alternative sites. Policy EI11 supports the provision of sports facilities and it is clear from the

Planning Statement that the proposal is fully compliant with all aspects this policy.

6.15 Overall, the proposals will provide facilities for FGR which will allow the club to continue to

develop, an urgent matter as a result of its promotion into League 2. The existing stadium is

constrained, and the proposals reflect FGR aspirations for long-term, sustainable growth to

provide a hub, combining the new stadium with a range of training facilities for the first team.

The site is in an accessible and sustainable location for both players and fans of FGR and the

proposal is essential for FGR’s continued development. This is a material consideration which

should be given significant weight in the determination of the application.

6.16 It has also considered that the Revised Scheme constitutes sustainable development, providing

net gains across all three dimensions set out within the NPPF. At the heart of the NPPF is a

presumption in favour of sustainable development. For decision-taking this means approving

development proposals that accord with the development plan without delay. Whilst there is

some minor conflict with CP15, the proposal is consistent with the purpose of this policy and is

supported by the Local Plan objectives in general and particularly Policy EI11.

6.17 It is considered that the proposal is consistent with the Development Plan when read as a whole.

Furthermore, the proposal is fully consistent with the NPPF and Sport England’s guidance, and

as such is acceptable in planning policy terms.


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7 ARCHAEOLOGY AND CULTURAL HERITAGE

Summary

7.1 Several phases of survey and assessment have been carried out to fully inform the following

chapter on ‘Archaeology and Cultural Heritage’. This has included historical research, inspection

of the Site and wider landscape, geophysical survey and archaeological trial trenches. This

approach has allowed a proportionate level of information to be collected on the heritage assets

of the Site and its locale, and enabled an informed assessment to be made on any effects that

the development may have. This approach is in accordance with Paragraph 128 of the NPPF14,

regarding levels of information accompanying an application.

7.2 The proposals align with the Council’s Strategic Assessment of Land Availability report15 for area

EAS 007 (which comprises the present Redline Boundary) which states that “land to the north of

the A419 has no significant heritage constraints.”

7.3 No development will take place within the Stroud Industrial Heritage Conservation Area (IHCA),

or in its immediate vicinity. The Revised Scheme will not harm the significance of the IHCA, and

adheres to the Five Priorities and accompanying Management Proposals of the IHCA

Supplementary Planning Document (SPD)16. The only archaeological remains of significance

within the Redline Boundary comprise those of the Roman ‘Whitminster’ villa. The Revised

Scheme has ensured that these remains are removed from the areas of built development, and

that no built development is near them. It has been agreed in consultation with the

Gloucestershire County Council (GCC) archaeology officer that mitigation works may suitably

form a condition of any planning application.

7.4 The Revised Scheme will not lead to any significant harm to any other designated heritage assets

through changes to their setting. A very small degree of harm (the lower end of ‘less than

substantial harm’) would be occasioned to the heritage significance of the Grade II listed

Westend Farmhouse and Mulgrove, both on Grove Lane. No other designated heritage assets

will be harmed.

7.5 It is concluded that the Revised Scheme will lead to no significant heritage harm in

Environmental Impact Assessment (EIA) terms.

Introduction

7.6 This chapter of the Environmental Statement considers the likely significant effects of the

Revised Scheme on heritage assets. The chapter describes the assessment methodology; the

baseline conditions within the Site and its environs; the likely significant environmental effects

upon identified and potential heritage assets; the mitigation measures required to prevent,

reduce, or offset any significant adverse effects; potential enhancement measures; and the likely

residual effects after these measures have been employed.

7.7 The chapter assesses both potential physical effects and non-physical effects upon heritage

assets.

14 Department for Communities and Local Government (2012) National Planning Policy Framework 15 Stroud District Council 2017 Strategic Assessment of Land Availibility 16 Stroud District Council 2008 The Industrial Heritage Conservation Area Management Proposals


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7.8 The chapter is informed by a range of archaeological and heritage work which is held in the

following Technical Appendices: -

• RS Appendix 7.1: Heritage Assessment

• RS Appendix 7.2: Geophysical Survey

• RS Appendix 7.3: Evaluation Trial Trenches

• RS Appendix 7.4: Written Schemes of Investigation

• RS Appendix 7.5: Key Consultation Responses (from original application)

7.9 The survey work has been designed to fulfil the requirements set out in Paragraph 128 of the

National Planning Policy Framework (the NPPF), which states that “In determining applications,

local planning authorities should require an applicant to describe the significance of any heritage

assets affected, including any contribution made by their setting. The level of detail should be

proportionate to the assets’ importance and no more than is sufficient to understand the

potential impact of the proposal on their significance”.

7.10 This chapter addresses an area of land defined on RS Figures 7.1 and 7.2 and referred to as the

‘Redline Boundary’. This includes land which will be developed, and land which will not (as

described in Chapters 3 and 5). The land to the north of the A419 where development will take

place is referred to as the ‘Development Footprint’. Assessment work has specifically addressed

this proposal. Reference is also made to the original application and development proposal that

was made in January 2016, referred to as the ‘original application’. These include advice from

the Gloucestershire County Council (GCC) archaeology officer; the Stroud District Council (SDC)

Conservation Officer; and Historic England. Key communications from these consultees are

provided in RS Appendix 7.5 for convenience.

Legislation, Policy and Guidance

Heritage Statute

7.11 This chapter has been prepared within the following key heritage statutes: -

• Ancient Monuments and Archaeological Areas Act 197917;

• Planning (Listed Buildings and Conservation Areas) Act 199018;

• National Heritage Act 198319.

7.12 The Ancient Monuments and Archaeological Areas Act 1979 pertains to the protection of

Scheduled Monuments. It refers explicitly to the monument itself, and does not, for example,

refer to the ‘setting’ of Scheduled Monuments.

7.13 Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 notes (regarding

Listed Buildings) that a decision maker “shall have special regard to the desirability of preserving

the building or its setting or any features of special architectural or historic interest which it

possesses”.

17 Ancient Monuments and Archaeological Areas Act, 1979 18 Planning (Listed Buildings and Conservation Areas) Act, 1990 19 National Heritage Act, 1983


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7.14 Section 72 of the same Act notes that “with respect to any building or other land in a conservation

area…(2), special attention shall be paid to the desirability of preserving or enhancing the

character or appearance of that area”. It should be noted that this requirement of the Act refers

explicitly to buildings or land ‘in’ a Conservation Area, not outside.

National Heritage Policy

7.15 Regarding National heritage policy this chapter has been compiled within the context of the

NPPF. Relevant policies regarding heritage are set out in Paragraphs 126 – 141 of the NPPF.

7.16 The NPPF defines heritage assets as “a building, monument, site, place, area or landscape

identified as having a degree of significance meriting consideration in planning decisions, because

of its heritage interest. Heritage asset includes designated heritage assets and assets identified

by the local planning authority (including local listing)”.

7.17 Designated heritage assets comprise World Heritage Sites, Scheduled Monuments, Listed

Buildings, Protected Wreck Sites, Registered Parks and Gardens, Registered Battlefields, and

Conservation Areas. Within this category, the NPPF (Paragraph 132) identifies designated

heritage assets ‘of the highest significance’, which comprise Scheduled Monuments, Protected

Wreck Sites, Battlefields, Grade I and II* Listed Buildings, Grade I and II* Registered Parks and

Gardens, and World Heritage Sites. Non-designated heritage assets comprise all other heritage

assets which have a degree of significance meriting consideration in planning decisions.

Development Plan Policy

7.18 The Development Plan for the district comprises the Stroud District Local Plan November 201520.

The Local Plan sets out the Council’s policies for the historic environment. Policy ES10 references

‘Valuing our Historic Environment and Assets’.

7.19 Part 1 of the Policy essentially addresses the requirement of Paragraph 128 of the NPPF (see

above), and requires the significance of heritage assets affected to be described, as well as the

impact of the development. This may include desk-assessment, field evaluation, and should

utilise the Historic Environment Record. These provisions have been addressed in the present

application.

7.20 Part 2 of the Policy notes that “Proposals and initiatives will be supported which conserve and,

where appropriate, enhance the heritage significance and setting of the District’s heritage

assets”. Parts 3 and 4 similarly note that proposals which preserve/ enhance local heritage assets,

and key views, will be supported. Part 5 notes that “any harm or loss would require clear and

convincing justification to the relevant decision-maker as to why the heritage interest should be

overridden.” This requirement is aligned, broadly, to Paragraph 134 of the NPPF which states that

harm which is less than substantial “should be weighed against the public benefits of the

proposal”.

Assessment Methodology and Significance Criteria

7.21 The detailed methodologies of the different elements of heritage work are set out in the relevant

RS appendices. A brief summary of the key elements is provided here.

20 Stroud District Council 2015 Stroud District Local Plan


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7.22 The EIA heritage work has been carried out by Cotswold Archaeology, a Registered Organisation

with the Chartered Institute for Archaeologists (CIfA). The work has been managed for Cotswold

Archaeology by Richard Morton, Principal Heritage Consultant, and a Member of CIfA. Mr

Morton is highly experienced in managing and carrying out EIA heritage assessment both in

Gloucestershire and across the country, with particular expertise in archaeological remains,

historic buildings and the historic landscape. He has been a professional archaeologist and

heritage consultant for 26 years.

Consultation

7.23 A consultation response for the Revised Scheme has been provided by the archaeological officer

at Gloucestershire County Council (provided in RS Appendix 7.5, dated 26 October 2017). In

summary, the officer has confirmed that “there would be no objection in principle to development

affecting those remains, with the proviso that a programme of archaeological investigation and

recording is undertaken, secured as a condition of any planning permission granted for this

scheme.” An appropriate programme of mitigation is set out in this chapter (‘Mitigation and

Enhancement Measures’, below). An appropriate draft Planning Condition has also been

provided at RS Appendix 6.2.

7.24 Historic England and the Council’s Conservation Officer provided consultation responses with

regard to the previous scheme (key ones of which are provided in RS Appendix 7.5).

Heritage Assessment: (RS Appendix 7.1)

7.25 The heritage assessment is informed by all of the heritage and archaeological works undertaken.

It includes detailed desk-based assessment, carried out in accordance with the Standard and

Guidance for Historic Environment Desk-Based Assessment provided by the Chartered Institute

for Archaeologists21. The documentary research included the key sources set out in Table 7.1

below.

Table 7.1: Heritage Assessment Data Sources

Source Data

Gloucestershire Historic

Environment Record

- Heritage sites and events records, Historic Landscape

Characterisation (HLC) data, and other spatial data supplied in

digital format (shapefiles) and hardcopy.

Historic England Archives - Additional sites and events records, supplied in digital and hardcopy

formats.

Gloucestershire Records

Office

- Historic mapping, historic documentation, and relevant published

and grey literature.

Historic England’s Aerial

Photograph Research Unit

- Vertical and oblique aerial photography ranging in date from the

1940s to present.

A History of the County of

Gloucester, Volume 10

- The Victoria County History (Westbury and Whitstone Hundreds)

Stroud District Council - The Industrial Heritage Conservation Area: Conservation Area

Statement, Part 1: Conservation Area Appraisal

- The Industrial Heritage Conservation Area Management Proposals:

Supplementary Planning Document

21 Chartered Institute for Archaeologists 2014 Standard and Guidance for Historic Environment Desk-Based

Assessment


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Source Data

LiDAR data - LiDAR imagery and point cloud data, available from the Environment

Agency website.

British Geological Survey

data

- UK geological mapping (bedrock & superficial deposits) & borehole

data.

Cranfield University’s LandIS

Soil Portal

- UK soil mapping.

7.26 The heritage assessment assessed the contribution that the Redline Boundary makes to heritage

assets beyond its boundaries, and any effects that the development may have on their

significance.

7.27 ‘Setting’ is not a heritage asset: it may, however, contribute to the value of a heritage asset. The

‘setting’ of a heritage asset is defined by the NPPF as “the surroundings in which a heritage asset

is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve.

Elements of a setting may make a positive or negative contribution to the significance of an asset,

may affect the ability to appreciate that significance or may be neutral.”

7.28 Guidance on assessing the effects of change upon setting and significance is provided in the

Historic England publication ‘The Setting of Heritage Assets: Historic Environment Good Practice

Advice in Planning: 3’22 (hereon referred to as GPA3), which was used in the heritage assessment.

The landscape around the Redline Boundary was examined in the field, and a photographic

record and written notes taken.

Study Area

7.29 The heritage assessment was informed by a suitable ‘Study Area’. With regard to ‘archaeological

remains’ the above sources were examined for both the Redline Boundary itself, and also land

beyond to provide context. A fixed ‘Study Area’ was not used. Rather, appropriate context was

examined for different elements of the historic environment. The CIfA Standard and Guidance

does not stipulate a particular size of ‘Study Area’ that should be utilised: rather, the ‘significance

and character’ of the Study Area should be examined, to inform the nature of potential change.

Data from sources including the Historic Environment Record and Historic England Archives was

gathered for at least a 1km area around the Redline Boundary.

7.30 It is with regard to potential non-physical effects of development that a ‘Study Area’ is of

particular relevance. The appropriate guidance on this is provided in ‘GPA3. GPA3 does not

advise a particular size of ‘Study Area’ that should be utilised. Rather, heritage assets which may

be affected by development should be identified (as part of Step 1) and their settings, and

potential development effects, assessed accordingly. This has been carried out in the RS

Appendix 7.1 Heritage Assessment. All designated heritage assets within 2km distance of the

Redline Boundary were assessed in order to identify if their significance might be affected by

development.

Geophysical Survey (RS Appendix 7.2)

22 Historic England 2015 The Setting of Heritage Assets: Historic Environment Good Practice Advice in Planning 3


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7.31 The geophysical survey was carried out with a Bartington Grad 601-2 instrument. This is a high-

resolution fluxgate gradiometer, used for measuring small variations in the magnetic field caused

by hidden features underground. Traverse Intervals of 1m and Sample Intervals of 0.25m were

used. Data processing was carried out using GeoSuB software, with Zero Mean Traverse step

correction and interpolation. These are industry-standard methods of processing the raw survey

data, to allow interpretation of potential archaeological features. The survey was carried out by

Sumo GSB Prospection Ltd., a specialist geophysical surveyor. The survey was carried out 24-28

August and 28-29 September 2015.

7.32 The survey was carried out in accordance with the Historic England guidance ‘Geophysical Survey

in Archaeological Field Evaluation’23.

Evaluation Trial Trenches (RS Appendix 7.3)

7.33 The archaeological evaluation comprised the excavation of some 82 trial trenches, each

measuring 1.8m in width and 50m in length. The evaluation was carried out in accordance with

a Written Scheme of Investigation (RS Appendix 7.4) approved by the archaeology officer at GCC.

The evaluation was carried out in accordance with the ‘Standard and Guidance: Archaeological

Field Evaluation’ issued by the Chartered Institute for Archaeologists24.

Heritage Asset Significance (EIA Sensitivity of Receptor)

7.34 Significance (for heritage policy) is defined in the NPPF (Annex 2) as “the value of a heritage asset

to this and future generations because of its heritage interest. That interest may be

archaeological, architectural, artistic or historic. Significance derives not only from a heritage

asset’s physical presence, but also from its setting”.

7.35 The NPPF identifies designated heritage assets ‘of the highest significance’, namely Scheduled

Monuments, Protected Wreck Sites, Battlefields, Grade I and II* Listed Buildings, Grade I and II*

Registered Parks and Gardens, and World Heritage Sites.

7.36 Current national guidance for the assessment of the significance of heritage assets is based on

criteria provided by Historic England (formerly English Heritage) in ‘Conservation Principles,

Policies and Guidance for the Sustainable Management of the Historic Environment’25.

Significance is weighed by consideration of four forms of value: historic; evidential; aesthetic;

and communal.

7.37 Table 7.2 below sets out the criteria for assessing heritage asset significance. This table is guided

by the criteria included in HA 208/07. The NPPF also identifies designated heritage assets of ‘the

highest significance’, notably Scheduled Monuments, Registered Battlefields, Grade I and II*

Listed Buildings, Grade I and II* Registered Parks and Gardens and World Heritage Sites.

Table 7.2: Heritage Asset Significance

Heritage Asset Value

Description

23 Historic England 2008 Geophysical Survey in Archaeological Field Evaluation 24 Chartered Institute for Archaeologists 2014 Standard and Guidance: Archaeological Field Evaluation 25 English Heritage 2008 Conservation Principles Policies and Guidance for the Sustainable Management of the Historic

Environment


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High

Designated heritage assets of ‘the highest significance’ as described

in NPPF Paragraph 132. Includes Scheduled Monuments, Protected

Wreck Sites, Battlefields, Grade I and II* Listed Buildings, Grade I

and II* Registered Parks and Gardens, and World Heritage Sites.

Also, non-designated heritage assets of demonstrably equivalent

significance

Medium

Designated heritage assets not defined by the NPPF as ‘of the

highest significance’. Includes Grade II Listed Buildings and

Conservation Areas

Also, non-designated heritage assets of demonstrably equivalent

significance

Low

Non-designated heritage assets

Negligible

Elements of the historic environment that have insufficient

heritage value to comprise ‘heritage assets’

The scale of harm or benefit (EIA magnitude of effect)

7.38 The heritage works undertaken in support of this chapter have looked closely at the particular

values of heritage assets, and in particular the concept of ‘what matters and why’ set out in GPA3.

The magnitude of effect of development upon designated heritage assets is expressed with

reference to heritage planning policy, and ‘harm’ and ‘benefit’, set out in the NPPF, as

summarised in Table 7.3 below.

Table 7.3: Assessment of Magnitude of Effect on Designated Heritage Assets

Heritage

Magnitude of

Effect

Description

Note regarding statute and policy

Benefit The proposals would better

enhance or reveal the heritage

significance of the designated

heritage asset.

Enhancing or better revealing the significance of a

designated heritage asset is a desirable

development outcome in respect of heritage. It is

consistent with key policy and guidance, including

the NPPF (2012) Paragraphs 126 and 137

No effect The proposals would preserve

the significance of the

designated heritage asset

Preserving a Listed Building and its setting is

consistent with s66 of the Planning (Listed

Buildings and Conservation Areas) Act (1990).

Preserving or enhancing the character or

appearance of a Conservation Area is consistent

with s72 of the Act.

Sustaining the significance of a designated

heritage asset is consistent with Paragraph 126 of

the NPPF, and should be at the core of any material

local planning policies in respect of heritage.

Less than

substantial

The proposals would be

anticipated to result in a

restricted level of harm to the

In determining an application, this level of harm

should be weighed against the public benefits of

the proposals, as per Paragraph 134 of the NPPF

(2012).


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Heritage

Magnitude of

Effect

Description

Note regarding statute and policy

harm – lower

half


heritage asset, such that the

asset’s contributing heritage

values would be largely

preserved

Proposals involving change to a Listed Building or

its setting, or any features of special architectural

or historic interest which it possesses, or change

to the character or appearance of Conservation

Areas, must also be considered within the

context of Sections 7, 66(1) and 72(2) of the 1990

Act. The provisions of the Act do not apply to the

setting of Conservation Areas.

Proposals with the potential to physically affect a

Scheduled Monument (including the ground

beneath that monument) will be subject to the

provisions of the Ancient Monuments and

Archaeological Areas Act (1979); these provisions

do not apply to proposals involving changes to the

setting of Scheduled Monuments.

Less than

substantial

harm – upper

half

The proposals would lead to a

notable level of harm to the


heritage asset. A reduced, but

appreciable, degree of its

heritage significance would

remain

Substantial

harm

The effect is so serious that the

significance of the heritage

asset is removed altogether or

very much reduced

Paragraphs 132 and 133 of the NPPF (2012) would

apply. Sections 7, 66(1) and 72(2) of the Planning

Act (1990), and the Ancient Monuments and

Archaeological Areas Act (1979), may also apply

7.39 The NPPF (Paragraph 135) requires the magnitude of effect of an application on a non-

designated heritage asset to be defined as ‘the scale of any harm or loss’.

7.40 Combining the magnitude of effect on the heritage significance of the heritage asset provides

the significance of effect of development.

7.41 The NPPF (Paragraph 132) identifies ‘substantial harm’ as a key consideration in the effects of

development, and it is clear that effects leading to this level of harm are ‘significant’. Effects of

less than substantial harm may also be ‘significant’ if they lead to a notable level of harm, such

as would impair future appreciation or understanding of a heritage asset. Thus, for the purposes

of this ES, effects which lead to ‘substantial harm’ or ‘the upper half of less than substantial harm’

are considered EIA ‘significant effects’.

7.42 The NPPF (Paragraph 135) requires the effect of an application on a non-designated heritage

asset to be considered and expressed in terms of:

• The scale of any harm or loss (EIA magnitude of effect)

• The significance of the heritage asset (EIA sensitivity of the receptor)

Baseline Conditions

Designated heritage assets

7.43 Designated heritage assets assessed as part of the heritage works are summarised in Table 7.4

below, and illustrated on RS Figure 7.1.

Table 7.4: Designated heritage assets


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Reference Heritage asset Designation Heritage

Significance

D1 Stroud Industrial Heritage

Conservation Area

Conservation Area Medium

D2 Grove Farmhouse Grade II listed Medium

D3 Westend Farmhouse Grade II listed Medium

D4 Mulgrove Grade II listed Medium

D5 Milestone Grade II listed Medium

D6 Nupend Court Grade II listed Medium

D7 The Nestings and Sundial Grade II listed Medium

D8 Rose Tree Cottage Grade II listed Medium

D9 Nupend House Grade II listed Medium

D10 Oldbury House Grade II listed Medium

D11 Nastend House and barn Grade II* listed

(house)

Grade II listed (barn)

High and Medium

D12 Somerlea Grade II listed Medium

D13 Nastend Green Farmhouse and

stables and barn

Grade II listed Medium

D14 Nastend Farmhouse Grade II listed Medium

D15 Oldend Farmhouse Grade II listed Medium

D16 Blunder Lock, Spill Weir and

Boundary Markers


D17 Newtown Lock, Spill Weir And

Boundary Markers


D18 The Gatehouse at Bonds Mill Grade II listed Medium

D19 Little Court and The Coach House,

including coach house and cart

shed



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Significance

D20 Splash Cottage; mill workshops;

Leonard Stanley House; and

associated stable and cartsheds


D21 Eastington Park, and stables and

coach house


D22 3, 4 and 5 Churchend Grade II listed Medium

D23 Weir between the River Frome

and the Kemmett Canal


D24 Church of St Michael and All

Angels

Grade II* and Grade

II listed churchyard

monuments

High and Medium

D25 Elm Beams And Manor Cottage Grade II listed Medium

D26 Millend Mill Grade II listed Medium

D27 Brookhill House and Meadow

Cottage


D28 Eastington House and stable Grade II listed Medium

D29 Springhill Cottages Grade II listed Medium

D30 Former Stable And Coach House

To Springhill House


D31 Alkerton Farmhouse and barn Grade II* and Grade

II listed barn

High and Medium

D32 The Kings Head Grade II listed Medium

D33 Alkerton Cross House Including

Front And Rear Walls And

Outbuilding To Rear


D34 Direction Post Grade II listed Medium

D35 Green Farmhouse Grade II listed Medium

D36 1 2 And The Cross Grade II listed Medium


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Significance

D37 Alkerton Grange Grade II and Grade

II* listed

summerhouse

High and Medium

D38 Alkerton Court and barn Grade II listed Medium

D39 Claypits Farmhouse Grade II listed Medium


D41 The Hawthornes Grade II listed Medium

D42 Nethermills Farmhouse Grade II listed Medium

D43 Fromebridge Mill Grade II listed Medium

D44 Millowner's House, Also Known

As Fromebridge Mill


D45 Nastfield Farmhouse Grade II listed Medium


D47 The Old Forge Grade II listed Medium

D48 Parklands Grade II listed Medium

D49 Parkland Farmhouse Grade II listed Medium

D50 Yew Tree Cottage (North End) Grade II listed Medium

D51 Oak Cottage Grade II listed Medium

D52 Jaxons Farmhouse Grade II listed Medium

D53 King's Orchard Grade II listed Medium

D54 Manor Farmhouse Grade II listed Medium

The Stroud Industrial Heritage Conservation Area (D1)

7.44 The southernmost part of the Redline Boundary lies within the Stroud Industrial Heritage

Conservation Area (IHCA). No development will take part within the Conservation Area, as the

Development Footprint lies entirely to the north of the A419.


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7.45 The IHCA (No. 29) was designated by Stroud District Council in September 1987. The IHCA has

been extended in several places since that date, including at Eastington in January 1989. In

November 2008 a Conservation Area Statement for the IHCA was adopted by the Council.

7.46 The IHCA divides the Conservation Area into numerous ‘Character Parts’. The southernmost part

of the main Site area lies within the IHCA, within Character Part 4.4 ‘Fromebridge to Chipman’s

Plat’. A small part of the south-eastern corner of the Redline Boundary also lies within Character

Part 1.2 ‘Newtown and Chipman’s Plat’. Character Part 7.1 ‘Meadow Mill, Eastington’ lies

immediately adjacent to the southernmost part of the Redline Boundary. The smaller part of the

Redline Boundary on the western side of the M5 lies wholly within the IHCA, within Character

Part 4.4 ‘Fromebridge to Chipman’s Plat’.

Listed Buildings

7.47 A total of 77 Listed buildings have been considered as part of step 1 of the settings assessment.

These comprise:

• Three Grade II* Listed Buildings (designated heritage assets of ‘the highest significance’)

• Seventy-four Grade II Listed Buildings (designated heritage assets not of ‘the highest

significance’)

7.48 The locations of the Listed Buildings are illustrated on RS Figure 7.1, and comprise D2 – D54 in

Table 7.4 above. Several of the ‘D’ references include more than one Listed Building (for example

churches, with associated listed tomb chests). Reference D1 is the IHCA, which has been

discussed above.

Non-designated heritage assets

7.49 The phased archaeological works carried out within the Redline Boundary have characterised the

archaeological resource in detail. Non-designated heritage assets are summarised on RS Figure

7.2, and itemised in Table 7. 5 below.

Table 7.5: Non-designated heritage assets

Heritage asset Description Heritage Significance

Whitminster Roman

villa

The below-ground remains of a Roman villa. Not

of the highest quality and significance, but may

contribute to the understanding of the Roman

period in the region

Medium to High

Roman field system Boundary ditches of the field system of the villa Low

Ridge and furrow

earthworks

Eroded ridge and furrow earthworks of medieval

date

Low

‘Important’

hedgerows

Hedgerows which qualify as ‘important’

hedgerows under the criteria for ‘archaeology

and history’ of the Hedgerow Regulations 1997

Low

7.50 The Cotswold Archaeology evaluation confirmed that the Roman villa (known as the

‘Whitminster Villa’) was occupied between the 2nd to 4th centuries AD, and possibly even in the


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first century. Roman villas are relatively numerous in the Cotswolds, with over 50 probable sites

recorded in Gloucestershire. Stone wall foundations and floor layers with mosaic and opus

signinum were recorded, and also a potential T-shaped kiln, set within a rectangular ditched

enclosure. The remains are not well-preserved, as walls had been subject to later robbing and

there has also been significant plough damage.

7.51 The villa is situated in the area south of the A419 and will not be impacted upon by the

Development Footprint. The GCC archaeology officer confirmed in his consultation advice that

the villa “is not of the highest quality and significance”, but nonetheless may contribute to the

understanding of the Roman period in the region.

7.52 Boundary ditches of the associated Roman field system were also recorded, largely, again, to the

south of the road near the villa (see also RS Appendix 7.2). Some evidence was found for these

to also extend into at least part of the Development Footprint to the north of the A419. Such

remains are of sufficient interest to comprise ‘heritage assets’, but of low heritage significance.

7.53 Earthworks of ridge and furrow cultivation survive within parts of the Redline Boundary (RS

Figure 7.2). These comprise heritage assets of low heritage significance.

7.54 The hedgerows that survive in the Redline Boundary (RS Figure 7.2) qualify as ‘important’

hedgerows under the criteria for ‘archaeology and history’ of the Hedgerow Regulations 1997.

The Regulations require appropriate notice to be provided to the Council prior to their removal.

The hedgerows comprise ‘heritage assets’ of low heritage significance, and are situated along

the boundaries of fields created in the post-medieval period. Any below-ground ditches of

removed field boundaries will not comprise heritage assets. There has been significant boundary

loss in the Redline Boundary and adjacent areas, and it is not one of high historic landscape value.

Design Evolution

7.55 Step 4 of GPA3 is directed towards ‘maximising enhancement and minimising harm’. This best-

practice guidance is specifically tailored to effects on the setting of heritage assets, through non-

physical change.

7.56 GPA3 states that” options for reducing the harm arising from development may include the

relocation of a development or its elements, changes to its design, the creation of effective long-

term visual or acoustic screening.” Furthermore,” good design may reduce or remove the harm,

or provide enhancement, and design quality may be the main consideration in determining the

balance of harm and benefit.”

7.57 Following the original submission, a very much smaller scheme is now proposed. No

development will be carried out in the fields to the south of the A419. The following elements

have been removed from the proposals: -

• The Green Technology Hub;

• The sporting facilities south of the A419;

• The leisure facilities south of the A419;

• The indoor training pitch;

• Two outdoor training pitches;

• The proposed Ecotricity B1 building.


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7.58 The design has included measures to minimise any harm to the heritage significance of the listed

buildings on Grove lane, namely; Grove Farmhouse, Westend Farmhouse, and Mulgrove.

Measures include landscape structures such as earthed bunds. The bunds are designed to limit

noise, visual and light intrusion. Where appropriate tiered seating will be incorporated into the

bunds surrounding sports pitches. Gaps through the hedge on Grove Lane are limited, but where

views into the Redline Boundary are possible (such as opposite Mulgrove) the earthed bunds

(which will be grassed) will screen the car parking areas. A landscape buffer area along the

northern boundary with Westend Farmhouse has also been provided, including a provision for

orchard planting (reflecting a former landuse). Soft landscaping measures have also been

proposed, including extensive planting, including ‘parkland’ trees between car park bays. Existing

hedgerows and trees are retained as far as possible. It is also noted that the stadium itself has

been designed with measures such as non-reflective surfaces, and recessive colours and textures.

Potential Effects

Construction Effects

7.59 The assessment of construction effects includes consideration of all groundworks required for

the stadium, pitches, car parking, infrastructure (including drainage/ services) and also the

construction compound, which will be located immediately to the north of the A419 (RS Figure

5.4). Construction effects are summarised in Table 7.7 below.

7.60 The Roman villa, a heritage asset of Medium-High heritage value, will not be impacted upon as

it is outside the Development Footprint.

7.61 As non-designated heritage assets, the low heritage significance of the boundary ditches should

be taken into account in determining the application (in accordance with Paragraph 135 of the

NPPF). The scale of impact is likely to be limited (to the stadium, landscaping for the practice

pitches, and below-ground works such as drainage and services), and the majority of any such

buried ditches would be preserved.

7.62 Eroded earthworks of ridge and furrow cultivation survive within parts of the Redline Boundary

(RS Figure 7.2). Although not within the area of the new stadium, it is likely that the car park

creation and landscaping will require levelling of these earthworks, and surfacing with hard core/

rough stone (for the car-parks). This will comprise removal of a heritage asset of low heritage

significance. Such earthworks are reasonably well-represented in the parish.

7.63 Several post-medieval hedgerows which qualify as ‘important’ under the Hedgerow Regulations

1997 lie within the Redline Boundary, as illustrated on RS Figure 7.2. The hedgerows mark field

boundaries created in the post-medieval period, a form of enclosure very well-represented in

the parish and wider region. They are non-designated heritage assets of low heritage

significance. The hedgerows are retained where possible, although the Revised Scheme will

require the translocation of several of the hedgerows. This represents a very small loss of this

form of heritage asset (see also Chapter 8, Ecology, as well as RS Figure 8.2 and 8.14.

7.64 The hedgerow translocation that is required, and the Revised Scheme itself, will not lead to harm

to an area of historic landscape value. The proposals would not lead to any significant heritage

effects in EIA terms.

Operational Effects


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7.65 A detailed analysis of the potential effects of the Revised Scheme on the setting of heritage assets

(those set out in Table 7.3, above) is provided in the RS Appendix 7.1 heritage assessment.

7.66 The Revised Scheme would not lead to any substantial harm to any designated heritage assets

through changes to their setting. The proposals would not lead to any significant heritage effects

in EIA terms.

7.67 The significance of the Industrial Heritage Conservation Area will not be harmed.

7.68 A very small degree of harm (the lower half of ‘less than substantial harm’) will be occasioned to

the heritage significance of:

• the Grade II listed Westend Farmhouse;

• the Grade II listed Mulgrove.

7.69 This level of harm is not a significant environmental effect in EIA terms.

7.70 No other designated heritage assets will be affected.

Mitigation and Enhancement Measures

7.71 In an email of 26th October 2017 (RS Appendix 7.5), the GCC archaeology officer confirmed that

the mitigation works may suitably form a condition of any planning application, and that “there

would be no objection in principle to development affecting those remains”. It is recommended

that this mitigation would comprise archaeological observation and recording, the detailed

methodology for which should be agreed in a Written Scheme of Investigation to be approved

before construction with the archaeology officer.

Residual Effects

7.72 The NPPF guides (Paragraph 141) that LPAs “should also require developers to record and

advance understanding of the significance of any heritage assets to be lost (wholly or in part) in

a manner proportionate to their importance and the impact, and to make this evidence (and any

archive generated) publicly accessible”. However, the ability to record evidence of our past

should not be a factor in deciding whether such loss should be permitted.

7.73 The mitigation measures agreed with the archaeology officer are appropriate, and are in line

with the requirements of the NPPF. They do not, however, reduce the limited, and EIA not-

significant, harm to the non-designated heritage assets which has been identified above, and

would as such constitute enhancement measures.

Cumulative Effects

7.74 The following section considers potential effects from other development schemes in the area,

and whether additional heritage effects may occur in-combination with the present proposals.

The section considers both construction and operation effects. RS Figure 18.1 may be consulted

for locations of the relevant schemes, and Table 2.5 for further descriptive detail.

Land West of Stonehouse, Stroud (Ref. S.14/0810/OUT) and S.17/0095/REM


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7.75 Land to the West of Stonehouse is a permitted mixed-use development of up to 1,350 dwellings

and 9.3ha of employment land. The development will stretch from Grove Lane to the railway line

east of Oldends.

7.76 Development is now proceeding in areas H1, H6 and H7 as identified in the Reserved Matters

Application. This comprises 103 new dwellings, with associated infrastructure, open space and

landscaping. The new development includes a new vehicular access off the lower part of Grove

Lane (opposite the Travelodge and Service Station) which is now under construction.

7.77 Under ‘landscape’ the Statement of Common Ground for Land to the West of Stonehouse notes

that” The Landscape Appraisal Study confirms that the site has a medium-low landscape

sensitivity to change. The SA Addendum Report notes that the site is relatively unconstrained in

landscape and heritage terms and there is good potential to address landscape and heritage

issues through the Concept Design / planning application process”. That situation is in fact closely

correlated to the Revised Scheme, where no significant effects have been identified upon

designated heritage assets including Listed Buildings and the Conservation Area.

7.78 It is therefore not anticipated that the development of that site will lead to effects upon any

heritage assets over and above those identified within this ES chapter. The Listed Buildings of

greatest proximity to the current site have been assessed in detail in the heritage assessment

comprising RS Appendix 7.1. Mulgrove is the building in greatest proximity to the West of

Stonehouse site but, as clarified in RS Appendix 7.1, it faces the opposite way, to the west, and

there is little inter-visibility with that land due to intervening hedges and tree cover. Westend

Farmhouse and Grove Farmhouse lie a good deal further north on Grove Lane, and inter-visibility

is highly restricted.

7.79 It is concluded that there will be no greater ‘in-combination’ effects from development of the

current and future development West of Stonehouse, and the present application.

Westend Courtyard, Grove Lane, Westend, Stonehouse (Ref. S.15/1088/FUL)

7.80 The proposals for Westend Courtyard are for extension to provide additional offices. This site lies

around 100m to the north-east of the present site, and a detailed analysis of the setting of the

farmhouse has again been provided in RS Appendix 7.1. The proposed works are relatively

limited, comprising an extension to allow 10 additional offices. The current proposals will lead to

a very small level of harm to its significance as a historic farmhouse. This effect will not be

increased in conjunction with the planned Courtyard extension.

Comment regarding potential restoration of the Stroudwater Navigation canal

7.81 Delivery Policy ES11 of the Local Plan regards ‘maintaining, restoring and regenerating the

District’s canals’. The Council will “encourage the restoration of, and other necessary functional

improvements to, the District’s canals. It will seek to improve access to, and along, the canals to

encourage use for transport and leisure/ recreational purposes. Development on the route of, or

adjacent to, the Stroudwater Navigation, the Thames and Severn canal or the Gloucester and

Sharpness Canal must not prevent the improvement, reconstruction, restoration or continued use

of the canals or towpaths.” The current proposals are in accordance with these requirements,

and will not affect any future restoration plans for the canal – including restoration of the now

in-filled element which passes within the Redline Boundary.


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7.82 The same policy notes that all developments must respect the character and setting of the canals.

Again, the present proposals do this (as set out in RS Appendix 7.1).

7.83 If the canal were to be restored in the future, including the part below-ground within the Redline

Boundary, it seems very likely that it would present a ‘heritage benefit’. It would be consistent

with the guidance of Paragraph 137 of the NPPF which states that “Local Planning Authorities

should look for opportunities for new development within Conservation Areas and World Heritage

Sites and within the setting of heritage assets to enhance or better reveal their significance.”

Restoration of the canal is likely to better reveal the significance of the canal, given that it is

completely in-filled in this section.

7.84 RS Appendix 7.1 provides a detailed analysis of the heritage significance of the canal-route and

the IHCA in which it lies. The Revised Scheme will not hinder future restoration. Neither will they

harm the significance of the canal due to any change to its setting. It is concluded that if this

Revised Scheme north of the A419 is permitted and constructed, then this will not affect future

heritage benefits (or harms) that restoration of the canal might bring.

Other schemes

7.85 Table 7.6 below lists further schemes which have been considered in terms of any further ‘in-

combination’ effects which may take place. Following review, it is concluded that none of these

schemes will, or would, lead to additional effects.

Table 7.6: Other developments considered in the assessment of cumulative effects

Application

Reference

Description Comment

S.12/0763/FUL Unit 27 Bonds Mill, Bristol Road,

Stonehouse, Gloucestershire, GL10

3RF. Permitted

No additional in-combination effect.

The proposals are limited to alterations

to an existing warehouse, in a specific

urban character area

13/0001/INQUIR Land at Javelin Park proposed

development of Energy from Waste

(EfW) facility for the combustion of

non-hazardous waste and the

generation of energy. Permitted


The facility is some 3.5km north-east of

the Redline Boundary, and is not

anticipated to lead to harm to any

heritage assets in the vicinity of the

Development Footprint. The Secretary

of State (APP/T1600/A/13/2200210)

considered that the ‘heritage assets

most affected’ by the Javelin Park

scheme would be St Peter’s Church,

Haresfield and Hiltmead Farmhouse:

neither of these buildings would be

affected by the current Revised

Scheme.

S.17/0337/FUL Land Adjoining Bristol Road,

Stonehouse, Gloucestershire, GL10

3RW Change of use to low key open



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Application

Reference

Description Comment

storage/employment base (use class

B8) restricted to use in association

with contractor for gardening/tree

surgery/landscaping services and siting

of associated steel storage container

unit (green). Appeal in progress

The proposals are of insufficient scale

to lead to any harm to heritage assets

in the vicinity of the Revised Scheme.

S.16/0607/FUL John Stayte Services Ltd Puddlesworth

Lane, Eastington, Stonehouse,

Gloucestershire, GL10 3AH Erection of

four commercial units. Permitted


The development is in a specific

context of existing development on the

west side of the M5. The proposals

would lead to no harm to heritage

assets in the vicinity of the Revised

Scheme.

S.17/1133/FUL

and

S.17/1134/LBC

Former Standish Hospital and Former

Westridge Hospital Standish,

Stonehouse, Gloucestershire

Conversion and refurbishment of the

former Standish Hospital complex.

Under consideration


The proposals are in a specific built

environment on the east side of

Stonehouse, and would lead to no

harm to heritage assets in the vicinity

of the Revised Scheme.

S.16/2155/FUL Lake Cottage Lake Lane, Frampton On

Severn, Gloucester, Gloucestershire,

GL2 7HG Erection of 6 dwellings with

associated vehicular access and

parking. Permitted


The proposals are in the urban area of

the village, and will lead to no harm to

heritage assets in the vicinity of the

Revised Scheme.

S.16/0922/REM Land Adjoining Station Road Bristol

Road, Stonehouse, Gloucestershire,

GL10 3RB. Permitted


The proposals are on the east side of

the significant built-up industrial area

at Oldends.

S.15/2089/OUT Land adjacent to Eastington Trading

Estate


The heritage assessment accompanying

the proposals found that there would

be no adverse effects upon the setting

of heritage assets.

S.17/2331/OUT Land adjoining Oldbury Lodge Pike,

Lock Lane, Eastington. Erection of new

buildings for uses within use class C1

(Hotel) and use classes A3 / A4 Pub

(Pub/Restaurant)


The heritage report accompanying the

application found that the proposals

would not harm the significance of any

heritage assets.

Conclusions


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7.86 The only archaeological remains of significance within the Redline Boundary comprise those of

the Roman ‘Whitminster’ villa. There is no built development near them.

7.87 It has been agreed in consultation with the GCC archaeology officer that mitigation works may

suitably form a condition of any planning application. This measure would suitably manage the

remains of low significance which do lie within the area north of the A419 where development

will take place. It is recommended that this will comprise archaeological observation and

recording, the detailed methodology for which will be agreed in a Written Scheme of

Investigation with the archaeology officer to be approved before construction.

7.88 This assessment has found that the Revised Scheme will not lead to any significant harm (no

significant heritage effects in EIA terms) to any designated heritage assets through changes to

their setting. The IHCA will not be harmed. A very small degree of harm (the lower end of ‘less

than substantial harm’) will be occasioned to the heritage significance of the Grade II listed

Westend Farmhouse and Mulgrove, both on Grove Lane. This will not comprise a significant

heritage effect in EIA terms. No other designated heritage assets will be harmed.

7.89 No development will take place within the IHCA, or in its immediate vicinity. All development is

north of the modern tree-lined A419. This road is identified in the Council’s SALA report as a

defining boundary: the report for EAS 007 notes that” land to the north of the A419 has no

significant heritage constraints.” The Revised Scheme will not harm the significance of the IHCA,

and adheres to the Five Priorities and accompanying Management Proposals of the IHCA SPD

(see RS Appendix 7.1, Table 7.1). In particular, it will not harm the transition from built

development at Chipmans Platt and Meadow Mill, to the post-medieval field system comprising

the Green Corridor of the Rural Frome Vale.

7.90 It is concluded that the Revised Scheme will lead to no significant heritage harm, and no

significant heritage effects in EIA terms.

7.91 The amended scheme has considered appropriate methods to minimise heritage harm, in

accordance with heritage best-practice. The Revised Scheme can successfully be implemented

and avoid significant heritage harm. This conclusion is consistent with the Council’s SALA, which

found that the land to the north of the A419 has no significant heritage constraints.

7.92 It is recommended that a planning condition is attached to any planning permission for the

Revised Scheme which provides for archaeological mitigation in the form of archaeological

observation and recording during construction phase (an archaeological ‘watching brief’). An

appropriately worded draft condition is supplied in RS Appendix 6.2.


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Table 7.7: Summary of Archaeology and Cultural Heritage Effects and Mitigation

Receptor Effect Phase

(Construction /

Operation)

Embedded

Mitigation

Sensitivity of

Receptor

Magnitude

of Change

Level of Effect and

Significance Prior to

Mitigation

Mitigation Enhancement Level of

Effect (and

EIA

Significance)

after

Mitigation

Nature of effect (short

term / medium term /

long term, permanent /

temporary, direct /

indirect)

Roman field

boundary

ditches

Disturbance of

in-filled former

ditches

Construction

phase

Non-designated

heritage asset –

low heritage

value

Lower end

of less than

substantial

harm

(adverse)

Not

Significant

Archaeological

monitoring and

recording by

Condition

Design has

been amended

to remove any

impact to

remains of

more than low

heritage

significance

Possible on-

site

interpretati

on

None Permanent Adverse

Ridge and

furrow

earthworks

Disturbance/

removal

Disturbance/r

emoval of

remains

during

construction

Non-designated

heritage asset

Lower end

of less than

substantial

harm

(adverse)

Not

significant

N/A N/A Recording

of remains

that will be

disturbed/

removed

and

publication

None Permanent Adverse

The in-filled

Stroudwater

Navigation

No change No change Non-designated

heritage asset

No change Not

significant

N/A No built

development

N/A N/A N/A

‘Important’

hedgerows

Partial

translocation

Partial

translocation

during

construction

works

Non-designated

heritage asset

Lower end

of less than

substantial

harm

(adverse)

Not

significant

N/A N/A None N/A

Stroud

Industrial

Heritage

Conservation

Area

No change No change Designated

Heritage Asset

of the Highest

Level of

Significance

No change

to

significance

Not

significant

N/A No built

development

N/A None N/A

Grove

Farmhouse

Grade II

Change to

landuse in

wider vicinity

Change to

landuse in

wider vicinity

Designated

Heritage Asset

of less than the

No change

to

significance

Not

significant

N/A Use of

planting and

green space

N/A None N/A


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Listed

Building

Highest Level of

Significance

Westend

Farmhouse

Grade II

Listed

Building

Change to

landuse in

wider vicinity

Change to

landuse in

wider vicinity

Designated

Heritage Asset

of less than the

Highest Level of

Significance

Lower end

of less than

substantial

harm

(adverse)

Not

significant

N/A Use of

planting and

green space

N/A Not

significant

Permanent Adverse

Mulgrove

Grade II

Listed

Building

Change to

landuse in

wider vicinity

Change to

landuse in

wider vicinity

Designated

Heritage Asset

of less than the

Highest Level of

Significance

Lower end

of less than

substantial

harm

(adverse)

Not

significant

N/A Use of

planting and

green space

N/A Not

significant

Permanent Adverse


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8 ECOLOGY AND NATURE CONSERVATION

Summary

8.1 This chapter of the Environmental Statement addresses the significant ecological effects of the

Revised Scheme of a 5,000 capacity football stadium, associated training pitches, access

arrangements from the A419 and car parking for Forest Green Rovers Football Club (FGRFC). It

suggests a number of avoidance and mitigation measures to maintain ecological coherence,

habitat connectivity and conservation of protected species present. It is concluded that after

mitigation there will be no significant ecological effects. It also outlines a number of

enhancements to increase the biodiversity value of the Development Footprint to north of the

A419. The Development Footprint currently consists of improved and semi-improved pasture cut

for silage and some cattle grazing, divided by mature hedgerows and associated ditches.

8.2 This is a revision to original Eco park application (S.16/0043/OUT). This differs in that the Revised

Scheme now only includes the Football Stadium, two practice pitches, a goal keeping practice

area, associated access and car parking all located to the north of the A419 (See Chapter 5

Description of Revised Scheme for full details).

8.3 The original surveys submitted as part of S.16/0043/OUT were accepted as being suitable to

allow an assessment of the original outline application. Throughout this chapter the Term ‘Site’

refers to the land at M5 Junction 13 West of Stonehouse. ’Survey Area’ refers to the area covered

by the 2015 and 2016 surveys. The term ‘Development Footprint’ or ’Revised Scheme’ is used

throughout this chapter to refer to the area subject to works, largely to the north of the A419.

However, for this chapter, it is also taken to encompass the section of hedgerow to the south of

the A419, which will require translocating to allow for the dualling of A419 and creation of the

new access.

8.4 The detailed ecological surveys are provided as appendices to this chapter (RS Appendix 8.1, RS

Appendix 8.2, RS Appendix 8.3, RS Appendix 8.4. and have been used to assess the potential

effects of the Revised Scheme. Further information on potential ecological enhancements that

will be brought forward as part of Reserved Matters Applications are documented in RS

Appendix 8.5 and RS Appendix 8.6.

8.5 Receptors considered unlikely to be significantly affected by the development have been scoped

out of the assessment. These are listed in Table 8.9, along with the reason for their removal.

Those receptors considered in this chapter are those where a potential significant effect has been

identified or where a precautionary approach had been taken and mitigation or enhancements

are proposed.

8.6 A desk study within 5km of the Survey Area identified two internationally important sites, four

nationally important sites, 18 Key Wildlife Sites, two of which are adjacent to, and partly within,

the southern Survey Area boundary, and a Conservation Road Verge along the A419. The

Gloucestershire Centre for Environmental Records (GCER) has provided protected species

records for otter, badger, hare, water vole, reptiles and amphibians within 5km of the centre of

the Development Footprint and records of fourteen species of bats within 10km. A total of 232

species of birds have been recorded within 5km. This is largely due to the proximity of the Site

to the Severn Estuary SPA, where large numbers of wetland species overwinter on the Estuary.


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8.7 Zones of Influence were considered for a range of species present on or near the Survey Area.

For most habitats and species, the Zones of Influence applied to an area within or immediately

adjacent to the Survey Area. However, for the River Frome the Zone of Influence includes the

flood plain and habitats downstream of the Development Footprint, which extend to the Severn

Estuary 4.5km away. For most bats it was considered the Zone of Influence was unlikely to extend

beyond 1-5km, although potentially up to 10km for larger strong-flying species.

8.8 An extended Baseline Survey was conducted in 2015 to identify habitats and the potential for

the presence of protected species. Potential habitat suitable for otter, water vole, badger,

reptiles, bats and farmland birds were identified. Subsequent surveys in 2015 and 2016 were

carried out to verify the presence of these protected species. A National Vegetation Classification

(NVC) survey was also carried out in 2016 to further elucidate grassland community structure.

The main habitats present are improved and semi-improved grassland, hedgerows, and small

patches of woodland and mature trees. There are two permanent streams present on the

boundary of the Survey Area and a number of internal ephemeral ditches which had dried out

by late spring in both 2015 and 2016. This was confirmed by site walkovers in 2017.

8.9 The surveys showed that grasslands both to the north and south of A419 are mostly agriculturally

improved species poor with small areas of semi-improved grassland whilst those to west of the

A419 are mostly semi-improved grassland.

8.10 The boundary hedgerows are mostly intact, whilst a number of the internal hedgerows are

becoming gappy due to lack of management and damage by cattle. The Arboricultural Survey

(carried out only on land to the east of the M5) identified 101 individual trees, 32 hedgerows and

16 tree groups (RS Figure 8.1). Two active badger setts were identified to the north of the A419

in 2015. In 2016 and 2017 only one was active. During the otter survey in 2015 and 2016, otter

spraints were found just outside the Survey Area on the River Frome.

8.11 Bat surveys consisted of:

• Transects monthly from May to September 2015 (five surveys), and April to July 2016 (five

surveys) including a dawn survey in 2016;

• Endoscope surveys on 47 of trees for evidence of roosting bats in 2016, of these, 20 trees

were within the Development Footprint;

• Emergence surveys were conducted on 52 trees (19 within the Development Footprint)

and re-entry surveys on 27 trees (6 within the Development Footprint) identified as having

bat roost potential;

• An assessment of the potential for roosting bats was made on the derelict farm buildings

to the north of the survey area followed by two emergence surveys and one re-entry

survey;

• Static monitoring from August to October in 2015 and April to July in 2016 (this included

533 nights from 34 locations within the Development Footprint);

• Targeted surveys of bats using the M5 Pedestrian Underpass and River Frome Underpass

in 2016;

• Targeted surveys of bats crossing the A419 in 2016.

8.12 A low level of bat activity was recorded over most of the Survey Area but with a concentration

of activity close to suitable foraging areas. Common pipistrelle Pipistrellus pipistrellus and

soprano pipistrelle Pipistrellus pygmaeus were the most frequently recorded species across most


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of the Survey Area. However, there was a very high level of Myotis (Daubenton’s bat Myotis

daubentonii) activity adjacent to the River Frome particularly over the river under the M5 River

Frome Underpass. There were smaller numbers of noctule Nyctalus noctula bat passes and

evidence of small numbers of greater horseshoe Rhinolophus ferrumequinum and lesser

horseshoe Rhinolophus hipposideros, serotine Eptesicus serotinus, brown long-eared bat

Plecotus auritus, and occasional records of a Nathusius pipistrelle Pipistrellus nathusii and

Leisler’s bat Nyctalus leisleri. Endoscope investigations of 47 trees found no evidence of bat

roosts. Emergence surveys (on 52 trees, and dawn re-entry on 27 of these) located just one

individual Myotis sp. roosting in an old Field Maple in hedgerow SH10 south of the A419.

8.13 Bird surveys were conducted from May to July 2015 and March to July 2016. Fifty-two species of

birds were recorded in 2015 and 54 in 2016, of which 31 were breeding in 2015 and 30 in 2016.

Five UK red listed species (herring gull, skylark, song thrush, house sparrow, and starling) were

recorded during the surveys but only one (song thrush) was recorded breeding within the Survey

Area. Three species (skylark, house sparrow and starling) were recorded breeding outside the

boundary of the Survey Area and herring gull was recorded foraging during the breeding season.

8.14 Reptile surveys were conducted in 2016 with small numbers of grass snake and slow worm being

recorded adjacent to the A419, and to the west of the M5.

8.15 Water Samples for eDNA were collected from two water bodies (ditches) in 2016. The test results

from Agricultural Development and Advisory Service (ADAS) proved negative for great crested

newt DNA.

8.16 The effect of the development on habitats and species within the Development Footprint was

significantly reduced during the design evolution by avoidance and suitable mitigation measures.

8.17 With regards to bats, the detailed design of the Revised Scheme (avoidance) will include the

retention of the majority of mature trees and the translocation or replacement of hedgerows.

Further mitigation through the creation of bat commuting corridors, bat-friendly lighting

throughout the Development Footprint and the creation of enhanced foraging areas (orchards

and pond) will reduce the potential negative effects to ‘not significant’. Habitat creation to

enhance the Development Footprint for bats is outlined in the Green Infrastructure Plan (RS

Figure 5.3 Indicative Green Infrastructure Parameter Plan).

8.18 With regards to birds, construction and operation effects are perceived to be minimal after

mitigation, and therefore not significant. Reptiles will be trapped and translocated to suitable

areas west of the M5, so after mitigation, there will be no residual significance.

8.19 Cumulative effects of six consented developments, one pre-planning and two pending

consideration within a 5km radius of the Development Footprint were assessed. It was concluded

that there will be no significant cumulative effects, singly or in concert, on the Revised Scheme.

8.20 A Green Infrastructure Plan (RS Appendix 8.5) outlines the enhancements for biodiversity,

mitigation for climate change, ecosystem services, landscape improvements and social benefits

for well-being. Implementation of the Green Infrastructure Parameter Plan will result in a net

gain in biodiversity.


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8.21 Therefore, the development will contribute to the delivery of the NPPF objective of net

biodiversity gains, the objectives of Stroud District Local Plan policies ES6 and ES8 and the

recently approved Eastington Neighbourhood Plan Policies EP2, EP4 and EP9.

Introduction

8.22 This Chapter concerns the potential effects of the construction and operation of a new Forest

Green Rovers Football Club (FGRFC) Stadium, associated training pitches, access arrangements

from the A419 and car parking adjacent to Junction 13 of the M5 in Gloucestershire on

biodiversity. The assessment of the nature conservation value of the Survey Area is based on

detailed surveys conducted in 2015 and 2016, as set out in the summary statement of EIA

significance. Further walk over surveys were conducted in 2017 to assess whether there has been

any significant changes in habitats within the survey area. This chapter explains the ways in which

habitats and species may be affected by the Revised Scheme and the significance of any potential

effects identified. It sets out any avoidance or mitigation measures required to reduce significant

negative effects to negligible and non-significant. It also describes biodiversity enhancements

that will be implemented as part of this development.

8.23 The ecological assessment follows the approach set out in the Chartered Institute of Ecology and

Environmental Management (CIEEM) Guidelines for Ecological Impact Assessment in the UK and

Ireland (2016)26. The guidelines are based upon the baseline description of the ecological

characteristics of the survey area, the evaluation of the habitats and species present (ecological

receptors), the identification of ecological effects, the assessment of the significance of the

identified ecological effects, the identification of mitigation to avoid or offset significant effects,

and other enhancement measures to address any other identified effects.

8.24 The technical reports, which comprise detailed raw data sets and other information prepared

following the surveys in both 2015 and 2016, can be found in RS Appendix 8.1 Baseline Survey,

in RS Appendix 8.2 Fauna surveys, RS Appendix 8.3 Arboricultural Survey, RS Appendix 8.4

Confidential Badger Report (not for public release) and RS Appendix 8.5 Green Infrastructure

Plan, describing proposed enhancements to encourage wildlife, improve landscape elements and

promote health and well-being. RS Appendix 8.6 Principles of Environmental Enhancements

provides further indicative information on the types of environmental enhancements proposed.

RS Appendix 8.7 Consultation Responses contains pre and post submission consultation

responses to the original Eco Park application (S.16/0043/OUT). RS Appendix 8.8 includes

further consultation from EPR and the responses which were the basis of the agreement that the

level of ecological survey and assessment was sufficient for the original outline application. RS

Appendix 8.9 contains the Planning Policy and Guidance. It should be noted that all European

Legislation still applies to the UK. The ecological Survey Area is shown on RS Figure 8.3.

8.25 The scope of this Ecological Impact Assessment covers the potential direct and indirect effects to

selected ecological receptors found within the Survey Area due to the construction and/or

operation of the football stadium, associated training pitches and car parking.

8.26 This is an outline planning application for a new Stadium for FGRFC, associated training pitches

and car parking to the north of the A419. The total area of the Development Footprint is

26 CIEEM (2016) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and

Coastal; 2nd Edition, Chartered Institute of Ecology and Environmental Management, Winchester


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approximately 19ha. The stadium and pedestrian area will cover 5.17 ha, the training pitches

1.73 ha and the car park and roads covers 5.7 ha. There will be 5.16 ha of enhanced wildlife

habitats including grasslands, orchards, ponds and park woodland. The remaining areas will be

either retained woodland, grassland and hedgerow (0.69ha) or site maintenance/ farm area

(0.44 ha). Full project description details are provided in Chapter 5: Description of the Revised

Scheme.


8.27 The ecology chapter considers how all levels of planning policy relating to ecology and relevant

to this application are addressed and how the Revised Scheme will contribute to their delivery.

8.28 International legislation includes the European Directive on the Conservation of Natural Habitats

and of Wild Fauna and Flora (92/43/EEC) and the Bern Convention, whilst national legislation

considers the Wildlife and Countryside Act, The Conservation of Habitat and Species Regulations

(2010) and the Natural Environment and Rural Communities Act 2006 (NERC), as well as the

National Planning Policy Framework (NPPF). Also, relevant national legislation and guidance are

the Hedgerow Regulations (1997), Tree Preservation Orders made under the Town and Country

Planning act 1990, the town and Country Planning (Tree Preservation) (England) Regulations

2012, the UK Biodiversity Action Plan and England’s Biodiversity Strategy 2020.

8.29 On a local level, policies of the Stroud District Council Local Plan Policies ES6 and ES8 and the

Eastington Neighbourhood Plan Policies EP2, EP4 and EP9 are considered in RS Appendix 8.9

Planning Policy and Guidance.


Professional Competence

8.30 Dr. Simon Pickering and Dr. Grace O’Donovan, who carried out the Assessment, are both

experienced ecologists and consultants. Dr. Simon Pickering has a Bachelor of Science with

Honours degree in Biological Sciences from Hatfield Polytechnic and a degree of Doctor of

Philosophy in Zoology from the University of Durham. He has worked as a professional ecologist

for over 30 years and has been the Principal Ecologist at Ecotricity since 2008. He is responsible

for overseeing the ecological assessment process for renewable energy as well as other

development projects for the company and has experience of writing over 25 Ecological Impact

Assessments (EcIA), the most recent ones being for wind farms at Dulater, Scottish Borders and

Upper Sonachan, Argyll and Bute

8.31 Grace O’Donovan is a professional botanist with 30 years’ experience in the environmental

sector, of which 13 years’ experience is in environmental consultancy. She has written over 10

EcIAs, the most recent ones being Fiddington, Gloucestershire, New Lawn, Gloucestershire and

Berkeley Green Energy Storage, Gloucestershire. She is a full member of the Chartered Institute

of Ecology and Environmental Management (CIEEM) and holds protected species licences for

bats, barn owl and great crested newt.

Potential Zone of Influence


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8.32 The Zone of Influence is the area over which the ecological feature identified may be subject to

significant effects as a result of the Revised Scheme. These will vary between ecological

receptors26..

8.33 The key receptors are considered to be:

• The River Frome, its flood plain and designated sites downstream of the Survey Area;

• The grassland habitats within the Survey Area;

• The hedgerows, woodland relics and historic ecological features;

• The functional ecology of the population of protected species using the Survey Area or

influenced within the Development Footprint. This would include: breeding birds, reptiles,

bats, badgers and potentially otter.

River Frome

8.34 Sources of water pollution on building sites include: diesel and oil; paint, solvents, cleaners and

other harmful chemicals; and construction debris and dirt. When land is cleared, it causes soil

erosion that leads to silt-bearing run-off and sediment pollution. Silt and soil that runs into

natural waterways turns them turbid, which restricts sunlight filtration and destroys aquatic life.

8.35 Surface water run-off also carries other pollutants from the site such as diesel and oil, toxic

chemicals, and building materials like cement. When these substances get into waterways they

poison water life and any animal that drinks from them.

8.36 The River Frome is over 400 m from the Development Footprint to the south of the A419.

Therefore, the potential risk of silt run-off and pollution entering the River Frome during

construction is considered to be very low. It is therefore considered highly unlikely that any silt

or pollution from the Revised Scheme, could reach the confluence with the Severn Estuary

approximately 4.5km downstream to the west of the Survey Area.

Grassland Habitats

8.37 The effects on grasslands, hedgerows, trees and breeding birds through construction are likely

to be largely restricted to within the Development Footprint or the immediate vicinity. Semi-

improved grasslands are not well mapped in Gloucestershire, but the CEH Land Cover Map (2007)

in RS Figure 8.4 shows the distribution of ‘semi-improved grassland’ (a combination of

calcareous-, acid-, neutral- and rough grassland) in a 5km radius. From this it can be seen that

there are a number of isolated patches scattered throughout the area and they are not a rare

feature locally.

8.38 Semi-improved grassland is interpreted and mapped variously depending on the requirement.

As grasslands are often not a permanent feature, their mapping is not very reliable at the

National scale. The semi-improved grasslands within the Survey Area may be a significant seed

source for adjacent habitats available for habitat restoration at the landscape scale, as part of

the Green Infrastructure Framework for Gloucestershire. Grass seed can be dispersed by wind

tens of metres, but rarely over 50m, and herbaceous and grass seed may also be dispersed by

animals too such as birds, deer, badger and hare (epizoochory) observed within the Survey Area.

As most of the grassland affected by the development is improved, the loss of this grassland to

the development will not have a large zone of influence as the majority of grasslands in the

surrounding area are also improved and not of conservation interest.


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Hedgerows and Woodlands

8.39 Hedgerows act as important corridors for movement of species such as birds, bats and

invertebrates. The Zone of Influence for hedgerows is the Survey Area, however this zone of

influence would link in to the 10km zone of influence for bats. Loss of hedgerow continuity could

have a significant influence on bat movements because the majority of bat species (with the

exception of high flying species such as noctule, and Daubenton’s - which tend to follow water

courses) tend to forage and commute along hedgerows. It has been suggested that gaps as small

as 10-15m wide may present a deterrent to some species of bats to cross27, although recent

research has shown that pipistrelle spp. will cross gaps up to 80m even in a lit urban

environment28 . It should be noted that the Survey Area is already dissected by the M5 and the

A419. Hedgerow loss within the Development Footprint may affect the wider area with regard

to connectivity with other hedgerow networks, but as hedgerow loss will be compensated with

a net gain in hedgerow length, the zone of influence is confined to the Development Footprint.

Protected Species

8.40 Although temporary disturbance or loss of breeding habitat could result in temporal

displacement of breeding birds to the surrounding area, this is unlikely to extend more than a

few hundred metres.

8.41 The effect on reptiles is likely to be restricted to the Development Footprint, as slow worms have

very poor dispersal rates - 4m within a lifetime (Smith 1970)29 and reptiles in general have limited

dispersal rates30. Habitat where reptiles are present may be removed, but reptiles will be

translocated to the area within the Redline Boundary west of M5, so the Zone of Influence is

within the Development Footprint.

8.42 Otter territories can extend up to 20km and although the River Frome is 400m from the

Development Footprint, there is no potential risk of silt run-off and pollution that, if it entered

the River Frome during construction, could reach the Severn Estuary approximately 4.5km

downstream of the Survey Area, so the Zone of Influence is considered to be 20km.

8.43 Badger territories can extend up to several kilometres although the effects are likely only to

extend to the sett territory and the surrounding badger territories.

8.44 The majority of bats typically forage with 1-5km of their roost although some species may travel

further to suitable feeding sites, such as noctule, which travels up to 9km, Daubenton’s bats up

to 10km, Serotine up to 6km, lesser horseshoe up to 6km and greater horseshoe, when habitat

is restricted, up to 12km. There are large areas of high quality bat foraging habitat within the

Stroud Valleys and it is highly unlikely greater horseshoe bats would travel such a distance to the

lower quality habitat within this Survey Area to forage. However, it is known that greater- and

lesser horseshoes breeding at Woodchester Mansion migrate to hibernacula in old mines within

27 JNCC 2001 Habitat management for bats: A guide for land managers, land owners and their advisors.

http://jncc.defra.gov.uk/pdf/Habitat_Management_for_bats.pdf. 28 Hale, J.D, Fairbrass, A.J., Matthews, T.J., Davies, G. and Sadler, P. 2015. The ecological impact of city lighting

scenarios: exploring gap crossing thresholds for urban bats. Global Change Biology 21, 2476-2478. 29 Smith N.D. (1990) The ecology of the slow-worm (Anguis fragilis L.) in southern England. M.Phil. University of

Southampton. 30 Reptile Management Handbook 2010. ARC. Bournemouth.


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the Forest of Dean, and therefore may cross the Survey Area during autumn migration. Potential

Zones of Influence for particular receptors are shown in Table 8.1.

Table 8.1: Potential Zones of Influence

Ecological receptor Potential zone of influence

River Frome Up to 4.5km downstream to confluence with River Severn

Grasslands Within Survey Area

Hedgerows Within Survey Area

Trees Within Survey Area

Breeding birds Within or adjacent to Survey Area

Reptiles Within Survey Area

Otter Up to 20km

Badger Within Survey Area and neighboring territories

Common & Soprano Pipistrelle, and

Myotis species

Up to 1.5km

Serotine Up to 6km

Noctule Up to 9km

Daubenton’s Up to 10km

Lesser Horseshoe Up to 6km

Greater Horseshoe Up to 12km

Consultation

8.45 There has been very extensive consultation for the planning application of Eco Park

(s.16/0043/OUT), which included the Sports Park south of the A419 (no longer to be developed

as part of this Revised Scheme), and a Green Business park north of the A419 (now the location

of the Revised Scheme). Details of all these consultations are provided RS Appendix 8.7 and RS

Appendix 8.8. A further consultation letter has been sent to Stroud District Council on 23rd

October 2017, though no response has been received to this.

Methodology - Desk Study

8.46 The desk-based study methodology involved consulting both statutory and non-statutory bodies’

pre-application in order to identify protected sites and species (both confirmed and potential)

within a 5km radius of the Survey Area. Gloucestershire Environmental Records Centre (GCER)

and the Gloucestershire Bat Group provided records of protected sites and species present

within 5km, and within 10km for bats. A review of the ecological survey information from the

adjacent West of Stonehouse ES was also undertaken to ensure the data search was as

comprehensive as possible.


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8.47 This approach follows guidelines on ecological assessments that have been produced by CIEEM

in 201531 and 201626.

8.48 Features of nature conservation interest are considered to be the ecological receptors. These are

populations, species, communities, habitats and sites selected as likely to be affected (in a

positive or negative way) by the environmental changes created by a development.

8.49 The important ecological receptors define the nature conservation interest of the Survey Area

and must be valued to provide a basis for assessing the effects of a development. Valuation

usually seeks to assign a geographical frame of reference for the importance of an ecological

receptor. Those used are as follows in Table 8.2:

Table 8.2: Determining Factors for Nature Conservation Importance

Designation Importance

International Sites of international importance on the basis of their habitats or species are

designated under the EU Habitats Directive and include Special Areas of

Conservation (SACs). Candidate or potential sites for these designations are also

considered to be of international importance. Species protected under Annex II

of the Habitats Directive and given UK protected status by Schedule 2 of the

Conservation of Habitats and Species Regulation 2010.

National (i.e.

England, Wales,

Scotland or

Northern Ireland)

Sites of Special Scientific Interest (SSSIs) are of national importance and are

designated under the Wildlife and Countryside Act 1981 using guidelines on their

selection (JNCC, 1998), as well as the presence of species listed in Schedule 5 of

the Act. National Nature Reserves (NNRs) were established to protect some of

our most important habitats, species and geology, and to provide ‘outdoor

laboratories’ for research.

Regional Local authorities and County Wildlife Trusts may have designated sites of regional

importance, designation criteria being published locally. This may include areas,

habitats or species identified in regional BAPs.

County (or

Metropolitan)

Local authorities and County Wildlife Trusts may have designated sites at

regional, county or district levels (e.g. Sites of (Local) Importance for Nature

Conservation – S (L) INCs, Key Wildlife Sites (KWS) and the designation criteria

may be published locally.

District (or Unitary

Authority, City or

Borough)

Local Nature Reserve (or LNR) is a statutory designation made under Section 21

of the National Parks and Access to the Countryside Act 1949 by principal local

authorities, Parish and Town Councils

Local or Parish Habitats within a parish of local importance which may be designated as Local

Nature Reserves or local designations such as pocket parks, village greens, or

Conservation Road Verges.

Within zone of

influence only

(site or Study

Area).

Evaluation of features or resources likely to be affected. Areas or resources

affected by the biophysical changes caused by the project. Features of sufficient

value to be included and are vulnerable to significant impacts arising from the

project.

8.50 Sites worthy of designation with habitat and/or species interest at any level must have a 'viable

area' of habitat. Viability means that the area should be sufficient to maintain the habitat interest

in adequate condition through appropriate management (which might involve some form of

rotational manipulation of vegetation), as well as providing sufficient territory and suitable

habitat for the breeding and wintering populations of species of interest.

31 CIEEM (February 2015). Guidelines for Ecological Report Writing CIEEM.


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8.51 It is more difficult to judge a level of importance for Study Areas/ sites with no designation.

Ecological resources contributing to the biodiversity or nature conservation importance of a

Study Area may include:

• Internationally, nationally or locally rare or uncommon species, subspecies or varieties;

• Ecosystems or their parts supplying the requirements of populations of the above species;

• Habitat rarity, diversity and connectivity;

• Communities typical of valued natural or semi-natural vegetation types;

• Large populations of uncommon or threatened species;

• Species-rich assemblages;

• Species on the edge of their range;

• Typical faunal assemblages of homogenous habitats.

8.52 Establishment of the level of importance relating to the ecological features found by the baseline

surveys firstly involves applying the criteria for designation of international, national and sub-

national (where available) sites to the feature set. The approach should be to consider the

ecologically coherent unit(s) of the Study Area and to establish as well as possible the extent of

equivalent ecologically coherent units at the local, regional, national and international scales in

order that the Study Area can be placed in context.

8.53 Reference to national and local BAPs is necessary, although the biodiversity importance of a

particular species must be judged in relation to its rarity, distribution (national and international,

including consideration of its mobility), population size, status (e.g. population stable or

declining) and priority according to BAPs.

8.54 Other aspects that may be important in the valuation of habitats and species include potential

value (e.g. the potential for habitat enhancement or creation), social value (e.g. the value of the

Study Area to local people for recreation and the enjoyment of wildlife), economic value (e.g.

hunting and fishing interests or the value of the ecological interest as a tourist attraction), and

secondary ecological value (e.g. buffer zones to areas of greater importance or areas that are

important in ecological networks or corridors).

8.55 Legal protection must be considered and may apply to habitats and species that are rare and

declining and are covered by statutory instruments such as the Conservation of Habitats and

Species Regulations 2010, the Countryside and Rights of Way Act (CRoW Act) 2000 and the

Wildlife and Countryside Act 1981 (as amended). Species may be protected under legislation (e.g.

parts of the Wildlife and Countryside Act 1981, the Protection of Badgers Act 1992 and the Wild

Mammals (Protection) Act 1996) for reasons other than rarity. In these cases, the ecological

importance of the species concerned must be judged in their local context.

Predicting and characterising effects

8.56 Following the identification of the activities likely to cause significant effects, it is necessary to

predict and characterise the resultant changes (effects) and to assess the effect on the valued

ecological resource.

8.57 In order to do this, it is necessary to take into account the effects the following parameters will

have on the ecological structure and function of the relevant feature.

Likelihood


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8.58 A level of likelihood should be attached to both the occurrence of a predicted effect and the

assessment of its ecological effect (Table 8.3):

Table 8.3: Likelihood of Occurrence

Likelihood Definition

Certain/near-Certain: Probability estimated at 95% chance or higher.

Probable Probability estimated above 50% but below 95%.

Unlikely Probability estimated above 5% but less than 50%.

Extremely Unlikely Probability estimated at less than 5%.

Positive or Negative effect

8.59 In addition, a description of any potential effect also needs to address whether that effect will

have a positive or negative effect on the population level of a particular species or habitat.

Magnitude

8.60 This is the size or amount of an effect (e.g. a small increase in the proportion of the population

of a rare species is displaced, or a total loss of the structure and function of semi-natural

grassland). Broad categories of spatial magnitude can be defined as below (Table 8.4):

Table 8.4: Spatial Magnitude Criteria

Magnitude Definition

Very High Total loss or very major alteration to key elements/features of the baseline (pre-

development) conditions such that the post-development attributes will be

fundamentally changed and may be lost altogether.

Guide: >80% of population lost (or gained).

High Major loss or major alteration to key elements/features of the baseline conditions such

that the post development attributes will be fundamentally changed.

Guide: 21-80% of population lost (or gained).

Moderate Loss or alteration to one or more key elements/features of the baseline conditions

such that post development attributes will be partially changed.


Minor Shift away from baseline conditions. Change arising from the loss/alteration will be

discernible, but the underlying attributes will be similar to pre-development

circumstances/patterns.


Negligible Very slight change from baseline conditions. Change barely distinguishable,

approximating to the ‘no change’ situation.

Guide: < 1% population lost (or gained).

Duration and Reversibility

8.61 The period over which the effect is expected to last prior to recovery and replacement of the

feature is considered. An irreversible (permanent) effect is one from which recovery is not

possible. A reversible (temporary) effect is one from which recovery is possible (see Table 8.5).

Note these timeframes differ from the general assumed timeframes set out in the introductory

chapters of this ES.


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Table 8.5: Temporal magnitude criteria

Magnitude Definition

Permanent Effects continuing indefinitely beyond the span of one human generation (taken as

approximately 25 years), except where there is likely to be substantial improvement

after this period (e.g. the replacement of mature trees by young trees which need >25

years to reach maturity, or restoration of ground after removal of a development.

Such exceptions can be termed very long-term effects).

Temporary Long term (15 - 25 years or longer)

Medium term (5 – 15 years).

Short term (up to 5 years).

Timing and frequency

8.62 Some changes may only cause an effect if they happen to coincide with critical life stages or

seasons, such as the breeding season. The frequency of an activity should also be considered.

Significance of Effects

8.63 The effects identified are then attributed a level of significance (based on the sensitivity of the

receptor and the magnitude of the effect) and their beneficial or harmful character identified. In

order to provide a consistent approach and ensure different environmental effects are assessed

in a comparable manner; receptor value, magnitude of change and level of effect for each

environmental topic are described consistently throughout the ES as set out in ES Chapter 2:

Approach to EIA.

8.64 Where sufficient information exists to ascribe a value to a receptor and to understand the

magnitude of change, EIA often uses a matrix to determine the level of effect. An example of a

common matrix used to assess the significance of ecological effects is presented in Table 8.6. In

this approach, the level of effect matrix combines the sensitivity or importance of the receptor

being affected with the magnitude of change resulting from the development.

Table 8.6: Level of Effect Matrix with boxes highlighted considered as having significant effects

requiring mitigation

Magnitude of

Change

Importance or Sensitivity of Receptor


Very High / High Very Substantial /

Substantial

Substantial /

Moderate

Moderate /

Slight Negligible

Moderate Substantial /

Moderate Moderate Slight Negligible

Minor Moderate / Slight Slight Slight /

Negligible Negligible


8.65 While effects are considered to fall into one of five effect categories ranging from ‘negligible’,

‘slight ‘, ‘moderate’, ‘substantial’ to ‘very substantial’, it is only those effects that fall into the

‘moderate’, ‘substantial’ or ‘very substantial’ categories that are considered to be the significant

environmental effects within the meaning of the EIA Regulations arising from the construction

and operation of the development.


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8.66 However, CIEEM guidance moved away from the use of this matrix in 2006. Instead, a

transparent approach is promoted, whereby an effect is determined to be significant or not on

the basis of an evaluation of the factors that categorise it. In this chapter, the matrix set out

above is only used as a broad guide to assess whether an identified activity will have a significant

effect on ecological receptors.

Designated/defined sites and ecosystems

8.67 Significant effects encompass effects on structure and function of defined sites and ecosystems.

8.68 For designated sites it needs to be determined whether the project and associated activities are

likely to:

• Undermine the site’s conservation objectives or affect the conservation status of species

or habitats for which the site is designated either positively or negatively; or,

• Whether it may have positive or negative effects on the condition of the site or its

interest/qualifying features.

8.69 For ecosystems it needs to be determined if the project is likely to result in a change in ecosystem

structure and function. Consideration should be given to whether any processes or key

characteristics will be removed or changed; whether there will be an effect on the nature, extent,

structure and function of component habitats; or whether there is an effect on the average

population size and viability of component species.

8.70 Consideration of functions and processes acting outside the formal boundary of a designated site

is required, particularly where a site falls within a wider ecosystem e.g. wetland sites. Predictions

should always consider wider ecosystem processes.

8.71 Many ecosystems have a degree of resilience to perturbation that allows them to tolerate some

biophysical change. Ecological effects should be considered in the light of any information

available or reasonably obtainable about the capacity of ecosystems to accommodate change.

Habitats and species

8.72 Consideration of conservation status is important for evaluating the effects of impacts on

individual habitats and species and assessing their significance.

8.73 For habitats, the conservation status is determined by the sum of the influences acting on the

habitat that may affect its extent, structure and functions, as well as its distribution and its typical

species within a given geographical area.

8.74 For species, the conservation status is determined by the sum of influences acting on the species

concerned that may affect its abundance and distribution within a given geographical area.

8.75 In many cases (e.g. for species and habitats of principal importance for biodiversity), there may

be an existing statement of the conservation status of a feature and objectives and targets

against which the effect can be judged. However, not all species or habitats will be described in

this way. The conservation status of a habitat or species will vary depending on the geographical

frame of reference.

8.76 When assessing potential effects on conservation status, the known or likely background trends

and variations in status should be taken into account. The level of ecological resilience or likely


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level of ecological conditions that would allow the population of a species or area of habitat to

continue to exist at a given level, or continue to increase along an existing trend, or reduce a

decreasing trend, should also be estimated.

Limitations of Assessment

8.77 It is neither possible nor intended to cover the entire ecology of a site during a survey for an

outline application such as this.

8.78 This report is based upon the results obtained from ecological surveys conducted in 2015 and

2016 plus a walkover survey in 2017. There is only a limited time- lag between the detail surveys

and the date when activities are likely to take place, therefore surveys still provide a reliable

indication of the baseline conditions and a robust basis to assess any potential effects. Walkover

surveys conducted during 2017 noted no changes the distribution or management of habitats

recorded on site and no change in badger sett use from 2016.

8.79 Best practice was followed for the faunal field surveys, the species in question are secretive

animals and it is possible that some field signs may have been overlooked. In addition, usage of

the Survey Area by many mammal species for foraging, shelter and as a transit route varies with

season, and the surveys carried out therefore represent only ‘snapshots’ of activity within the

Survey Area at the time of the survey. In order to overcome this limitation in relation to bats, an

intensive static bat detectors survey was conducted to record bat activity throughout the Survey

Area over the survey period. (See RS Figure 8.5). It should also be noted that absence of recorded

field signs is not necessarily evidence that a particular species is not utilising an area. However,

this report will identify the probable value of the Survey Area for the pertinent species, based

upon the survey data gathered.

Baseline Conditions

8.80 The area surveyed (Survey Area) for the baseline habitat, NVC and protected species surveys is

shown in RS Figure 8.3. It encompasses land to north of A419 (18.9ha), south of A419 (13.5ha)

west of the M5 (4.6ha), as well as an area between the Redline Boundary and the river Frome.

The full details of the survey methods and results for the vegetation surveys and protected

species are presented in RS Appendix 8.1 Baseline Survey and RS Appendix 8.2 Fauna Surveys

respectively. The surveys were carried out by experienced professional ecologists following the

appropriate survey guidance.

Site description

8.81 The Site is situated in the Severn and Avon Vale Natural Area, an area that is a low-lying

undulating plain through which the rivers Severn and Avon and their many tributaries flow. It

comprises of agricultural land with fields cut for silage and hay and some limited cattle grazing.

The Development Footprint is bounded by the M5 on the west and the A419 to the south. Grove

Lane, residential housing and agricultural land bound the site to the north and agricultural land

and a service station adjoin it on the eastern boundary. The Development Footprint is bounded

by hedgerows. The external hedgerows are largely intact, although a number of the internal

hedgerows are becoming gappy and defunct due to damage by cattle and lack of management.

A number of hedgerows have standard trees present. There is one small water course on the

north-western boundary of the Survey Area (the Selbrook). This flows under the M5 and flows

parallel to the River Frome before entering the Frome at Wheatenhurst 3 km to the west of the


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site. Construction has started on the West of Stonehouse (WOS) housing development (1,350

houses) on the opposite side of Grove Lane, the boundary of which is less than 50m from the

boundary of the site.

8.82 The Survey Area south of the A419, which is not to be developed as part of the Revised Scheme,

is surrounded by scattered industrial development, residential housing, the M5, and agricultural

land. William Morris College and Eastington Business Park are directly to the east and south-east

of the Redline Boundary south of the A419. Stonewater Business Park is 1.5 km to the east. The

south is bounded by the River Frome flood plain. The original route of the Stroudwater Canal

runs through the land to the south of the Redline Boundary from east to west. The former line

of the Canal was infilled, and the route blocked during the construction of the M5.

Statutory designated sites - International and nationally important sites

8.83 Statutory Designated Sites within 10km of the Development Footprint are shown on RS Figure

8.6.

8.84 The Severn Estuary SPA/SAC/Ramsar Site (designated for overwintering wetland birds and for

presence of mudflats, Atlantic salt meadows, sea lamprey, river lamprey and Twaite shad) is

located 3.8km directly to the west of the Survey Area in a straight line (4.5km downstream

following the Frome to its confluence with the Severn).

8.85 Rodborough Common SAC/SSSI, internationally important for calcareous grasslands, is 6km to

the east of the Survey Area and the Cotswold Beech Wood SAC is just over 10km from the Survey

Area.

8.86 Frampton Pools SSSI (wetland) is 1.6km from the Survey Area to the west of the M5 and A38.

The Upper Severn Estuary SSSI (estuarine habitat including salt marsh, pasture and over

wintering wetland birds) is 3.8km to the west of the Survey Area in straight line and Haresfield

Beacon SSSI (limestone grassland) is 4.2km to the east of the Survey Area. Woodchester Park

SSSI is designated for a breeding colony of greater horseshoe bats within the Mansion (deciduous

woodland and semi-improved grassland and associated species) and is just over 5km from the

Development Footprint, but within 5km of the of proposed cycle track improvements.

8.87 Selsley Common SSSI, just over 5km from the Survey Area, is designed principally for the herb

rich calcareous grassland and associated species but also includes Leigh’s Quarry which is notified

for its geological interest.

8.88 Minchinhampton Common SSSI is just over 8km from the Survey Area. Whilst principally

designated for herb-rich limestone grassland and associated species, the citation also mentions

the disused stone mines on the Nailsworth side of the Common, which are used as winter roost

sites by the greater horseshoe bat.

8.89 There are three principal geological SSSIs within 10km: Edge Common 6.5km to the north east,

Garden Cliff 5.6km to the west on the bank of the River Severn and Coaley Wood Quarries 7.2km

to the south.

Non-statutory designated sites and Strategic Nature Area

8.90 Non-Statutory sites within 5km are shown on (RS Figure 8.6). There are 18 Key Wildlife Sites

(KWS), six conservation road verges and a further 22 Potential Key Wildlife Sites (PKWS) within

5km of the Survey Area.


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8.91 The Frome Valley Strategic Nature Area (SNA) (No. 55) encompasses the two KWSs (River Frome

(SO70) and River Frome (SO80) and is part of the larger Severn Vale Priority Landscape. The main

body of the SNA and associated floodplains extends for 5km on either side of the Survey Area

(RS Figure 8.6) linking the River Frome with the River Severn to the North.

Historic management

8.92 The land has traditionally been farmed. There is evidence within the Survey Area of ridge and

furrow dating from the Middle Ages and more recent ridge furrow probably dating from the

Napoleonic Wars period. The hedgerow network and field boundaries appear to have changed

little, although the construction of the canal, M5 and A419 has dissected the landscape through

the Survey Area (see Figure 10.6a 1st edition OS Map).

Desk Study Protected Species

Flora

8.93 Native Bluebell Hyacinthoides non-scripta is the only protected plant species recorded within the

Survey Area.

Amphibians and reptiles

8.94 There are no records of reptiles or amphibians from within the Survey Area. However, there are

records of common toad Bufo bufo, common frog Rana temporaria, great crested newt Triturus

cristatus, common lizard Lacerta zootoca, grass snake Natrix natrix and slow-worm Anguis fragilis

within 5km (as supplied by GCER). The nearest record of great crested newt is at 2.2km north-

east of the Survey Area. Further details are provided in RS Appendix 8.2 Fauna Surveys and the

location of these records is shown on RS Figure 8.7.

Invertebrates

8.95 There are no records for White-clawed crayfish Austropotamobius pallipes within 5km of the

centre of the Survey Area. In addition, a detailed evaluation was procured from GCER for the

adjacent Key Wildlife Sites, and white-clawed crayfish were only reported in the upper reaches

of the Frome and tributaries.

Mammals other than bats

8.96 Water vole Arvicola amphibius, badger Meles meles, and otter Lutra lutra have been recorded

within a 5km radius of the Survey Area and the location of these records is shown on RS Figure

8.7 and on RS Figure 8.8 Confidential Protected Species Records-Badgers (not for general

release to the public). There are records of otter signs from the River Frome.

8.97 There are no records for Hazel dormouse Muscardinus avellanarius within 5km of the Survey

Area. There has been no evidence of hazel dormouse present within the Survey Area, and surveys

conducted as part of the WOS application did not find this species.

Birds

8.98 Protected bird species were identified as being on the Red List for Britain (Birds of Conservation

Concern, Schedule 1 of the Wildlife and Countryside Act and Annex I of the Birds Directive). Due

to the close proximity of the Severn Estuary SPA, a large number of protected bird species records

(2,356) fitting these criteria occur in the area. The species are shown on RS Figure 8.9, RS Figure

8.10 and Figure 8.11, where they are mapped according to their level of protection.

Bats


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8.99 There are records of fourteen species of bat within 10km of the Survey Area: greater horseshoe,

lesser horseshoe, common pipistrelle, soprano pipistrelle, whiskered bat Myotis mystacinus,

Brandt’s bat Myotis brandtii, Natterer’s Myotis nattereri, Daubenton’s bat, Bechstein’s Myotis

bechsteinii, barbastelle Barbastella barbastellus, brown long eared Plecotus auritus, serotine

Eptesicus serotinus, Leisler’s Nyctalus leisleri and noctule Nyctalus noctula (RS Figure 8.12 and

RS Figure 8.13). RS Figure 8.13 distinguishes between the different types of roost recorded on

the GCER database.

Baseline Ecological Conditions - Habitats

8.100 Full details of the habitat and species surveys are provided in RS Appendix 8.1 and RS Appendix

8.2 and these are summarised below.

8.101 The majority of the habitat within the Development Footprint is lowland neutral agriculturally

improved and semi-improved grassland divided by mature hedgerows (RS Figure 8.14).

Hedgerows within the Survey Area contain a number of mature trees. The Survey Area is drained

by a small number of ditches - the internal ditches are seasonally dry. There is a permanently

flowing water course (the Selbrook) in the north west corner which flows into the River Frome

3km west of the Survey Area (it is culverted under the M5 – see also RS Figure 9.1). On the

northern boundary adjacent to Grove Lane there is a modern barn used for hay storage

surrounded by several abandoned and partially derelict farm buildings.

Hedgerows

8.102 Hedgerows surround all the fields within the Development Footprint. Whilst most of the

boundary hedgerows are intact, a number of the internal hedgerows have become gappy and

defunct due to lack of maintenance and cattle damage. Analysis of the hedgerow flora to the

north of the A419 showed that three hedgerows (NH12, NH13 and NH15, RS Figure 8.14) showed

evidence of being woodland remnants due the presence of woodland ground flora. This indicates

that one of the fields (Field 5, RS Figure 8.14) may have been woodland in the past that was

cleared prior to 1846. This would have incorporated the existing two small blocks of woodland

to the north of the A419 and connected directly to the double hedgerow (Hedgerows NH5 and

NH6, RS Figure 8.14). The rest of the hedgerows in the Development Footprint fell into three

compartments: hedgerows of low species diversity (18-21 spp.), of medium species diversity (25-

34 spp.) and of high species diversity (36-45 spp.). The number of woody species in all hedgerows

ranges from three-nine, and nine of the 16 hedgerows meet the criteria for ‘Important

Hedgerows’ under the Hedgerow Regulations (Defra 199732). With the exception of the

hedgerows either side of the A419, all the hedgerows were present on the 1846-1899 Ordnance

Survey Map (RS Figure 10.6a). The hedgerows either side of the A419, or adjacent to the M5,

were planted in the late 1960’s/early 1970’s when these roads were constructed. Full details of

hedgerows present are provided in RS Appendix 8.1.

Woodland

8.103 There are two small areas of broad-leaved woodland within the Development Footprint. The first

woodland to the north of A419 occurs between Field 2 and Field 5 (Woodland (RS Figure 8.14)).

Tree species present include Goat Willow Salix caprea, Pedunculate oak Quercus robur, Field

maple Acer campestre and saplings of Hawthorn Crataegus monogyna. The Field Maples have

32 The Hedgerow Regulations (1997) A guide to the law and good practice. DEFRA.


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rot holes suitable for roosting in by bats. The ground flora is rank with abundant grass species,

bramble and some Rose Rosa species with very few woodland species present. The second area

of woodland to north of A419 has been truncated by the A419. There are several mature trees

present e.g. Pedunculate Oak, Ash Fraxinus excelsior, Field Maple, Poplar Populus spp. and Elder

Sambucus nigra. The ground here is in a dip, is muddy in places and has some species indicating

wetness e.g. Small Sweet Grass Glyceria declinata and Hairy Sedge Carex hirta. The ground flora

is overgrown with brambles and rank grassland but some remnants of a woodland flora are

present e.g. Violets Viola spp., Bluebell Hyascinthoides non-scripta, Lords and Ladies Arum

maculatum and Creeping Jenny Lysimachia nummularia. The full species list can be found in RS

Appendix 8.1; Annex 1D (Woodland (ii)).

8.104 There are two further areas of woodland on the boundary of the Development Footprint. These

areas are part of an embankment adjacent to the M5 roundabout, which extends beyond the

Survey Area boundary and are of recent origin (1977). A mixture of early mature broadleaved

species were found here including Field Maple, Hawthorn, Elm Ulmus spp., Ash, Poplar and Crack

Willow. The two areas form a broad shelter belt providing good screening (see RS Appendix 8.3

Arboricultural Report and RS Figure 8.1).

Trees

8.105 The small blocks of mature woodland within the Development Footprint contain mature Ash,

Pedunculate Oak, Field Maple and Hawthorn. These are marked on the 1845 1st Edition

Ordnance survey map (RS Figure 10.6a). The southern block of woodland was divided into two

parts with the construction of the A419 which opened in 1970-71.

8.106 There are also standard mature trees in a number of the hedgerows throughout the Survey Area

e.g. Ash, Field maple, Elm, Wild Pear Pyrus communis and Hawthorn.

8.107 An Arboricultural Survey was carried out in 2016 (RS Appendix 8.3). This identified eight Category

A1 trees (trees of high quality), 21 Category B (moderate quality) and 25 Category C trees (low

quality) or tree groups (RS Figure 8.1). Of note is the well-formed and broad roadside Oak, tree

T21 and other Oak trees T14 and T26 to T28 within the Development Footprint, which collectively

form a significant and large feature.

8.108 There is one large and old Ash tree which are classed as of high conservation value (T4), due to

size, age and features such as internal decay and cracks that provide valuable habitat for many

species of flora and fauna. These trees have been pollarded over many years and this has helped

them remain standing as well as increasing the number of potential wildlife-friendly features.

Pollarded Ash are also of significance through the County of Gloucestershire. Similarly, tree T3,

an ancient Oak in decline, provides numerous habitat features although it has been classed as

the lowest retention category (Category U; Trees with serious defects, or dead) within the British

Standard.

Grassland

8.109 The majority of the grasslands within the Development Footprint are improved, with some semi-

improved grassland present (MG7, MG7b, MG7d; Lolium perenne leys and related grasslands)

(RS Figure 8.15). A strip of grassland forming roughly a 30m margin along the western boundary

of Field 3 adjacent to the M5 was classified as MG6a, b (Lolium perenne-Cynosurus cristatus

grassland), which is less improved and characterised by Sweet Vernal Grass Anthoxanthum

odoratum (RS Figure 8.15). Fields 1, 2, 4 and 5 are predominantly MG7, but more disturbed areas


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within 4 and 5 reflected OV 23 (Lolium perenne - Dactylis glomerata community) and OV 26

(Epilobium hirsutum community), due to heavy tractor movements within those fields (RS Figure

8.15).

8.110 There are ridge and furrow formations within the fields present, particularly in Fields 1, 2 and 5

(RS Figure 8.15). There are a mixture of wide medieval and narrow post-medieval (Napoleonic)

furrows, with both types present in Field 5 to the north of the A419. However, the botanical

survey did not identify any flora typical of ridge and furrow indicating that these have been

improved with fertilizers or possibly re-seeding.

8.111 The two verges along the A419 belong to Conservation Road Verge CRV009, designated by

Gloucestershire County Council in association with the Gloucestershire Wildlife Trust (GWT) and

GCER. This includes the roundabout on Chipmans Platt and beyond the M5 roundabout to the

A38 junction. The verges were surveyed in June 2016 and results showed that the verge north of

the A419 has a greater species diversity than the southern side, with 70 species recorded and

four indicator species. More hedgerow ground flora and wetland species are also present in the

northern verge. This corresponded with the most recent surveys carried out by the GWT in 2015.

Water courses

8.112 There is a water course (Selbrook, RS Figure 9.1) in the northwest corner of the Development

Footprint which flows south and the under the M5 and A38 and flows parallel to the River Frome

before entering the Frome at Wheatenhurst 3 km to the west of the site. This flows throughout

the year in a deep cut channel approximately 1.5m deep. It is heavily shaded by the adjacent

hedgerow with very limited flora. (RS Figure 8.15).

Baseline Ecological Conditions - Species

Flora

8.113 Bluebell Hyacinthoides non-scripta was the only protected plant species recorded during the

surveys on several hedgerows and woodland remnants to north and south of A419 (RS Appendix

8.1).

Amphibians

8.114 No ponds or standing waters holding water beyond early May 2015 were found within the Survey

Area. Water Samples for eDNA were collected from two water bodies in 2016; one from the west

of the M5 and one from the south of the A419. The test results from ADAS proved negative for

great crested newt DNA.

Reptiles

8.115 There is limited suitable habitat for reptiles within the Survey Area. Reptile surveys were

conducted in spring and summer 2016 and recorded very low numbers of grass snake and slow

worm adjacent to the A419 and west of the M5 (see RS Figure 8.16).

Water voles

8.116 Whilst the habitat along the River Frome is suitable, there was no evidence of water voles on this

section of the Frome. American mink, a major predator of water vole are still present in the

Severn Vale. However, with an increasing otter population in the Stroud Valleys there may be

future potential for re-colonisation of water vole in the local area. There is insufficient flow and

riparian habitat in the Selbrook adjacent to the Development Footprint site to support water

vole.


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Hazel dormouse

8.117 There is very limited suitable habitat for use by hazel dormice within the Survey Area and no

ecological connections to suitable habitat or woodland where dormice are known to be present.

Badgers

8.118 Badger setts were found within the Development Footprint. A Confidential Badger Report is

provided with regard to this in the Confidential RS Appendix 8.4 and RS Figure 8.8, RS Figure

8.29 and RS Figure 8.30. The report and the figures are not publicly available.

Otters

8.119 Fresh otter footprints and spraints were recorded on rocks and wet mud adjacent to the River

Frome under the M5 River Frome Underpass and under the road bridge over the Frome on Spring

Hill during 2015 and 2016. The flow in the Selbrook is insufficient to provide suitable foraging

habitat for otter where it flows adjacent to the Development Footprint.

Bats

Endoscope surveys

8.120 A preliminary bat roost feature assessment of trees and buildings within the Survey Area was

carried out from ground level in 2016 with the aid of binoculars. This included looking for

woodpecker holes, rot holes, cracks, crevices, cavities, gaps between overlapping branches and

extensive areas of ivy on larger trees, signs of bats, such as staining or bat droppings below a

PRF, scent of bats or audible squeaking in suitable conditions. A total of 80 trees in the Survey

Area were surveyed for potential roost features (PRFs) of which 34 of these were within the

Development Footprint. Endoscope surveys were carried out on 20 trees with identifiable PRFs

(RS Figure 8.17) within Development Footprint. Inspections of PRFs were carried out up to 4m

above ground level with a telescopic ladder (Annex VI in RS Appendix 8.2). No bats or signs of

bats were found during the endoscope surveys. Emergence surveys were conducted on trees

with PRFs features above 4m. A visual assessment of the derelict farm buildings was carried from

safe locations. Limited suitable potential roost location were identified. Although no feeding

signs (moth wings or beetle carapaces) of horseshoe bats were found it was considered that

three of these barns could potentially provide suitable night roosts.

Emergence surveys on buildings and trees

8.121 Two emergence surveys and one re-entry survey was carried out on the derelict farm buildings

north of the Survey Area in June 2016. Emergence surveys were conducted on 52 trees (19 within

Development Footprint) and re-entry surveys conducted on 27 trees (6 within the Development

Footprint) (RS Figure 8.18 and Annex VI in RS Appendix 8.2).

8.122 No roosts were identified within the Development Footprint during the emergence, re-entry and

endoscope surveys. A single bat (Myotis sp. probably a whiskered/ Brandt’s bat based on the

echolocation), was recorded emerging from a group of old Field Maple (Hedgerow SH10, T81-

T89; south of the A419 (RS Figure 8.18) on one occasion. This tree is over 150m from the

Development Footprint. Evidence from emergence- and re-entry surveys indicate the bats using

the Development Footprint are from off-site roosts. During transect surveys and emergence

surveys bats were observed coming onto the Survey Area after sunset or leaving the Survey Area

just before dawn.


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Transect activity surveys

8.123 Five bat activity transect surveys were conducted in 2015 and a further five activity transect

surveys were carried out in 2016, including a dawn re-entry survey (RS Figure 8.19).

8.124 At least ten bat species were recorded during the transects: common pipistrelle, soprano

pipistrelle, Myotis spp. (mainly Daubenton’s, but also Natterer’s Myotis natterer and

Whiskered/Brandt’s Myotis mystacinus/Myotis brandtii), noctule, lesser horseshoe, brown long-

eared and Leisler’s.

8.125 A low level of bat activity was recorded over most of the Revised Scheme area with

concentrations of activity close to suitable foraging areas such as woodlands, mature trees and

green lanes (double hedgerows with a track or footpath between the two hedgerows). Common

and soprano pipistrelle were the most frequently recorded species within the Survey Area.

However, there was a high level of Myotis spp. (Daubenton’s bat) activity adjacent to the River

Frome, particularly adjacent to the River Frome Underpass. This is, however, over 400m from

the Development Footprint. There were smaller numbers of noctule bat passes and several

Leisler’s passes. One lesser horseshoe pass and one long- eared bat pass was recorded during

the transect surveys. A visual summary of bat passes on activity transects in 2015-2016 is shown

in RS Figure 8.19.

Static surveys

8.126 Static detector surveys (2015 and 2016) obtained a total of 935 nights recording from detectors

placed at 62 different locations across the Survey Area as well as two locations on and adjacent

to Chipmans Platt roundabout (RS Figure 8.5). Paired static detectors were deployed at four

locations along the A419 in order to detect evidence of bats crossing the A419. Paired detectors

were also placed in the M5 Pedestrian Underpass and the River Frome Underpass under the M5

to discover if bats were using these. A total of 533 night’s recording from 34 locations were made

within or directly adjacent to the Development Footprint.

8.127 A total of 147,979 passes were recorded from all static locations in the Survey Area. The number

of bat passes ranged from zero to over 2,900 Myotis spp. passes per night (mainly Daubenton’s

at the River Frome Underpass). Overall Myotis spp. (mainly Daubenton’s) were the most

frequently recorded species although this was largely due to the high level of bat activity

recorded from locations adjacent to the River Frome (RS Figures 8.21 to 8.26 and Annex IV A in

RS Appendix 8.2.). A total 46,839 passes were recorded within the Development Footprint over

the two seasons of intensive static monitoring. (Annex VI in RS Appendix 8.2).

8.128 Within the Development Footprint, common pipistrelle are the most frequent species recorded

accounting for 74% of passes, soprano pipistrelle 10%, Myotis spp. 8%, noctule 5%, lesser

horseshoe 1.2 %, greater horseshoe 0.9%, serotine 0.01%, brown long-eared 0.2% and Nathusius

pipistrelle 0.04%( Annex IV f in RS Appendix 8.2).

8.129 There appear to be several Myotis species using the Survey Area. Daubenton‘s were recorded

foraging over the Frome, particularly at the River Frome Underpass. Based on calls only, it

appears that there are probably also Natterer’s and Brandt’s/Whiskered using the Survey Area

(RS Figure 8.23 and RS Appendix 8.2 Annex IV f).

8.130 Greater horseshoe was recorded along the northern boundary of the Survey Area, occasionally

along other hedgerows, adjacent to the open disused farm buildings on the northern boundary


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of the site, as well as along the alignment of the disused Stroudwater Canal and under the

Pedestrian Underpass of the M5 (see RS Figure 8.26). Within the Development Footprint greater

horseshoe were recorded mainly along the northern boundary and within derelict farm buildings.

8.131 Lesser horseshoe were recorded in the open partially dilapidated farm buildings. They were also

recorded throughout the Survey Area along the old route of the canal, adjacent to the River

Frome, on the River Frome under the River Frome Underpass, and in the M5 Pedestrian

Underpass (see RS 8.21). Within the Development Footprint Lesser Horseshoe bats were

recorded along the northern boundary, within the derelict farm building and along the double

hedgerow.

8.132 A small number of serotine and brown long- eared bats were recorded, along with several

Nathusius pipistrelle.

8.133 Evidence from static and transect surveys indicates a generally low level of bats commuting along

hedgerows around the Survey Area. However, there was a concentration of activity when one or

two bats were feeding around mature trees, tall hedgerows, farm buildings, in the lee of the

small blocks of woodlands, over orchards north of the Survey Area or over the River Frome (RS

Figures 8.21 to 8.26 and RS Appendix 8.2 Annex IV f).

Bat use of the M5 Pedestrian Underpass

8.134 Paired bat detectors were placed within the M5 Pedestrian Underpass in June, July 2016 and

August, September 2016. These recorded a small number of greater horseshoe and lesser

horseshoe passes each night and provided evidence that a small number of these may have been

passing through the M5 Pedestrian Underpass (RS Appendix 8.2 Annex II location 16 location

46; RS Appendix 8.2, Table 8.2.8 - 8.2.10.). However, without radio-tracking, it is not possible to

categorically prove an individual bat is passing through the tunnel at a particular time. However,

the data collected provides evidence that the M5 Pedestrian Underpass is used by a small

number of lesser and great horseshoe bats to get from one side of the M5 to the other.

Assessment of bats crossing the A419

8.135 Paired bat detectors at four locations along the A419 recorded a relatively high level of bat

activity in some locations (common pipistrelle and Myotis spp.), close to the small block of

woodland either side of the A419 and by more recent woodland adjacent to the M5 junction.

There was evidence of a number of common pipistrelle crossing the A419 within the range of the

bat detectors (RS Appendix 8.2; Table 8.2.7a). A visual survey confirmed several common

pipistrelle and Myotis spp. crossing at locations 54-55 by the green lane on the eastern boundary

of the Survey Area and three bat species crossing at locations 52/53 between the blocks of

woodland adjacent to Junction 13 on the M5 (RS Appendix 8.2, Table 8.2.7b; RS Figure 8.5).

Noctule bats were regularly seen and heard flying high over the A419 during transect and

emergence surveys. There was no evidence of greater or lesser horseshoe bats crossing the A419.

Birds

8.136 A total of 52 species were recorded during the 2015 breeding bird survey of which 31 species

showed evidence of breeding (RS Appendix 8.2 Table 8.2.2; RS Figure 8.27 and RS Figure 8.28).

In 2016, 54 species were recorded of which 30 were recorded breeding. Most of the species

recorded breeding were common farmland or garden birds.


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8.137 Five UK Red Listed species (herring gull, skylark, song thrush, house sparrow and starling) were

recording during the surveys but only song thrush was recorded breeding within the Survey Area.

House sparrow and starling were recorded breeding in dwellings just outside the Survey Area

boundary. A single skylark was recorded defending a territory outside the Survey Area south of

the River Frome in 2015 and 2016. Herring gull were recorded foraging after hay/silage was cut,

these were most likely from the breeding population on the factory roofs in Stonehouse

Industrial Estate. One reed bunting (Local BAP species) was recorded defending a territory south

of the River Frome to the south-west of the Survey Area.

8.138 Kingfisher, listed on Schedule 1 of the Wildlife and Countryside Act (1981) and Annex 1 of the

Birds Directive (1979), was recorded on the River Frome although the nest site was not recorded.

A pair made a successful breeding attempt along the river close to the Survey Area in 2015 as

young were observed. Little egret, which is listed on Schedule 1, was recorded foraging adjacent

to the River Frome in 2015 and 2016.

8.139 Within or directly adjacent to the Development Footprint 15 species of common farmland birds

were recorded breeding in both 2015 and 2016, including Song Thrush.

Design Evolution

8.140 Several aspects of the design evolution were modified to avoid significant negative effects on

habitats and species identified within the Development Footprint (embedded mitigation/

avoidance). Further account was also taken of the location of the ecological features described

above in order to ensure that effects on ecology were minimised and avoided through further

embedded changes to design. These included, for example, adjustment of the location of the

entrance to avoid a group of trees and adjustment to the stadium location and car park

arrangement to minimise hedgerow loss. The construction effects are defined in Table 8.7 in

this document.

8.141 The majority of mature trees will be retained both for their ecological and landscape value within

the Development Footprint. The placement of the road entrances from the A419 (Transport and

Access, Chapter 12) was designed to avoid the small woodland blocks along the A419 identified

during the Phase I Habitat Survey (RS Appendix 8.1).

8.142 Hedgerows SH1 and SH4 to the south of the A419 (RS Figure 8.14) and two Class A mature oak

trees (T59 and T60 RS Figure 8.1) and a further seven younger trees will be affected by the

widening of the A419. Prior to the carriageway widening, the hedgerows will be translocated

40m to the south of the original alignment. The translocation of this hedgerow rather than re-

planting will ensure rapid re-growth and retention of the ground flora (3-5 years). The road verge

will also be re-established from locally sourced seed banks e.g. from the Conservation Road

Verge CRV009. The majority of hedgerow NH6 and NH5 will be affected by the construction of

the stadium. The affected parts of these hedgerows will be translocated to a line parallel with

NH3 to re-create a new double hedgerow to retain ecological connectivity.

8.143 A bat commuting corridor will be created to provide commuting and foraging opportunities for

bats while preventing light spill. The bat corridor will incorporate a 2m bund on which the inner

hedgerows (the hedgerows closest to the built development) will be planted to prevent light spill

and act as a buffer against noise (enhancement).

Potential Effects


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Potential construction effects to be assessed

8.144 A range of construction activities will be required for the various elements of the project (Chapter

5; Description of the Revised Scheme). These include temporary construction compound(s),

storage of construction materials, temporary access routes on and within the Development

Footprint, vegetation clearance, soil removal, ground and excavation work, establishment of

built structures, roads and car parking.

Table 8.7: Construction effects to be assessed

Construction Activity Effect Potential Effects on Receptors

General (Temporary) Noise, vibration,

movement and physical

disturbance of vegetation

Loss or disturbance of habitat and

fauna, runoff of silt and fine

sediment into water courses.

Foundations (Temporary) Noise, vibration,

removal or alteration of

habitat

Disturbance or loss of habitat

Built development

(including roads and car

parks)

Removal / overlaying of

vegetation

Loss of habitat runoff of silt and

fine sediment into water courses.

Construction Lighting Increasing lighting of dark

areas

Creation of ecological traps for

insects attracted to lighting,

disruption of foraging and

commuting routes due to

avoidance of light by certain bat

species.

Construction Compound Removal / overlaying of

vegetation

Loss of habitat

Potential operational effects to be assessed

8.145 Operational effects are defined in Table 8.8 as habitat- or species loss due to development

infrastructure.

Table 8.8: Operational effects to be assessed

Operating Effects Effect Potential Effects on

Receptors

Use of Stadium and Car

parking

Increased movement of cars and

people, noise and lighting

Disturbance to species

Service and Maintenance Vehicle movements / personnel on Site Disturbance to species


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Operating Effects Effect Potential Effects on

Receptors

Lighting Increased lighting of dark areas Creation of ecological traps

for insects attracted to

lighting. Disruption of

roosting, foraging and

commuting routes by

certain bat species due to

avoidance of light.

Water run-off from

buildings and hard standing

Increased flow in the drainage ditches

within the Survey Area and River

Frome.

Increased silt, carried along

ditches and potential

damage to habitat

Ecological receptors to be considered

8.146 The ecological receptors (habitats and species) found on or adjacent to the Survey Area are

considered in this section. Receptors considered unlikely to be significantly affected by the

development have been scoped out of the assessment. These are listed in Table 8.9, along with

the reason for their removal.

Table 8.9: Ecological receptors scoped out of the Assessment

Ecological Receptor Nature

Conservation

Value/

sensitivity

Rationale for Scoping out of Detailed Assessment

Rodborough

Common SAC

High -

Internationally

important

calcareous

grassland

The development is over 6km from the SAC. There will be

no residential development and therefore no increase in

recreation pressure on Rodborough Common.

Cotswold Beech

Woods SAC

High-

Internationally

Important Beech

Woods

The development is over 10km from the SAC. There will be

no residential development and therefore no increase in

recreational pressure on the Cotswold Beech Woods SAC.

There will be no heavy industrial processes, producing

increased levels of air pollution and will therefore not add

to the cumulative air pollution effect on the SAC (See

Chapter 13 Air Quality).

Severn Estuary

SPA/Ramsar

High

International

Importance for

wintering water

fowl

There will be no direct loss of habitat within the SPA

boundary. During construction there is potential for noise

and disturbance, however the Development Footprint is to

the east of the A38 and M5 from the estuary and over

3.8km away (straight line distance), therefore there will be

no noise or visual disturbance to wintering waterfowl.

There is a hydrological connection between the Revised

Scheme and the SPA, but as the Key Wildlife Site is acting as

a buffer and, providing no pollution is allowed to enter the

watercourse, it is probable that likely significant effects can

be screened out).


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Ecological Receptor Nature

Conservation

Value/

sensitivity

Rationale for Scoping out of Detailed Assessment

The football stadium will attract an increase in numbers of

people to the area, but any increase in road traffic will be

sufficiently distant from the estuary to have no effect on

wintering waterfowl. The new football stadium will be lit at

certain times; however, the level of lighting will not reach

the estuary. Therefore, it is considered the development

will have no effect on the Severn Estuary SPA.

Frampton Pools SSSI High: National

importance for

wetland plants

and wetland

birds.

There is no hydrological connection between Development

Footprint and Frampton Pools SSSI; therefore, the Revised

Scheme will have no effect on the water quality of the SSSI.

Frampton Pools is separated from the site by an area of

woodland, an old gravel working currently being used for

inert landfill, a very active lorry depot, a mineral extraction

site as well as the A38 and M5. Therefore, it is considered

that there will be no disturbance to wetland birds from

either the construction or operation of a stadium.

Haresfield Beacon

SSSI

High There will be no development in or adjacent to SSSI and

there is no hydrological connection.

Rodborough

Common SSSI



Edge Common SSSI High There will be no development in or adjacent to SSSI and


Minchinhampton

Common SSSI

(botanical interest)



Coaley wood

Quarries SSSI



Garden Cliff SSSI High There will be no development in or adjacent to SSSI and


Selsley Common

SSSI



Otter High Present but there will be no development within a distance

of c. 400m of River Frome.

Water Vole High Not currently present on this section of River Frome.

Hazel Dormouse High No records close to Survey Area and very limited suitable

habitat. Non-recorded on surveys on the adjacent WOS site

Amphibians Local Some ephemeral ditches were found within the Survey

Area although these had dried up before the main breeding

period.

Great crested newt High No suitable ponds within the Survey Area, no evidence of

great crest newt DNA from suboptimal water bodies.

Identified construction effects


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Statutory Designated Sites of International Importance: Severn Estuary SAC

Evaluation and assessment of potential effects and significance

8.147 The SAC is over 3km from the Development Footprint, therefore there will be no direct

disturbance or habitat loss during construction. There will be no construction within 400m of the

River Frome. Therefore, during construction, there is very limited potential for increased run-off

of sediment, fine silts or contaminated water via the streams or as run-off into the River Frome,

and ultimately the SAC during construction. The Selbrook flows along the northwest corner of

the Development Footprint which flows south under the M5 and A38 and flows parallel to the

River Frome before entering the Frome at Wheatenhurst 3 km to the west of the site. There will

be no built development within 150 m of the Selbrook, however the northern practice pitch will

be constructed within 10m of this water course. Therefore, there is a very low potential risk for

silt runoff. It is considered highly unlikely that any fine silts, sediments or chemical

contamination will enter these water courses or reach the River Severn SAC 3km downstream.

Given the massive volume of silt moving up and down the estuary on each tide the volumes

involved would be insignificant.

8.148 Therefore, there will be no potential negative effect on Sea Lamprey, River Lamprey and Twaite

shad and therefore the effect is not significant. However, a precautionary approach has been

taken.

Mitigation

8.149 Despite the effects being considered not significant, a precautionary approach will be adopted.

A detailed Construction Environment Management Plan (CEMP), including a Pollution Prevention

Plan will be developed and agreed with the LPA and the Environment Agency prior to

commencement of development and secured by condition as part of any permission granted. An

Ecological Clerk of Works (ECoW) will be employed to ensure this is fully implemented.

8.150 Suitable Sustainable Drainage Systems (SuDS) will be installed throughout the Revised Scheme.

Where necessary, this will include silt and oil traps (see Chapter 9, Flood Risk, Hydrology and

Drainage). Therefore, it is certain there will be no significant effects of the Severn Estuary SAC.

Residual significance

8.151 There is no residual significance.

Statutory Designated Sites of National Importance: Woodchester Park SSSI


8.152 Woodchester Park SSSI is designated principally for a breeding colony of greater horseshoe bats

within the Mansion, deciduous woodland and semi-improved grassland and associated species.

The Mansion building also supports a large breeding colony of lesser horseshoe bats although

these are not included in the citation. This SSSI is just over 5km from the Development Footprint,

although within 5km of the proposed cycle path improvements. There will be no direct loss of

habitat to this SSSI. Greater horseshoe bats tend to forage within 2-3km of maternity roosts33.

The habitat close to the breeding roost at Woodchester Mansion within the SSSI is specifically

managed for bats and highly suitable for greater- and lesser horseshoe bats. Therefore, it is highly

33 Duvergé, L. & Jones, G. 1994. Greater Horseshoe Bats – Activity, foraging behaviour and habitat use. British

Wildlife,6,69-77.


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unlikely that individuals from Woodchester Park SSSI will forage as far as the Development

Footprint during the breeding season. However, individual greater horseshoe bats including

young regularly use hibernacula sites in the Forest of Dean. It is unknown where these bats cross

the M5. The greater width of motorways may make them more effective barriers than a road for

bats (Berthinussen & Altringham 201234). The River Frome Underpass and the Pedestrian

Underpass under the M5 therefore may provide safe crossing points for bats.

8.153 There is no development within 400m of the River Frome and no development within 250m of

the M5 Pedestrian Underpass, therefore it is considered highly unlikely that there will be any

negative effects from construction on the potential use of the River Frome Underpass or the M5

Pedestrian Underpass by bats.

8.154 Therefore, prior to mitigation it is considered that there will be no significant negative effect on

bats from Woodchester Park SSSI. However, a precautionary approach will be taken and secured

by condition as part of any permission granted. Any lighting required for safe working will be of

low intensity and only be used within or directed into the construction area.



Statutory Designated Sites of National Importance: Minchinhampton Common SSSI


8.156 Minchinhampton Common SSSI is designated principally for its unimproved, herb-rich limestone

grassland and geological importance of disused quarry workings. Potential effects on the

grassland or geological interest has been scoped out of this assessment. The citation, however,

does also mention the disused stone mines on the Nailsworth side of the Common are used as

winter roost sites by greater horseshoe bat. Minchinhampton Common is over 8km from the

Survey Area and there is no hydrological connection to this, therefore the Revised Scheme will

have no effect on the botanical or geological interest of the SSSI. Whilst greater horseshoe bats

may travel up to 10km in winter in search of roosts with the correct temperature and feeding

opportunities35, there are no suitable roosting caves within the Development Footprint and there

are large tracts of high quality bat foraging habitat between Minchinhampton Common and the

Development Footprint. Therefore, it is considered there will be no negative effect on this SSSI

during construction and the effect is therefore not significant. However, as noted for

Woodchester Park SSSI, a precautionary approach will be taken. Any lighting required for safe

working will be of low intensity and only be used within or directed into the construction area to

avoid any disruption if these bat species are crossing the site and secured by condition as part of

any permission granted.



34 Berthinussen A, Altringham J. 2012a. The effect of a major road on bat activity and diversity. Journal

of Applied Ecology 49, 82-89.

35 Ransome, R. D. 1991. Greater horseshoe bat. In: The Handbook of British Mammals (G. B. Corbet & S. Harris

eds.), pp. 88-94. Oxford: Blackwell.


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Non-Statutory Designated Sites (County Importance) - Evaluation and assessment of potential

effects and significance

River Frome and River Frome Mainstream Tributaries KWS

8.158 The development will be approximately 270m from the designated KWS River Frome and River

Frome Mainstream and Tributaries (RS Figure 8.6). Whilst there is potential for increased

sediment run-off, fine silts or contaminated water during construction, there will be no built

development within 400m of River Frome and no direct drainage ditches from the development

to the River Frome. Therefore, it is considered highly unlikely that any run –off will reach the

River Frome. Whilst this is considered not significant, a precautionary approach has been

adopted.

Precautionary mitigation

8.159 A detailed Construction Environmental Management Plan (CEMP), including a Pollution

Prevention Plan will be developed and agreed with the LPA and the Environment Agency prior to

commencement of development and secured by condition as part of any permission granted. An

Ecological Clerk of Works (ECoW) will be employed to ensure this is fully implemented.

8.160 Suitable SuDS will be installed throughout the Development Footprint. Where necessary, this will

include silt and oil traps (see Chapter 9, Flood Risk, Hydrology and Drainage). Therefore, it is

certain there will be no significant effects on the KWSs River Frome and River Frome Mainstream

and Tributaries.



Habitats – Hedgerows - Evaluation and assessment of potential effects and significance

8.162 Whilst most of the boundary hedgerows are intact, some of the internal hedgerows have become

gappy and defunct due to lack of maintenance and cattle damage. The hedgerows are important

for ecological connectivity within the Survey Area and the surrounding area and are considered

to be of local importance. Embedded mitigation (avoidance) as part of the Revised Scheme

retains 1,900m of internal hedgerows (RS Figure 8.2). However internal hedgerow NH1, NH3

NH5, NH6, NH10, NH11, NH 12 and NH15 will be affected by the Revised Scheme (see RS Figure

1.4 and RS Figure 8.2). In addition, SH4 and SH1 directly to south of A419 will be affected by the

creation of an access junction with the A419. Construction works close to hedgerows present a

risk of damage to both hedgerows and associated ground flora. Whilst there is potential loss of

internal hedgerows, they are considered to be only of local importance. However, it is still

moderate and therefore significant at a local level.

Mitigation

8.163 While the exact layout of the development will be subject to a Reserved Matters Application the

approach to hedgerows will be to ensure that those hedgerows affected will be translocated and

where appropriate enhanced with additional planting to improve species diversity. Based on the

current layout of 3,200m of existing hedgerows 1,900m will be retained. A total length of

approximate 1,300 m of hedgerows (including woody species and ground flora) will be

translocated to new locations. These hedgerows will be supplemented by woody hedgerow

species of local provenance to ensure each hedgerow provides pollen and nectar throughout the

spring, summer and autumn.


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8.164 Translocating the hedgerow rather than planting a new hedgerow will mean quicker re-growth

(3-5 years) and ensure any negative effects from this are short term rather than medium term.

8.165 In addition, part of the mitigation for bats will involve creating a commuting route for bats across

the site which will involve planting of approximately 1,800 m of new hedgerow. Consequently,

there will be approximately 5,000m of hedgerow post development an overall net gain of 56% %

in the length of hedgerows within the Development Footprint over the medium term (up to

seven years. All retained hedgerows, translocated and new hedgerows will be taken into

conservation management to enhance their ecological value and connectivity throughout the

Development Footprint. The management will be hedgerow-specific but will include planting up

gaps with native broadleaved species, together with cutting and potentially laying on a 4-7 year

rotation. The aim will be to create tall (4m), thick hedgerows.

8.166 To avoid damage to hedgerows and associate ground flora, all hedgerows to be retained will be

fenced off prior to the commencement of construction at least 2m from the boundary of the

hedgerow. This will also protect ground flora and grassland margins to the hedgerows.


8.167 There is no residual significance

Habitats – Grassland


8.168 The majority of the grassland within the Development Footprint is agriculturally improved

(species- poor) with some semi-improved grassland. This is considered as important within the

site. The grassland to south of the A419 adjacent to river Frome and west of M5 may be

considered of local importance. The exact layout of the development will be subject to reserve

matter applications, however with the current layout there will be a permanent loss of

approximately 12.6ha of mostly improved and some semi improved grassland for the Stadium

training pitches car parking and access to the Stadium Complex. The remaining area of the

grassland south of A419 (13.4ha) will be unaffected by construction. Approximately 5.4ha of

grassland to north of A419 will be enhanced and restored to species rich grassland.

8.169 Given the low nature conservation value of the grassland affected by the development, the

effects are not considered to be significant. However, a precautionary approach will be

implemented, and a number of measures will be taken to avoid damage, restore and re-create

species- rich grassland with the Development Footprint secured by condition as part of any

permission granted.

8.170 The hierarchy of grassland conservation is set out below:

• Areas of grassland unaffected by development will be fenced to protect from

construction work.

• Where semi-improved grasslands are to be removed for development, it is proposed that

the turfs of the semi-improved grassland will be cut and set aside to re-turf disturbed

areas after construction.

• Where this method of grassland re-establishment is not possible, it is proposed to re-

seed disturbed areas with species-rich seed mixes and/ or green hay from local sources.


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Potential sources would include the species-rich embankments on Junction 13 or the

Chipmans Platt roundabout.



Woodland and Trees


8.172 There are a number of mature trees within the three small woodland blocks within the

Development Footprint; two on the north of the A419 (Woodland I and Woodland II,) and one to

the south of the A419 (Woodland III, RS Figure 8.14). There are also a number of mature Ash,

Oak and Field Maple within hedgerows throughout the Survey Area (RS Appendix 8.3). The

woodland and hedgerow trees within the Survey Area are considered to be of local importance.

The embedded design principle of the Revised Scheme is one of avoidance to reduce the loss of

woodlands and mature trees during development. The main access point to the Development

Footprint has been relocated and the small blocks of woodland are to be retained. The layout of

the stadium and of the concourse ensure minimal loss and retention of mature trees within the

design.

8.173 The construction of the Stadium will result in the loss of one mature Ash tree T32. The proposed

dualling of the A419 and the provision suitable visual splays for the access will potentially affect

nine trees adjacent to the A419. Of these T59, T60, and T67 are classed as Category A (trees of

high quality). The Category A trees have been assessed for conservation value and T59 (A) and

T60 (A) were considered to be of conservation value to the Survey Area as these are mature Oak

trees which were present on the OS Ordnance Survey maps dated 1842-1852 (RS Figure 10.6a).

The Category B and Category C trees are not of high conservation value. Trees within the Survey

Area have been assessed for bat roost potential with a follow up endoscope survey (RS Figure

8.17 and RS Appendix 8.2 Annex VI). Trees T59, T60 and T61, likely to be affected by the creation

of visual splays, do not have features of bat roost potential. Trees T2 Oak and T2 Hawthorn are

likely to be affected by the construction of the car park although the exact layout of the car park

will be subject to a reserved matter application

Mitigation

8.174 The two mature Oak trees of conservation interest (T59, T60) that will potentially be affected by

the widening of the A419 will be translocated to a suitable position along the translocated

Hedgerow HN4.

8.175 The loss of the seven younger trees in Hedgerow adjacent to A419 will be compensated by

further planting. There will be extensive tree planting of approximately 400 native deciduous

trees throughout the development plus approximately 100 native fruit trees of local provenance

to ensure a net significant gain of in biodiversity of over 500% in term of the number of native

deciduous trees.

8.176 Fencing off all important trees and groups of trees of nature conservation interest will be carried

out observing Root Protection Areas (RPA) (as per the Arboricultural Survey RS Appendix 8.3)

before construction.

Significance of residual effects

8.177 There will be no residual significance.


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Rivers and water courses


8.178 The River Frome corridor is considered of county importance by virtue of its designation as a Key

Wildlife Site. However, this is 400m from the Development Footprint and therefore it is

considered highly unlikely (RS Figure 8.14 and RS Figure 9.1) that during construction there will

be run-off of sediment, fine silts or contaminated water directly into the Frome. There is one

small water course (the Selbrook) on the north-western boundary of the Development Footprint.

This flows under the M4 and flows parallel to the River Frome before entering the Frome at

Wheatenhurst 3 km to the west of the site. The Selbrook is considered to be of local importance

although any fine silts or contaminated water could enter the River Frome and therefore

eventually the Severn Estuary SAC. The Selbrook is of local importance, although it has

hydrological connection to an internationally important site.

8.179 There will be no built development within c. 150m of the Selbrook, however the northern

practice pitch will be constructed within 10m of this water course. Therefore, there is a potential,

but very low risk, for silt runoff. This risk will be considerably lower than run-off from the normal

arable cultivation of the field which will be to within 1-2m of the water course boundary. It is

considered highly unlikely that any fine silts, sediments or chemical contamination will enter

these water courses or reach the River Frome. Whilst any risks are considered extremely unlikely,

and therefore not significant, a precautionary approach has been taken.

Mitigation

8.180 A detailed Construction Environmental Management Plan (CEMP) including a Pollution

Prevention Plan will be developed and agreed with the LPA and the Environment Agency prior to

commencement of development (secured by condition as part of any permission granted) and

an ECoW will be employed to ensure this is fully implemented. SuDS will be employed throughout

the Development Footprint (see Chapter 9 Hydrology).



Protected Species – Bats


8.182 At least ten species of bat were identified during the activity transects and at least twelve species

during static surveys. The transect survey recorded low numbers of bats commuting along

hedgerows with the Development Footprint with a concentration of activity when one or two

individual bats where found foraging. These concentrations in activity were at suitable foraging

locations close to woodlands, mature trees, green lanes and around farm buildings. The static

surveys found a similar pattern of activity to transect surveys. There was a relatively low level of

activity throughout most of the Survey Area but with a higher level of activity adjacent to higher

quality bat habitat such as mature trees, the River Frome and tall hedgerows. A very low level of

activity of both greater horseshoe and lesser horseshoe bats was recorded (See RS Appendix 8.2

for full details). There was no evidence of active roosts within the Development Footprint. The

area is therefore considered to be of local importance of foraging bats.

8.183 The removal of mature trees during construction could pose a direct threat to potential roosts

and breeding behaviour, and a risk of injury or death to any bats in a roost. There is no evidence


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of roosts within the Development Footprint. Therefore, there will be no direct effect on breeding

bats, risk of death or injury from the removal of trees within the Development Footprint.

However, the loss of trees and hedgerows could potentially reduce foraging habitat and possibly

commuting routes.

8.184 The use of lighting during construction could interfere with commuting patterns of bats and

disrupt breeding behaviour, particularly those species sensitive to light, which are all Myotis

species and greater- and lesser horseshoe bats. However, the number of greater- and lesser

horseshoe bats using the Development Footprint is very low and therefore the effects on this

species are likely to be very limited. There is no evidence of breeding roosts on the area of the

Development Footprint, and therefore there will be no direct effects on breeding success from

lighting.

8.185 Therefore, prior to mitigation lighting during construction could have a moderate negative effect

on bats using the Development Footprint, which would be considered as significant.

Avoidance and Mitigation

8.186 The embedded mitigation (avoidance) as part of the Revised Scheme retains the majority of the

mature trees.

8.187 The embedded mitigation also includes the translocation of hedgerow lengths. Whilst there will

a temporary loss of these commuting features, translocation rather than re-planting will ensure

rapid re-growth of these hedgerows which should provide a suitable commuting feature within

3-5 years. Hedgerow lost will be replaced with a great length of hedgerow of similar species and

new hedgerow will be planted as part of the bat commuting corridor. There will be a 56% net

gain in the length of hedgerow.

8.188 Hedgerows to be retained will be fenced during construction to prevent accidental damage. The

positive management of retained hedgerows and planting of new hedgerows throughout the

Development Footprint, combined with retention, enhancement and creation of species-rich

grassland, will minimise any losses of foraging habitat and enhance the quality of the retained

habitat. The creation of linear orchards and parkland habitat throughout, combined with the

creation of ponds in dark unlit areas, will provide new foraging habitats within the Development

Footprint.

8.189 A commuting corridor for bats will be created along the northern boundary of the site to create

an unlit commuting route through the site. This is close to an existing orchard outside the

northern boundary adjacent to the proposed new orchards.

8.190 New roost sites including potential maternity roosts suitable for pipistrelle, Myotis and noctule

bat species will be provided in suitable unlit locations (typically on large mature trees) using

woodcrete bat boxes.

8.191 Any lighting required for safe working will be limited to winter use when bats are hibernating. If

construction lighting is required during the summer months, this will be of low intensity and only

be used within the construction area.

Residual Significance

8.192 There will be no residual significance.


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Protected Species - Badgers


8.193 Precise locations of badger setts within the Survey Area are to be found in the confidential

document RS Appendix 8.4. The main sett was occupied in 2015, 2016 and 2017 whilst the

outlying sett was unoccupied in 2016 and 2017. The Severn Vale and the Stroud Valleys support

a very high density of badgers. The value of the Development Footprint in terms of badgers is

considered to be at the local level.

8.194 The potential effects of the development will be (a) disturbance of the active main sett and

possibly the outlier sett if it becomes re-occupied and (b) removal of foraging habitat. Surveys

during 2016 indicated that there were several preferred foraging areas outside the Survey Area.

8.195 The main sett will not be directly affected by construction. Surveys will be conducted in the

appropriate season prior to construction. If there are new active entrances within 20m of any

proposed works a precautionary approach will be taken and appropriate mitigation implemented

to ensure there will be no disturbance during development to the main sett.

8.196 The removal of 12.6ha of improved or semi-improved grassland during construction could

potentially result in the loss of foraging habitat for badgers within the Development Footprint.

However, this will leave over 30 ha within Ecotricity’s land holding unaffected. It is therefore

considered that any effects on badger will be negligible and not significant. However, a

precautionary approach will be adopted, and badger surveys will be conducted in the

appropriate season prior to construction.



Protected Species - Birds


8.198 The number and composition of the breeding birds recorded is very typical of this type of habitat

over large parts of lowland England and is therefore considered of local importance. The

distribution of nesting birds varied between 2015 and 2016.

8.199 The removal of sections of internal hedgerow will result in a loss of potential breeding habitat

for a number of common farmland birds. There was one red listed species (song thrush) recorded

breeding within the Development Footprint. This was within a mature Oak which will be retained

as part of the development

8.200 The removal of sections of hedgerows whilst birds are nesting (1st March-31st August)) would

be a contravention of the Wildlife and Countryside act 1981 and therefore considered significant.

8.201 There will be no built development within c.400m of the River Frome and therefore there will be

no effect on breeding kingfisher (Schedule 1 species).

8.202 The house sparrow and starling are both tolerant of human disturbance and were breeding

within domestic properties outside the Survey Area boundary and therefore will not be disturbed

by construction works.

Mitigation


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8.203 Careful design of the development has ensured no net loss of hedgerows and trees. Any

hedgerow removal and translocation will be completed outside the bird breeding season (March

to August inclusive). If for unforeseen reasons works on hedgerows are required during the bird

breeding season, detailed breeding bird surveys will be conducted prior to commencement. If

active nests are located, works will be delayed until the young have fledged or the breeding

attempt has failed.



Protected Species - Reptiles


8.205 No reptiles were recorded to the north of the A419, however a small population of grass snake

and slow worm was identified using the hedgerow to the south of the A419. Slow worm and

grass snake are relatively common in suitable habitat within the Severn Vale. This population is

considered to be of local importance. The translocation of the hedgerow and the Conservation

Road Verge directly to the south of the A419 will pose a direct risk of disturbance, injury or death

to both grass snake and slow worm and loss of habitat. Therefore, prior to mitigation that there

will be a significant negative effect on reptiles.

Mitigation

8.206 It is proposed that any reptiles using the hedgerow and the road verge to the south the A419 will

be trapped and translocated following appropriate guidance to a suitable nearby location, such

as the land to west of M5 within the Redline boundary or the banks of the river Frome.

Significance of residual effects


Operational effects

Non-Statutory Designated Sites


8.208 The River Frome is considered of county importance by virtue of designation as a Key Wildlife

Site. There will be no development works within c. 250m of boundary of the Key Wildlife Site.

There is one water course (the Selbrook) which flows from the northwest boundary of the

Development Footprint flows under the M5 and then parallel to the river Frome before entering

the Frome at Wheatenhurst 3 km to the west of the site into the Frome. There is no built

development proposed within 150m of the Selbrook although the closest training pitch is within

10m from this water course. All training pitches will include internal watering and drainage

systems and therefore there will be no run-off from these into the Selbrook or into the River

Frome Key Wildlife Site. Therefore, will be no significant effect on the River Frome Key Wildlife

Site. Whilst any risks are considered extremely unlikely, and therefore not significant, a

precautionary approach has been taken.

Mitigation

8.209 A Pollution Prevention Plan will be developed and agreed with the LPA and the Environment

Agency prior to commencement of development and an ECoW will be employed to ensure this


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is fully implemented. SuDS will be employed throughout the Development Footprint (see ES

Chapter 9 Hydrology) secured by condition as part of any permission granted.

Protected Species – Bats


8.210 No bat roosts were identified within the Development Footprint, which has been identified as of

local importance for foraging and commuting bats. Bats can be affected by light while commuting

and foraging. There will be no lighting required for the training pitches, however there will be

external lighting required for the Stadium, car parking and access routes within the site. The use

of external lighting will be greatest during the winter months when bats are hibernating and

there are no bats using the Development Footprint. However, lighting during the shorter spring

and autumn nights may have a negative effect on the use of the Development Footprint by bats

sensitive to white light (Stone 201336).

8.211 A Baseline survey on lighting found that there is low background level lighting within the

Development Footprint at present. Expected levels of lighting within the Development Footprint

for the stadium, public car park, general roads, private roads and footpaths are given in Table

14.1 (Guidance Illumination Levels of each Task areas) vary between an average of 5 lux in

footpath and amenity areas to 25 lux in car parks and 500 lux within the stadium

8.212 Whilst most bats tend to avoid brightly lit areas, almost certainly to avoid predators, some bats

such as Pipistrelle sp. and noctule frequently feed on insects attracted to lights and may benefit

from the introduction of lighting. However certain bat species particularly of the genera

Rhinolophus (horseshoe bats,), Plecotus (e.g. Brown long-eared bat) and Myotis species avoid

areas with light levels likely to found within part of Development Footprint (Stone 2013).

Therefore, there may be a moderate negative effect on commuting or foraging Myotis and

Horseshoe species during matches in early spring or late autumn which would be considered as

significant.

8.213 There will be no development south of the A419 and therefore there will be no effect on the

River Frome Underpass or the M5 Pedestrian Underpass which were identified as potential

routes for Horseshoe bats to cross the M5. Therefore, it is considered that there will be no risk

to Greater and Lesser horseshoe bats potentially crossing the Survey Area to hibernation roosts

in the Forest of Dean.

8.214 The loss of internal hedgerows could reduce the length of suitable foraging habitat or disrupt

commuting routes. The area of the Development Footprint is considered as being of local

importance for foraging bats and therefore the negative effects of the removal of a number of

internal hedgerows is likely to be substantial to moderate and therefore significant.

Mitigation

8.215 Embedded mitigation (avoidance) in the design will ensure retention of the majority of mature

trees within the Development Footprint. The hedgerows affected by the Revised Scheme will

either be translocated where appropriate, or replaced with hedgerows of equal length and

36 Stone E. L. (2013) Bats and lighting. Current evidence and mitigation guidance. University of Bristol.


December 2017

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similar species composition. The creation of species- rich grassland, water bodies and parkland

woodland around the stadium will provide new habitat for foraging bats.

8.216 Embedded mitigation through the creation of a commuting corridor for bats in the north of the

Development Footprint (RS Figure 5.3, RS Figure 5.6 and RS Figure 8.2) will allow bat species that

avoid light to commute across the area of the Development Footprint. These will take the form

of a bund planted with dense hedgerow species on the side of the corridor closest the

development. It will also incorporate a narrow open path 1-2m wide and second hedgerow on

the outside (see RS Figure 5.6). Lighting throughout the Revised Scheme will be designed and

used to minimise effects on bats, and enhancements will include:

• Lighting of the junction on A419 will be directed onto the carriageway through the

inclusion of back plates and directional lighting to minimise spill.

• There is a provisional curfew for the Development Footprint of 21.00 (likely to be a

condition at Reserved Matters)

• Lighting throughout the Development Footprint will be designed to minimise horizontal

spill of light by use of back shields and louvers to direct light spill way from hedgerows,

woodlands, new ponds and areas of species-rich grassland.

• The use of bright white and ultra-violet light will be avoided where appropriate.

• Dimmed and reactive lighting and variable lighting regimes will be used where

appropriate.

• The roads within the Development Footprint will be private and therefore lighting will be

under control of the Facilities Manager and will be switched off when not required.

During the bat activity period April-October, this can be managed automatically or be

reactive by use of road loops.

• Car parking areas will only be lit when required.

8.217 The implementation of the mitigation and enhancement measures will reduce the significant

effect to negligible and not significant.



Major Accidents and Disasters

8.219 An assessment has been undertaken of any potentially significant adverse effects on the

environment deriving from the vulnerability of the development to risks of major accidents and/

or disasters in Chapter 17.

8.220 Given a number of proposed design and operational measures, which are all considered and

reported in the assessment, it is not anticipated that the Revised Scheme is vulnerable to any

major accidents and/ or disasters which could result in significant effects on the environment.

8.221 In relation to biodiversity large spillage of materials, particularly liquids, could in theory result in

significant adverse effects on environmental receptors such as the river Frome Key wildlife site

or the River Severn SAC. However, given the distance from the stadium and associated

infrastructure to the river Frome and the Severn Estuary SAC any risks are considered extremely

unlikely, and therefore not significant. However, a precautionary approach has been taken and

Pollution Prevention Plan will be developed and agreed with the LPA and the Environment


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Agency prior to commencement of development secured by condition as part of any permission

granted.

Climate Change

8.222 A detailed assessment has been undertaken of the potential effects of the Revised Scheme on

climate change (‘climate change mitigation’) and of the vulnerability of the Revised Scheme to

climate change (‘climate change adaptation’) in Chapter 16.

8.223 Natural England published its ‘climate change risk assessment and adaptation plan’ report in

2015, part of the statutory requirement on Government Agencies to provide such advice, arising

from the Climate Change Act 2008. In the report Natural England sets out the risks and threats

posed by current climate change predictions and how the agency proposes to respond to them.

As part of its strategy Natural England recognises that climate change offers opportunities as well

as threats. For instance:

“There is an opportunity to facilitate landscape change in ways that create valuable new

landscapes that are more resilient to climate change and deliver improved benefits for society

(sense of place, biodiversity and other ecosystem services).”

8.224 Increased rainfall and flooding events, coupled with rising temperatures, are likely to modify UK

flora and fauna over time. Habitat management measures can be introduced to cope with and

adapt to the anticipated change. Such measures form part of the SUDS proposals (embedded

mitigation) for the Revised Scheme, which will be the subject of detailed design at the Reserved

Matters Application stage. This will include details of climate change adaption measures at this

particular location, for example by specifying suitably resilient plant species or pollinator species

suitable for invertebrates shifting their range northward, so as to exploit the opportunity climate

change presents to create ‘valuable new habitat’.

8.225 Other climate change adaption measures relating to green infrastructure / ecosystem services,

which form part of the embedded mitigation and promote a quality and healthy environment,

are set out in the landscape strategy at RS Appendix 8.7 and Green Infrastructure Plan RS

Appendix 8.5. These measures include extensive tree planting to establish a ‘parkland’

landscape, species rich meadows, wildlife corridors and orchards. Ponds will create shade for

cooling effects and sequestrate carbon.

Statement of residual significance

8.226 The potential residual significance of the Revised Scheme is detailed in Table 8.10 in this chapter.

Proposed additional monitoring

8.227 There will be a programme of ongoing ecological monitoring to assess delivery of biodiversity

targets for the Revised Scheme. Habitat management programmes will be modified as required.

Biodiversity enhancements

8.228 There will be a wide range of potential biodiversity enhancements, as outlined in the Green

Infrastructure Plan (RS Appendix 8.5) and bulleted below. These will be developed subject to

detailed design and assessment as part of Reserved Matters Applications.


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• 1,800m of new hedgerow planting.

• Enhancement/positive management of existing hedgerows.

• Planting of native hedgerow ground flora.

• Creation of new night roosts to maintain and extend foraging area of greater horseshoe

and lesser horseshoe bats.

• Sowing of species-rich grassland using seed of local provenance.

• Planting of native broadleaved trees throughout.

• Creation of orchards to the north of the stadium, training pitches and car parking

• Installing bat boxes and bird nesting boxes on suitable trees throughout the Development

Footprint.

• Creation of flower-rich verges throughout from locally sourced seed.

• Enhancement of the Development Footprint for invertebrates, particularly butterflies and

bees through native wild flower and shrub planting.

• Creation of hibernacula for reptiles.

• Use of Sustainable Drainage (SuDS) throughout the Development Footprint.

• Ongoing monitoring and maintenance programme.

8.229 An Environmental Enhancement Plan has been written to give indicative illustrations of how

some of these habitat mitigation, management and enhancement will be carried out at. This is

detailed in RS Appendix 8.6 Principles of Environmental Enhancements.

Summary and statement of significance

8.230 Detailed baseline Surveys, NVC and protected species surveys have been carried out on the

Survey Area and an assessment of potential effects on designated sites and protected species

has been undertaken. Much of the Survey Area is currently of low biodiversity value. This

assessment concludes that without mitigation there is a low potential risk to hedgerows, mature

trees, and bat species sensitive to excessive light pollution, breeding birds and reptiles.

8.231 Embedded mitigation (avoidance) will ensure the design of the development, combined with a

detailed Construction Environmental Management Plan, will minimise effects on breeding birds,

bats, hedgerows and trees. In addition, a bat-friendly lighting strategy will be implemented

across the Development Footprint and reptiles will be trapped and translocated to a suitable

receptor site. Therefore, these potentially significant effects can be avoided, to ensure there are

no significant residual effects on these habitats and species.

8.232 Comprehensive ecological enhancements throughout the Revised Scheme will ensure that

ecological value, ecosystem service value and benefit to human health and wellbeing is

enhanced.

Cumulative effects

8.233 Cumulative effects, both individually and in combination, on ecological receptors may arise from

multiple developments within the range of sensitivity of each receptor. Effects may be direct

(such as habitat loss) or indirect (such as sediment run-off degrading the quality of water in a

catchment).

Scope of Cumulative Assessment


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8.234 The cumulative assessment considers relevant planned developments (i.e. validated planning

applications and schemes at appeal) within 5km of the developable area (RS Figure 18.1).

Relevant proposals at the pre-planning stage (‘in scoping’) are also considered including the

SDC/CCT partnership for restoration proposals of the Stroudwater Canal. The Cumulative

Assessment Schemes (CAS) which have the potential to cause cumulative ecological effects are

listed in Table 2.5, and illustrated on RS Figure 18.1.

Cumulative Ecological Effects

Consented developments

8.235 There are six consented developments within a 5km radius of the Development Footprint; WOS

development (c. 50m); the incinerator at Javelin Park (nearly 4.0km); land at Bond’s Mill on the

Bristol Road, Stonehouse (c.1.5km); Westend Courtyard, Grove Lane (100m); land adjacent to

Eastington Trading Estate and land adjoining Station road, Stonehouse (development of 49

residential units) (RS Figure 18.1 Cumulative Schemes).

8.236 WOS is the closest cumulative development, at approximately 50m away at its closest point. It is

a mixed use development for 1,350 dwellings and 9.3ha of employment land. The area for

development is mostly of low ecological value and WOS is considered to be in an area of generally

low sensitivity in terms of the water environment.

8.237 The creation of areas of species-rich grassland along the stream to the south, and along the green

corridors through the WOS development, will retain and enhance foraging opportunities for bats

and birds. The planting of new hedgerows and trees will provide new and enhanced foraging and

nesting opportunities for birds. This approach resonates with the Green Infrastructure proposed

for the Revised Scheme and should provide combined greater connectivity for bats and birds in

the immediate area.

8.238 The Environment Agency has identified potential problems with the River Frome downstream

which is currently failing to meet the Water Framework Directive objective of a ‘Good’ status by

2027. The WOS development will not result in any deterioration of the status of the River Frome.

The use of SuDS, together with ecological enhancements to the existing watercourses, will help

improve the quality of the existing watercourses and is considered to have a minor beneficial

effect.

8.239 Severn Trent Water has confirmed that the foul sewage from the development can be

accommodated within the existing sewerage infrastructure without modification and without

causing any additional flooding. The effect of WOS on the existing foul sewerage infrastructure

is therefore considered to be negligible. WOS will be mitigated against flooding, and flood risk

will not be increased downstream. Overall flood risk in the area will be reduced. As WOS is

upstream of Revised Scheme, the development will have a negligible effect on flood risk and will

not pollute the waterway.

8.240 With the mitigation proposed, WOS will not result in any adverse residual effect on habitats or

species of any significance, and there will be no net loss of features of ecological importance.

Therefore, despite the scale and proximity of this development to the Development Footprint,

the cumulative effect is considered not significant.


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8.241 Westend Courtyard involved the extension to provide additional office space. No ecological

receptors were identified with this development, and therefore the cumulative effect is not

significant.

8.242 The development of land adjacent to Eastington Trading Estate includes the delivery of three

employment buildings comprising a total floor space of up to 2,695sqm with associated access,

car parking and service yards. This permitted development is within an improvement grassland

field entirely within the River Frome Key Wildlife Site. Conditions attached to this permission

require the implementation of a number of ecological mitigation measures and enhancements.

There is however no compensation offered for the loss of the land within the Key Wildlife Site.

The Revised Scheme north of A419 does not impact on the river Frome Key Wildlife Site. The

cumulative effect is therefore considered not significant.

8.243 The development at Bond’s Mill involves the demolition of a warehouse, renovation of office

space and erection of a two storey extension. No ecological factors were identified in the

planning application, and given the nature of the development and the distance from the

Development Footprint; it will have no effect on the Revised Scheme in ecological terms. The

cumulative effect is therefore considered not significant.

8.244 Land at Javelin Park is to be developed as an Energy from Waste (EfW) facility for the combustion

of non-hazardous waste and the generation of energy. It is nearly 4km away to the Development

Footprint, adjacent to Junction 12 of the M5. Javelin Park is already poor in ecological receptors

and is a brownfield site, being formerly an airfield. There is limited connectivity in terms of

habitat for bats, and no hydrological connection as the stream to the southern boundary of the

Javelin site is not currently connected to the River Frome.

8.245 There are plans for substantial ecosystem reconstruction on Javelin Park. The wildlife corridor

along the existing watercourse on the site boundary will be protected for the duration of

construction activities and on completion will be supplemented with additional native planting

to optimise biodiversity potential. In addition to the woodland and tree planting, all areas of land

not required for operational activities will be used for local ecosystem reinstatement and

enhancement. Extensive conservation grassland areas will be sown, which will ultimately support

diverse insect communities. Within the sustainable site drainage system (SuDS), new wetland

habitats (both permanent ponds and seasonally damp grassland) will be introduced. A long term

Management Plan will be prepared for the site.

8.246 The large volumes of water that can be generated by buildings of this scale will be managed on

Javelin Park within an appropriately scaled surface water drainage system to prevent adverse

effects on local water courses including erosion and flooding. The proposed design includes

swales and attenuation ponds to collect excess run-off during storm events and store it within

the site before gradually releasing the water after the storm has passed.

8.247 The design of the lighting scheme for Javelin Park will also take into account the need to avoid

unnecessary light pollution so as to limit any adverse effects upon local residents, flora and fauna.

With all these safeguards in place, and given the site is sufficiently far away from Revised Scheme

to have no direct effect, the cumulative effect of this proposed development is considered to be

not significant.

Developments in planning


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8.248 There are two submitted planning applications pending a decision: one for the conversion and

refurbishment of the former Standish Hospital and the second for a Hotel on land at Pike Lock.

8.249 The conversion and refurbishment of the former Standish Hospital complex, will include

refurbishment of Standish House and associated building to form 50 dwellings. The development

will also include the demolition of Westridge Hospital and associated building and the

development of 98 new build homes within the grounds with associated vehicle and cycle car

parking, pedestrian and vehicular access and associated landscaping, ancillary storage and plant

and ecological bat housing; and all associated engineering works and operations. The Standish

site has been identified as being important for bats and although 3.5km from the Development

Footprint it is possible that bats from this site could occasionally visit the area of the

Development Footprint. It is proposed that the development at Standish Hospital will include

significant ecological mitigation and enhancements including new bats roosts. With all these

safeguards in place, and given the site is sufficiently far away from the Revised Scheme to have

no direct effect, the cumulative effect of this proposed development is considered to be not

significant.

8.250 The outline planning application at Pike lock is for a new pub/ restaurant 56 bed hotel and

associated access, parking, drainage and landscaping. This site is approximately 240m to south

and east of the Development Footprint adjacent to Chipmans Platt roundabout. This site is

currently an abandoned agricultural field with rough grassland/tall ruderal vegetation of limited

ecological value. Although only at outline stage, the applicant has suggested ecological

enhancements to improve the floristic value of the habitats, to provide foraging habitat for birds

and pollinators species and to ensure bat friendly lighting throughout the scheme. This is

complementary to the proposed enhancement for the Revised Scheme. With all these

safeguards in place, and given the site is sufficiently far away from Revised Scheme to have no

direct effect, the cumulative effect of this proposed development is considered to be not

significant.

Pre-planning

8.251 There is a proposal for restoration of the Stroudwater Canal by Cotswold Canal Trust (CCT)

directly to the south of the Development Footprint, within the wider Survey Area (RS Figure

18.1). This is a planned restoration of the canal between the Ocean at Stonehouse and the

Gloucester/ Sharpness canal at Saul Junction. This will recreate the missing length of the canal

between Westfield Bridge and the A38 which had been previously in filled during the

construction of the M5. The previous application to the Heritage Lottery was unsuccessful.

Stroud District Council in partnership CCT are continuing to seek funding and resubmitted a bid

in November 2017. As part of this process an outline planning application for restoration of the

section between Westfield Bridge and the A38 is imminent.

8.252 It is understood that this will include a full ecological assessment of the effects of the restoration

and a detailed biodiversity offsetting programme to ensure an overall net gain in priority

habitats, in line with national and local conservation priorities throughout the length of the canal.

Therefore, there is likely to be a positive cumulative net biodiversity gain.

Conclusion


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8.253 The Revised Scheme Footprint consists of agricultural land, with mixed pasture/hay meadow and

interconnecting hedgerows throughout. There is one boundary stream which ultimately flows

into the River Frome 3km to the west.

8.254 The Survey Area is generally of low biodiversity interest in terms of habitats – although the

interconnecting hedgerow network provides good connectivity for bats and nesting

opportunities for birds. Embedded mitigation (avoidance) and translocation has minimised loss

of mature trees that the effect of the development on trees is deemed to be not significant.

8.255 Whilst there is potential loss of internal hedgerows, they are considered to be only of local

importance. However, this is still moderate and therefore will result in significant effects.

Mitigation will involve translocation and replacement of hedgerow of the same length and

species composition, as well as creation of a commuting corridor for bats. Overall there will be

significant net gain in hedgerow length

8.256 Approximately 12.6 ha of agriculturally improved and semi-improved grassland of low ecological

value will be lost due to the footprint of the development.

8.257 Due to the ephemeral nature of the water bodies within the Survey Area, it was not considered

suitable for great crested newts. New ponds will be created throughout the Revised Scheme as

part of the SuDS and the Green Infrastructure to encourage amphibians to colonize and breed.

8.258 A total of 15 common farmland birds were recorded breeding within or adjacent the

Development Footprint in 2015 and 2016 including one red –listed species (Song Thrush)

breeding within the Development Footprint. The removal of any potential bird nesting habitat

will be carried out outside the bird breeding season. Other construction effects on birds are

perceived to be minimal and not significant. As part of the Green Infrastructure proposals, there

will be extensive planting of new hedgerows, which will enhance and extend foraging and nesting

opportunities.

8.259 The main sett will not be affected by the stadium construction and is sufficiently distant from

training pitches to ensure no disturbance and therefore the effects are not considered to be

significant.

8.260 Extensive bat surveys over two seasons recorded up to twelve bat species using the Survey Area.

Common pipistrelle were the most frequently recorded species within the Development

Footprint. Lesser horseshoe and greater horseshoe bats were also recorded in low numbers, each

accounting for approximately 1% of total bat activity. Detailed design of the Revised Scheme,

creation of ponds, orchards, bat commuting corridors, bat friendly lighting and the minimal loss

of mature trees and tall hedgerows will reduce negative effects on bats to negligible.

8.261 Cumulative effects of nearby developments were considered and it was concluded that there will

be no ecological cumulative effects, singly or in concert, with the Revised Scheme.

8.262 The Green Infrastructure Parameter Plan outlines the enhancements for biodiversity, ecosystem

services, climate mitigation, landscape improvements and social benefits for well-being.


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Table 8.10: Summary of Ecology and Nature Conservation Effects, Mitigation and Enhancement assessed

Receptor and

indicative

importance

Effect Developmen

t phase

Potential

unmitigated

effect on the

feature

Magnitude

change

Likely

occurrence

Level of

effect (and

significance

) prior to

mitigation

Mitigation/Embedd

ed mitigation

Enhancement Residual significance

Severn Estuary

SAC/

International

During

construction

there is

potential for

increased run-

off of sediment,

fine silts or

contaminated

water into the

River Frome and

therefore the

SAC during

construction

Construction

/ Operation

Potential

negative

effect on Sea

Lamprey,

River

Lamprey and

Twaite shad.

Negligible Temporary

and

extremely

unlikely

Negligible

and not

significant

A precautionary

approach will be

adopted which will

involve

development and

implementation of a

Pollution Prevention

Plan and installation

of suitable drainage

systems

incorporating Suds

drainage.

N/A Any potential risks of

significant effects will be

removed to ensure no residual

significant effect

Woodchester

Park SSSI

National

Disruption of

Commuting

behaviour of

bats

Construction

/ Operation

Removal or

alteration of

habitat, and

potential

effects of

lighting on

foraging and

migrating

patterns

Moderate Extremely

unlikely

Negligible

and not

significant

A precautionary

approach will be

taken.

Retention and

appropriate

management of

existing hedgerows.

Creation of dark

corridors and

orchards. A bat-

friendly lighting

scheme throughout

the Revised Scheme

Planting of new

hedgerows and

creation of ponds

and species-rich

grassland.

No residual significance


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Receptor and

indicative

importance

Effect Developmen

t phase

Potential

unmitigated

effect on the

feature

Magnitude

change

Likely

occurrence

Level of

effect (and

significance

) prior to

mitigation

Mitigation/Embedd

ed mitigation


Minchinhampton

Common SSSI

National

Disruption of

Commuting

behavior of bats

Construction

/ Operation

Removal or

alteration of

habitat, and

potential

effects of

lighting on

foraging and

migrating

patterns

Negligible Certain Negligible

and not

significant

A precautionary

approach will be

taken. Retention

and appropriate

management of

existing hedgerows.

Creation of dark

corridors and

orchards. A bat-

friendly lighting

scheme throughout

the Revised Scheme

Planting of new

hedgerows.


River Frome and

River Frome

mainstream

tributaries KWSs

County

During

construction

there is

potential for

increased run-

off of sediment,

fine silts or

contaminated

water into the

River Frome and

therefore the

KWSs during

construction.

Construction

/ Operation

Contaminatio

n of the River

Frome and its

tributaries,

and animals

associated

with it, due to

run-off from

the

development.

Temporary

moderate

negative

effects

Highly

unlikely

that any silt

or chemical

contaminat

ion will

reach the

River

Frome.

Negligible

and not

significant

A precautionary

approach will be

adopted which will

involve

development and

implementation of a

Pollution Prevention

Plan and installation

suitable drainage

systems

incorporating SuDS

drainage

N/A No residual significant effect

Hedgerows

Local

Removal or

alteration of

habitat.

Construction Loss of

habitat

Slight/

negative

Certain Moderate

and

significant

Design of the

Revised Scheme

ensures retention of

hedgerows.

Mitigation will

include

translocation and

new planting of

hedgerows and

Enhancement of

retained hedgerows

and ground flora.

Any risks of significant effects

will be removed to ensure no

significant residual effect


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Receptor and

indicative

importance

Effect Developmen

t phase

Potential

unmitigated

effect on the

feature

Magnitude

change

Likely

occurrence

Level of

effect (and

significance

) prior to

mitigation

Mitigation/Embedd

ed mitigation


result in a net

increase in

hedgerow length by

planting of new

hedgerows to

beyond original

extent...

Grasslands

Local

Removal Construction Loss of

species-rich

grassland

Slight /

Negative

Certain Negligible

and not

significant

Not required

However retained

grassland will be

managed

appropriately to

increase species

diversity.

Sow species-rich

grassland verges

around footpaths

and car parks using

local seed from the

adjacent

Conservation Road

Verge.

No residual significance.

Trees

Local

Removal or

alteration of

habitat.


habitat

Slight/

negative

Certain Moderate

and

significant

Avoidance will

ensure retention of

the majority of

trees, translocation

of two mature oaks

(T59, T60) as a

result of the

widening of the

A419.

Any risks of significant effects

will be removed to ensure no

significant residual effect.

Grasslands

Local

Removal of

grassland verge

south of the

A419


feature

Negative Certain Moderate

and

significant

Re-establishment of

the grass verge as

part of hedgerow

translocation.

Species of local

provenance will be

used to re-establish

the road verge e.g.

grass seed from

Chipmans Platt

Roundabout and M5

roundabout.

No residual significance.


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Receptor and

indicative

importance

Effect Developmen

t phase

Potential

unmitigated

effect on the

feature

Magnitude

change

Likely

occurrence

Level of

effect (and

significance

) prior to

mitigation

Mitigation/Embedd

ed mitigation


Bats Greater and

Lesser Horseshoe

International

although in

survey area only

of local

importance

Disruption of

foraging

behavior

Construction

/ Operation

Removal or

alteration of

habitat,

effects of

lighting on

foraging and

roosting

patterns

Moderate Moderate

and

significant

Retention and

appropriate

management of

hedgerows and

mature trees.

Replacement of an

equal length of

hedgerow lost.

Creation of dark

corridors and

orchards. A bat-

friendly lighting

scheme throughout

the Revised Scheme

will reduce negative

effects to a

negligible effect.

Creation of ponds

and species-rich

grassland beneath

parkland. Creation

of orchards.


Myotis bat

species

International

although

development site

only of local

importance

Disruption of

foraging

behavior

Construction

/ Operation

Removal or

alteration of

habitat,

effects of

lighting on

foraging and

roosting

patterns

High Certain Moderate

and

significant

Retention and

appropriate

management of

hedgerows, and

mature trees.

Replacements of an

equal length of

hedgerow lost.

Creation of dark

corridors and

orchards. A bat-

friendly lighting

scheme throughout

the Revised Scheme

will reduce negative

effects to a

negligible effect.

Planting of new

hedgerows and

creations of ponds

and species-rich

grassland. Provision

of bat boxes.



December 2017

Page | 121

Receptor and

indicative

importance

Effect Developmen

t phase

Potential

unmitigated

effect on the

feature

Magnitude

change

Likely

occurrence

Level of

effect (and

significance

) prior to

mitigation

Mitigation/Embedd

ed mitigation


Common and

Soprano

Pipistrelle bats

International

although

development site

only of local

importance

Disruption of

foraging

behavior

Construction

/ Operation

Removal or

alteration of

habitat,

effects of

lighting on

foraging and

roosting

patterns

High Certain

Moderate

and

significant

Retention,

replacements and

appropriate

management of

existing hedgerows.

Creation of dark

corridors and

orchards will reduce

negative effects to a

negligible effect.

Planting of new

hedgerows and

creations of ponds

and species-rich

grassland. Provision

of bat boxes.


Badger

Local

Disruption of

main breeding

sett

Construction Removal or

alteration of

habitat

Moderate Unlikely Negligible

and not

significant

A buffer of 20m will

be established

around the main

sett. If the outlying

set is occupied an

alternative sett will

be created and the

badgers temporarily

excluded under

licence to prevent

disturbance during

construction.


Birds

Local

Disruption of

breeding habitat


alteration of

habitat.

Temporary

lights, noise,

vibration,

foundation

construction,

movement

and physical

Minor/

Negligible

Certain Moderate

and

significant

Any in hedgerow

removed or

hedgerow

translocated will be

completed outside

the bird breeding

season

The design process

will include

retention and

enhancement of

hedgerows and

planting of new

hedgerows.



December 2017

Page | 122

Receptor and

indicative

importance

Effect Developmen

t phase

Potential

unmitigated

effect on the

feature

Magnitude

change

Likely

occurrence

Level of

effect (and

significance

) prior to

mitigation

Mitigation/Embedd

ed mitigation


disturbance

of vegetation

Reptiles; Slow

worm and Grass

snake

National

Risk of

disturbance,

injury or death

and removal of

habitat.


alteration of

habitat.

High Certain High and

significant

Capture and

translocation of

slow worm and

grass snake from

hedgerow and road

verge south of A419

and trans-location

to suitable habitat.

Creation of

hibernacula in

suitable locations.


Eco Park, Land at M5 Junction 13, West of Stonehouse | Environmental Statement Vol.1 Main Text

December 2015

Page | 123

9 HYDROLOGY, FLOOD RISK AND DRAINAGE

Summary

9.1 The location of the Revised Scheme is currently a Greenfield site located to the north of the A419.

In terms of hydrology and flood risk, the closest watercourse to the Site is known as the Selbrook,

which flows for a section adjacent to the western boundary of the Revised Scheme. Further

hydrological receptors are present in the wider area, including the River Frome which is located

approximately 500m to the south of the Revised Scheme.

9.2 A Flood Risk Assessment has been completed for the Revised Scheme and is included in RS

Appendix 9.1 and outlines that the Revised Scheme is predominantly at a very low risk of flooding

from all sources, with only a small section of pluvial flood risk on site.

9.3 The nature and the scale of the Revised Scheme have the potential to affect different receptors

during the construction of the development and operational phase, though due to the nature of

the works this is predominantly the Selbrook and the River Frome.

9.4 During the construction period adverse effects may arise from the development resulting from

the siting of the stadium and associated infrastructure.

9.5 The primary adverse effects generally arise from the potential for uncontrolled sediment runoff

created during the construction of the site or spillages of chemical pollutants (oils, cements,

paints etc.) entering the surface water network. These effects are more prevalent in relation to

the stadium development, where longer-term, more invasive construction works are

undertaken.

9.6 During the operation phase, adverse effects may arise from uncontrolled spills and leaks of

vehicular fluids entering the surface water network or surface water flooding caused by heavy

rainfall falling on the new road and areas of hardstanding. These effects are limited to the area

surrounding the stadium and the associated parking areas. Embedded mitigation incorporated

through the use of SuDS within the drainage design may give rise to positive biodiversity and

water quality effects during the operation of the site.

9.7 The incorporation of the SuDS schemes for Revised Scheme could deliver positive significant

effects, whilst all other effects have been assessed as not significant following the incorporation

of the appropriate mitigation.

Introduction

9.8 This chapter presents the assessment of the likely effects on flood risk, hydrology and surface

water drainage as a direct or indirect result of the Revised Scheme as outlined in Chapter 5 -

Description of the Revised Scheme. The chapter sets out the legislative and policy context

associated with flood risk, hydrology and drainage for the Revised Scheme, the scope of the

assessment and the methodology which has been followed throughout the assessment, along

with the baseline conditions. The assessment identifies the potential effects occurring through

the construction and operation phases of the development and outlines any mitigation measures

required to offset significant environmental effects, as well as any in-combination effects


December 2015

Page | 124

between the Revised Scheme and other planning applications in the surrounding area. Residual

effects are determined following assessment and the incorporation of mitigation.

9.9 This chapter has been produced in line with the EIA Regulations (2011). However, it should be

noted that the 2017 Regulations now contain additional matters which were not required to be

assessed in the 2011 Regulations. As these matters are clearly important, whilst this ES will be

determined in line with the 2011 Regulations, the additional matters which would have been

required under the 2017 Regulations have also been assessed, and the scope of this work is

explained in more detail within Chapter 1 and Chapter 2.


Water Framework Directive (WFD) 2000/60/EC37

9.10 This was established in 2000 to preserve, restore and improve the water environment, and is

transposed into law in England and Wales through the Water Environment (Water Framework

Directive) (England and Wales) in 2003 with the data recorded in the River Basin Management

Plans.

9.11 The Environmental Objectives of the WFD for surface waters include:

• Prevent deterioration in status of all water bodies;

• Protect, enhance and restore all bodies of surface water with the aim of achieving good

surface water status by 2015 [or in some cases 2027];

• Comply with the standards and objective for Protected Areas;

• Aim to cease or phase out discharges, emissions and losses of priority hazardous

substances.

Directive on Environmental Quality Standards (EQSD) 2008/105/EC38

• Sets out the environmental quality standards (EQS) for the substances in surface waters

(river, lake, transitional and coastal) and confirm their designation as priority or priority

hazardous substances.

• With reference to the WFD, good chemical status is achieved when a water body complies

with the EQS for all the priority substances and other pollutants listed in Annex I of the

EQSD.

Water Act 200339 and Water Resources Act 199140

• Governs the control of water abstraction, discharge to water bodies, water impoundment,

conservation and drought provision.

37European Commission (2000),’Directive 2000/60/EC - Water Framework Directive’ 38 European Commission (2008), Directive on Environmental Quality Standards (EQSD) 2008/105/EC 39 Water Act 2003 40 Water Resources Act 1991


December 2015

Page | 125

• The 2003 Act has changed six key areas of the 1991 Act and relevant to the components

of the Revised Scheme is the need to obtain a license for any dewatering for engineering

works, which was previously exempt.

• The Water Resources Act sets out the relevant statutory regulatory controls that provide

protection of water bodies and water resources.

Flood and Water Management Act 201041

• Provides for better, more comprehensive management of flood risk for people, homes

and businesses, helps safeguard community groups from unaffordable rises in surface

water drainage charges, and protects water supplies to the consumer.

• The activities required under this act aim to reduce the flood risk associated with extreme

weather.

Environmental Protection Act 199042

• Establishes the legislative framework for identifying and dealing with contaminated land

and water.

The Land Drainage Act, 199143

• Underpins ordinary watercourse regulation undertaken by Local Authorities.

• Requires that a watercourse be maintained by its owner in such a condition that the free

flow of water is not impeded.

• The riparian owner must accept the natural flow from upstream but need not carry out

work to cater for increased flows resulting from some types of works carried out

upstream.

Groundwater Regulations 199844

• Outlines the requirement for the prevention of risks to groundwater from certain

substances.

Environmental Permitting Regulations 2010 (as amended)45

• Includes the discharge of water and groundwater activates.

Environmental Protection (Duty of Care) Regulations 1991 (as amended)46

• Ensures that waste is properly stored while on the premised and that it is adequately

packaged for transportation.

41 Flood and Water Management Act 2010 42 Environmental Protection Act 1990 43 The Land Drainage Act, 1991 44 Groundwater Regulations 1998 45 The Environmental Permitting (England and Wales) Regulations 2010 46 The Environmental Protection (Duty of Care) Regulations 1991


December 2015

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Environmental Damage (Prevention and Remediation) Regulations 200947

• Aim to prevent and remedy damage to land, water and biodiversity.

The Water Environment (Water Framework Directive) Regulations 200348

• Transposes 2000/63/EC into law in England.

National Planning Policy

National Planning Policy Framework (NPPF) 201249

• The aims of planning policy on development and flood risk are to ensure that flood risk is

taken into account at all stages in the planning process to avoid inappropriate

development in areas at risk of flooding, and to direct development away from areas at

the highest risk.

• Where new development is, exceptionally, necessary in such areas, policy aims to make it

safe without increasing flood risk elsewhere and where possible, reducing flood risk

overall. It also emphasises the need to adopt proactive mitigation to protect development

against Climate Change in the long term.

Planning Practice Guidance (PPG) - 201450

• Provides additional guidance to ensure the effective implementation of the planning

policy set out in the NPPF on development in areas of flood risk.

• Provides more detail on the Sequential and Exception Test, producing Flood Risk

Assessments, with the inclusion of climate change and managing residual flood risk.

Local Policy

Gloucestershire County Council Local Flood Risk Management Strategy51

9.12 Under the Flood and Water Management Act 2010, Gloucestershire County Council was

designated a Lead Local Flood Authority (LLFA), with a key requirement of the Act requiring

Gloucestershire County Council to produce and maintain a Local Flood Risk Management

Strategy. The Local Strategy is an important tool to help individuals, communities, businesses

and authorities understand and manage flood risk within the county.

Stroud District Council Adopted Local Plan (adopted November 2015)52

9.13 SDC Local Plan has been adopted and Policy ES4 (Water resources, quality and flood risk) will be

the key development policy with respect to the development and flood risk and drainage. The

policy emphasises the reduction of flood risk, the incorporation of SuDS and mitigation measures

to reduce flood risk and surface water runoff.

47 Environmental Damage (Prevention and Remediation) Regulations 2009 48 The Water Environment (Water Framework Directive) Regulations 2003 49 Communities and Local Government (2012), ‘National Planning Policy Framework’ 50Communities and Local Government (2014), ‘Planning Practice Guidance - Flood Risk and Coastal Change, ID 7’,

March 2014. http://planningguidance.planningportal.gov.uk/blog/guidance/flood-risk-and-coastal-change/ 51 Gloucestershire County Council (2014) Local Flood Risk Management Strategy, Main Document 52 The Stroud District Local Plan available from https://www.stroud.gov.uk/media/1455/stroud-district-local-

plan_november-2015_low-res_for-web.pdf accessed on 27th November 2017.


December 2015

Page | 127

Eastington Neighbourhood Development (adopted October 2016)53

9.14 The NDP was made in October 2016, and now forms part of the Development Plan. Policy EP2

sets a criteria based test. It requires that where appropriate, development proposal should

incorporate SuDS. It also confirms that development will not be supported within 8m of all

watercourses in the parish and within Flood Zone 3.

9.15 Further information in relation to planning policy is provided in Chapter 6 – Planning Policy

Context.


9.16 This assessment has been prepared by a suitably competent person. Kristian Jackson BA (hons)

MCD is a Senior Hydrologist and Member of Chartered Institute of Water and Environmental

Management (MCIWEM) and an affiliate member of the Institute of Environmental Management

and Assessment.

9.17 Kristian has over six years of consultancy experience within the hydrology and flood risk sector

and has worked on a number of EIA projects throughout the UK including residential and

commercial developments, cable routes, solar farms, rail projects and windfarms. Kristian is also

a Technical Specialist ES reviewer for hydrology and flood risk for a London Borough.

9.18 This section of the chapter presents the following:

• Identification of the information sources that have been consulted throughout the

preparation of this chapter;

• Details of the consultation undertaken with respect to hydrology, drainage and flood risk;

• The methodology behind the assessment of hydrological effects, including the criteria for

the determination of sensitivity of a receptor and magnitude of change from the existing

(baseline) condition;

• An explanation as to how the identification and assessment of potential hydrological

effects has been reached;

• The significance criteria and terminology for the assessment of the residual effects to flood

risk, hydrology and drainage.

Data Sources

9.19 Initial baseline information on the physical environment was gathered from the following

sources:

• Environment Agency flood maps and data54;

• Severn River Basin District River Basin Management Plan55;

• Scheme proposals and design parameters;

• OS Mapping;

53 Eastington Neighbourhood Development Plan available from http://eastington-pc.gov.uk/wp-

content/uploads/2016/08/Eastington-NDP-Adopted-Version-Oct-2016.pdf accessed on 27th November 2017. 54 Environment Agency online mapping, available at http://watermaps.environment-

agency.gov.uk/wiyby/wiyby.aspx?lang=_e&topic=floodmap&layer=default&scale=2&x=357683&y=355134#x=3576

83&y=355134&scale=2 55 Environment Agency (2009), River Basin Management Plan, Severn River Basin District


December 2015

Page | 128

• Aerial mapping;

• British Geological Survey geology maps and borehole records56;

• Soilscapes soil classification data57;

• Borehole data provided by Cotswolds Canals Trust58

• Stroud Strategic Flood Risk Assessment59;

• Gloucestershire Preliminary Flood Risk Assessment60;

• Gloucestershire Local Flood Risk Management Strategy;

• Private Water Supply data;

• Abstraction and Discharge license data.

9.20 This chapter of the ES has been accompanied by a Flood Risk Assessment for the Site produced

by RSK (660670 R3 (01)) and included as RS Appendix 9.1.

Data Limitations

9.21 Reliance has been placed on factual and anecdotal data obtained from the sources identified

above. New information, revised practices or changes in legislation during the assessment or

development stages may necessitate the reinterpretation of the report, in whole or in part.

9.22 There are no significant areas of uncertainty with regard to the assessment of hydrological

environmental effects and mitigation measures. However, further hydrological/ geotechnical

assessment may be undertaken at the detailed design stage during Reserved Matters

Applications for construction and engineering purposes.

9.23 Overall, despite the potential uncertainties, it is considered that the available data is sufficient

to provide a robust basis for the assessment undertaken.

Study Area

9.24 The Study Area (see RS Figure 9.1) covered by this chapter includes the assessment of the

hydrological environment within the Redline Boundary, with a range extending to approximately

250m downstream for direct effects (ensuring the survey encompasses the River Frome). Direct

effects have been assessed on watercourses within the 250m search boundary. Under the

direction of the Water Framework Directive, it is required that recorded watercourses

downstream of the Site have been considered within the assessment process to ensure that no

deterioration of downstream watercourse status occurs. Therefore, indirect effects upon the

downstream recorded watercourses have been included in the assessment process.

Consultation and Scoping Overview

9.25 As part of the scoping phase of the Environmental Impact Assessment (EIA), a Scoping Report

was prepared in July 2015 (RS Appendix 1.3), setting out the proposed approach to the

56 British Geological Survey online mapping, available at

http://mapapps.bgs.ac.uk/geologyofbritain/home.html?location=&gobBtn=go 57 Cranfield Soil and Agrifood Institute – Soilscapes, available at

http://mapapps.bgs.ac.uk/geologyofbritain/home.html?location=&gobBtn=go 58 Cotswolds Canal Trust, Borehole Data 59Stroud District Council (2008) Strategic Flood Risk Assessment for Volume 1 – FINAL September 2008 60Environment Agency (2011) Gloucestershire County Council Preliminary Flood Risk Assessment


December 2015

Page | 129

assessment in respect to the previous scheme. The Scoping Report outlined the identification of

methods utilised for the assessment on flood risk, hydrology and drainage.

9.26 A summary of the Scoping Opinion for the previous scheme (RS Appendix 1.2) is outlined below.

Due to the nature of the Revised Scheme, the scoping responses gained through the previous

submission will still hold relevance for the Revised Scheme and have been included below for

completeness:

Table 9.1: Scoping Responses

Consultee Issue Raised Location in chapter

where addressed

Environment

Agency Scoping

Response dated

17/08/15

The Flood Risk to the proposed development Site has been

correctly identified within section 3.63 of the report, in

accordance with our Flood Map for Planning (Rivers and

Seas). The floodplain at this location is from the River

Frome, which is classified as a ‘main river’. As highlighted

the Site benefits from the presence of defences in the area,

and is therefore offered some protection from flooding,

however for planning purposes it is important to consider

the floodplain without the presence of such defences. This

is because the defences may not always be present, and

therefore cannot be relied upon, or they may not be

maintained to their current standard for the lifetime of the

development. In addition, any defence can be subject to

breach, failure or overtopping.

Flood Risk

Assessment (RS

Appendix 9.1)

Environment

Agency Scoping

Response dated

17/08/15

In addition, there are some smaller watercourse and ditches

crossing the southern boundary of the Site, which are

classed as ‘ordinary watercourses’. Please note our Flood

Maps primarily show flooding from main rivers, not

ordinary watercourses with a catchment of less than 3km2.

Therefore, an assessment of flood risk associated with these

unmodelled watercourses may also be necessary.

Flood Risk

Assessment (RS

Appendix 9.1)

Environment

Agency Scoping

Response dated

17/08/15

The need for a Flood Risk Assessment as required by the

National Planning Policy Framework (NPPF) has been

correctly highlighted in paragraphs 3.72 of the report.

Flood Risk

Assessment (RS

Appendix 9.1)

Environment

Agency Scoping

Response dated

17/08/15

The FRA should define the exact extent of all flood zones

upon the Site to define the appropriate developable area

and appropriately locate development uses in a sequential

manner following the guidance set out within the Flood and

Coastal Change section of the National Planning Practice

Guidance (NPPG).

Flood Risk

Assessment (RS

Appendix 9.1)

Environment

Agency Scoping

Response dated

17/08/15

The assessment should include the effect of climate change

based on the 1% modelled extent of the floodplain that

forms the basis of the outlines shown on our Flood Map.

Flood Risk

Assessment (RS

Appendix 9.1)

Environment

Agency Scoping

Response dated

17/08/15

A Level 2 Strategic Flood Risk Assessment (SFRA) has also

been produced as an evidence base in support of SDC’s

Emerging Local Plan, which we note has been referenced as

a useful source of information on surface water, flood risk

and ground conditions.

Flood Risk

Assessment (RS

Appendix 9.1)

Environment

Agency Scoping

Response dated

17/08/15

For Sites greater than 1 hectare in size, a surface water

strategy should be carried out as part of a Flood Risk

Assessment (FRA) to demonstrate that the proposals will

not create an increased risk of flooding from surface water.

Flood Risk

Assessment (RS

Appendix 9.1)


December 2015

Page | 130

Consultee Issue Raised Location in chapter

where addressed

We note paragraph 3.74 indicates a drainage strategy is to

be developed to address this issue and detailed further in

paragraph 3.80.

Environment

Agency Scoping

Response dated

17/08/15

We [the EA] would expect the subsequent planning

application to detail any effects on the water environment

in the context of the WFD. This would include any effects

on the watercourses close to the Site, the groundwater

below and any water features in hydraulic continuity.

Potential Effects

section

Environment

Agency Scoping

Response dated

17/08/15

This work should identify existing pressures on the water

body; measures to ensure there is no deterioration in

ecological status and measures to ensure the achievement

of this is not precluded in the future.

Potential Effects

section

Environment

Agency Scoping

Response dated

17/08/15

Measures to improve the ecological status of the water

bodies should also be identified as part of any assessment.

This might include the positive contribution that

Sustainable Urban Drainage (SuDS) can play to water

quality.

Flood Risk

Assessment (RS

Appendix 9.1)

Significance Criteria

9.27 The assessment includes a qualitative assessment of potential effects on flood risk, hydrology

and drainage from construction works and operational activities on Site.

9.28 Potential effects of the Revised Scheme on flood risk, hydrology and drainage have been

identified and assessed using criteria from the Institute of Environmental Management and

Assessment (IEMA 2011).

9.29 The content of this assessment has been identified through a combination of project experience,

available documentation, consultation and professional judgement.

9.30 The assessment of effects has taken into account the sensitivity / importance of the receptor and

the magnitude of the effect on that receptor as set out below.

Table 9.2: Definition and description of sensitivity

Receptor

Sensitivity/

Importance

Receptor

Type

Description / Notes

High Hydrology

and Water

Resources

• Low lying land and local drainage network;

• Areas at high risk of flooding;

• Human receptor – public and visitors;

• Highly and more vulnerable developments, including landfill and Sites

used for waste management facilities for hazardous waste; and

• Principal aquifers.

High Water

Quality

• High and good water quality (as defined by the WFD) with pristine or near

pristine water quality; and

• Areas of known/ confirmed contaminated land/ groundwater.

High Desig-

nated

Sites

• Protected or designated areas e.g. Sites of Special Scientific Interest

(SSSI), Ramsar Sites, Special Protected Areas (SPAs), Special Areas of

Conservation (SACs), which are highly sensitive to disruption.


December 2015

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Receptor

Sensitivity/

Importance

Receptor

Type

Description / Notes

Medium Hydrology

and Water

Resources

• Areas with intermediate groundwater vulnerability;

• Surface water (flow patterns);

• Secondary (A, B and undifferentiated aquifers);

• Areas at a medium risk of flooding;

• Human receptor – construction crew and operators, locals and occupants

with prior knowledge of Site conditions or the local area;

• Less vulnerable developments, including industrial properties and waste

treatment (except landfill and hazardous waste facilities); and

• Surface water drainage networks including drainage ditches and drains

(flow patterns and capacity).

Medium Water

Quality

• Moderate water quality (as defined by the WFD) with a measurable

degradation in its water quality.

Low Hydrology

and Water

Resources

• Areas with low groundwater vulnerability;

• Non-aquifers;

• Areas at a low risk of flooding;

• Water compatible developments, including water transmission

infrastructure and pumping stations, and sand and gravel workings; and

• Local drainage network including drainage ditches and drains, and private

Site drainage.

Low Water

Quality

• Poor or bad water quality (as defined by the WFD) resulting from

anthropogenic factors.

Negligible Hydrology

and Water

Resources

• Features not designated under the WFD, assessed in terms of water

quality or hold any designated affiliation which may be effected upon.

Negligible Water

Quality

• Features not designated under the WFD, assessed in terms of water

quality or hold any designated affiliation which may be effected upon.

9.31 The magnitude of the potential effects resulting from the environmental effects of the

development (adverse or beneficial) on flood risk, hydrology and drainage is outlined in Table

9.3. The allocation of the level of magnitude has been identified through the consideration of

and the application of professional judgement and the assessment of supporting evidence.

Table 9.3: Definition and description of magnitude

Magnitude Receptor Type Description / Notes

Substantial Large scale change to key

hydrological elements

Major or permanent change in

the quality of surface water

resources

Moderate to severe

temporary effect on aquatic

flora and fauna

Moderate increase in peak flood level

Deterioration of a water body leading to a failure to meet

Good Ecological Status (WFD) and reduction in class

Loss of a protected area

Medium Noticeable change to key


Moderate increase in peak flood level


December 2015

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Magnitude Receptor Type Description / Notes

Moderate or temporary

reduction in the quality of

surface water resources

Moderate to severe

temporary effect on aquatic

flora and fauna

Discharge of polluting substances to water body but

insufficient to change water quality status in the long

term

Loss in production of fisheries.

Minor Slight changes to key


Slight reduction in surface

water quality, reversible

within a short period of time

Minor or reversible

detrimental effects on aquatic

flora and fauna

Small increase in peak flood level

Measurable discharge of pollutant to water body which

does not lead to reduction in water quality or failure to

improve status.

Negligible Minute to none identifiable

change to key hydrological

elements

No discernible effects on hydrological elements (neither

beneficial nor adverse)

9.32 The effect is the term used to express the consequence of an impact (expressed as the

significance of effect), which is determined by correlating the magnitude of the effect to the

sensitivity of the receptor. This is achieved using the matrix presented in Table 9.4.

Table 9.4: Significance of effect assessment matrix



Ma

gn

itu

de

of

Ch

an

ge

/ e

ffe





9.33 The terms as used within the table have been defined below:

• Major positive or negative effect: where the development will cause significant

improvement (or deterioration) to the existing environment (significant in EIA terms).

• Moderate positive or negative effect: where the development will cause noticeable

improvement (or deterioration) to the existing environment (significant in EIA terms).

• Minor positive or negative effect: where the development will cause perceptible

improvement (or deterioration) to the existing environment (not significant within the

meaning of the EIA Regulations).


December 2015

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• Negligible: no discernible improvement or deterioration to the existing environment (not

significant within the meaning of the EIA Regulations).

9.34 Effects requiring mitigation measures would be those of significance (which is generally

considered to be a moderate significant effect or higher). An assessment has also been made of

the significance of the residual effects, i.e. those which will remain after application of embedded

and additional mitigation.

9.35 Where the certainty of the effect could be variable, professional judgement and understanding

of the hydrological conditions and knowledge of the Revised Scheme and area has been used in

assessing the consequence of the effect.

9.36 The likelihood of the potential consequence of the effect occurring is then explicitly taken into

account to derive the overall consequence of the effect on hydrology. In terms of the duration

of an effect (as outlined in Chapter 2), short-term has been considered as 1 year (or below), a

medium term effect has been considered to be between 1 and 10 years in duration and a long-

term effect has been considered to be greater than 10 years in duration.

9.37 The levels of likelihood that have been considered are shown in Table 9.5 and the method for

assessing the likelihood of an effect is adapted from the IEMA Quality Mark Article61 .

Table 9.5: Likelihood of effects

Likelihood Definition

Highly

Likely

The event appears very likely in the short term and almost inevitable over the long term

or there is evidence at the receptor of harm or pollution.

Likely It is probable that an event will occur or circumstances are such that the event is not

inevitable, but possible in the short term and likely over the long term.

Unlikely Circumstances are possible under which an event could occur, but it is not certain in the

long term that an event would occur and it is less likely in the short term.

Highly

Unlikely

Circumstances are such that it is improbable the event would occur, even in the long term.

Baseline Conditions

General Site Description

9.38 The Site is located approximately 3.2km to the west of Stonehouse and approximately 7.2km to

the west of Stroud in Gloucestershire. The Site is located around the roundabout at J13 of the

M5, with the development of the Stadium area situated to the north of the A419. The

development proposals are listed in Table 1.1 and shown in RS Figure 1.1.

9.39 The overall Redline Boundary is currently open Greenfield / agricultural land totalling

approximately 39.5ha.

61 Derek Duckett, Xodus, unknown date


December 2015

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Hydrological Features

9.40 Several significant hydrological features are located in close proximity to the Site (see also RS

Figure 9.1). The closest Main River to the Site is the River Frome, which is located adjacent to

the southern Redline Boundary and approximately 500m to the south of the Revised Scheme.

The River Frome rises from springs in the region of Birdlip and Brimpsfield (approximately 16km

to the north-east of the Site). The Frome flows south from its source towards Sapperton where

it turns to the west, flowing past Stroud and the Site before passing beneath the Gloucester and

Sharpness Canal, eventually discharging to the River Severn at Upper Framiload (approximately

4.32km to the north west of the Site).

9.41 An ordinary watercourse (not classed as a Main River by the Environment Agency and therefore

under the LLFA’s jurisdiction) surfaces at Grove Farm to the north of the Site, flows to the north

before turning to the south west and flowing adjacent to the western boundary of the Site. The

drain is then culverted beneath the M5 and appears to re-surface to the west of the Eastington

Maintenance Compound and follow the Redline Boundary before discharging to the River Frome.

9.42 To the east of the Site, the River Frome splits into two branches to the south west of Ebley. The

branches of the Frome converge approximately 800m to the south.

9.43 Sections of the now abandoned Stroudwater Navigation (canal) area are present to the south

and west of the Redline Boundary. When operational, the Stroudwater Navigation linked Stroud

(and the Thames and Severn Canal) to the River Severn. The Stroudwater Navigation was severed

in the vicinity of the Site by the construction of the M5 and the A38. The Stroudwater Navigation

running from the east terminates at William Morris College (approximately 350m from the

Revised Scheme). The former channel of the canal runs adjacent to the south of the Redline

Boundary, this has been confirmed as infilled. A small stretch of the channel exists to the west

of Whitminster. The WFD status of the canal sections has been detailed in RS Appendix 9.2.

9.44 Ordinance Survey mapping shows several small drains, ditches and watercourses, however there

is potential that these may be ephemeral ditches remaining along the line of the former canal

corridor.

9.45 The River Severn is located approximately 3.7km to the west of the Site.

9.46 The watercourses and water bodies within the Site and the surrounding environs (as defined by

the Study Area) are outlined in Table 9.6 and detailed further within the Flood Risk Assessment

(RS Appendix 9.1) and RS Figure 9.1.

Table 9.6: Watercourses in the vicinity of the Site

Watercourse

/Water body

Description Distance from Site

River Frome Main River running to the south of the Site and A419 and

adjacent to the southern Redline Boundary (west of the

M5). Approximately 15m in width at top of bank.

Designated a Main River and recorded under the WFD

(GB209054032450). To the south of Ebley, the River

Frome splits into several branches, which converge again

to the south east of the Proposed Development Site.

500m south of Site (at

closest point)


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Watercourse

/Water body


Stroudwater

Navigation

(canal)

Truncated canal terminates south of William Morris

College. Approximately 15m width of channel prior to

the terminus. Small drain potential connects into

tributary of the River Frome. The Stroudwater

Navigation to the east of the Site is classified by the

Inland Waterways Association as an isolated section, ‘a

canal in water and used for limited navigation but

isolated from other parts of the waterway’. The section

of ‘watered’ canal closest to the Site is classified as a

Disused Canal, where, ‘the line of the waterway is clearly

evident and retaining some water although it may be

heavily silted or overgrown’. The Stroudwater Navigation

to the south of the Site is classified by the Inland

Waterways Association as an Historic Line of Canal, the

‘line of waterway largely obliterated; built over or filled

in, with little or no visible evidence of canal remaining’.

To the west of the Site (beyond the A38 to the River

Severn) the Stroudwater Navigation is classed as either a

derelict canal or disused canal. The Cotswold Canals

Partnership has bid to the Heritage Lottery Fund towards

the cost of the restoration of the 6.4km stretch of the

Stroudwater navigation from Stonehouse to Saul. A

Scoping Request has also been submitted ahead of

making a planning application.

350m to the south of the

Revised Scheme

The Selbrook Small drain (assumed 1-2m width at top of bank), tree

lined channel. Surfaces at Grove Farm to the north of the

Site, flows to the north before turning to the south west

and flowing adjacent to the western boundary of the

Site. The drain is then culverted beneath the M5 and

appears to re-surface to the west of the Eastington

Maintenance Compound and follow the line of the Site

boundary before discharging to the River Frome.

Flowing adjacent to the

western boundaries of the

Site.

Former line

of

Stroudwater

Navigation

(infilled)

Small depression may remain where former Stroudwater

Canal is infilled (potentially ephemeral), with no ability

to convey surface water flows

Located to the south of the

Redline Boundary

Unnamed

Drain

Small watercourse shown on OS mapping flowing from

the east, beneath the roundabout on the A419, then to

the south of William Morris College, towards a

confluence with the River Frome near the Eastington

Trading Estate. The watercourse emerges from several

spring locations to the north and east of Stonehouse and

flows via Stonehouse, Oldends and Nastend towards

Chipmans Platt. Approximately 1 – 2m in width at top of

bank.

Located to the south of the

Redline Boundary for

highway works.

Unnamed

Drain

Small watercourse runs to the south of the River Frome,

roughly parallel to the line of the river. The origin of the

ditch is unclear, though appears to form as part of a field

drain before running to the west and beneath the M5

and discharges to the River Frome at Fromebridge Mill.

Approximately 650m to

the southeast of the Site.

Lakes at

Frampton On

Severn

Former gravel pits now utilised for sailing and course

fishing. Northern lake recorded under the WFD

(GB30940946).

Designated a SSSI (Frampton Pools SSSI)

Approximately 1.8km to

the west of the Site


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Watercourse

/Water body


Pond located

in grounds of

Eastington

Court

Small pond located within the grounds of Eastington

Court

Approximately 435m to

the south of the Site

River Severn Main river – Estuarine nature. Designated under the

WFD GB530905415403 – Severn Upper, (where the

Frome discharges to the Severn) and GB530905415402 –

Severn Middle, (closest section to the Site).

Designated SSSI, SPA, SAC and RAMSAR Site

Approximately 3.7km to

the west of the Site.

Flood Defences

9.47 Flood Defences are shown to be in the area along the Frome according to the Environment

Agency Detailed Flood Map for Planning. Further details are included within the Flood Risk

Assessment (RS Appendix 9.1). The Environment Agency did not supply any more information

with regard to the defences in their response to the Product 4 data request.

Geology

Bedrock

9.48 Blue Lias Formation and Charmouth Mudstone Formation (undifferentiated) – Lithological

Description: Thinly interbedded limestone (laminated, nodular, or massive and persistent) and

calcareous mudstone or siltstone (locally laminated). Individual limestones are typically 0.10 –

0.30m thick. In some areas, intervening mudstone units with relatively few limestone beds.

Superficial

9.49 River Terrace Deposits, 3 (Frome, Glos) – Lithological Description: Sand and gravel, locally with

lenses of silt, clay or peat.

9.50 Alluvium – Lithological Description: Normally soft to firm, consolidated, compressibly silty clay,

but can contain layers of silt, sand, peat and basal gravel. A stronger, desiccated surface zone

may be present.

BGS Borehole Records

9.51 Numerous borehole records are present in the surrounding areas of the Site (predominantly

associated with J13 of the M5 – central to the Redline Boundary location). Of the J13 boreholes,

five extend beyond 10m below ground level (mBGL); SO70NE107, SO70NE15, SO70NE109,

SO70NE110, and SO70NE111. The borehole records present similar results with Made Ground

to approximately 6.5mbgl - 8mbgl, with stiff grey thinly laminated clays extending beyond this

depth.

Stroudwater Canal – Preliminary Site Investigation Interpretive Report62

9.52 Preliminary investigation works were undertaken for a stretch of the Stroudwater Canal between

the Ocean (a minor waterways place on the Cotswold Canal to the east of the Site) and Saul

Junction including the infilled section of the canal. In summary, the borehole / geological

sequence was recorded for the area of the Site as;

62 White Young Green (2007) Preliminary Site Investigation Interpretative Report – Stroudwater Canal


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• Topsoil – present at up to 1.0m thickness.

• Alluvium – thickness varied between 0.4m and 3.5m. Greater thicknesses of alluvium

were present closer to the River Frome, indicating that the deposit is closely related to the

course of the river. The alluvium was typically a soft-grey – brown slightly gravelly clay.

• River Terrace Gravels – thickness varied between 0.4m and 2.2m and was found at depths

up to 4.8mbgl. The river terrace gravels were typically a yellow brown slightly clayey

gravel of angular to subangular fine to coarse limestone, although in places graded to a

gravelly clay.

• Weathered Lower Lias – thickness extended beyond 8.8m and was encountered at depths

of between 1.8mbgl and 4.8mbgl. Typically described as firm (becoming stiff with depth)

silty clay within the upper 2 – 3m, becoming a stiff grey silty clay with weak mudstone

bands at depth.

• Lower Lias – only encountered in one borehole comprising of grey weathered mudstone

with silty clay bands.

Designations

9.53 International, national and locally designated Sites within a 5km buffer zone of the Site are

illustrated within RS Figure 8.6.

Water Quality

9.54 The WFD requires that environmental objectives be set for all surface and groundwaters in

England and Wales to enable them to achieve Good Status (Or Good Ecological Potential for

Heavily Modified and Artificial Water Bodies) by a defined date.

9.55 The assessment of sensitivity is based on the current status of the waterbody. If the aquatic

environment is of existing poor quality, it is likely to be less sensitive to changes that occur as a

result of construction works (e.g. from an increase in silt content from construction Site

discharge). Therefore, the sensitivity is considered to decline with poorer water quality.

9.56 The WFD classification is not available for all surface waters in the vicinity of the Site. Those

recorded under the WFD are outlined in RS Appendix 9.2.

WFD Screening

9.57 A Water Framework Directive screening exercise has been undertaken with respect to the

watercourses and waterbodies are detailed in RS Appendix 9.2. Due to the nature of the

development, there will be no in-channel works within any of the watercourses listed above, and

current proposals are for discharge via infiltration and as such no off-Site connection to a

watercourse is being sought. Therefore, the potential effects on the watercourses would be

negligible and as there will be no development in, or around the watercourse, the potential to

improve the geomorphology would be very limited. As such this assessment has considered the

objectives of the WFD and ensured that the objectives are not compromised. Therefore, a full

WFD assessment has been scoped out of this EIA.

Flood Risk

Fluvial


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9.58 The Revised Scheme is located outside the flood zone for all return periods up to the 1,000-year

event, indicating a low risk of flooding from fluvial sources.

Tidal

9.59 The Site is not outlined to be a risk of tidal flooding. The River Frome has a flapped outfall

structure to prevent tidal inundation. An extreme fluvial flood event may be exacerbated when

outfalls are tide-locked. The impact of tidal flooding to the development has therefore been

scoped out of the following assessment. However, details regarding this form of flooding have

been considered with the Flood Risk Assessment for the Site, (included in RS Appendix 9.1).

Pluvial

9.60 Surface water flood risk has been a major cause of flooding in more recent times and is a result

of inundation of an area subject to excessive runoff or served by inadequate drainage

infrastructure. Surface water flooding is a potential issue in areas to the north of the A419. It

has been noted by the ecologist that, following a Site walkover, a culvert was located flowing

under the A419. This culvert was heavily silted and therefore the road embankment is acting as

a dam for overland flow routes, contributing to the pluvial flood risk at the site.

Groundwater

9.61 The Revised Scheme is located outside a Source Protection Zone, however they overlie a

Secondary A and Secondary B aquifer (Superficial Deposits) and a Secondary (undifferentiated)

aquifer (bedrock). The Secondary A and to a lesser extent the Secondary B aquifers may have

permeable layers capable of supporting water supplies at a local scale. With the Blue Lias

bedrock beneath the Site, it is possible that areas of perched groundwater may be encountered.

Groundwater flooding however is sporadic and groundwater records are generally limited. It has

been indicated that Groundwater Emergence Maps do not cover the Stroud District and there

are no records of groundwater flooding incidents in the area. Groundwater flooding has

therefore been scoped out of the following assessment, however details regarding this form of

flooding have been considered with the Flood Risk Assessment for the Site, (included in RS

Appendix 9.1).

Sewer

9.62 With the predominantly Greenfield nature of the Site, it is believed that any sewer flood risk to

the Site would be low, and in all likelihood contained within the arterial road network

surrounding the Site areas. Residual effects from non-functioning / over flowing septic tanks

could lead to isolated incidents of ‘sewer flooding’ on Site. Sewer flooding has therefore been

scoped out of the following assessment.

Reservoirs

9.63 The Revised Scheme is not indicated to be at risk of flooding from reservoirs according to the EA

reservoir flood maps.

9.64 Small sections of the area within the Redline Boundary west of the M5 are classed as being at

risk of reservoir flooding with the potential source reservoirs being Parkmill Pond, Kennel Pond

and Middle Pond in Woodchester, according to the EA reservoir flood maps.

9.65 The risk of reservoir flooding is extremely unlikely. There has been no loss of life in the UK from

reservoir flooding since 1925. Since then safety legislation has been introduced to ensure


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reservoirs are maintained. The EA reservoir flood map shows the largest area that might be

flooded if a reservoir were to fail and release the water it holds. Since this is a prediction of a

worst case scenario, it is unlikely that any actual flood would be this large. This is therefore

scoped out for the purposes of this assessment, however details regarding this form of flooding

have been considered with the Flood Risk Assessment for the Site, (included in RS Appendix 9.1).

Artificial Structures (Canals)

9.66 The truncated Stroudwater Navigation is in close proximity of the Site; however, the section of

the canal up to its terminus to the south east of the Site is not classed as providing a residual

flood risk to the surrounding area and is therefore scoped out of this assessment. As such the

risk of flooding to the Site is considered low, with further details provided within the Flood Risk

Assessment for the Site, (included in RS Appendix 9.1).

Historic Flood Records

9.67 Historic flood events have been recorded in the vicinity of the Site. Two isolated records are

located within the vicinity of the Northern and Southern Site areas (an unknown flood event

within the Development Footprint to the north of the A419, and a flood event from artificial

drainage on the A419). By contrast, a total of 18 flood events are mapped by SDC within the area

west of the M5 or at the neighbouring Eastington Maintenance Compound (2 surface water

records, 5 artificial drainage records, 1 fluvial record and 11 unknown records).

Climate Change

9.68 Climate Change can affect local flood risk in several ways. Effects will depend on local conditions

and vulnerability. In terms of the wider effects of the climate change these are detailed in RS

Chapter 16. Climate Change influences specific to hydrology and flood risk for the Revised

Scheme are outline below.

9.69 In accordance with the recently published Flood Risk Assessments: Climate Change allowances

applicable to this Site are predictions of anticipated change for peak river flow (by river basin

district) and peak rainfall intensity.

Peak River Flow

9.70 The Guidance provides a range of peak river flow allowances against an Allowance Category. The

Allowance Categories are based on percentiles (a measure used in statistics to describe the

proportion of possible scenarios that fall below an allowance level), with:

• The central allowance based on the 50th percentile

• The higher central based on the 70th percentile

• The upper end based on the 90th percentile.

9.71 The determination of the Allowance Category applicable to the Site is ascertained through the

confirmation of the River Basin District in which the Site lies, the flood risk vulnerability of the

development and the flood zone designation of the Site.

9.72 With the location of the Revised Scheme in Flood Zone 1 the Guidance does not provide

information of peak river flow allowances for this scenario.


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Peak Rainfall

9.73 In the Severn River Basin District, wetter winters and more rain falling in wet periods may

increase river flooding for rivers and tributaries. More intense rainfall causes more surface

runoff, increasing localised flooding and erosion. In turn, this may increase pressure on drains,

sewers and water quality. Storm intensity in summer could increase even in drier summers.

Rising sea or river levels may increase local flood risk inland or away from major rivers because

of interactions with drains, sewers and smaller watercourses.

9.74 In accordance with the recently published Flood Risk Assessments: Climate Change Allowances,

for the surface water runoff assessment of a mixed use (sports and associated infrastructure)

development (60-year lifetime), the Flood Risk Assessment is required to assess both the central

and upper end allowances to understand the range of impacts at the Site.

9.75 As such an allowance of a 40% increase in the rainfall intensity values for the period 2060 to 2115

will be included in the detailed design of the drainage. This allows for the impact of climate

change on the design of the development with respect to the Central (20%) and Upper End (40%)

allowance. Such events have been considered to ensure that there is no flooding to properties

during these events. These increases will apply towards the end of design lifetime of the

development.

Design Evolution

9.76 The concept design for Eco Park, and the amendments now incorporated within the Revised

Scheme, has evolved such that the Stadium has been located in Flood Zone 1.

9.77 The Revised Scheme will increase the impermeable area from the pre-development state, and

as such will result in an increase in surface water runoff across the Site. It will therefore be

necessary to manage surface water on Site in order to limit the discharge of surface water off

Site at an agreed rate, to provide sufficient on Site attenuation up to the 1 in 100-year climate

change rainfall event and to provide improvements to water quality through appropriate source

treatment.

9.78 The embedded mitigation for the Site will take the form of the proposed SuDS which could

include a combination of soakaways, swales, infiltration basins and permeable paving which

should be located depending on the relative groundwater depths, underlying soil type and

locality of proposed buildings. Subject to infiltration test results, discharge from the Site may be

via infiltration or direct connection to watercourse.

9.79 In terms of Site drainage, most adopted surface water drainage networks are designed to the

criteria set out in the SuDS Manual. One of the design parameters is that sewer systems be

designed such that no flooding of any part of the Site occurs in a 1 in 30-year rainfall event.

9.80 To ensure that sewer and surface water flooding is not exacerbated; surface water must be

considered within the design of the Site. This ensures that any additional surface water and

overland flows are managed correctly, to minimise flood risk to the Site and the surrounding

area. The proposed surface water network on the Site has been designed to ensure exceedance

of the network has been considered and that there is no flooding of properties during a 1 in 100-

year rainfall event.


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9.81 A SuDS system will be utilised on Site, and a new attenuation pond designed as part of the

drainage strategy for the Site.

9.82 The development of the Site will be designed to ensure that any excess surface water during

storm events is contained within the road network and away from properties and released to

the sewer network as capacity dictates.

9.83 Due to the nature of the Site (and in line with the Flood Risk Assessment), surface water will be

discharged from the Site via infiltration (subject to test results).

9.84 Further information on the provisional surface water drainage strategy for the Site is included as

part of the associated Flood Risk Assessment (RS Appendix 9.1) and in the Scheme Specific

Mitigation sections of this Chapter.

Potential Effects


9.85 The construction assessment stage is based on the designs with design evolution (embedded

mitigation - outlined above) during the construction phase. During the construction phase, there

is the potential for the construction of the Revised Scheme to result in the following effects on

the water environment:

• Water pollution from silt laden runoff if allowed to drain to surrounding watercourses

untreated;

• Chemical / fuel spillages and leaks from plant and machinery;

• Cements and concrete spillages from building works;

• Inappropriate disposal of foul waste from the Site;

• Debris from construction Sites blocking culverts, increasing risk of flooding;

• Impermeable areas constructed on Site increasing surface water runoff;

• Changing overland flow routes, increasing flood risk.

9.86 During the construction phase, following embedded mitigation, but prior to mitigation measures

being implemented, there is the potential significant effects anticipated from spillages of fuels,

oils, paints or solvents from the Revised Scheme into watercourses affecting water quality. The

assessment of these is discussed below, however the full detailed assessments for non-

significant effects during the construction phase are included in RS Appendix 9.3

9.87 The closest watercourse to the Revised Scheme is the small watercourse/ drain, which for a short

distance, runs adjacent to the western boundary (the Selbrook). The watercourse is small and

not recorded under the WFD; however, the watercourse does discharge to the River Frome to

the north of the western parcel of the Redline Boundary.

9.88 Due to the proximity of the proposed works to the watercourse, and the relatively short distance

to its discharge point into the River Frome, the watercourse is classed as having a medium

sensitivity. Small watercourses and ditches predominantly have low flows and as such will

reduce the likelihood of any potential contaminants entering the River Frome for the

development location.


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Chemical and Fuel Spillages

9.89 During the construction phase there will be a notable presence and frequency of use of plant and

vehicles on Site. As such fuels, oils, paints, solvents and other chemical contaminants will be

stored and used on Site. The presence and utilisation of these contaminants increases the

potential for spillages and the likelihood of the contaminants reaching a watercourse.

9.90 Where fuels, oils and other chemicals enter a watercourse, they can have a number of effects on

water quality and can be particularly harmful to the local aquatic fauna.

9.91 The sensitivity of the Selbrook adjacent to the western boundary is considered medium due to

the connectivity with the River Frome (medium sensitivity).

9.92 Accidental spillages of chemical pollutants which could migrate towards the watercourse

adjacent to the Revised Scheme would have a substantial magnitude of impact on the

watercourse, with the potential to cause significant, long term changes to the watercourse.

9.93 In line with the assessment of significance matrix (Table 9.4), the overall significance of

accidental spillages of oils, fuels, or other chemicals during construction activities entering the

Selbrook adjacent to the western boundary of the Revised Scheme degrading water quality is

considered a moderate negative significance of effect, and therefore significant in EIA terms. Any

effect on the watercourse will be considered short term (i.e. duration of construction works in

proximity to the watercourse), and with the low-level sensitivity of the watercourse, non-

permanent and restricted to the local scale.

9.94 Due to the hydrological connectivity of the watercourse to the River Frome (medium sensitivity

in accordance with the WFD status), the magnitude of the impact due to a reduction in water

quality following accidental chemical spillages into the small watercourse discharging to the

Frome is considered medium. The flow of the River Frome and the distance from the Revised

Scheme to the confluence of the adjacent watercourse and the Frome is such that itallows for

potential remediation actions prior to reaching the Frome).

9.95 In line with the assessment of significance matrix (Table 9.4), the overall significance of

accidental spillages of oils, fuels, or other chemicals from the Revised Scheme degrading water

quality within the River Frome is considered a moderate negative significance of effect, and

therefore significant in EIA terms. Any effect on the watercourse will be considered short term

(i.e. duration of construction works in proximity to the watercourse), with the flow of the River

Frome and the distance from the Revised Scheme to the confluence of the adjacent watercourse

and the Frome limiting some of the impact. Both effects will therefore be viewed as significant

in EIA terms.

Cements and Concrete Spillages

9.96 During the construction phase there will be an increased presence and frequency of use of

cements and concretes. This use will necessitate the storage on Site and the transport to the

Site of the mixtures. The presence and utilisation of these mixtures increases the potential for

spillages and the likelihood of the contaminants reaching a watercourse.

9.97 Concretes and cements, when entering a watercourse, can have a number of effects on water

quality. Concretes and cements are highly alkaline and corrosive and can cause serious pollution


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to watercourse. Invertebrates and fish are particularly sensitive to changes in pH levels. Unlike

oil spillages, changes to pH levels in watercourses are not immediately apparent and can occur

for some time before the extent is realised.

9.98 Concretes and cements could potentially reach surface water receptors following accidental

spillages during the construction of the commercial units, via concrete wastewater or via

dispersal of concrete dust.

9.99 The sensitivity of the unnamed watercourse adjacent to the western boundary is considered

medium due to the connectivity with the River Frome (medium sensitivity).

9.100 Ingress of concretes and cements via spillages, wastewater or dust dispersal would have a

substantial magnitude impact on the watercourse adjacent to the Revised Scheme, with the

potential to cause significant, long term and potentially unseen changes to the watercourse.

9.101 In line with the assessment of significance matrix (Table 9.4), the overall significance of cements

and concretes activities entering the watercourse adjacent to the western boundary of the

Revised Scheme (The Selbrook) degrading water quality is considered a moderate negative

significance of effect, and therefore significant in EIA terms. Any effect on the watercourse will

be considered short term (i.e. duration of construction works in proximity to the watercourse),

and with the low-level sensitivity of the watercourse, non-permanent and restricted to the local

scale.

9.102 Due to the hydrological connectivity of the watercourse to the River Frome (medium sensitivity

in accordance with the WFD status), the magnitude of the impact due to a reduction in water

quality following ingress of concretes or cements into the small watercourse discharging to the

Frome is considered medium. The flow of the River Frome and the distance from the Revised

Scheme to the confluence of the adjacent watercourse and the Frome is such that it allows for

potential remediation actions prior to reaching the Frome).

9.103 In line with the assessment of significance matrix (Table 9.4), the overall significance of cements

and concretes from the Revised Scheme degrading water quality within the River Frome is

considered a moderate negative significance of effect and therefore significant in EIA terms. Any

effect on the watercourse would be considered short term (i.e. duration of construction works

in proximity to the watercourse), with the flow of the River Frome and the distance from the

Revised Scheme to the confluence of the adjacent watercourse and the Frome limiting some of

the impact. Both effects will therefore constitute significant effects in terms of the EIA

Regulations.

Operational Effects

9.104 The operational assessment stage is based on the completed designs with design evolution

(embedded mitigation - outlined above) and assumed design standards during the operational

phase.

9.105 During the operational phase, there is the potential for the utilisation of the Revised Scheme to

result in the following impacts on the water environment:

• Oil / fuel spillages and leaks from vehicles;


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• Potential flooding from surface water drainage network exceedance;

• New impermeable areas altering surface water runoff rates, impacting upon downstream

flood risk;

• New impermeable areas increasing risk on Site surface water flooding;

• Potential risk of increased flooding caused by climatic changes;

• Biodiversity and conservation effects.

9.106 Other than biodiversity and conservation effects, there are no significant effects anticipated by

the Revised Scheme. The full detailed assessments for non-significant effect during the

operational phase are included in RS Appendix 9.3.

9.107 The incorporation of the SuDS infiltration features into the surface water drainage network will

provide beneficial ecological and conservation effects. The SuDS features will introduce

attractive planting features, and increased biodiversity whilst helping to ensure adaptation to

climate change. Due to the desired nature of the development, demonstrating the best in

sustainability principles, the magnitude of the impact of the increased biodiversity following

SuDS development is considered medium.

9.108 In line with the assessment of significance matrix (Table 9.4), the overall significance of the

increased biodiversity following the incorporation of SuDS techniques into the drainage design

is considered moderate positive and therefore significant within the meaning of the EIA

Regulations.


9.109 This sub-section details all of the mitigation and enhancement measures that will be

implemented during the construction and operational phases of the Revised Scheme.

9.110 Such measures will be secured through the production of a Construction Environmental

Management Plan (CEMP) for the development. A standalone Surface Water Management Plan

(SWMP) will be prepared in response to a condition on any planning permission that is granted.

These documents will be secured through planning conditions.

Best Practice

9.111 Mitigation and enhancement will include the use of appropriate measures as outlined on the

Environment Agency’s website and in the now revoked Environment Agency’s Pollution

Prevention Guidelines (PPGs) including guidance on storing and handling materials and products,

Site drainage and dealing with trade effluents, and good environmental practice. Specific details

are provided below:

• PPG 1: General guide to the prevention of water pollution;

• PPG 2: Above ground oil storage tanks;

• PPG 3: Use and design of oil separators in surface water drainage systems;

• PPG 4: Treatment and disposal of sewage where no foul sewer is available;

• PPG 5: Works and maintenance in or near watercourses;

• PPG 6: Working at construction and demolition Sites;

• PPG 7: Safe storage – The safe operation of refueling facilities;

• PPG 8: Safe storage and disposal of used oils;


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• PPG 13: Vehicle washing and cleaning;

• PPG 20: Dewatering of underground ducts and chambers;

• PPG 21: Pollution incident response planning;

• PPG 22: Incident response – dealing with spills;

• PPG 26: Safe storage - drums and intermediate bulk containers.

9.112 In line with the Pollution Prevention Guidelines (in particular PPG5) and best practice to reduce

the instance of silt laden and or contaminated runoff from the Site during the construction

period, the following measures will be implemented.

9.113 With respect to stockpiles, exposed ground and sediment:

• Minimise the amount of exposed ground and soil stockpiles from which water drains and

the period of time such water drains (any surplus excavated materials will be disposed of

offsite as early as possible);

• Gaps will be provided at intervals in the stockpiles to act as water pathways to ensure that

floodwater movement is not hindered and surface water flooding is not exacerbated;

• Only remove vegetation from the area that needs to be exposed in the near future (ensure

a vegetated strip will be left adjacent to any watercourses);

• Seed or cover stockpiles;

• All soils will be stored away from watercourses and any potentially contaminated soil will

be stored on an impermeable surface and covered to reduce leachate generation and

potential migration to surface waters;

• Use of silt fences at the toe of the slopes, made from semi-permeable geotextile fabric,

vertically held on timber post, to reduce sediment transportation;

• Use of silt traps on the inlet or outlets side of culverts to reduce sediment transportation;

• Provided lagoons / ponds that allow suspended solids to settle out before disposal;

• Use of straw bales to filter out sediment from normal flows in drainage ditches, pinned

into position to avoid being washed away. Silt laden bales should be discarded in line with

relevant waste regulations.

9.114 With respect to on-Site working:

• Ensure that any vehicle or plant washing is carried out on designated areas of hard

standing at least 10m from any watercourse or surface water body;

• Collect run-off from hard standing area in a sump;

• Ensure settled solids are removed regularly.

9.115 For the disposal of contaminated water treatment and disposal methods include:

• Tanker off Site by registered waste carrier;

• Discharge to foul sewer (subject to agreements);

• Use of Sustainable Drainage Systems (SuDS);

• Settlement lagoons to allow contaminants to settle out;

• Filtration through use of straw bales or geotextiles.

9.116 With respect to safe storage and use of concrete and cement, concrete and cement mixing and

washing areas should:


December 2015

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• Be sited 10m from any watercourse or surface water drain to minimise the risk of runoff

entering a watercourse;

• Have settlement and re-circulation systems for water re-use, to minimise the risk of

pollution and reduce water usage;

• Dispose of contained water to either foul sewer if possible, or tanker off Site.

9.117 With respect to safe storage and use of oils and chemicals:

• Fuel, oil and chemical storage should be on an impervious base within a secondary

containment system such as a bund. The base and bund walls should be impermeable to

the solution stored and be able to contain at least 110% of the volume stored;

• The storage facility should be sited at least 10m from any watercourse and 50m away from

any well, borehole or spring;

• Appropriate spill kits should be stored in the immediate vicinity of the storage facility and

trained staff to utilise in case of incident.

9.118 When refuelling (risk of spillage is greatest when refuelling plant):

• Refuel mobile plant in designated areas, or on impermeable base away from drain,

watercourses or abstraction locations;

• Use a bunded bowser;

• Supervise all refuelling and bulk deliveries;

• Check the available capacity in the tank before refuelling;

• Don’t jam open a delivery valve;

• Check hoses and valves regularly for signs of wear;

• Turn off valves after refuelling and lock them when not in use;

• Position drip trays under pumps to catch minor spills;

• Keep a spill kit with sand, earth or commercial products for containment of spillages;

• Provide incident response training to staff and contractors.

9.119 With respect to vehicle and wheel washing on Site:

• Vehicle washing and cleaning should be carried out in areas that are clearly marked and

isolated from surface water drainage systems, unmade ground and porous surfaces

(designated washing bays);

• A designated washing bay should be designed so that runoff is isolated using channels,

gullies, gradients, directed to a silt trap or sediment tank to remove larger particles, and

either collected in a sealed system for reuse or authorised disposal or discharged to public

foul sewer (subject to approval).

9.120 With respect to oils and trade materials on Site:

• If possible, use biodegradable hydraulic oil in plant when working in or near watercourses;

• If possible, use water based or low solvent products;

• Avoid products containing lead as a drying agent and those containing hazardous solvents

(toluene or chlorinated hydrocarbons);

• Provide safe and secure storage (biodegradable oils to same standards as synthetic oils).


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9.121 With respect to any uncontrolled (and particulate) runoff from construction areas and access

tracks:

• Any compounds should, where possible, utilise a wide strip of geotextile laid on the

ground covered by a nominal layer of stone to form the compound. Areas of the

construction compound such as porta cabins, storage systems etc., will result in the

potential increase in surface water runoff;

• Generally, the compounds will maintain a permeable nature, however as there will be an

increase in hard standing, a form of attenuation will be required on Site to maintain flow

rates at the pre-development level;

• Any flows in excess of the infiltration rates will be stored in the attenuation facility and

will not have an effect on land outside the Site. The specifications of the attenuation

facility will be determined at the detailed design stage;

• Where stone is used as a capping layer, the content of the stone should not include a high

percentage of fines so as not to increase the risk of sediment contamination of the

adjacent area and watercourses.

Residual Effects

9.122 An assessment of the significance of the effects likely to arise as a result of the Revised Scheme

after embedded mitigation and further mitigation and enhancement measures have been

employed is included at the end of the chapter in Table 9.8 (Construction) and Table 9.9

(Operational).

9.123 The assessment of significance in terms of each receptor is included (in full) for both significant

and non-significant effects in RS Appendix 9.3.

9.124 A detailed Flood Risk Assessment has been carried out on this Site and an assessment of potential

effects on potential receptive watercourses and other hydrological elements has been carried

out. Several of the watercourses in the vicinity of the Site have been assessed to be of moderate

sensitivity. This assessment concludes that without mitigation there is potential for significant

negative effects on the River Frome and associated tributaries, primarily from spillages of

chemicals and cements potentially degrading water quality of the watercourses.

9.125 Suitable mitigation in the form of an appropriately detailed CEMP (including a Pollution

Prevention Plan), will be developed and agreed with the Local Planning Authority (LPA) and the

Environment Agency during the evolution of Reserved Matters Applications prior to

commencement on Site. Therefore, these potentially significant effects can be removed, to

ensure there are no significant negative effects on these watercourses.

9.126 Comprehensive biodiversity enhancements throughout the Site through the development of the

SuDS drainage network will ensure that water quality is not diminished, and in turn, the

development does not compromise the objectives of the Water Framework Directive. The

development will also ensure that ecological value, ecosystem service value and benefit to

human health and wellbeing is increased and represents a residual positive effect resulting from

the biodiversity enhancements.


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9.127 The majority of the effects following the Design Evolution and any further mitigation (as secured

through the CEMP) are not considered significant.

Cumulative Effects

9.128 Cumulative effects, both individually and in combination, on hydrological receptors may arise

from multiple developments within the range of sensitivity of each receptor. Effects may be

direct (such as water pollution) or indirect (such as habitat loss).


9.129 The cumulative assessment considers major planned development (i.e. validated planning

applications and schemes at appeal) within 5km of the developable area. Relevant proposals at

the pre-planning stage (‘in scoping’) are also considered including the Cotswolds Canals

Partnership Phase1b Proposals for restoration of the Stroudwater Canal. The cumulative

assessment schemes (CAS) which have the potential to cause cumulative ecological effects are

listed in Table 9.7.

Effect interactions

9.130 The potential for interaction between effects on the hydrology, drainage and flood risk and other

aspects of the environment are identified in other technical chapters and also described here.

Biodiversity and Hydrology

9.131 Possible inter-relationships can occur between the water environment and aquatic ecology and

biodiversity.

9.132 Mobilised materials (suspended solids) can potentially produce adverse effects on aquatic

ecology. In particular, suspended solids may have an effect on:

• the survival of fish eggs in gravel beds or spawning grounds as a result of deoxygenation

caused by silt deposition;

• the survival of plants and algae by smothering;

• the survival of young fish and aquatic invertebrates such as dragonflies through gill

damage from sediment particles;

• the success of angling owing to increased turbidity;

• amenity value through impaired visual appearance.

Ground Environment and Hydrology

9.133 Inter-relationships will occur between the hydrological and ground environment. The ground

environment interacts with the hydrology principally through groundwater and the

hydrogeological environment. The hydrology can also be affected through changes in soil

drainage parameters, which has implications on flooding patterns; via sediment ingress or

migration of contamination to surface watercourses. Groundwater within permeable superficial

and bedrock strata provides base flow of water to surface water courses and rivers on a local and

regional scale. Contamination within groundwater has the potential to migrate to surface water.

Similarly, possible inter-relationships will also be present between surface water hydrology and

hydrogeology.


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Climate Change and Major Accidents and Disasters

9.134 Inter-relationships will occur between the hydrological and changing climatic influences. In

terms of Climate Change, in line with the current guidelines the Revised Scheme has been

considered in line with the allowances for peak river flow increases and rainfall increases. Due

to the location of the Revised Scheme in Flood Zone 1, the flow increase attributed to climate

change in the Frome are not applicable to the Revised Scheme. Climate Change allowances in

terms of increased rainfall will be included as part of the drainage strategy for the Revised

Scheme.

Cumulative Inter-Relationships

9.135 There are 9 applications at varying stages of planning as outlined by SDC that have been

identified as having as either having effect interactions or in-combination effects. The details of

the proposals are provided in Table 2.5 and illustrated in RS Figure 18.1 (other than the Junction

13 Highways Drainage Works).

9.136 The following committed developments (Table 9.7), as set out on the following page, have been

cumulatively assessed with respect to hydrology and flood risk and scoped in or out of the

assessment accordingly.


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Table 9.7: Cumulative Effects

Planning application

/ allocation ref no. Application Cumulative Assessment

Cumulative Effects

S.14/0810/OUT

Land West of

Stonehouse

Nastend Lane,

Nastend,

Stonehouse,

Gloucestershire

Application

Permitted

S.17/0095/REM

Land West of

Stonehouse Nastend

Lane, Nastend,

Stonehouse,

Gloucestershire,

S.14/0810/OUT

A mixed-use development

comprising up to 1,350

dwellings and 9.3 hectares

of employment land for

use classes B1, B2 and B8;

a mixed use local centre

comprising use classes A1,

A2, A3, A4, A5, D1, D2 and

B1; primary school, open

space and landscaping,

parking and supporting

infrastructure and utilities;

and the creation of new

vehicular accesses from

Grove Lane, Oldends Lane

and Brunel Way.

S.17/0095/REM

Development of areas H1

H6 and H7 as identified in

S.14/0810/OUT for 103

new dwellings comprising

73 open market units and

30 affordable units with

associated infrastructure,

open space and

landscaping.

Summary of Project Detail

Land West of Stonehouse

The construction of the Land West of Stonehouse on land to the north east of Redline Boundary is outlined for a mixed-use

development comprising up to 1,350 dwellings and areas of employment and non-residential uses off Nastend Lane Stonehouse.

Description of Potential Effects

The aspects of the Revised Scheme and the proposed Land West of Stonehouse Site that will result in potential effects on

hydrology are identified below and include;

• The introduction of the stadium and associated infrastructure

• The introduction of the residential and non-residential components of the Land West of Stonehouse scheme

Assessment of Potential Cumulative Effects – During Construction

Revised Scheme.

As discussed in this Chapter, the Revised Scheme will have a moderate negative significance of effect on the tributary of the River

Frome and the River Frome, which both attain a medium sensitivity in line with the direction of the WFD in terms of water quality

following chemical or cement spillages.

The Land West of Stonehouse development

The construction the development is underway, therefore there is potential that there will be an overlap between the

construction phases of the two developments. If developed unmitigated it is assumed that similar effects would occur during the

construction phase and it is therefore inferred that the effect on hydrology will be considered a moderate negative significance

of effect.

Cumulative Effects

Flood Risk

The sensitivity of the land outlined for development (land undeveloped at the Site until 2017) will be classified as low significance

in terms of flood risk. Should the developments occur simultaneously (unmitigated), the magnitude of the cumulative effects will

be considered medium. Therefore, the overall significance of the cumulative increase in surface water runoff and pluvial flooding

potential is considered slight negative, and as such will not be considered significant in EIA terms. If the development timescales

were staggered, the significance of effect will be reduced to negligible

Water Quality

Generally, due to the ‘upstream’ location of the development of ‘West of Stonehouse Site’ the construction works can affect the

Revised Scheme (i.e. increase in silt laden runoff / spillages). As there is potential that both Sites be constructed simultaneously,

Pre-mitigation – minor negative

to moderate negative

significant effects, therefore if

left unmitigated will be

considered significant in EIA

terms.

Following mitigation if both

developments are constructed

simultaneously - negligible

cumulative effects expected

and therefore not significant in

EIA terms.


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Cumulative Effects

there will be an elevated potential for cumulative effects stemming from silt laden runoff or pollutant spillages. The significance

of the receptor unnamed tributary of the River Frome will be medium (draining to the River Frome) and in turn the River Frome

will be considered medium (moderate water quality under the WFD).

Should the developments occur simultaneously (unmitigated), the magnitude of the silt laden runoff cumulative effects will be

considered medium. Therefore, the overall significance of the unmitigated cumulative increase in silt laden runoff from both

developments will be considered moderate negative if the development timescales overlap. If the development timescales were

staggered, the significance of effect will be reduced to minor.

Should the developments occur simultaneously (unmitigated), the magnitude of the chemical spillages cumulative effects will be

considered substantial. Therefore, the overall significance of the unmitigated cumulative increase in chemical spillages both


staggered, the significance of effect will remain moderate negative.

Mitigation / Design Evolution

It is anticipated that West of Stonehouse will be developed in line with the planning policy guidance at the time (NPPF)

It was confirmed that for the Land West of Stonehouse Site, the FRA demonstrated that the Site is suitable for development

without increasing flood risk elsewhere. The development will also ensure that SuDS will be used to manage surface water from

the development and to ensure that water quality is not adversely affected.

The proposed surface water outfall from Revised Scheme is via soakaway and there will be negligible effects on water quality if

both developments are constructed simultaneously.

No mitigation is proposed above and beyond what has already been outlined for the Revised Scheme as this has been developed

to satisfy local and national policies.

Residual Cumulative Effects (following mitigation)

The residual cumulative effects on flood risk following the implementation of the specified mitigation and best if both

developments are constructed simultaneously will be seen as negligible.

The residual cumulative effects on water quality following the implementation of the specified mitigation and best if both


If development timescales for the two developments are staggered, the significance of the residual cumulative effects will remain

negligible.

Cumulative Effects between the Revised Scheme, Land West of Stonehouse Site and Canal Restoration.

There are no cumulative effects anticipated between the West of Stonehouse Site, the Revised Scheme and the proposed canal

works. This is due to the A419 and the tributary of the River Frome separating the West of Stonehouse Site and the proposed

canal works. The tributary of the River Frome and the A419 will create a hydraulic separation between the West of Stonehouse

Site and the canal.


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Cumulative Effects

The cumulative effects of the Revised Scheme and the proposals for the canal are outlined within this table.

S.12/0763/FUL

Unit 27, Bonds Mill,

Bristol Road,

Stonehouse

Permitted

Demolition of part of an

existing warehouse

including a hoist on the

adjacent building,

renovation of the

remainder as office space

and erection of a two

storey extension.

Overview

Approximately 1.65km from the northernmost Site boundary and separated by the Grove Lane and Grove Farm.

As a permitted development it is assumed that the demolition and construction works will have commenced if not completed

within 3 years (from 2102 determination date for S.12/0763/FUL) and unlikely to be in conjunction with the Revised Scheme.

The development is outlined to drain to soakaway / River Frome. There will be no cumulative hydrological effects as a result of

the Revised Scheme.

No cumulative effects

anticipated

S.15/1088/FUL

Westend Courtyard

Grove Lane,

Westend,

Stonehouse,

Gloucestershire

Permitted

Proposed extension to

Westend courtyard to

provide 10 additional

offices (B1 use).

Overview

Approximately 150m from the northernmost Redline Boundary and separated by the Grove Lane and Grove Farm.

The development is outlined to drain to soakaway, and as such there will be no direct hydraulic linkages between the two

developments. There will be no cumulative hydrological effects as a result of the Revised Scheme.


anticipated

S,15/2089/OUT

Land adjacent to

Eastington Trading

Estate, Churchend,

Eastington,

Gloucester

Permitted

Erection of three

industrial employment

buildings with associated

access, car parking and

service yards (Outline

application - Access,

Layout and Scale

included).


The Site to the east of the Redline Boundary is outlined for industrial employment uses.


The aspects of the Revised Scheme and the proposed Former Land adjacent to Eastington Trading Estate site that will result in

potential effects on hydrology are identified below and include;

• The introduction of the stadium and associated infrastructure and the introduction of the new industrial uses


The Revised Scheme

As discussed in this Chapter, the Revised Scheme will have a moderate negative significance of effect on the River Frome, which

attains a medium sensitivity in line with the direction of the WFD in terms of water quality following chemical or cement

spillages.

Land at adjacent to Eastington Trading Estate


anticipated


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Cumulative Effects

The construction timeframe for the development is as yet unconfirmed, the application has been permitted, therefore there is

potential that there could be an overlap between the construction phases of the two developments. If developed unmitigated

it will be assumed that similar effects will occur during the construction phase and it is therefore inferred that the effect on

hydrology will be considered a moderate negative significance of effect.

Cumulative Effects

Water Quality

Generally, due to the ‘upstream’ location of the development of ‘Eastington Trading Estate site’ the construction works can

affect the Revised Scheme (i.e. increase in silt laden runoff / spillages). As there is potential that both Sites be constructed

simultaneously, there will be an elevated potential for cumulative effects stemming from silt laden runoff or pollutant spillages.

The significance of the receptor, the River Frome will be medium (moderate water quality under the WFD).

Should the developments occur simultaneously and unmitigated, the magnitude of the cumulative silt laden runoff cumulative

effects will be considered minor, as a hydraulic connection is maintained through River Frome. Therefore, the overall

significance of the unmitigated cumulative increase in silt laden runoff from both developments will be considered minor

negative if the development timescales overlap. If the development timescales were staggered, the significance of effect will

be reduced to minor.

Should the developments occur simultaneously and unmitigated, the magnitude of the cumulative chemical spillages will be

considered medium, as a hydraulic connection is maintained through the Stroudwater Navigation / River Frome. Therefore, the

overall significance of the unmitigated cumulative increase in chemical spillages both developments would be considered

moderate negative if the development timescales overlap. If the development timescales were staggered, the significance of

effect would remain moderate negative.


It is anticipated that development at the Eastington Trading Estate, will be developed in line with the planning policy guidance

at the time (NPPF)

It is assumed that the development will also ensure that SuDS will be used to manage surface water from the development and

to ensure that water quality is not adversely affected as has been outlined in the Flood Risk Assessment for the development.

The proposed surface water outfall from the Revised Scheme is via soakaway and there will be negligible effects on water

quality if both developments are constructed simultaneously.

No mitigation is proposed above and beyond what has already been outlined for the development of the Revised Scheme as

this has been developed to satisfy local and national policies.


The residual cumulative effects on flood risk following the implementation of the specified mitigation and if both developments

are constructed simultaneously will be seen as negligible.


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Cumulative Effects

The residual cumulative effects on water quality following the implementation of the specified mitigation and if both


If development timescales for the two developments are staggered, the significance of the residual cumulative effects will

remain negligible.

Canal to the south

of the Site

(reinstatement of

Stroudwater Canal)

Canal realignment scheme

subject to successful bid

funding from Canal and

River Trust.


Stroudwater Canal reinstatement

The reinstatement of the Stroudwater Canal in land adjacent to the southern Redline Boundary.


The aspects of the Revised Scheme and the proposed Land West of Stonehouse Site that will result in potential effects on



• The reinstatement of the Stroudwater Canal and any new features added.


The Revised Scheme

As discussed in this Chapter, the Revised Scheme will have a moderate negative significance of effect on the tributary of the River

Frome and the River Frome, which both attain a medium sensitivity in line with the direction of the WFD in terms of water quality

following chemical or cement spillages.

Stroudwater Canal

The construction timeframe for the development is as yet unconfirmed, the application is currently being submitted for funding,

therefore there is potential that there could be an overlap between the construction phases of the two developments. If

developed unmitigated it will be assumed that similar effects will occur during the construction phase and it is therefore inferred

that the effect on hydrology will be considered a moderate negative significance of effect.

Cumulative Effects

Water Quality

Generally, due to the ‘downstream’ / adjacent location of the reinstatement works the construction works can affect the Revised

Scheme and on the canal, works (i.e. increase in silt laden runoff / spillages). As there is potential that both Sites be constructed


The significance of the receptor (The Selbrook) y of the River Frome will be medium (draining to the River Frome) and in turn the

River Frome will be considered medium (moderate water quality under the WFD).




cumulative effects expected.


December 2015

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Cumulative Effects

Should the developments occur simultaneously and unmitigated, the magnitude of the cumulative silt laden runoff will be

considered medium. This is due to the potentially large volume of excavated soils to construct the canal in close proximity to

assessed watercourses that maintain a hydraulic connection between the Sites. Therefore, the overall significance of the

unmitigated cumulative increase in silt laden runoff from both developments will be considered moderate negative if the

development timescales overlap. If the development timescales were staggered, the significance of effect will be reduced to

minor.


considered medium. Therefore, the overall significance of the unmitigated cumulative increase in chemical spillages both


staggered, the significance of effect will remain moderate negative.


It is anticipated that canal restoration will be developed in line with the planning policy guidance (NPPF) / design standards at the

time.

The proposed surface water outfall from the Revised Scheme is via soakaway and there will be negligible effects on water quality

if both developments are constructed simultaneously.

No mitigation is proposed above and beyond what has already been outlined for the development of the Revised Scheme as this

has been developed to satisfy local and national policies.






If development timescales for the two developments are staggered, the significance of the residual cumulative effects will remain

negligible.

13/0001/INQUIR

Land at Javelin Park

Planning Appeal

Proposed development of

an Energy from Waste

(EfW) facility for the

combustion of non-

hazardous waste and the

generation of energy

Overview

The application at Javelin Park is approximately 5km from the Redline Boundary and separated by various built infrastructure.

With no hydraulic connectivity between the Sites there will be no cumulative effects anticipated through the development of

both applications.


anticipated

17/0563/OUT

Land off School

Lane, Whitminster,

Gloucestershire

Residential development

for up to 60 dwellings

including infrastructure,

ancillary facilities, open

Overview


anticipated


December 2015

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Cumulative Effects

Application Refused

space and landscaping.

Construction of a new

vehicular access from

School Lane.

The application is approximately 3km from the Redline Boundary and separated by various built infrastructure. With no hydraulic

connectivity between the Sites there will be no cumulative effects anticipated through the development of both applications.

S.17/1133/FUL

S.17/1134/LBC

Former Standish

Hospital and Former

Westridge Hospital

Standish,

Stonehouse,

Gloucestershire

Pending

Consideration

Conversion and

refurbishment of the

former Standish Hospital

complex, including

Standish House (Building

A), Stable Block (Building

B), Ward Blocks (Buildings

C & G), Standish Lodge

(Building L), Building I, and

demolition and works to

associated out-buildings

and gatehouse to form 50

dwellings; demolition of

Westridge Hospital and

associated building.

Development of 98 new

build homes within the

grounds; conversion;

associated surface vehicle

and cycle car parking,

pedestrian and vehicular

access and associated

ancillary development,

landscaping, ancillary

storage and plant and

ecological bat housing;

and all associated

engineering works and

operations


Former Standish Hospital and Former Westridge Hospital Standish, the site to the east of the Revised Scheme is outlined for a

residential development comprising up to 148 dwellings and areas of ancillary facilities and landscaping.


The aspects of the Revised Scheme and the proposed Former Standish Hospital and Former Westridge Hospital Standish Site

that will result in potential effects on hydrology are identified below and include;


• The introduction of the residential and non-residential components of the Former Standish Hospital and Former

Westridge Hospital Standish, scheme


The Revised Scheme



spillages.

Former Standish Hospital and Former Westridge Hospital Standish,

The construction timeframe for the development is as yet unconfirmed, the application is currently at appeal, therefore there is

potential that there could be an overlap between the construction phases of the two developments. If developed unmitigated

it will be assumed that similar effects will occur during the construction phase and it is therefore inferred that the effect on

hydrology will be considered a moderate negative significance of effect.

Cumulative Effects

Water Quality

Generally, due to the ‘upstream’ location of the development of ‘Former Standish Hospital and Former Westridge Hospital

Standish Site’ the construction works can affect the Revised Scheme (i.e. increase in silt laden runoff / spillages). As there is

potential that both Sites be constructed simultaneously, there will be an elevated potential for cumulative effects stemming

from silt laden runoff or pollutant spillages. The significance of the receptor, the River Frome will be medium (moderate water

quality under the WFD).






December 2015

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Cumulative Effects


effects will be considered minor. This is due to the 4km separating the Site, yet a hydraulic connection being maintained

through the River Frome. Therefore, the overall significance of the unmitigated cumulative increase in silt laden runoff from

both developments will be considered minor negative if the development timescales overlap. If the development timescales

were staggered, the significance of effect will be reduced to minor.


considered medium. This is due to the 4km separating the Site, yet a hydraulic connection being maintained through the River

Frome. Therefore, the overall significance of the unmitigated cumulative increase in chemical spillages both developments

would be considered moderate negative if the development timescales overlap. If the development timescales were staggered,

the significance of effect would remain moderate negative.


It is anticipated that Former Standish Hospital and Former Westridge Hospital Standish, will be developed in line with the

planning policy guidance at the time (NPPF)


to ensure that water quality is not adversely affected.











remain negligible.

S.16/0922/REM

Land Adjoining

Station Road Bristol

Road, Stonehouse,

Gloucestershire,

GL10 3RB

Approval of reserved

matters Appearance and

Landscaping from appeal

APP/C1625/A/13/2195656

(S.12/2538/OUT) -

residential development

Overview

The application is a reserved matters application (Appearance and Landscaping) and in excess of 2km from the Site there will be

no cumulative effects anticipated through the development of both applications.


anticipated


December 2015

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Cumulative Effects

Application

Approved

for 49 units, new access

way and associated works.

S.17/2331/OUT

Land Adjoining

Oldbury Lodge Pike

Lock Lane

Eastington

Gloucestershire

Awaiting Decision

Erection of new buildings

for uses within use class

C1 (Hotel) up to 1,908

Sqm (56 Beds), and use

classes A3 / A4 Pub

(Pub/Restaurant) up to

711 Sqm (Including

ancillary manager's

apartment) and associated

access, servicing, parking,

drainage and landscaping

(outline application: all

matters reserved except

for access and scale)


The Site to the east of the Redline Boundary is outlined for hotel and pub development comprising up to 56 beds and areas of

ancillary facilities and landscaping.


The aspects of the Revised Scheme and the proposed Former Land at Oldbury Lodge, site that will result in potential effects on


• The introduction of the stadium and associated infrastructure The introduction of the hotel and pub


The Revised Scheme



spillages.

Land at Oldbury Lodge

The construction timeframe for the development is as yet unconfirmed, the application is currently awaiting decision, therefore

there is potential that there could be an overlap between the construction phases of the two developments. If developed

unmitigated it will be assumed that similar effects will occur during the construction phase and it is therefore inferred that the

effect on hydrology will be considered a moderate negative significance of effect.

Cumulative Effects

Water Quality

Generally, due to the ‘upstream’ location of the development of ‘Former Land at Oldbury Lodge, Site’ the construction works

can affect the Revised Scheme (i.e. increase in silt laden runoff / spillages). As there is potential that both Sites be constructed


The significance of the receptor, the River Frome will be medium (moderate water quality under the WFD).


effects will be considered minor, as a hydraulic connections maintained through the Stroudwater Navigation / River Frome.

Therefore, the overall significance of the unmitigated cumulative increase in silt laden runoff from both developments will be

considered minor negative if the development timescales overlap. If the development timescales were staggered, the

significance of effect will be reduced to minor.






December 2015

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Cumulative Effects


considered medium, as a hydraulic connections maintained through the Stroudwater Navigation / River Frome. Therefore, the

overall significance of the unmitigated cumulative increase in chemical spillages both developments would be considered

moderate negative if the development timescales overlap. If the development timescales were staggered, the significance of

effect would remain moderate negative.


It is anticipated that development at the Land adjoining Oldbury Lodge, will be developed in line with the planning policy

guidance at the time (NPPF)


to ensure that water quality is not adversely affected.











remain negligible.


December 2015

Page | 160

Conclusions

9.137 The development has the potential to effect upon different receptors during the construction of

the development and operational phase.

9.138 During the construction period significant adverse effects may arise from the development of

the Revised Scheme from uncontrolled sediment runoff created during the construction of the

Site or spillages of chemical pollutants (oils, cements, paints etc.) entering the surface water

network. Upon operation significant adverse effects may arise from uncontrolled spills and leaks

of vehicular fluids entering the surface water network or surface water flooding caused by heavy

rainfall falling on the new road and areas of hardstanding. The incorporation of the SuDS within

the drainage design may give rise to positive biodiversity and water quality effects during the

operation of the Site.

9.139 The risks to the water environment and development during the construction phase and

operational phase has been assessed in line with current policy and legislation. Mitigation has

been outlined to ensure that in line with good construction practices, the surface water and

groundwater networks will be sufficiently protected against pollution and occupiers of the Site

and the adjacent areas will not experience any residual adverse significant effects in EIA terms.

The detailed summary of the specific effects is outlined in Table 9.8 and Table 9.9.

9.140 Due to the inclusion of the surface water drainage plan and associated landscape / biodiversity

works, there will be a residual positive significant effect in EIA terms through the biodiversity

enhancements.


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Table 9.8: Summary of Flood Risk, Hydrology and Drainage Construction Effects and Mitigation

Receptor Effect Development

Phase

Sensitivity

/

importance

of receptor

Magnitude

Change

Level of Effect

(and

Significance)

prior to

mitigation

Mitigation Enhancement Level of Effect

(and

Significance)

after mitigation

Nature

of

effect

Watercourse

adjacent to western

Redline Boundary

boundary

Sedimentation of

watercourses effecting upon

water quality

Construction Medium Minor to

Negligible

Minor

negative / not

significant

PPG 5 N/A Negligible / not

significant

N/A

River Frome Sedimentation of

watercourses effecting upon

water quality

Construction Medium

Minor to

Negligible

Minor

negative / not

significant

PPG 5 N/A Negligible / not

significant

N/A

Culvert beneath M5 /

land upstream of

culvert

Siltation of M5 culvert

reducing capacity

Construction Low

N/A Minor

negative / not

significant

PPG 5 Unblocking of

culvert

maintaining /

improving flow

Minor positive /

not significant

Positive

The Selbrook Spillages of fuels, oils, paints

or solvents into watercourse

effecting upon water quality

Construction Medium

Substantial

to

Negligible

Moderate

negative /

significant

PPGs Prevention of

pollutants

entering

watercourse

Negligible / not

significant

N/A

River Frome Spillages of fuels, oils, paints

or solvents into watercourse

effecting upon water quality

Construction Medium

Medium to

Negligible

Moderate

negative /

significant

PPGs Prevention of

pollutants

entering

watercourse

Negligible / not

significant

N/A

The Selbrook Spillages of cements and

concretes into watercourse

increasing alkalinity of water

Construction Medium Substantial

to

Negligible

Moderate

negative /

significant

PPGs Prevention of

pollutants

entering

watercourse

Negligible / not

significant

N/A

River Frome Spillages of cements and

concretes into watercourse

increasing alkalinity of water

Construction Medium Medium to

Negligible

Moderate

negative /

significant

PPGs Prevention of

pollutants

entering

watercourse

Negligible / not

significant

N/A

Open watercourse Inappropriate disposal of

foul waste to watercourse

Construction N/A N/A No effect / not

significant

Industrial waste will be

stored on Site,

N/A No effect / not

significant

N/A


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transported off Site by

registered carrier.

Culvert beneath M5 Debris blocking culverts

resulting in upstream

flooding

Construction Low Minor to

Negligible

Minor

negative / not

significant

PPGs and ensuring no

large materials enter the

watercourse. If

blockages are detected,

remove blockage

immediately

Unblocking of

culvert

maintaining /

improving flow

Negligible / not

significant

N/A

Stadium Location New impermeable areas

increase surface water

runoff and flood risk

Construction Low Medium to

Negligible

Minor

negative / not

significant

PPGs and development

of surface water

drainage network

Enhancement

through formal

drainage network

Negligible / not

significant

N/A

Stadium Location Changing overland flow

paths

Construction Low N/A Minor positive

/ not

significant

Incorporation of a

formal drainage

network.

Enhancement

through formal

drainage network

Minor / not

significant

Positive


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Table 9.9: Summary of Flood Risk, Hydrology and Drainage Operation Effects and Mitigation


Phase

Sensitivity

/

importance

of receptor

Magnitude

Change

Level of Effect

(and

Significance)

prior to

mitigation


(and

Significance)

after

mitigation

Nature

of

effect

The Selbrook Spillages of fuels, oils, and

other chemicals from

stationary vehicles

Operation Medium N/A Negligible

negative / not

significant

SuDS drainage network

design

Surface water

drainage through

treatment train

Negligible / not

significant

N/A

River Frome Spillages of fuels, oils, and


stationary vehicles

Operation Medium

N/A Negligible

negative / not

significant


design

Surface water

drainage through

treatment train

Negligible

negative / not

significant

N/A

Groundwater Spillages of fuels, oils, and


stationary vehicles

Operation Low

N/A Negligible

negative / not

significant


design

Surface water

drainage through

treatment train

Negligible

negative / not

significant

N/A

The Selbrook Diffuse highways pollution

from moving vehicles

Operation Medium

Minor to

Negligible

Minor negative /

not significant


design

Surface water

drainage through

treatment train

Negligible

negative / not

significant

N/A

River Frome Diffuse highways pollution


Operation Medium

Minor to

Negligible

Minor negative /

not significant


design

Surface water

drainage through

treatment train

Negligible

negative / not

significant

N/A

Groundwater Diffuse highways pollution


Operation Low N/A Negligible

negative / not

significant


design

Surface water

drainage through

treatment train

Negligible

negative / not

significant

N/A

Stadium Location Flood risk from surface

water runoff

Operation High Medium to

Negligible

Negligible

positive / not

significant


design

Surface water

drainage through

treatment train

Negligible

negative / not

significant

N/A

Stadium Location Climate Change Operation High N/A Negligible

negative / not

significant


design

N/A Negligible

negative / not

significant

N/A

Stadium Location Biodiversity enhancements Operation Medium N/A Minor positive /

not significant


design

Moderate

positive /

significant

Positive


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10 LANDSCAPE AND VISUAL

Summary

10.1 The Eco Park Revised Scheme (RS) will be designed and constructed to the highest architectural

and sustainability standards. The overall design of the Revised Scheme has been informed by an

integrated landscape strategy which seeks to create an attractive ‘parkland’ setting for Zaha

Hadid Associates’ (ZHA) landmark stadium, one which will both enhance the landscape and visual

amenity of the Site itself and preserve the character of the surrounding area. The Site layout,

stadium design and choice of materials have been informed by the character of the locality as

reflected in the landscape strategy which includes generous setbacks and landscape buffers

adjacent to neighbouring settlements and properties. Of particular importance is the use of

natural materials (timber) in the stadium building, with non-reflective, recessive and muted

colours and textures, resulting in a striking landmark structure. This exciting new landscape

feature, whilst sensitively responding to its rural surroundings in both form and appearance, will

create a memorable sense of arrival at this ‘gateway’ to Stroud location, enlivening the western

approach to the town.

10.2 Mitigation and enhancement measures are proposed to avoid or minimise potential adverse

landscape and visual effects on local residents and visitors to the Site and surrounding area.

These measures are embedded in the Eco Park Revised Scheme as illustrated in RS Figure 1.1

Indicative Concept Plan and outlined in the RS Figure 5.3 Indicative Green Infrastructure

Parameter Plan both contained in Volume 2.

Landscape effects

10.3 The proposal will have a significant adverse effect on the landscape fabric of the Site and will

significantly change the character of both the Site itself and the immediate surrounding area of

Stroud District up to a distance of approximately 250m from the Development Footprint where

uninterrupted visibility of the proposal exists. These changes to the local landscape, although

transformative and significant in the EIA context, will involve an innovative and sensitively

designed landmark building, together with sports pitches and informal open space, set within a

framework of existing hedgerows, mature trees / woodland and appropriate new planting,

including orchard trees. The remainder of Stroud District’s landscape will not be affected to any

significant degree character wise. No significant landscape effects are predicted to arise beyond

250m, including on the character and special qualities of the Cotswolds AONB and its prominent

escarpment, or Registered Parks and Gardens in the vicinity.

Visual effects

10.4 Significant residual visual effects are predicted for users of Eastington Footpath Nos 37 and 38

crossing the Development Footprint and short stretches of public highway adjacent to the Site

including the M5 motorway, the A419 and Grove Lane. The visual amenity of three dwellings

adjacent to the Site, namely Mole Cottage, Ivy Cottage and Westend House is likely to experience

significant adverse change in the short term due to relatively unrestricted visibility of the Revised

Scheme (or part of) at close range. However, these initially significant visual effects will reduce

as the embedded mitigation establishes and matures over time to become not significant

adverse residual effects in the longer term.


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10.5 Other visual receptors, including residential properties / settlements at Westend, Nupend and

Chipmans Platt (including West of Stonehouse), Eastington and Claypits, and recreational

resources and publicly accessible routes and land in the vicinity, will not experience significant

visual effects. No significant adverse visual effects are predicted to arise on the Cotswold Way

or the Thames and Severn Way, or any publicly accessible land such as commons, National Trust

property, access land, country park and village green.

Cumulative effects

10.6 Implementation of the Revised Scheme will have a significant adverse cumulative landscape and

visual effect in combination with the proposed Land West of Stonehouse and Pike Lock in the

vicinity of Westend and Chipmans Platt up to a distance of approximately 500m from the

Development Footprint. The significant cumulative effect will be residual in the case of

landscape character, but not in respect of visual effects. Apart from that no other significant

cumulative effects attributable to the Revised Scheme are predicted in conjunction with the

assessed cumulative schemes.

Conclusion

10.7 The Revised Scheme will significantly alter the landscape character and visual amenity of the

Development Footprint and its immediate surroundings up to approximately 250 metres from

the Development Footprint (up to approximately 500m in the cumulative context). The change

will be adverse during construction, but effects will reduce as the embedded landscape

mitigation matures and provides landscape and visual benefit. Some people are likely to perceive

the localised change as negative (as assumed in this LVIA), whilst others will see it as neutral or

positive. This difference in landscape perception will be due to the potential for the stadium,

should it be consented, to become a much admired, landmark feature and a symbol of Stroud’s

forward thinking, ‘green’ credentials63.

Introduction

The Assessment

10.8 This Chapter contains a Landscape and Visual Impact Assessment (LVIA) of the Eco Park Amended

Application (the Revised Scheme) located adjacent to the M5 Junction 13 (the Site), which is the

subject of an outline planning application to Stroud District Council (SDC) with all matters

reserved except access. The LVIA assesses the potential impact of the Revised Scheme on the

landscape and visual environment and comprises a suite of descriptive text, methodology and

assessment tables / schedules (all provided in Volume 3 – RS Appendices 10.1 – 10.10) and

graphic information (all provided in Volume 2 – RS Figures 10.1 – 10.15) which are intended to

be read in conjunction with this chapter. Other information of particular importance to the LVIA

includes the Indicative Concept Plan (RS Figure 1.1), the Building Height Parameter Plan (RS

Figure 5.1), the Land Use Parameter Plan (RS Figure 5.2) and the Indicative Green Infrastructure

Parameter Plan (RS Figure 5.3). Cumulative schemes considered in the LVIA are listed in Chapter

2, Table 2.5 and shown on RS Figure 18.1 Cumulative Schemes.

63 The European Landscape Convention defines landscape as: “an area, as perceived by people, whose character is

the result of the action and interaction of natural and/or human factors.” (para. 2.2)


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Scope

10.9 This LVIA considers the potential for significant effects (negative and / or positive) to arise on the

landscape and visual resource of the Site and surrounding area within a 10km radius of the

Redline Boundary – the Study Area (refer RS Figure 10.1 Site Location, Study Area and Viewpoint

Location (Study Area)). Having due regard to emphasis on proportionality of assessment urged

in best practice guidance contained in the Landscape Institute’s ‘Guidelines for Landscape and

Visual Impact Assessment – Third Edition’ (2015) (GLVIA3), and taking account of the type and

scale of the Revised Scheme and the landscape context, a 10km study area is considered

appropriate and sufficient to identify likely significant landscape and visual effects arising. The

assessment scope has been refined and agreed through extensive consultations dating back to

2015.

Authorship

10.10 The principle LVIA author was Gavin David with supporting contributions from Fiona Sharman

and Kara Davies. Kara has a PhD in Strategic Environmental Assessment and MSc in

Environmental Impact Assessment with over eight years’ experience lecturing in these subjects.

She has been working in a landscape role at Ecotricity for the past three years on a range of

renewable energy and built development projects and is an Affiliate Member of the Landscape

Institute (AMLI). Fiona is a freelance Chartered Landscape Architect and Member of the

Landscape Institute (CMLI) until recently formerly in the employ of Ecotricity; she was previously

a Landscape Planner at Bristol City Council where she gained considerable experience in the

assessment of planning applications for a range of development projects. Gavin is also a

freelance Chartered Landscape Architect and CMLI with over twenty years’ experience, including

as expert witness at planning inquiries and appeals. In addition to serving with Ecotricity for the

past eight years as Lead Landscape Architect and team manager (up to January 2017), he was

formerly technical director at WSP Parsons Brinckerhoff (London), and previously employed by

RPS Planning and Development (Oxford) and Land Use Consultants (London and Bristol), involved

in a wide range of urban design, landscape architecture and environmental planning work on a

day to day basis.

The Site

10.11 The Revised Scheme is proposed on agricultural land situated adjacent to the A419 and M5

motorway Junction 13 (the Site) near Stonehouse in Gloucestershire, as delineated by the

Redline Boundary on RS Figure 10.1 described in this ES as ‘the Site’. The Site comprises three

separate parcels of land the majority of which lies to the east of the M5 J13. The built

development proposed will take place on the land parcel lying immediately north of the A419

and east of the M5, described in this ES as the ‘Development Footprint’ (also termed the ‘Revised

Scheme’); the remaining parcels located south of the A419 either side of the M5 adjacent to the

River Frome will remain as they are. Save certain mitigation and enhancement works proposed

in Chapter 8 Ecology and Nature Conservation (in relation to the required highways works) no

development is proposed in these areas in this application. More details of the Site and its

landscape are provided in the Baseline Conditions section below, and a general description of

the Site is contained in Chapter 3.

Terminology


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10.12 The following terms are used in this chapter (and across the ES as a whole) in relation to the

Revised Scheme (see also Chapter 1):

• The "Site" = land at M5 Junction 13 West of Stonehouse (see RS Figure 1.1 Indicative

Concept Plan).

• The "Redline Boundary" = the redline boundary of the Site as shown on RS Figure 1.1 and

RS Figures 10.1 – 10.15.

• The "Study Area" = area surrounding the Site within which landscape and visual effects are

assessed (see RS Figure 10.1 Site Location, Study Area and Viewpoint Location).

• The "Development Footprint" = the area of the Site subject to works (north of A419 and

east of M5 motorway) in this Revised Scheme (see RS Figure 5.2 Land Use Parameter

Plan).

The Revised Scheme

10.13 The Eco Park RS proposal is as described in Chapter 5 Description of the Revised Scheme and

shown on RS Figure 1.1. For the purposes of the LVIA the main components of the Revised

Scheme are summarised as follows:

• a 5,000 capacity football stadium and other ancillary uses (Use Class D2);

• two full-sized grass pitches and a goal practice area;

• a car parking area for 1,700 vehicles with signalised access and dualling of A419 from the

M5 to Chipmans Platt roundabout;

• a signal controlled pedestrian / cycle crossing at the A419 access point and a combined

bus route and footway / cycleway linking with Grove Lane (National Cycle Route 45) via

the Development Footprint;

• soft and hard landscape works relating to the stadium and the car parking area (hard core

surface) including formal and informal open space provision incorporating a landscape

‘buffer’ with planted bund adjacent to Westend;

• stadium lighting elements integrated into roof structure with controlled illumination

direction and levels to fulfil different requirements.


Legislative Context

European Landscape Convention

10.14 The European Landscape Convention was signed and ratified by the UK government in 2006, and

became binding in the UK in 2007. The Convention seeks to promote landscape protection,

management and planning across Europe, and to organise European-wide co-operation on

landscape issues. It states that:

”Landscape’ means an area, as perceived by people, whose character is the result of the action

and interaction of natural and / or human factors”

Planning Policy Context

10.15 The Site is located in Gloucestershire in the jurisdiction of SDC.


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10.16 A review of relevant national and local planning policy and guidance relating to landscape and

visual resources is provided at RS Appendix 10.9 (a-d). Planning policy generally is dealt with in

Chapter 6 and RS Appendix 6.1.

10.17 A summary of relevant landscape related policy and guidance is presented below.

Planning Policy and Guidance

National Planning Policy Framework (NPPF)

10.18 The NPPF published on the 27thof March 2012. Aspects of the NPPF with particular relevance to

landscape include Section 7 (Requiring Good Quality Design) and Section 11 (Conserving and

Enhancing the Natural Environment) which support the core planning principles set out in

Paragraph 17. NPPF paragraphs considered particularly relevant to the Revised Scheme are listed

in Table 10.9.2 of RS Appendix 10.9b. Also of importance is the Planning Practice Guidance

(PPG)64 in particular with respect to LVIA the Natural Environment: Landscape section.

10.19 The ethos of the Revised Scheme aims to support key themes of the NPPF and PPG, particularly

in relation to planning positively for good quality design and respecting local character, identity

and sense of place (refer NPPF Paragraphs 60-63).

Local Planning Policy

10.20 Chapter 6 / RS Appendix 6.1 Planning Policy Context provides a detailed description of all

relevant policies contained in the Stroud District Local Plan (2015) adopted on the 19th November

2015. Strategic and overarching policies are also covered in more detail in Chapter 6. The 2015

Plan replaces the 2005 Local Plan entirely and provides a planning policy framework for Stroud

District up to 2031.

10.21 RS Appendix 10.9b, Table 10.9.1 provides an overview of policies with particular relevance to

landscape and visual resources, acknowledging that there will also be an interrelationship with

policies than span across a number of other disciplines (e.g. ecology, cultural heritage). Relevant

(adopted) planning guidance is also referred to in Table 10.9.1 of RS Appendix 10.9b. Local

policies with particular relevance to landscape and cultural heritage can be summarised as:

Stroud District Local Plan (Adopted November 2015)65

• Strategic objective SO6 (Our District’s distinctive qualities, based on landscape, townscape

and biodiversity);

• Strategic policies: CP4 (Place Making), CP14 (High Quality Sustainable Development);

• Delivery Policies: ES7 (Landscape Character), ES8 (Trees, hedgerows and woodland). EI11

(Promoting sport, leisure and recreation), ES12 (Better Design of Places), ES3 (Maintaining

Quality of Life within our Environmental Limits);

• Cross cutting policies with other topics: E6 (Biodiversity and Geodiversity), ES10 (Valuing

our Historic Environment and Assets).

64 Planning Practice Guidance available from http://planningguidance.communities.gov.uk/ accessed on 16th

December 2015. 65 Stroud District Local Plan available from

http://www.stroud.gov.uk/docs/planning/planning_strategy.asp#s=sectioncontent2&p=lp accessed on 16th

December 2015.


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Eastington Parish Council Neighbourhood Development Plan (Adopted October 2016)66

• Policy EP2: Protect and enhance biodiversity and the natural environment;

• Policy EP4: Siting and design of new development and conservation;

• Policy EP9: Public rights of way and wildlife corridors.

10.22 It is important to note here regarding Eastington NDP Policy EP9 that the Revised Scheme makes

provision for improvements to both wildlife corridors and public rights of way which are

described in this LVIA below in the Landscape Fabric section.

Industrial Heritage Conservation Area Supplementary Planning Document (Adopted Nov 2008)67

• Five Overarching Policy and Design Priorities (1-5);

• Management Proposals: IHCA-MP 5: Policy and design priorities, IHCA-MP 6: Policy and

design guidance;

• Policy and Design Guidance: IHCA-G 1 (Building in Context). Relevant Landscape Policy and

Design Guidance (PDG1 – PDG42) are also referenced where appropriate.

Sustainable Construction Supplementary Planning Document (Adopted February 2017)

10.23 The Design and Access Statement and Chapter 5 describes how the proposal has been designed

to promote a high standard of sustainable construction and design. The LVIA has had regard to

this SPD in respect to the approach to the design and hard and soft landscape works as outlined

in RS Figure 5.3 and RS Figure 10.11c Landscape Strategy and 10.11d Landscape Mitigation and

RS Appendix 10.7 Landscape Strategy.

Stroud District Landscape Sensitivity Assessment (December 2016)68 – Part of Strategic

Assessment of Land Availability (SALA)

• The Council has produced, and published on its website, a range of environmental

evidence to support the preparation of the Local Plan69. This information will be a material

planning matter for the determination of planning applications;

• As part of this, SDC appointed White Consultants to undertake a Landscape Sensitivity

Assessment of land parcels in Stroud District. This study forms part of the Council’s

Strategic Assessment of Land Availability (SALA) process, which in turn will inform

subsequent reviews of the local plan. A full report of findings on the SALA process

(covering multiple topics) was published by SDC in May 201770 ;

• Information relating to the December 2016 Landscape Sensitivity Assessment, which was

utilised in the SALA process, is summarised in Landscape Resource section below with

66 Eastington Neighbourhood Development Plan available from http://eastington-pc.gov.uk/neighbourhood-

development-plan/ accessed on 24/10/2017. 67 Industrial Heritage Conservation Areas Supplementary Planning Document available from

https://www.stroud.gov.uk/environment/planning-and-building-control/conservation-listed-buildings-trees-and-

hedgerows/conservation-areas/conservation-area-no29-stroud-industrial-heritage/the-ihca-conservation-area-

management-proposals-spd accessed on 24/10/2017. 68 Stroud District Landscape Sensitivity Assessment (December 2016) available from

https://www.stroud.gov.uk/environment/planning-and-building-control/planning-strategy/evidence-

base/environmental-evidence/landscape-sensitivity-assessment-2016 accessed on 24/10/2017. 69 Stroud District Environmental Evidence available from https://www.stroud.gov.uk/environment/planning-and-

building-control/planning-strategy/evidence-base/environmental-evidence accessed on 24/10/2017 70 Stroud District Strategic Assessment of Land Availability (SALA, May 2017). Available from

https://www.stroud.gov.uk/media/355585/final-report-of-findings.pdf accessed on 24/10/2017.


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further details provided in RS Figure 10.8a SALA Assessment of Onsite Landscape

Sensitivity with Project Components (SDC), RS Appendix 10.2 and RS Appendix 10.9c and

10.9d (full extract).

Cotswold Area of Outstanding Natural Beauty Management Plan (2013-18)71

• Landscape Policies LP1 & LP2.

Cotswold Area of Outstanding Natural Beauty Position Statements72

• Cotswold Conservation Board Position Statements, in particular ‘Development in the

Setting of the Cotswolds AONB’ (as amended in June 2016) and Tranquility and Dark Skies

(with Appendices) (2010).


Introduction

10.24 As described in the main Introduction section above this LVIA has been undertaken by qualified

landscape architects with the relevant expertise and experience of similar types of development,

and carried out in line with current best practice guidelines, according to the stated methodology

summarised below and set out in more detail at RS Appendix 10.1 LVIA Methodology.

10.25 The Site (defined by the Redline Boundary) and the Revised Scheme are described, and an outline

description of the local landscape and visual amenity provided drawing on desk study / published

documents and fieldwork. The terms Revised Scheme and Development Footprint both refer to

the area of built development within the Site as distinct from the other areas within the Redline

Boundary left undeveloped (i.e. land to the south of the A419, and land west of the M5

Motorway).

10.26 Potential landscape, visual and cumulative effects arising from the Revised Scheme are identified

and the significance of the residual effects on the landscape fabric, landscape character, views

and visual amenity assessed. The likely effects are identified and described for three stages of

development: A) during construction; B) at commencement of operation (Year 1); and C) upon

establishment / maturing of proposed landscape mitigation (Year 15).

10.27 A range of mitigation and enhancement measures are considered and the potential benefits

factored into the statement of residual effects.

Basis of Assessment

10.28 The LVIA is based on the Revised Scheme Parameter Plans (RS Figures 5.1-5.5) which comprise

the following information submitted as part of the planning application:

• Building Height Parameter Plan (RS Figure 5.1);

• Land Use Parameter Plan (RS Figure 5.2);

71 Cotswold Area of Outstanding Natural Beauty Management Plan available from

http://www.cotswoldsaonb.org.uk/management_plan/index.html accessed on 24/10/2017. 72 Cotswold Area of Outstanding Natural Beauty Position Statements

http://www.cotswoldsaonb.org.uk/conservation-board/position/ accessed on 24/10/2017.


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• Indicative Green Infrastructure Parameter Plan (RS Figure 5.3);

• Indicative Construction Compound Locations (RS Figure 5.4);

• Site Plan and Sections (RS Figure 5.5);

• Cross Section at Grove Lane (RS Figure 5.6).

10.29 The LVIA is also informed, inter alia, by the:

• Indicative Concept Plan (RS Figure 1.1)

• Design and Access Statement (seperate document submitted as part of the Revised

Scheme).

Consultations

10.30 The following pre-application consultations relating to the Revised Scheme were carried in order

to agree the scope and approach of the LVIA.

Table 10.1: Pre-Application Consultations

Consultee Date Note Summary Comment

Stroud

District

Council

(David

Lowin)

23/10/17 Pre-application consultation letter

setting out the approach, method

and scope of the LVIA together

with plans showing the site

location, study area, preliminary

ZTV and viewpoint locations.

No formal consultation response

received to date, but relevant

comments and advice received at

the meeting with SDC / David Lowin

on 2nd November 2017 have been

incorporated into this LVIA.

Natural

England

23/10/17 Copy of the above pre-application

consultation letter forwarded to

statutory consultee.

No consultation response or

comments received to date.

Cotswolds

AONB

23/10/17 Copy of the above pre-application

consultation letter forwarded to

statutory consultee.

No consultation response or

comments received to date.

Assessment Assumptions and Limitations

10.31 The landscape and visual environment is understood to be a public resource. In this LVIA private

interests such as views from private property (residential visual amenity) are considered only in

so far as they relate to the public interest73.

10.32 LVIA concerns the landscape and visual environment considered as a public resource as

experienced and / or perceived by the dispassionate observer. This position is reflected in the

European Landscape Convention definition of landscape. It should be kept in mind that some

people will perceive changes to the landscape and visual resource as negative, and others

positive or neutral (neither positive nor negative). This is likely to be case with the Revised

73 The ‘public interest test’ (the Lavender test) holds that when developments “… represent an unpleasantly

overwhelming and unavoidable presence in main views from a house or garden, there is every likelihood that the

property concerned would come to be widely regarded as an unattractive and thus unsatisfactory (but not necessarily

uninhabitable) place in which to live. It is not in the public interest to create such living conditions where they did not

exist before.”


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Scheme due to the innovative nature and high standard of the stadium’s architecture combined

with its ‘parkland’ setting. Notwithstanding this predicted landscape and visual effects arising

from the Revised Scheme are assumed to be negative unless stated otherwise in order to

assess worst case scenario in line with EIA good practice.

10.33 A significant landscape and visual effect is one which is ‘significant’ in the context of the relevant

EIA Regulations. However, EIA significance does not mean the effect is unacceptable in planning

terms, but rather that the assessor considers it likely to be material to the determination of the

planning application. As such certain parts of the proposal will come into operation whilst

construction is proceeding on others. Thus, although assessed separately, construction and

operational effects will in fact be a continuum of landscape change starting with site clearance

and proceeding through site works (construction phase) to completion of the Revised Scheme

and the landscape mitigation works (operation phase Year 1), culminating in the establishment

and maturing of the ‘parkland’ landscape (operation phase Year 15); the residual effects in other

words.

10.34 The LVIA assesses the Revised Scheme as described by the Parameter Plans and relevant

supporting information including the Indicative Concept Plan.

10.35 In line with the NPPF and the PPG the proposed built development will be of the highest

architectural quality and of the highest standards in sustainable design that responds sensitively

to the local landscape context. Further details on this are provided in the separate Design and

Access Statement and RS Appendix 10.7. Furthermore, it is assumed that built form so designed

will be perceived by dispassionate observers as logical and appropriate development at this

particular location.

10.36 The LVIA was carried out in the summer and autumn of 2017 (drawing on work undertaken in

2015 and 2016) and reviewed and finalised in November and December 2017. The assessment

of likely significant effects is that predicted to arise during the winter months when deciduous

vegetation is devoid of foliage – the ‘worst case scenario’. Photographs of the baseline situation

in summer and winter are provided at RS Figure 10.13 Baseline Photographs (including Night-

time) for each of the agreed representative viewpoints. Variations in magnitude of likely effect

in summer compared with winter are described in the assessment narrative as appropriate. The

LVIA has regard to scheme variations due to design evolution and proposed mitigation and

enhancement measures, embedded or otherwise (e.g. landscape works), within the range of

defined parameters, so as to assess the likely maximum effect or worst case scenario.

10.37 It is assumed that the proposed tree planting on top of the 2m tall earth bund would reach a

height of approximately 5m by Year 15, as shown on RS Figure 5.6 Cross Section at Grove Lane.

This assumption takes into account variations in growth rates dependent on growing conditions

and choice of species, details of which will be provided at the Reserved Matters Stage.

10.38 The LVIA has regard to the night time environment baseline and the effect of the Revised Scheme

lighting on it. The lighting design described in Chapter 14 will provide required illumination for

sporting events whilst minimising light obtrusion through the careful positioning and aiming of

lighting elements as well as integrating lighting elements into the architectural roof structure.

The sports lighting control system will allow switching for different illumination levels to fulfil

different requirements such as maintenance, training and league matches with all controls

accessible via a graphical user interface. The proposed training pitches will be unlit.


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10.39 Further details on the Assumptions and Limitations of the LVIA are provided in RS Appendix 10.1.

Method Statement

10.40 The approach used in carrying out this LVIA is summarised below. More information on the LVIA

methodology is provided in RS Appendix 10.1.

Best Practice Guidance

10.41 The assessment was undertaken in accordance with current best practice outlined in published

guidance, in particular:

• Guidelines for Landscape and Visual Effect Assessment (GLVIA), 3rd Edition (2013)

Landscape Institute and the Institute for Environmental Management and Assessment

(referred to below as GLVIA3);

• An Approach to Landscape Character Assessment, Natural England (2014);

• Landscape Institute Advice Note 01/11 photography and photomontage.

10.42 Other documents consulted when undertaking the LVIA include, inter alia, best practice

guidelines contained in the following adopted supplementary planning guidance / advice and

publicly available, landscape related publications:

• Stroud District Landscape Assessment (2000);

• The Cotswolds AONB Landscape Assessment (2004);

• Cotswold Area of Outstanding Natural Beauty Management Plan (2013-18);

• The Industrial Heritage Conservation Areas Statement (2008);

• The Industrial Heritage Conservation Area Design Guide (2008): Scope of Assessment.

Identification and Description of Landscape and Visual Effects

10.43 The landscape and visual effects potentially occurring during the construction and operational

phases of the development are described under the following headings:

• Physical effects on the landscape fabric e.g. vegetation removal and / or new planting;

• Effect on the character of the landscape;

• Effect on designated (valued) landscapes;

• Effect on views and visual amenity having regard to sensitive receptors e.g. people at/

using public rights of way and residential properties.

Study Area

10.44 The Study Area is defined by a 10km radius from the Revised Scheme Redline Boundary – see RS

Figure 10.1. The LVIA considers the potential effect on landscape character and visual amenity

across the 10km study area. However, having due regard to GLVIA3’s emphasis on

proportionality, as explained below, the focus of the assessment of visual amenity and character

effects is a 5km radius from the Redline Boundary. The reason for this is that, taking account of

the type and scale of the Revised Scheme and the landscape context, significant adverse effects

on landscape character and views / visual amenity are considered highly unlikely in excess of 5km


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from the Site. The Study Extent was previously agreed with consultees in relation to the original

submission74.

Assessment Approach

10.45 The approach to the LVIA involved:

• Recording and analysis of the existing landscape elements (physical features) landscape

character and visual amenity associated with the Site and surrounding area through desk

based study and field appraisal;

• Appreciation of the nature, form and scale of the Revised Scheme having regard to the

landscape and visual context;

• Evaluation of the ‘sensitivity’ of the existing landscape and visual receptors likely to be

affected by the Revised Scheme. Sensitivity is a product of the ‘value’ of the receptor and

its ‘susceptibility’ to the type of development proposed. More detail on the evaluation of

landscape and visual sensitivity is provided in RS Appendix 10.1.

• An assessment of the ‘level’ of effect likely to result from implementation of the Revised

Scheme, having regard to the landscape and visual context and potential cumulative

effects. The level of effect is derived from combining an assessment of the magnitude of

effect (from the baseline situation) and the sensitivity of the receptor. More details on the

assessment approach are provided in RS Appendix 10.1.

• Assessment of whether the predicted effects will be ‘significant’ or ‘not significant’ in the

context of the relevant EIA Regulations75;

• Identification of mitigation and enhancement measures appropriate to the Revised

Scheme and its effects and to the receiving landscape;

• Assessment of the residual effects on the landscape and visual environment including

cumulative;

• Provision of appropriate supporting graphics including baseline photographs for

assessment purposes;

• Consideration of other cumulative schemes in the Study Area, the approach for which is

outlined in the subsequent sections. In this instance the cumulative schemes considered

as part of this application were informed by advice provided by the Council in a meeting

on 03/08/2015 and its Scoping Response (RS Appendix 1.2)) along with the approach set

out in Chapter 2 (Approach to EIA) and Chapter 18 (Cumulative Effects).

10.46 More detail on the assessment approach is provided in RS Appendix 10.1.

10.47 The baseline assessment includes collation of relevant published information relating to

landscape character and designations (national and local). Preliminary Zone of Theoretical

Visibility (ZTV) plans were prepared based on the parameter dimensions of the Revised Scheme

to assist in the identification of viewpoints and sensitive receptors. Key features, components,

characteristics and views contributing to the character and quality of the landscape and visual

amenity it provides were identified and evaluated.

74 Previously agreed with Natural England, the Cotswolds AONB Conservation Board and SDC during pre-application

and post-application consultations relating to the original submission. 75 The Town and Country Planning (Environmental Impact Assessment) Regulations 2011


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10.48 The potential effects of the Revised Scheme on the existing landscape and views / visual amenity

were assessed having regard to the potential harm or benefit to the receiving environment and

sensitive receptors. The process relies on a combination of quantitative and qualitative

assessment using professional judgement including as to whether landscape and/ or visual

effects are ‘significant’ or not in the context of the EIA Regulations.

10.49 The LVIA process and identification of likely significant adverse effects formed part of an iterative

process which has informed the design and layout of the Revised Scheme. As part of this process

mitigation measures have been identified which are incorporated into the design as ‘embedded

mitigation’.

10.50 The assessment concludes with a statement that identifies the significant, adverse residual

landscape and visual effects that are likely to result from the Revised Scheme and will potentially

remain, post mitigation.

Identifying Significant Effects

10.51 The purpose of EIA is to identify significant environmental effects (negative and / or positive)

likely to arise from the Revised Scheme. GLVIA states that:

“The EIA Directive and UK Regulations refer to projects likely to have significant effects on the

environment. This means that identifying and describing the effects of a project is not enough in

itself. They must also be assessed for their significance. This is a key part of the LVIA process and

is an evidence-based process combined with professional judgement (Para 3.23) ... LVIA, in

common with other topics in EIA tends to rely on linking judgements about the sensitivity of the

receptor and about the magnitude of the effects to arrive at the conclusions about the

significance of the effects ... (GLVIA3, para 3.24, p37).”76

10.52 GLVIA3 emphasises the importance of ‘proportionality’ in carrying out the assessment stating

that:

“Identifying significant effects stresses the need for an approach that is in proportion to the scale

of the project that is being assessed and the nature of its likely effects. Judgement needs to be

exercised at all stages in terms of the scale of investigation that is appropriate and proportional.”

(GLVIA3, para 1.17, page 9)

10.53 The principle of proportionality has guided the content of the LVIA, the scope of which is the

result of various consultations with the Council, Natural England and the Cotswolds AONB.

10.54 The likely landscape and visual effects resulting from the Revised Scheme are assessed in

accordance with the approach set out in GLVIA3. This establishes the magnitude of landscape

and/ or visual change, weighing it against the sensitivity of the landscape and/ or visual receptor,

to arrive at the level of landscape and/ or visual effect and whether that level of change is

significant within the meaning of the EIA Regulations. The process uses a combination of

objective and subjective analysis and assessment informed by professional judgement.

Table 10.2: Level and Significance Matrix

Sensitivity of Receptor

M a g High Medium Low

76 Guidelines for Landscape and Visual Effect Assessment 3rd Edition (2013). Landscape Institute and IEMA


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High Major Major/Moderate Moderate/Major

Major/Moderate Moderate/Major Moderate

Medium Moderate/Major Moderate Moderate/Minor

Moderate Moderate/Minor Minor/Moderate

Low Moderate/Minor Minor/Moderate Minor

Minor/Moderate Minor Minor/Negligible

Negligible Minor Minor/Negligible Negligible

10.55 The above matrix provides a framework and guide for establishing the ‘level of effect’. The

shaded area indicates where the landscape or visual effect will normally be judged to as

‘significant’ within the spirit of the EIA Regulations.

Presentation of Findings

10.56 In accordance with the recommendations contained in GLVIA3 the assessment findings are

presented as narrative in the main body of the text supported by the tabular results in the

appendices and graphic information in the figures as set out in the introductory section above.

In accordance with good practice, only significant EIA effects are discussed in this chapter; non-

significant effects are mentioned, but it should be noted that the reasoning explaining why they

are not significant is contained in RS Appendix 10.8 Potential Non-Significant Landscape and

Visual Effects.

Graphic Presentation

10.57 The LVIA is supported by a set of annotated plans – RS Figures 10.1 to 10.15 (Volume 2), including

Baseline Photographs looking towards the Site from the surrounding area taken from 22

representative Viewpoints. The methodology for photography and graphics production is

described in RS Appendix 10.1.

Baseline Conditions

General Site Description and Context

10.58 This section contains an outline baseline assessment of the landscape and visual resource; a full

baseline assessment for a wide range of landscape and visual receptors is provided at RS

Appendix 10.2. Both these elements should be read in conjunction with RS Figures 10.1 to 10.15.

The likely effects of the Revised Scheme against the baseline situation are assessed below in the

following sections.

10.59 An evaluation of the sensitivity of landscape and visual receptors is also provided here having

regard to the type and scale of development proposed. The sensitivity of each individual receptor

is recorded in RS Appendix 10.3 Landscape Assessment Schedules and RS Appendix 10.4 Visual

Assessment Schedules.

Site Landscape

10.60 The Site (Redline Boundary) is a 39.5ha tract of farmland and adjacent public highway, located

adjacent to the M5 Motorway at Junction 13, divided into three separate parcels by the

motorway and the A419 main road heading east towards Stroud and the Cotswolds. The

Development Footprint parcel comprises 18.9ha to the east of the M5 / J13 and north of the

A419; the area to the south of the A419 and east the M5 / J13 measures 13.5ha, and the parcel

to the southwest of J13, west of the M5 is 4.6ha.


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10.61 The Site is relatively flat, lying at an elevation of around 20m AOD, sloping slightly to the south

towards the River Frome to 15m AOD. RS Figure 5.5 Site Plan and Sections is helpful in

understanding the onsite topography. The M5, the A419, Grove Lane and their associated

boundary vegetation and fencing delineate the various parts of the Site. A remnant track

(without public access) formerly linking Westend with Chipmans Platt marks the south-eastern

boundary of the Site north of the A419. The entire site is currently used for agricultural purposes

for the grazing of cattle and cutting of hay. Onsite there is currently a modern barn in the

southern land parcel used for hay storage and a small cluster of five disused barns in the northern

parcel (within the Development Footprint) which are a mix of concrete / corrugated structures

(larger barns) and red brick barns (smaller structures).

10.62 Regarding the immediate environs of the Site, there are several low ridges and hills within 2km,

principally at Whtiminster (30m AOD approx) to the west, Nupend (40m AOD approx) in the east

and Eastington / Claypits (30m AOD approx) to the south. These are partly wooded and contain

the Site visually, partially restricting views towards and from the wider surrounding lowland.

Beyond 2km to the east, the topography becomes more varied and contrasting. At approximately

3km from the Site the Cotswolds footslopes and escarpment rise steeply towards the High Wolds

of the prominent Cotswold upland with its deep incised valleys, one of which the nearby town of

Stroud is located in. The combination of local topography, vegetation cover and settlement

pattern underlies the restricted ZTV with Screening of the Revised Scheme as depicted on the

figures (for example RS Figure 10.4 Bareground and With Screening ZTV and Viewpoint Location

(Study Area) and RS Figure 10.7a Key Landscape and Visual Receptors with ZTV.

10.63 With respect to the wider context, the landscape of the Study Area is composed of the relatively

flat flood plain of the River Severn with occasional gentle undulations and isolated low hills and

ridges across the Severn Vale. There is an abrupt change in topography from the broadly level

Vale to the Cotswolds escarpment in the east (300+mAOD) and the Forest of Dean upland area

to the West (300+mAOD) as shown on RS Figure 10.3 Topography Plan and Cross-Section (Study

Area). The elevated landforms of the Cotswolds and Forest of Dean run broadly parallel to the

each other, separated by the meandering course of the River Severn.

10.64 The majority of the Site is improved and semi-improved grassland divided by hedgerows (see RS

Figure 8.14 Baseline Survey. Sixteen hedgerows occupy the north part of the Site (within the

Development Footprint) and there are 21 hedgerow lengths on the southern part of the Site.

Hedgerows on site contain a number of mature trees, particularly Crack Willows (Salix fragilis),

close to the River Frome, Mature Ash (Fraxinus excelsior), Sessile Oak (Quercus petraea),

Hawthorn (Crataegus monogyna) and Blackthorn (Prunus spinosa), along with some very old field

maples (Acer campestre). Whilst most of the boundary hedgerows are intact, a number of the

internal hedgerows have become gappy and defunct due to lack of maintenance and cattle

damage.

10.65 Tree diversity within hedgerow lengths on the land east of the M5 and north of the A419 (within

the Development Footprint) is between 1 and 6 and tree species present were Ash (Fraxinus

excelsior), Blackthorn (Prunus spinosa), Crack Willow (Salix fragilis), Elder (Sambucus nigra),

English Elm (Ulmus procera), Field maple (Acer campestre), Goat Willow (Salix caprea), Hawthorn

(Crataegus monogyna), Sessile Oak (Quercus petraea), Wild Cherry (Prunus avium), Dogwood

(Cornus sanguineum) and Spindle (Eunonymus europaeus).


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Tree diversity within hedgerow lengths on the land east of the M5 and south of the A419 is

between 2 and 7, with all of the species found on the north side of the Site except for Sessile

Oak, Dogwood and Spindle, and with the addition of Sycamore (Acer pseudoplatanus) and Wild

Pear (Pyrus communis). Full details of hedgerows and species present is provided in RS Appendix

8.1 Baseline Survey.

10.66 There are three very small blocks of woodland onsite; two on the north side of the A419 (within

the Development Footprint) and one on the southern side which contain mature Ash (Fraxinus

excelsior), Sessile Oak (Quercus petraea), Field Maple (Acer campestre) and Hawthorn (Crataegus

monogyna). There are occasional standard mature trees in many of the hedgerows throughout

the Site, and in the south area close to the River Frome a number of very large Crack Willow (Salix

fragilis), and Goat Willow (Salix caprea). Further details are provided in RS Figure 8.1

Arboricultural Survey and RS Appendix 8.3 Arboricultural Survey. For more information on

vegetation and wildlife generally refer to Chapter 8 Ecology.

10.67 There are two Public Rights of Way (PRoW) which cross the Site: Eastington Footpath No.37

(EEA37) and Eastington Footpath No. 38 (EEA 38). EEA37 runs north east across the Site / Redline

Boundary from its junction with Eastington Footpath No.41 (EEA41) near to Westfield Bridge and

then crosses the A419 at grade, splitting into two paths (EEA37 & EEA38) across the Development

Footprint. EEA37 continues north to Westend Farm and Grove Lane; EEA38 runs north east

towards Westend Cross and Nupend beyond Grove Lane (see RS Figure 10.7b Key Landscape

and Visual Receptors with ZTV (Detail). PRoW are also shown on RS Figure 10.2 Aerial

Photograph and Indicative Site Layout and PRoW.

Landscape and Visual Context

10.68 Beyond its immediate context of the A419 and the M5 motorway / Junction 13 the Site is

surrounded by agricultural land with some settlement and employment development around the

perimeter and in the immediate environs. Thus, the existing landscape context is a combination

of built development and major infrastructure and rural land use – a dynamic landscape with

rural and peri-urban qualities influenced by the hustle and bustle (both aural and visual) of a

lively, settled environment.

10.69 The hamlets of Nupend and Nastend are situated within 0.5km and 1km to the north east of the

Site respectively, both of which are experiencing change due to the urban expansion nearby at

Land West of Stonehouse (WOS). The villages of Eastington and Whitminster are located

between 0.7km and 1km to the south and northwest of the Site respectively. Eastington Trading

Estate lies approximately 100m to the south of the Redline Boundary and Stroudwater and

Stonehouse Business Parks are located about 1-1.5km to the east and southeast, marking the

edge of Stonehouse.

10.70 The two PRoW crossing the Site described above link into a network of footpaths and trails in the

surrounding area including the Thames & Severn Way which follows the course of the

Stroudwater Canal Tow Path and River Frome and located immediately to the south of the Site,

the latter flowing in a north westerly direction towards the River Severn. The intervening fields

and grassland immediately south of the Site contain a currently infilled part of the Stroudwater

Canal route, known locally as the ‘missing mile’. This part of the former canal route is considered

in the Cumulative Effects section of this chapter under the title of Indicative Canal Realignment

as shown in RS Figure 18.1 Cumulative Schemes.


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10.71 The Severn Estuary with its associated Severn Way long distance trail is located approximately

3.5km to the west of the Site near Frampton-on-Severn. The Cotswolds AONB and Cotswold Way

National Trail are situated about 2km and 3km respectively at their nearest point in the vicinity

of Stonehouse. The Cotswolds is a nationally important upland landscape which together with

the Forest of Dean to the west (outside the Study Area) frames the Severn Vale and affords broad

views across the Severn Vale as well as providing a backdrop to views from the lowland. RS

Figures 10.1, 10.2, 10.3 and 10.6 Landscape Designations and Public Access / Recreational

Resources with ZTV (Study Area) are helpful in understanding the Site’s landscape and visual

context.

Landscape Resource

10.72 For the purposes of this assessment the landscape resource is described and its sensitivity to the

Revised Scheme assessed according to the following broad categories:

• Landscape Fabric (within the Development Footprint);

• Landscape Character (within the Study Area);

• Valued / Designated Landscape (within the Study Area).

10.73 An outline description of the landscape resource has been provided above; more detail on the

baseline landscape is included at RS Appendix 10.2 and RS Appendix 10.9(a-d).

Landscape Fabric and its Sensitivity

10.74 The following landscape fabric receptor groups, described in more detail above, have been

identified and assessed:

• Landform / Topography;

• Vegetation and Boundary Features;

• Other Site Elements including PRoW.

10.75 The Site lies adjacent to the River Frome corridor, located within the Severn Vale, approximately

4km to the east of the River Severn. The Development Footprint is situated to the north of the

A419 and sits at an elevation of around 20-24m AOD; the southern part of the Site lies adjacent

to the River Frome floodplain at around 13m AOD. The Frome valley drains west / south west

towards the River Severn. Generally speaking, the Site landform / topography is relatively flat

and uniform and plays a minor role in terms of its contribution to local landscape character (see

RS Figure 10.3 Topography Plan and Cross-Section (Study Area) and RS Figure 10.5a Landscape

Character with ZTV (SDC and National) (Study Area)). The onsite topography is judged to be of

low landscape value and have a medium susceptibility to the type of change proposed giving it a

low to medium landscape sensitivity.

10.76 The vegetation on the Site (described in more detail above) is typical of the locality and varies in

its landscape value and susceptibility to change. Regarding the Development Footprint, on

balance and taking into account the proposed embedded mitigation and careful design of the

Revised Scheme, the mature native trees and boundary hedgerows are considered to be medium

landscape sensitivity, and the improved / semi-improved grassland low landscape sensitivity.


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10.77 Other elements on the Site comprise agricultural fencing and several agricultural buildings which

are judged to be low sensitivity. PRoW are considered to be of high value and high susceptibility

to change and therefore are assigned high landscape sensitivity.

10.78 See RS Appendix 10.1 Methodology for more information on the evaluation of landscape

sensitivity.

Landscape Character and Sensitivity

10.79 This section considers the character of the local landscape and considers its sensitivity to and

capacity for the Revised Scheme. The sensitivity of individual landscape units as classified in the

various Landscape Character Assessments is evaluated further in the Potential Effects section

below.

10.80 Landscape character is a description and identification of:

“The overall character of the landscape in the study area, including any distinctive Landscape

Character Types or areas that can be identified, and the particular combinations of elements and

aesthetic and perceptual aspects that make each distinctive, usually by identification as key

characteristics of the landscape.”77

10.81 The landscape character of the Study Area has been assessed at various levels (i.e. degrees of

detail) over the past two decades. The following Landscape Character Assessments are

considered relevant to this LVIA:

• Natural England Landscape Character Assessment 2014 – National Character Area (NCA)

profiles78;

• Stroud District Landscape Assessment 2000;

• The Cotswolds AONB Landscape Assessment 200479;

• Gloucestershire Landscape Character Assessment 2006.

10.82 The various levels of assessment and their geographic extent are shown graphically as follows:

• RS Figure 10.5a Landscape Character with ZTV (SDC and National) (Study Area)

• RS Figure 10.5b Landscape Character with ZTV (Gloucestershire and Cotswolds AONB)

(Study Area)

• RS Figure 10.5c Industrial Heritage Conservation Area (IHCA) Character Areas (Study

Area)

• RS Figure 10.5d Relationship between Landscape Character Types and Areas in Study

Area

10.83 In the interest of proportionality of assessment, as referred to above, the focus of the LVIA with

respect to character is the potential effect on the host landscape within 5km of the Site. The

reason for this is that, taking account of the type and scale of the Revised Scheme and the

landscape context, significant adverse effects on landscape character are considered highly

77GLVIA 3rd Edition, 2013 (page 74, para 4) 78https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-

making/national-character-area-profiles#ncas-in-south-west-england 79http://www.cotswold.gov.uk/residents/planning-building/landscape/landscape-character/


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unlikely in excess of 5km from the Site. That said, erring on the side of caution, the character of

the AONB within 10km of the Site is included within the assessment due to the high sensitivity

of the nationally important designated landscape.

10.84 In terms of national landscape character classification the Site is located within the Severn and

Avon Vales National Character Area (NCA 106), to the west of The Cotswolds (NCA 107) (see RS

Figure 10.5a). Full descriptions of these areas are provided by Natural England in the character

area profiles on its website. The NCA are assessed further at RS Appendix 10.2 and RS Appendix

10.3 Landscape Assessment Schedules.

10.85 At the intermediate level (Gloucestershire Landscape Character Assessment 2006) the Site lies

within the Settled Unwooded Vale Landscape Character Type (LCT SV6) and Vale of Berkeley

landscape character area (LCA SV6A) (see RS Figure 10.5b). At the local level (SDLA) the Site is

located in Lowland Plain landscape character type (LCT5) (see RS Figure 10.5a)

10.86 An assessment of the likely effect on the relevant landscape character units (LCTs and LCAs)

described in these landscape character assessments is provided in RS Appendix 10.3. For the

relationship between the various different levels on LCTs and LCAs see RS Figure 10.5d.

Stroud District Landscape Assessment 2000

10.87 Stroud District Landscape Assessment (SDLA) provides a relatively fine grain and appropriate

level of assessment for the purposes of this LVIA. The Site is situated within SDC’s Rolling

Agricultural Plain LCT 5 and occupies parts of sub types Escarpment Foot slopes (5A), Lowland

Plain (5B) and Frome River Valley (5C). The wider Study Area is characterised by LCT 4 Escarpment

situated approximately 2.5km to the east, and LCT 7 Severn Vale Hillocks located approximately

5km to the northwest, transitioning into LCT 8 Severn Vale Grazing Marshland towards the River

Severn.

10.88 The Council’s SDLA describes the host landscape (LCT 5 Rolling Agricultural Plain) as having the

following key unifying characteristics:

• “Varied landscape of open flat plain to more undulating landform towards limestone

escarpment.

• Established old, rich, rural lowland, with some woodlands and mature hedgerow trees and

occasional fruit trees

• Land dissected by River Cam and Frome.

• Traversed from north to south by M5, railway, Gloucester-Sharpness Canal and the A38

• Semi-enclosed landscape with some distant views and more restrained views from Frome

Valley.

• Churches act as strong foci and landmarks.

• Dispersed pattern of isolated villages.

• Land use is a mix of arable and pasture.

• Strong field pattern medium to small in scale.”

10.89 Regarding the Development Footprint north of the A419, the north-eastern part adjacent to

Westend settlement occupies the Escarpment Foot slopes (5A), whilst the south-western section

adjacent to the A419 lies within the Lowland Plain (5B). It should be noted that no development


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is proposed in the River Frome Valley (5C). More detail on landscape character is provided in RS

Appendix 10.2.

Cotswold AONB Landscape Character Assessment 2004

10.90 A wider study area extent (to within 10km of the Site) for the assessment of the character of the

Cotswolds AONB is considered appropriate due to the high sensitivity of the designated

landscape. The following Cotswold AONB LCTs and LCAs are located within the bare ground ZTV

of the Revised Scheme in the Study Area:

• LCT 3 Rolling Hills and Valleys / LCA 3B Stinchcombe and North Nibley;

• LCT 1 Escarpment Outlier / LCA 1A Cam Longdown, Peaked Down and Downham Hill;

• LCT 2 Escarpment / LCA 2C Uley to Coopers Hill;

• LCT 7 High Wold / LCA 7A Nympsfield and Kingscote Plateau & Minchinhampton Common;

• LCT 18 Settled Unwooded Vale / LCA 18A Vale of Gloucester Fringe.

10.91 More information on the landscape character of the Site and the Study Area including the

Cotswolds AONB is provided at RS Appendix 10.2 and RS Appendix 10.9 and in RS Figure 10.5b.

Stroud District Landscape Sensitivity Appraisal (URS 2013)

10.92 The Council commissioned URS to conduct a high-level landscape sensitivity appraisal (LSA) of

Potential Locations (termed ‘PLs) for housing, mixed use and employment, considered as part of

the Local Development Plan process. The resulted was the ‘Landscape Sensitivity Appraisal’ (URS,

July 2013)80. A map of the relevant areas is provided on page 45 of the LSA.

10.93 The Site is located in the previously identified PL No.9 ‘Employment north of Eastington’ which

is assessed in the LSA as having ‘medium sensitivity’ and possessing the following characteristics:

• “Predominantly flat pastoral agricultural landscape dissected by the A419 to the east of

Junction 13 of the M5;

• Bound to the north by the Grove Lane, to the west by the M5 road corridor (and Junction

13) and by the River Frome to the south;

• Agricultural character is eroded by the presence of road corridors;

• Hedgerows in some locations appear degraded with landscape elements otherwise in

moderate condition;

• Generally, tree cover and vegetation along field boundaries act to provide visual

containment although degraded hedgerows act to increase intervisibility in some locations

where tree cover is sparse;

• Some distant views are available to the elevated Cotswolds uplands to the east from

elevated locations;

• Receptors primarily consist of users of the PRoWs, residents of adjacent farmsteads and

users of local roads/ M5;

• Tranquility heavily degraded by the influence of context of road infrastructure with traffic

noise associated with the A419 and M5 immediately to the west notable from most

locations;

80http://www.stroud.gov.uk/info/plan_strat/Landscape_Sensitivity_Appraisal.pdf


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• A small number of PRoW along the River Frome and surrounding the village suggest a

moderate amenity value.” (Landscape Sensitivity Appraisal, URS, July 2013. Page 2)

10.94 Fieldwork carried out as part of this LVIA confirms the above description is consistent with the

landscape characteristics of the site and its immediate surroundings.

10.95 An outline assessment of the sensitivity of the Stroud District local landscape character types /

areas to the Revised Scheme is provided as part of this LVIA at RS Appendix 10.2 as summarised

in the Assessment of Effects section below. The approach to the sensitivity assessment is based

on current best practice guidance which states that sensitivity should be determined by

combining judgements of landscape susceptibility to the type of change or development being

proposed and the value attached to the receiving landscape.

Stroud District Landscape Sensitivity Assessment (White Consultants 2016).

10.96 The 2016 Stroud District Landscape Sensitivity Assessment (LSA) issued in 2016 builds upon the

2013 URS appraisal, providing a more detailed assessment of local landscape sensitivity and

capacity for built development. Around 220 potential land parcels are considered in the 2016

LSA including the area relevant to the Site which falls within LSA Sensitivity Parcels ‘St04’ (to the

south of A419) and ‘St05’ (to the north of the A419). More details on 2016 LSA are provided in

RS Appendices 10.9c and 10.9d including extracts from this study as summarised below.

10.97 Sensitivity Parcel St05 – the Development Footprint area is located wholly within Sensitivity

Parcel St05, as shown RS Figure 10. 8a Landscape Sensitivity with Project Components (SDC),

which is assessed as exhibiting Medium / Low landscape sensitivity to employment uses defined

as follows:

“Landscape and/or visual characteristics of the land parcel are resilient to change and/or its

values are medium/low or low and it can accommodate the relevant type of development in

many situations without significant character change or adverse effects. Thresholds for

significant change are high.” (2016 LSA, Table 1, p6) [author emphasis]

10.98 It is important to note the SLA 2016 finding that, across the entirety of Stroud District, only

Sensitivity Parcel St05 (encompassing the Development Footprint) qualifies as a Medium / Low

landscape sensitivity to employment uses, with no potential sites qualifying in the low sensitivity

category. There are also very few potential sites qualifying in the medium sensitivity category,

with most potential employment sites exhibiting a high sensitivity to such uses.

10.99 Thus, from a landscape perspective, the Site is considered an appropriate location for built form

of a similar nature to employment development (B1, B2 and B8 Use Classes), with Sensitivity

Parcel St05 having the lowest sensitivity rating (medium-low) of any Sensitivity Parcel in Stroud

District. Relatively speaking, the Site therefore has notably fewer constraints in landscape and

visual terms for the type of development proposed, when assessed objectively, compared with

other locations in Stroud District. This reinforces the Site’s potential to accommodate the Revised

Scheme, subject to sympathetic design and a detailed assessment.

10.100 Notwithstanding the maximum height of 19.5m of the stadium proposal (see RS Figure 5.1

Building Height Parameter Plan, the variable height, sloped roof (12m at its lowest point)

combined with the gentle, sweeping lines of its organic form, will be broadly in accordance with

the building scales defined in the 2016 LSA for employment uses (see RS Appendix 10.2,

Paragraph 10.2.98).


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10.101 Regarding the design of the development and landscape enhancement opportunities it is

instructive to note the following observation in SLA 2016 regarding Sensitivity Parcel St05:

“The sensitivity of the area lies in its role as a buffer between Stonehouse which is expanding with the

M5 and vale to the west, its contribution to the setting of the traditional, rural linear settlement of

Westend including listed buildings and the trees within the area. The value of the area lies in the

PROWs and the listed buildings in Westend adjacent. Employment use would definitely extend the

current development corridor towards the vale and M5. This may be acceptable providing

development provides a suitable high-quality gateway to Stonehouse with substantial landscape

treatment and considered in the context of the overall road corridor through to, and including, Stroud.

Also, a buffer would be needed with more sensitive buildings in Westend including the orchard with

smaller scale development on this boundary.” (SALA page 341, St05) [author emphasis]

10.102 The Revised Scheme, with the landmark stadium as its centerpiece, provides an opportunity to

facilitate just such a ‘high quality gateway’, as referred elsewhere in this LVIA and described

further in the Planning Statement and Design and Access Statement provided as separate

documents as part of the submission.

Valued Landscapes

10.103 There are no known national landscape designations or local/ non-statutory landscape

designations covering the Site or its immediate environs. The Cotswolds Area of Outstanding

Natural Beauty (AONB) is the closest national landscape designation located to the south and

east of the Site, at a distance of approximately 2km at its closest point east of Stonehouse.

The Industrial Heritage Conservation Area (IHCA)

10.104 The part of the Site (Redline Boundary) to the east of the M5 and south of the A419 lies partly

within The Industrial Heritage Conservation Area (IHCA) – see RS Figure 10.5c and RS Appendix

7.1. The IHCA is a linear conservation area occupying the valleys of the River Frome and

Nailsworth Stream, extending to the east, west and south of Stroud. The linear form of the IHCA

reflects the various transport and other infrastructure which developed over the 18th and 19th

centuries, principally around the River Frome / Stroudwater Canal corridor.

10.105 The Council has produced various Supplementary Planning Advice and a Supplementary Planning

Document on the IHCA – all of which are listed as separate documents (carrying different weight)

under the umbrella title of the ‘Industrial Heritage Conservation Area Statement’ (Adopted Nov

2008); more information on this is provided in RS Appendix 10.2 The LVIA has considered the

conservation area designation in terms of the contribution it makes to the character of the

contemporary landscape which forms part of the assessment of local landscape character set out

in RS Appendix 10.3 Landscape Assessment Schedules. An assessment of potential effects on

the IHCA is provided in Chapter 7 Archaeology and Cultural Heritage and RS Appendix 7.1.

10.106 It should be noted that the Development Footprint is situated to the north of the A419, outside

the IHCA, and separated from it by the part of the Site south of the A419 which will remain in its

current undeveloped state.

Cotswolds Area of Outstanding Natural Beauty (AONB)

10.107 The Cotswolds AONB is a limestone upland landscape with a prominent west facing scarp and

elevated open plateau and gentle dip slope extending southeast. The scarp extends over 52km

between Bath and Broadway marking the transition of the Cotswolds and Severn / Avon Vales,


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providing a backdrop to views as well as long views out over the Severn Estuary and Vale towards

the Forest of Dean.

10.108 The character of the AONB is described in the Cotswolds Landscape Assessment 2004 as referred

to in the previous landscape character section. Also of importance to this LVIA is the Cotswold

Area of Outstanding Natural Beauty Management Plan (2013-18)81 which describes the

overarching ‘special qualities’ of the Cotswolds as follows:

• “the unifying character of the limestone geology – its visible presence as natural outcrops,

its use as a building material and through the plant and animal communities it supports;

• the Cotswold escarpment, including views to and from it;

• the high wolds – a large open, elevated landscape with commons, ‘big’ skies and long-

distance views;

• river valleys, the majority forming the headwaters of the Thames, with high-quality water;

• dry stone walls, which give the AONB its essential character in many areas;

• internationally important flower-rich limestone grasslands;

• internationally important ancient broadleaved woodland, particularly along the crest of

the escarpment;

• variations in the colour of the stone from one part of the AONB to another which add a

vital element of local distinctiveness;

• the tranquility of the area82;

• well-managed arable and livestock farms;

• distinctive settlements, developed in the Cotswold vernacular, high architectural quality

and integrity;

• accessible landscape for quiet recreation; and

• historic associations.” (p8 The Cotswold AONB Management Plan, 2013-2018)

10.109 The character assessment of the Cotswolds AONB and the analysis of its special qualities both

inform the assessment of likely effects of the Revised Scheme on the designated landscape

presented in the Landscape Assessment Schedules at RS Appendix 10.3.

Wye Valley Area of Outstanding Natural Beauty (AONB)

10.110 Wye Valley AONB (Forest of Dean District) is located approximately 19km northwest of the

Revised Scheme at its closest point and therefore lies outside the 10km LVIA Study Area. It is

considered here as a precautionary measure, bearing in mind the nature of the Revised Scheme.

It should be noted that the Forest of Dean is not formally designated for its landscape value.

10.111 RS Appendix 10.10 Bare ground ZTV to 25km including Wye Valley AONB illustrates the

extremely limited visibility of the Revised Scheme across the Wye Valley AONB. This figure is

based on a bare ground ZTV, with all ZTV markers set to 19.5m height (the maximum height of

81 http://www.cotswoldsaonb.org.uk/management_plan/index.html 82 Where this report states that “Tranquillity is very difficult to define but is essentially the absence of inappropriate

noise, development, visual clutter and pollution, ‘a feeling of being away from it all’.” (p8 The Cotswold AONB

Management Plan, 2013-2018). The Cotswold Conservation Board have also produced a position statement on

tranquillity.


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the stadium) and is therefore illustrative of a worst-case scenario. The figure indicates a small

area of theoretical visibility on the SE boundary of Wye Valley AONB near St Briavels and

Tidenham Chase at approximately 22-24km distance from the Site. At this distance, even in more

exposed areas, where more open views may be available, the project components are likely to

be barely discernable or ‘lost’ within the wider landscape and visual context. No further

assessment of the Wye Valley AONB is therefore provided.

Local Landscape Designations

10.112 There are no local landscape designations recorded in the Study Area, or described in the current

Local Plan.

Other Relevant Designations

10.113 Other landscape related designations considered in the LVIA or elsewhere in the EIA include:

• Registered Parks and Gardens including Frampton Court and Woodchester Park (refer to

RS Appendix 10.2 of the LVIA); and

• Industrial Heritage Conservation Area83 (referred to in RS Appendix 10.2 and 10.3 in the

context of landscape character; assessed from a historic setting perspective in Chapter 7

Archaeology and Cultural Heritage and RS Appendix 7.1)

10.114 More information on the valued landscapes and designated areas within the Study Area is

provided at RS Appendix 10.2 with the geographic extent of the designations shown in RS Figure

10.6.

Visual Resource

10.115 The baseline assessment considers the visual resource of the Study Area and identifies key visual

receptors and representative viewpoints lying within the (screened and unscreened) ZTV of the

Revised Scheme.

Visual Receptors and Viewpoints

10.116 The visual resource of a particular area is made up of both specific views and general visual

amenity. Visual amenity is defined by GLVIA3:

“The overall pleasantness of the views people enjoy of their surroundings, which provides an

attractive visual setting or backdrop for the enjoyment of activities of the people living,

working, recreating, visiting or travelling through an area.”

10.117 Principal visual receptors can be either static or dynamic. The following receptors (visual

sensitivity in brackets) are identified as being of ‘high’ sensitivity due to their susceptibility to

visual change and/ or the value placed on views and visual amenity (with the exception of public

highways which are assigned ‘low sensitivity’) – see RS Appendix 10.1 Methodology:

• Residential properties within 0.5km (high);

• Small and small / medium sized settlements within 2km (high)84;

• Small / medium to large settlements within 2-5km (high)85;

83 http://www.stroud.gov.uk/info/IHCA_SPD_Nov08.pdf 84 Hamlets and villages in the immediate vicinity of the Site e.g. Westend, Eastington and Whitminster. 85 Villages and towns in the wider surrounding area e.g. Stonehouse, Frampton-on-Severn and Stroud.


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• Places of interest with public access within 10km (high);

• Publicly accessible land within 10km – including Common Land, Open Access Land (as

defined by Countryside and Rights of Way Act 2000 (CRoW)), Country Parks and National

Trust Land (high);

• National Recreational Trails and Cycle Routes within 10km – including the Cotswold Way,

and Thames and Severn Way (high);

• PRoW within 2km - Footpaths, bridleways, byways and tracks, local cycle ways, canal

towpaths etc (focusing on those within 1km of the site and where views are potentially

available due to reduced vegetative cover (high);

• Public highways within 10km – people in vehicles and others using main roads and local

roads (low).

10.118 In addition to site visits in 2015 and 2016, further fieldwork was undertaken in 2017 to verify and

identify receptors surrounding the Site with potential views of the Revised Scheme.

10.119 In practice, at a local level, excluding the Cotswolds escarpment, the visual envelope of the Site

is broadly contained within an area extending from Whitminster Court 400m to the north (near

Grove Lane), Fromebridge and Netherhill Cottages 800m to the west (near A38), ‘Claypits’

1,200m to the south west (near A38), Eastington Footpaths 800m to the south (near Alkerton),

Chipmans Platt roundabout 150m to the east (near A419) and the minor road/ rise to Nupend

450m to the northeast. These views are further interrupted by intervening hedgerows and

woodland.

10.120 Longer distance views from the Cotswold escarpment lying to the east of the Site are available

which are discussed in the following sections.

10.121 Potential visual receptors include the local PRoW network crossing and immediately adjacent to

the site, places of interest, residential properties and settlements such as Westend, Nupend,

Chipmans Platt and Eastington, as well as users of the M5, A419 and local road network including

Grove Lane (National Cycle Network Route No.45) as shown below in Table 10.3 below.

Table 10.3: Representative viewpoints and visual receptors

Viewpoint Distance* from Site

(Stadium) (m)

Direction

of view

Receptors (representative of)

1. A419 at M5 Junction 13 0 W

(144)

SE Road users

2. Footpath at Westfield Bridge

(EEA 41)

0 S

(489)

NW PRoW users (and residents)

3. Footpath east of Westend

(EEA 22)

99 NE

(224)

SE to SW PRoW users (and residents)

4. A419 at Chipmans Platt

roundabout

0 SE

(568)

NW Road users

5. Thames and Severn Way east

of M5 (also Footpath EEA 46)

180 SW

(631)

NE PRoW users


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Viewpoint Distance* from Site

(Stadium) (m)

Direction

of view

Receptors (representative of)

6. Footpath West of Nupend

(EEA 23)

337 ENE

(581)

SW PRoW users (and residents)

7. Grove Lane M5 over bridge 213 N

(424)

S Road users and NCN cyclists

8. Footpath north of Eastington

(EEA 51)

660 SSW

(1126)

NNE PRoW users (and residents)

9. Maiden Hill (Cotswold Way) 3,885 E

(4,171)

W PRoW users

10. Haresfield Hill (Cotswold

Way)

4,699 ENE

(4,886)

WSW PRoW users, National Trust

and open access land users

11. Selsey Common (Cotswold

Way)

5,296 SE

(5,837)

NW PRoW and common land /

open access land users

12. Cam Long Down (Cotswold

Way)

6,698 S

(7,216)

N PRoW and open access land

users

13. A38 at Claypits 917 SW

(1,509)

NE Road users (and residents)

14. A38 / Thames and Severn

Way intersection

425 WNW

(1,035)

ESE PRoW / road users and

residents

15. Footpath at Doverow Hill

(MST 30)

2,927 ESE

(3,377)

WNW PRoW users

16. Footpath west of Westend

(EEA 38)

0 E

(293)

W PRoW users (and residents)

A. St Michael’s and Angels

Church, Eastington)

420 SSE

(942)

NNW PRoW / road users and

residents

D. A38 Whitminster ridge

(garden centre car park)

930 NNW

(1,140)

SSE Road users (and residents)

E. Footpath at Barrow Hill,

Fretherne

5,800 NW

(5,926)

SE PRoW users

F. Footpath at Pleasant Stile,

Littledean (Forest of Dean)

12,000 NW

(12,124)

SE PRoW users (and residents)

G. Field Lane, Cam (minor road) 7,300 SSW

(7,772)

NNE Road users (and residents)

H. Layby on Frocester Hill (minor

road)

4,670 SSE

(5,083)

NNW Road, PRoW, common land /

and open access land users

*distance in metres and direction from Redline Boundary (Stadium in brackets)

10.122 A previously agreed selection of the representation viewpoints (with one additional location

substituted (VP16) due to lack of visibility of the Revised Scheme from that location (VP13)) have

been modelled, and ‘enhanced wireframe visualisations’ prepared to illustrate the scale and

outline appearance of the Revised Scheme in the landscape which are identified in Table 10.4


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Enhanced Wireframe Visualisation Viewpoints below. Night-time baseline photographs have also

been taken for these seven viewpoints. All viewpoints are marked on various figures, for example

RS Figure 10.1 and RS Figure 10.4.

Table 10.4: Enhanced Wireframe Visualisation Viewpoints (and Night-time Viewpoints)

VP Ref Dist*

(m)

Title Night-time base

photo included

4 0 A419 at Chipmans Platt roundabout Yes

6 337 Footpath west of Nupend Yes

8 660 Footpath north of Eastington Yes

9 3,885 Cotswold Way at Maiden Hill Yes

12 6,698 Cotswold Way at Cam Long Down Yes

15 2,927 Pleasant Stile, Littledean (Forest of Dean) Yes

16 0 Footpath west of Westend Yes

*distance in metres from Redline Boundary

Night time baseline

10.123 With respect to baseline lighting levels, in keeping with the LVIA, Chapter 14 Lighting notes that

the Site area is currently agricultural land with no existing artificial light sources within the

boundary. Lighting does spill onto the Site from adjacent sources including the M5 motorway,

car parks, industrial and ancillary buildings located adjacent to it as outlined in the night time

baseline assessment contained in RS Appendix 10.1 and RS Appendix 10.2. The existing sources

of lighting which characterise the immediate and surrounding area within 500m – 2km of the Site

are primarily:

• Dairy Crest (renamed Muller) and Ryeford Buisness Park, Stonehouse;

• Stonehouse urban/ street lighting;

• A419 street lighting (Stonehouse to Chipmans Platt);

• Chipmans Platt service station;

• WMC;

• Eastington Trading Estate;

• Eastington settlement/ street lighting;

• M5 Junction 13 highways depot;

• Whitminster settlement/ street lighting;

• A38 street lighting;

• A38 transport/ logistics depots/ quarry;

• A38 vehicle auction yards.

10.124 Notwithstanding the baseline lighting assessment contained in Chapter 14 the night time

observations in the field noted levels of existing lighting in the immediate and surrounding area

of the Site are typically higher to the east (A419 corridor, Dairy Crest and Stonehouse) and west

(A38 commercial depots and logistics yards, sand and gravel works, salt storage depot on J13 and

traffic on M5 adjacent to Site). Levels of lighting are lower to the north and south (e.g. River

Frome Corridor and areas around Nupend / Westend). The existing night time environment is

illustrated in the baseline photographs provided at RS Figure 10.13 for a range of representative


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viewpoints surrounding the Site. Existing levels of illuminance / light pollution in the Study Area

are shown on RS Figure 10.10a Cotswolds AONB Light Pollution Map, RS Figure 10.10b Night-

time Baseline / Existing Light Sources / Lighting Levels (Study Area) and RS Figure 10.10c Night-

time Baseline / Existing Light Sources / Lighting Levels (Detailed Area).

10.125 As a consequence, based on the observations in the field at night time, there are variable

patterns of lighting across the area due to its settled and agricultural nature on the one hand,

and its peri-urban qualities on the other (see also Chapter 14).

Future Baseline

Overview

10.126 Landscape is a constantly evolving resource, reflecting developments in agriculture,

transportation, industry and energy, in addition to the ever-changing nature of settlement.

Planned new housing and employment development to the west of Stonehouse (known as WOS

and currently under construction in phases), accompanied by associated improvements in

access, services and green infrastructure/ landscape, is and will extend the existing settlement

westwards along the A419 towards the M5 motorway and the Site. This general trajectory of

landscape change is considered appropriate in SDC’s recent strategic landscape study SALA 2016.

Climate Change

10.127 Natural England published its ‘climate change risk assessment and adaptation plan’ report in

2015, part of the statutory requirement on Government Agencies to provide such advice, arising

from the Climate Change Act 2008. In the report Natural England sets out the risks and threats

posed by current climate change predictions and how the agency proposes to respond to them.

As part of its strategy Natural England recognises that climate change offers opportunities as well

as threats. For instance:



(sense of place, biodiversity and other ecosystem services).” (page 10)

10.128 The Landscape Institute’s position statement on climate change86 acknowledges that changes in

average temperatures, precipitation and extreme weather events will have an effect on the

landscape. However, it is difficult to quantify the potential effects arising and it is unlikely that

the anticipated changes in climate will appreciably change either the baseline landscape

conditions or the landscape and visual effects predicted in this LVIA.

10.129 Increased rainfall and flooding events, coupled with rising temperatures, are likely to modify UK

flora and fauna over time (partly due to changes is hydrology / ground conditions), and landscape

design measures can be introduced to cope with and adapt to the anticipated change. Such

measures form part of the SUDS proposals (embedded mitigation) for the Revised Scheme, as

outlined in the landscape strategy (refer RS Appendix 10.7) which will be the subject of detailed

design at the Reserved Matters Application stage. This will include details of climate change

adaption measures at this particular location, for example by specifying suitably resilient plant

species, so as to exploit the opportunity climate change presents to create ‘valuable new

landscapes’, in line with Natural England guidance.

86 Landscape architecture and the challenge of climate change (2008) Landscape Institute Position Statement.


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10.130 Other climate change adaption measures relating to SUDS and green infrastructure / ecosystem

services, which form part of the embedded mitigation and promote a quality and healthy

environment, are set out in the landscape strategy at RS Appendix 10.7 and include:

• extensive tree planting to establish ‘parkland’ landscape and wildlife corridors / networks

will create shade for cooling effect and sequestrate of carbon.

• hard landscape materials will be sustainably sourced and permeable paving used for all

parking areas and footpaths which together with other SUDS elements such as swales and

ponds will form part of a comprehensive drainage strategy.

Cotswold Canals

10.131 The Cotswold Canals Trust (CCT) aims to restore navigation along the Stroudwater Canal. The

Cotswold CCT has already embarked on a £37 million restoration project for ‘Phase 1a’ from

Stonehouse Court to Brimscombe Port; Phase 1b westwards to Saul Junction, including the

section immediately to the south of the Site is currently at the bid-submission stage.

10.132 For the purposes of this EIA, it has been assumed that the Cotswold Canals Trust will be successful

in acquiring their Heritage Lottery funding and subsequent planning permissions in the near

future and, therefore, the project is considered to be a ‘committed’ development in planning

terms, and is included in the Cumulative Landscape and Visual Impact Assessment (CLVIA) of the

Revised Scheme (see RS Figure 18.1 – cumulative scheme No.9 ‘Indicative Canal Realignment’).

10.133 The canal network is a historically important part of the local landscape and its restoration/

renaissance will offer a number of social, economic and environmental benefits, including

enhancement of both the landscape fabric and local character and distinctiveness of the historic

canal corridor within the IHCA. Such environmental enhancement measures within the Frome

River corridor are likely to benefit landscape character and visual amenity, a factor taken into

account in the CLVIA provided in this chapter.

Design Evolution

Introduction

10.134 The design of the Revised Scheme has evolved to support the overarching ethos of Eco Park, to

provide for exemplar innovative sustainable building design and landscape works as laid out in

Chapter 5. A key consideration informing the design evolution and landscape strategy was the

need to ensure that the Revised Scheme responds sensitively to its landscape context and, as far

as possible, preserves the character and visual amenity of surrounding landscape, property,

settlements and designated areas, particularly the Cotswolds AONB. Central to the design

strategy has been the ‘parkland’ landscape theme. The Revised Scheme as presented in RS Figure

1.1 Indicative Concept Plan, described in Chapter 5 Description of the Revised Scheme and

summarised in this chapter above.

Embedded versus Further Mitigation

10.135 The Revised Scheme has evolved in response to a range of environmental constraints and

opportunities identified during the design and EIA process. Mitigation measures have been

incorporated into the design to as far as possible avoid, reduce, and/ or offset potentially

significant adverse landscape and visual effects, thus demonstrating an iterative approach to the


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EIA in order to achieve the optimum outcome. EIA procedures follow a process of describing the

overall predicted level of effect prior to mitigation (Year 1), followed by the overall predicted

level of effect following mitigation (for example Year 15), termed the ‘residual effect’. However,

when carrying out an EIA, it is important to distinguish between those measures which are

integral to the design and those which proposed in addition.

10.136 For the purposes of this LVIA, and due to the outline status of the planning application, the

proposed mitigation is ‘embedded mitigation’ – measures integral to the proposal, formulated

during the design process and incorporated into the landscape strategy and the Indicative Green

Infrastructure Parameter Plan (RS Figure 5.3). All embedded mitigation will be subject to

approval as Reserved Matters at the detailed consents stage. ‘Further mitigation’ measures in

order to avoid, reduce, control, manage or compensate potential significant adverse landscape

and/ or visual effects identified in this LVIA will form part of the detailed design process should

the Revised Scheme be granted outline consent.

Enhancement

10.137 Where amelioration measures are proposed in order to ‘mitigate’ non-significant environmental

effects, this is termed enhancement. Beneficial/ positive effects may also be associated with

landscape or ecological enhancement measures that have a positive effect on landscape

character and visual amenity. Enhancement is not a formal requirement of the EIA Regulations

but is an implicit objective of the Revised Scheme. GLVIA3 states that:

“[Enhancement] is often referred to incorrectly as an outcome of proposed mitigation measures

– for example where planting is proposed to mitigate landscape and / or visual effects but will

also achieve an enhancement of the baseline condition of the landscape. In practice

enhancement is not specifically related to mitigation of adverse landscape and visual effects but

means any proposals that seek to improve the landscape and / or visual amenity of the Proposed

Development site and its wider setting beyond its baseline condition.” (GLVIA3 Para 3.39, p 43).

Landscape Constraints and Opportunities Plan

10.138 The Indicative Concept Plan (RS Figure 1.1) has evolved in response to the potential landscape

and visual constraints and opportunities identified during project inception, feasibility, design

development and consultation. Plans showing and describing these constraints and

opportunities are included at RS Figures 10.11a Offsite Constraints and Opportunities and

10.11b Onsite Landscape Constraints and Opportunities.

10.139 RS Figure 10.11a identifies offsite constraints and opportunities in relation to:

• Topography and Key Views;

• Landscape Character and Historical Context;

• Movement, Transport and Circulation;

• Settlement and Properties.

10.140 RS Figure 10.11b identifies onsite constraints and opportunities in respect of:

• Riparian Landscape and History;


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• Landscape Character and Historical Context;

• Movement, Transport and Circulation.

10.141 Together, the combined landscape and visual constraints and opportunities inform the landscape

design, Green Infrastructure and landscape mitigation strategies for the Revised Scheme as set

out in the next section.

Landscape Strategy and Green Infrastructure

10.142 Central to the design of the Revised Scheme is the aim to respect local landscape character and

visual amenity and, as far as possible, to contribute to their enhancement. Following

identification of the landscape and visual constraints and opportunities described above, a

bespoke landscape strategy has been devised outlining proposals for landscape mitigation and

enhancement. This information feeds into and underpins RS Figure 5.3 Indicative Green

Infrastructure Parameter Plan which sets out the proposed enhancements alongside the

embedded and further mitigation for biodiversity, ecosystem services and landscape

improvements.

10.143 The Landscape Strategy included at RS Appendix 10.7 and RS Figures 10.11c and 10.11d

describes the landscape design strategy and mitigation rationale using a combination of graphics

and text, and sets out the overall Vision, the Key Objectives and the Key Landscape Elements and

Design Principles. The Landscape Strategy articulates how the landscape and visual constraints

and opportunities identified in RS Figure 10.11a and RS Figure 10.11b and as summarised above,

have been translated into the landscape design and mitigation proposals embedded in the

Indicative Green Infrastructure Parameter Plan (RS Figure 5.3) and the Indicative Concept Plan

(RS Figure 1.1).

10.144 The key landscape strategies presented in RS Figure 10.11c are:

• Create a ‘parkland’ landscape setting;

• Retention of long distance views across the Site;

• Setting back of built form from adjacent settlement/ residential properties;

• Translocation of existing native species hedgerow; a

• Protection of cultural heritage and archaeology (onsite and offsite).

10.145 Regarding landscape mitigation and enhancement, a range of measures are proposed (see RS

Figure 10.11d) in order to avoid or minimise potential landscape and visual effects and enhance

local landscape character, visual amenity and biodiversity in the medium to long term including

the following:

• Generous set back of built form from the Redline Boundary to protect local character,

visual amenity and the setting of the IHCA;

• Planted belts of appropriate tree species to create ‘parkland’ setting;


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• Landscape buffer / ‘woodland meadow’ planting incorporating earth bunds and ‘dark bat

corridors’ to protect adjacent residential amenity and wildlife and provide landscape and

visual benefit (see RS Figure 5.6)87.

Landscape and Habitat Management Strategy Plan

10.146 In order to ensure the lasting success and longevity of the landscape and ecology strategies, a

combined management plan is proposed. It is intended that a landscape and habitat

management plan (secured by an appropriate planning condition) will be produced and

implemented.

Potential Effects

Introduction

Assessment Process

10.147 A detailed assessment of potential landscape and visual effects of the Revised Scheme is

provided in Volume 3 of the ES at RS Appendix 10.3 Landscape Assessment Schedules, RS

Appendix 10.4 Visual Assessment Schedules and RS Appendix 10.5 Cumulative Assessment

Schedules. The baseline situation is taken to be that pertaining at the time of submission in 2017,

as outlined earlier in this chapter and described in more detail in RS Appendix 10.2.

10.148 The assessment of potential effects considers the construction and operation phases of the

development separately; for operation the likely effects at the outset (Year 1) and following

establishment of the landscape works (Year 15) are assessed. A commentary on the night time

baseline situation and potential effects arising is also provided.

10.149 The cumulative assessment follows a similar format and considers the likely additional effect of

the Revised Scheme in combination with significant ‘committed’ and planned developments

within 5km of the Site.

10.150 The significant adverse landscape and visual effects predicted to result from the Revised Scheme

are summarised below based on the detailed assessments provided in RS Appendices 10.3-10.5.

Non-significant effects are described in RS Appendix 10.8.

Nature of Revised Scheme

10.151 As confirmed in the methodology section above, landscape and visual effects are assessed as

adverse / negative unless stated otherwise in order to test worst-case. That said, it is important

to note that this is a landmark building designed by internationally renowned architects Zaha

Hadid Associates, constructed in natural (timber) materials, placed within a ‘parkland’ setting at

a ‘gateway’ location to Stroud, which will be perceived positively by some members of the public.

Bearing in mind the European Landscape Convention definition of landscape quoted above in the

main Introduction section these positive perceptual factors cannot be discounted from the

assessment and therefore have been taken into account in the assessment of residual effects. In

practical terms this means that the establishment and maturing of the proposed landscape

87 It is assumed that planting on the earth bund would reach a height of approximately 5m by Year 15 as shown on

RS Figure 5.6 having regard to variations in growth rates dependent on species mixes and growing conditions.


December 2015

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mitigation / new planting will provide increasing landscape and visual benefit over time which

will moderate adverse effects in the longer term.

Sources of Effects

10.152 The sources of landscape and visual effects will vary across the lifecycle of the Revised Scheme

from construction through initial completion (Year 1) to longer term operation (Year 15). The

sources of temporary/ short term and permanent/ long term effects including embedded

mitigation are summarised below.

During Construction (Temporary / Short Term)

10.153 The Revised Scheme will be constructed as set out in Chapter 5. Construction will generate

temporary and short-term effects lasting for the duration of works for each phase. In summary

the sequence of works will involve all elements (except the training pitches) being be completed

before the stadium is brought into us. Effects likely to arise on the landscape and visual resource

during construction will include those emanating from:

• Site clearance, removal / trimming of vegetation etc.;

• Stripping and temporary earthworks including storage of topsoil and spoil;

• Construction of access roads, public highway improvements and associated infrastructure

and landscape works;

• Construction of stadium building and associated parking facilities and sports pitches;

• Construction compound(s) for delivery and storage of materials and temporary parking;

• Temporary buildings (cabins and storage containers), hoarding and other security fencing;

• Construction traffic and temporary activity associated with vehicles and machinery.

10.154 Construction effects will affect landscape and visual receptors temporarily in different ways

depending on their location / proximity to the Development Footprint.

During Operation (Permanent / Long Term)

10.155 Effects likely to arise following completion and during the operational life of the Revised Scheme

will include those arising from:

• The stadium, training pitches and ancillary facilities used primarily by FGRFC First Team;

• Access roads and highways improvements and associated movement of vehicles;

• New planting and other landscape works including hedges, tree cover, bunding and areas

of grassland.

10.156 Operational landscape and visual effects will tend to decrease over time as the proposed

landscape mitigation and enhancement becomes established and matures. Fifteen years is

generally considered an appropriate timeframe for this. Thus Year 15 is adopted as the suitable

point at which to judge the level of residual landscape and visual effect. In reality, the landscape

mitigation and enhancement will continue to mature after Year 15 providing increasing benefits

to landscape character, visual amenity and biodiversity.

Landscape Resource


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10.157 Predicted significant adverse effects potentially occurring during construction and operation in

relation to the various aspects of the landscape resource, as described in the baseline assessment

section, are set out below. Non-significant landscape effects are described in RS Appendix 10.8.

The level of residual landscape effect is judged by assessing the magnitude of landscape change

against the sensitivity of the receptor, the latter being a product of its value and susceptibility to

change of the type proposed.

Scope of Landscape Assessment

10.158 As outlined in the Baseline Conditions section above the landscape assessment examines the

following aspects of the landscape resource in the study area:

• Landscape fabric of the Site including PRoW;

• Landscape character;

• Valued or designated landscapes.

Effect on Landscape Fabric

10.159 The landscape fabric of the Site is shown on RS Figure 10.2 and includes the following landscape

elements:

• Landform/ Topography;

• Vegetation and Boundary features;

• Other Site Elements including PRoW.

Predicted Significant Effects on Landscape Fabric

10.160 The Revised Scheme will transform the landscape fabric of the Development Footprint from

agricultural land to a mixture of built development, sports pitches, access roads, car parking areas

and open spaces / new planting. The remainder of the Site will remain in its current undeveloped

state.

10.161 Notwithstanding the agricultural grassland and hedgerows and tree planting within the

Development Footprint that will need to be removed, translocated and replanted to

accommodate the proposed stadium, access and parking areas, the majority of existing trees will

be retained and incorporated within the Revised Scheme. A number of hedges will be

translocated and new ones planted; where translocation is not possible hedgerows will be

replanted in appropriate locations / alignments using suitable native species as shown on RS

Figure 8.2 Trees and Hedgerows Balance.

10.162 The Revised Scheme provides an opportunity to achieve synergies between hedgerow

translocation / replanting and future PRoW improvements / realignment. It is proposed to

increase the total length of hedgerows currently on the Site in order to maximise biodiversity

and wildlife benefits, and enhance landscape character and visual amenity locally. The current

proposal is for the PRoW to be retained as existing but, in accordance with Eastington

Neighbourhood Development Plan (NDP) Policy EP9 Public Rights of Way and Wildlife

Corridors, the intention is for them to be realigned (within the Development Footprint boundary)

to follow new green corridors incorporating double hedgerows (see NDP EP9 Map 4 Wildlife

Corridors and RS Figure 8.2). PRoW and hedgerow realignment will be the subject of detailed

design at the Reserved Matters Application stage, secured by a suitable planning condition.


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Considered together with the new A419 pedestrian crossing for footpath EEA 37 the outcome of

these realignments and hedgerow enhancements will be a benefit to the local PRoW network.

10.163 Drawing these various adverse and positive effects together, on balance, the magnitude of

effect on the generally low to medium sensitivity landscape fabric of the Site overall during

construction and Year 1 of operation will be medium to high, leading to a moderate / major

significant level of adverse effect at most during construction and at Year 1 of operation which

will be temporary and short term. As the proposed mitigation and enhancements become

established through operation, thus creating the ‘parkland’ setting for the Revised Scheme, these

effects will reduce so that at Year 15 the predicted magnitude of effect on the landscape fabric

will be low to medium, leading to a moderate / minor or lower (and not significant) residual

effect. In all likelihood adverse landscape effects will reduce over time becoming increasingly

beneficial / positive as the proposed mitigation and enhancement measures mature in the longer

term.

10.164 The same variation in magnitude of landscape change is predicted in relation onsite PRoW EEA

37 and EEA 38. In this instance, given the high sensitivity of this receptor and medium / high

magnitude of change predicted a major / moderate (and significant) level of adverse effect is

predicted in construction and at Year 1. This level of effect is though predicted to reduce during

operation to become moderate level and not significant by Year 15.

10.165 No adverse effects on landscape fabric are predicted in relation to existing structures on the

Site such as the various onsite barns and Westfield Bridge. These structures do not form part of

the proposed works for the Revised Scheme and will be retained in their existing form. A low to

medium magnitude of change and a minor / moderate level of adverse effect is predicted in

relation to site landform during construction and operation which will be direct, permanent

and not significant both in the short and longer terms.

10.166 Taking into account both the negative and positive aspects of the Revised Scheme, the predicted

residual effect on the landscape fabric of the Site overall at Year 15 will be moderate adverse

at most and not significant in the EIA context. This includes PRoW EEA 37 and EEA 38 which,

although being subject to significant physical effects initially, will be retained in their current

alignment in the short term, and appropriately integrated into the Site landscape in an attractive

manner at the detailed design stage in line with local planning policy objectives. Thus, the

significant adverse effects arising initially during construction and the first year of operation

(i.e. in the short term) will reduce to a not significant residual level during operation in the

longer term (by Year 15).

Assessment of Effect on Landscape Character

10.167 The baseline assessment above examined landscape character in the Study Area at the national,

county and local authority level in addition to considering the Cotswolds AONB. Based on scoping

and pre-application / post application consultation responses, particularly those received from

SDC and Natural England, it is considered appropriate to focus the assessment of potential

landscape character effects to the local level but to consider the regional and nation character

context as well. Thus the focus here is on the landscape units defined in the published Landscape

Character Assessments listed below:

• Stroud District Landscape Assessment (SDLA), 2000;

• Cotswolds AONB Landscape Assessment, 2004; and


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• Stroud Industrial Heritage Conservation Area (IHCA) Statement – Supplementary Planning

Advice (Adopted), 2008 – Volume 1: Summary and Character Overview (Parts 1-4) and

Volume 2: Character Parts.

10.168 A comprehensive assessment of landscape character effects is set out in RS Appendix 10.3 in

which the following landscape character assessments are also considered:

• Gloucestershire County Character Assessment 2006;

• Natural England National Character Assessment.

10.169 The various Landscape Character Assessment information referred to above and in the baseline

section (including RS Appendix 10.2) is displayed graphically at RS Figures 10.4a and 10.4b.

Landscape Character Sensitivity

10.170 The sensitivity of the local landscape to the Revised Scheme is discussed in the baseline section

above and an outline evaluation provided at RS Appendix 10.2. A summary of this high-level

assessment of local landscape sensitivity is provided in Table 10.5 below; RS Figure 10.8b

Landscape Sensitivity of Stroud District Landscape Character Types with Project Components

(Ecotricity) and RS Appendix 10.9 displays the SDLA information graphically:

Table 10.5: Landscape Sensitivity

Stroud District Landscape Assessment 2000 (SDLA)

Landscape Character Unit Ref Dist* Susceptibility Value Sensitivity

Escarpment Footslopes 5A Onsite

Medium /

High

Medium /

High

Medium /

High

Lowland Plain 5B Onsite Medium Medium Medium

Frome River Valley 5C Onsite

Medium /

High

Medium /

High

Medium /

High

Wold Tops 1 5.0 High High High

Secluded Valleys 3 3.5 High High High

Escarpment 4 2.8 High High High

Severn Vale Grazing Marshes 8 3.0 Medium Medium Medium

Severn Vale Hillocks (No.7) 7 4.0 Medium Medium Medium

Cotswolds AONB Landscape Character Assessment 2004


Escarpment Outlier / Cam

Longdown, Peaked Down and

Downham Hill.

LCT 1 /

LCA 1A 6.5 High High High


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Cotswolds AONB Landscape Character Assessment 2004


Escarpment / Uley to Coopers

Hill. LCT 2 /

LCA 2C 3.0 High High High

Rolling Hills and Valleys /

Stinchcombe and North Nibley. LCT 3 /

LCA 3B 7.0 High High High

High Wold / Nympsfield and

Kingscote Plateau

&Minchinhampton Common.

LCT 7 /

LCA 7A 5.0 High High High

Settled Unwooded Vale / Vale

of Gloucester Fringe

LCT 18

/ LCA

18A

2.0 High High High

Stroud Industrial Heritage Conservation Area Statement 2008


Stroudwater settlement LCT 1 0.0 Medium High

Medium-

High

Core Vale Settlement East of

Eastington LCT 2 0.3 Medium High

Medium-

High

Green Corridor: Rural Frome

Vale LCT 4 0.0 Medium High

Medium-

High

Meadow Mill LCT 7 0.0 Medium High

Medium-

High

* approximate distance from Redline Boundary in km at closest point

10.171 The landscape sensitivities recorded for each relevant character unit in the Study Area above

inform the assessment of effects on landscape character below.

Predicted Significant Effects on Landscape Character

10.172 The Revised Scheme will significantly change the character of the Development Footprint and

immediately adjacent landscape falling within SDC’s LCT 5A Escarpment Footslopes and LCT 5B

Lowland Plain (both forming part of the Rolling Agricultural Plan LCT 5), up to a distance of

approximately 250m, where uninterrupted visibility of the proposal occurs. The same level of

significant, adverse residual landscape effect would apply in respect of SV6A Vale of Berkeley

(Gloucestershire Landscape Assessment 2006). The adjacent Frome River Valley (LCT 5C) and

IHCA Green Corridor: Rural Frome Vale (LCT 4) which both lie to the south of the Development

Footprint (see RS Figure 10.5a and RS Figure 10.5c) will not be affected to any significant level

character wise.


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10.173 The magnitude of character change during construction and the first year of operation on and

immediately adjacent to the Development Footprint will be high which, taking account of the

medium to high landscape sensitivity of the host landscape, will generate a major to major /

moderate, adverse landscape effect initially at most on the Escarpment Footslopes (LCT5a) and

the Lowland Plain (LCT5b) within approximately 250m of the Development Footprint that will

be direct, temporary and significant in the context of this EIA.

10.174 Broadly similar extent and levels (or slightly lower) of significant adverse character effect will

apply in the short term in respect of the corresponding part of SV6A Vale of Berkeley (medium

sensitivity) and the SALA landscape units (low / medium, medium and high / medium sensitivity

as shown on RS Figure 10.8a both on and adjacent to the Development Footprint. It is important

to also consult RS Figure 10.5d which is provided to help understand the relationship between

the various levels of LCA, from the local IHCA and SDC LCAs, through to the national level NCAs.

10.175 As the proposed, embedded landscape mitigation establishes and matures during operation the

effect on the Escarpment Footslopes (LCT5a) and the Lowland Plain (LCT5b) will reduce to a

moderate / major (or lower) level of significant adverse residual effect in the longer term (by

Year 15) which will be direct and indirect, and permanent. The same level of significant, adverse

residual landscape effect would apply in respect of SV6A Vale of Berkeley (Gloucestershire

Landscape Assessment 2006).

10.176 It should be noted that the predicted significant adverse effects on landscape character will be

localised and limited. Furthermore, the proposed embedded mitigation and enhancement

including new planting and the creation of a ‘parkland’ setting for the stadium will provide

substantial landscape character and visual amenity benefits in the longer term.

10.177 Beyond approximately 250m from the Site, landscape character effects will be less, diminishing

with distance, and will therefore be not significant. The remainder of Stroud District’s landscape

and the associated character types/ areas within the Study Area, including those within and

defined by the IHCA, will not be affected to any significant degree character wise, and the

majority of the District’s landscape lying beyond will be unaffected.

10.178 There will be no significant adverse effect on the character of the high sensitivity Cotswolds

Area of Outstanding Natural Beauty (AONB) landscape, including the prominent escarpment,

the closest part of the AONB. This will be subject to a low magnitude of change and affected to

a moderate/minor, not significant level at its nearest point to the Site in the vicinity of

Stonehouse. The vast majority of the Cotswolds AONB will be unaffected by the Revised Scheme.

The setting of the Cotswolds AONB is dealt with in the following Valued Landscapes section.

Assessment of Effect on Valued / Designated Landscapes

10.179 There is one national level landscape designation in the Study Area – the Cotswolds AONB

located to the east of the Site, and several Registered Parks and Gardens situated within the

Study Area (see RS Figure 10.6). There are no local level landscape designations within the Study

Area; Conservation Areas such as the Stroud IHCA are assessed in Chapter 7 Archaeology and

Cultural Heritage and RS Appendix 7.1.

Predicted Significant Effects on Valued Landscape

10.180 No significant, adverse landscape and visual effects are predicted to arise on valued landscapes

in the Study Area as a result of the Revised Scheme. The worst case potential effect of the


December 2015

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proposal on the high sensitivity Cotswolds AONB landscape is assessed as low magnitude, causing

an indirect and moderate/minor level effect, extending up to approximately 5km from the Site.

Due to the sensitive design layout, form and appearance of the Revised Scheme, there will be no

significant adverse effect on either the setting or the special qualities of the Cotswolds AONB,

including the ‘escarpment’, the ‘high wold’ and ‘tranquillity’ aspects of the designated area.

Registered Parks and Gardens in the Study Area will be unaffected by the Revised Scheme.

Summary of Significant Effects on Landscape Resource

10.181 The Revised Scheme will transform the Development Footprint from its current agricultural land

use to a sensitively designed, landmark stadium building set in ‘parkland’ grounds incorporating

sports pitches, access roads, car parking areas and open spaces/ new planting, all planned and

constructed to the highest sustainability specification.

10.182 This change will have a significant adverse effect on part of the Site’s landscape fabric initially

during construction and the first year of operation, including short stretches of PRoW EEA 37

and EEA 38. However, these direct effects on the landscape fabric will be short to medium term,

reducing overtime during operation to become not significant in the longer term (Year 15 and

beyond).

10.183 The transformation of the Development Footprint will significantly change the character of both

the Development Footprint itself, and the immediate surroundings up to a distance of

approximately 250m from its boundary, where uninterrupted visibility of the proposal exists.

Although the level of adverse effect will reduce over time as the proposed embedded mitigation

and enhancement matures, and notwithstanding the positive attributes of the landmark stadium

and its ‘parkland’ setting, a significant adverse residual effect is predicted on the character of

the Development Footprint and immediately adjacent landscape up to approximately 250m

which will remain in the longer term.

10.184 No significant adverse landscape effects are predicted to arise on valued / designated

landscapes in the Study Area as a result of the Revised Scheme. There will be no significant effect

on the character or special qualities of Cotswolds AONB including its prominent escarpment.

Other valued landscapes in the Study Area, including Registered Parks and Gardens, will be

unaffected by the Revised Scheme.

10.185 Overall, the extent of likely significant adverse character effects will be limited and the

remainder Stroud District’s landscape will not be affected to any significant degree and will be

largely unaffected by the Revised Scheme.

10.186 Furthermore, although it is assumed in this LVIA that people will perceive the change as negative,

bearing in mind the European Landscape Convention definition of landscape quoted above, and

the nature of the Revised Scheme, it is reasonably likely that many will perceive it in a neutral or

even a positive way.

10.187 A summary of significant adverse landscape effects predicted to arise during construction and

operation as a result of implementing the Revised Scheme is set out in Table 10.6 below.

Significant landscape effects are highlighted in bold

Table 10.6: Summary of Significant Effects on Landscape Resource


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Effect Recept

or

Sensiti

vity

Magnitude

of Residual

Effect

Level of

Landscape

Effect on

Completion

(Year 1)*

Significant

or not?

Level of

Residual

Landscape

Effect (Year

15)*

Significant

or not?

Effect on

landscape

character

Escarpm

ent

Footslo

pes

(Stroud

No 5A)

Medium

to High

High within

250m of

Developme

nt Footprint

(Medium /

Low or Less

beyond

250m)

Major to Major

/ Moderate

within 250m of

Development

Footprint

(Moderate to

Moderate /

Minor or lower

beyond 250m)

Significant

within

250m

(Not

significant

beyond

250m)

Moderate /

Major within

250m of

Development

Footprint

(Moderate /

Minor or

lower beyond

250m)

Significant

within

250m

(Not

significant

beyond

250m)

Effect on

landscape

character

Lowland

Plain

(Stroud

No 5B)

Medium High

within

250m of

Developme

nt Footprint

(Medium /

Low or less

beyond

250m)

Major /

Moderate

within 250m of

Development

Footprint

(Moderate /

Minor or lower

beyond 250m)

Significant

within

250m

(Not

significant

beyond

250m)

Moderate to

Moderate /

Major within

250m of

Development

Footprint

(Minor /

moderate or

lower beyond

250m)

Significant

within

250m

(Not

significant

beyond

250m)

Effect on

landscape

character

LCT SV6

Settled

Unwood

ed Vale

(Glos),

LCA

SV6A

Vale of

Berkeley

Medium High up to

250m of

Developme

nt Footprint

Medium /

Low beyond

250m

Major /

Moderate

up to 250m of

Development

Footprint

Moderate /

Minor or less

beyond 250m

Significant

within

250m

(Not

significant

beyond

250m)

Moderate /

Major within

250m of

Development

Footprint

(Minor /

moderate or

lower beyond

250m)

Significant

within

250m

(Not

significant

beyond

250m)

* the 250m distance threshold for significant character effects is approximate and will vary

depending on visibility of the proposal on the ground.

Visual Resource

10.188 Predicted significant adverse effects in relation to the visual resource, as set out in the baseline

assessment section, are assessed below. Non-significant visual effects are described in RS

Appendix 10.8.

Scope of Visual Assessment

10.189 The visual assessment concerns the effect of the Revised Scheme on views and visual amenity

experienced by people in the following receptor groups, which are assessed below with

reference to RS Figures 10.1 to 10.7.

• Residential properties within 0.5km;

• Small to medium sized settlements within 2km (medium to large settlements within 5km);

• National recreational trails and cycle routes within 10km;


December 2015

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• Public rights of way within 2km;

• Public highways within 10km;

• Places of interest with public access within 10km;

• Publicly accessible land within 10km.

10.190 In addition, to assist in the visual (and landscape) assessment, the previously agreed88

representative viewpoints have been photographed in summer and winter as presented in RS

Figure 10.13 and visualisations prepared for an agreed selection of these viewpoints in RS Figure

10.14 Enhanced Wireframe Visualisations.

Assessment of Effect on Visual Resource

10.191 An assessment of the potential effect on representative viewpoints and key sensitive visual

receptors (including settlement and residential properties surrounding the Site) lying within the

ZTV of the Revised Scheme is provided at RS Appendix 10.4 Visual Assessment Schedules. The

level residual visual effect is judged by assessing the magnitude of change to visual amenity

against the sensitivity of the receptor (the latter being a product of its value and susceptibility to

visual change of the type proposed). The visualisations provided at RS Figure 10.14 are a useful

aid to visual assessment. A summary of this assessment identifying the predicted significant

effects on the visual resource is set out below.

Summary of Effects on Viewpoints

10.192 A summary of likely residual effects of the Revised Scheme on the representative viewpoints

previously agreed with consultees and SDC during pre-application and post-application

consultations relating to the original submission is set out in Table 10.7 below. Significant visual

effects are highlighted in bold.

Table 10.7: Assessment of Representative Viewpoints

Viewpoint Distance

from Site*

(Stadium)

Visual

Receptor

(and

Sensitivity)

Magnitude

of Visual

Effect

Level of

Adverse

Effect

(Year 1)

Significant

or not?

Level of

Adverse

Residual

Effect (Yr

15)

Significant

or not?

1. A419 at

M5

Junction

13

0m W

(144)

Road users

(Low)

Medium to

Low

Minor /

Moderate

Not

Significant

Minor Not

Significant

2.

Footpath

at

Westfield

Bridge

(EEA 41)

0m S

(489)

PRoW

users (High)

Low Moderate /

Minor

Not

Significant

Moderate /

Minor

Not

Significant

3.

Footpath

east of

Westend

(EEA 22)

99m NE

(224)

PRoW

users and

residents

(High)

Low Moderate /

Minor

Not

Significant

Minor /

Moderate

Not

Significant

4. A419 at

Chipmans

0m SE Road users

(Low)

Medium to

Low

Minor /

Moderate

Not

Significant

Minor Not

Significant

88 previously agreed with Natural England, the Cotswolds AONB Conservation Board and SDC during pre-application

and post-application consultations relating to the original submission.


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Viewpoint Distance

from Site*

(Stadium)

Visual

Receptor

(and

Sensitivity)

Magnitude

of Visual

Effect

Level of

Adverse

Effect

(Year 1)

Significant

or not?

Level of

Adverse

Residual

Effect (Yr

15)

Significant

or not?

Platt

roundabo

ut

(568)

5.

Thames

and

Severn

Way east

of M5

(Also

Footpath

EEA 46)

180mSW

(631)

PRoW

users (High)

Low to

Negligible

Minor /

Moderate

Not

Significant

Minor /

Moderate

Not

Significant

6.

Footpath

West of

Nupend

337m ENE

(581)

PRoW

users and

residents

(High)

Medium to

Low

Moderate Not

Significant

Moderate to

Moderate /

Minor

Not

Significant

7. Grove

Lane M5

over

bridge

213m N

(424)

Road users

and NCR

cyclists

(Low and

Medium)

Medium to

High

Moderate /

Major

Significant

Moderate to

Moderate /

Major

(Adverse

and

Beneficial)

Significant

8.

Footpath

north of

Eastingto

n (EEA

51)

660m

SSW

(1,126)

PRoW

users and

residents

(high)

Low Moderate /

Minor

Not

Significant

Moderate /

Minor

Not

Significant

9. Maiden

Hill

(Cotswold

Way)

3,885m E

(4,171)

PRoW

(High)

Low Moderate /

Minor

Not

Significant

Minor /

Moderate

Not

Significant

10.

Haresfield

Hill

(Cotswold

Way)

4,699m

ENE

(4,886)

PRoW,

national

trust and

open

access land

users (High)

Low Moderate /

Minor

Not

Significant

Minor /

Moderate

Not

Significant

11. Selsey

Common

(Cotswold

Way)

5,296m

SE

(5,837)

PRoW and

common

land / open

access land

users (High)

Low to

Negligible

Minor /

Moderate

Not

Significant

Minor Not

Significant

12. Cam

Long

Down

(Cotswold

Way)

6,698m S

(7,216)

PRoW and

open

access land

users (High)

Negligible Minor Not

Significant

Minor Not

Significant

13. A38 at

Claypits

917m SW

(1,509)

Road users

and

residents

(Low and

High

respectively

)

Low for

property

Low to

Negligible

for road

users

Moderate /

Minor for

property

Minor /

Negligible

for road

users

Not

Significant

Minor /

Moderate for

property

Negligible

for road

users

Not

Significant


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Viewpoint Distance

from Site*

(Stadium)

Visual

Receptor

(and

Sensitivity)

Magnitude

of Visual

Effect

Level of

Adverse

Effect

(Year 1)

Significant

or not?

Level of

Adverse

Residual

Effect (Yr

15)

Significant

or not?

14. A38 /

Thames

and

Severn

Way

intersecti

on

425m

WNW

(1,035)

Road,

PRoW

users and

residents

(Low and

High

respectively

)

Negligible Minor for

property /

PRoW

Negligible

for road

users

Not

Significant

Minor for

property /

PRoW

Negligible

for road

users

Not

Significant

15.

Footpath

at

Doverow

Hill (MST

30)

2,927m

ESE

(3,377)

PRoW

users (High)

Low Moderate /

Minor

Not

Significant

Minor /

Moderate

Not

Significant

16.

Footpath

west of

West End

Cross

(EEA 38)

0m E

(293)

PRoW users (High)

Medium to

High

Major /

Moderate

Significant Moderate /

Major

(Adverse &

Beneficial)

Significant

A. St

Micheal

and

Angels

Church

420m SSE

(942)

Historic Asset Grade

II*

(High)


Significant

Minor Not

Significant

D. A38

Whitminst

er Ridge

930m

NNW

(1,140)

Road Users (Low)

Low to

Negligible

Minor /

Negligible

Not

Significant

Minor /

Negligible

Not

Significant

E. Barrow

Hill

5,800m

NW

(5,926)

PRoW Users (High)

Low to

Negligible

Minor /

Moderate

Not

Significant

Minor Not

Significant

F. Little

Dean,

Forest of

Dean

12,000m

NW

(12,124)

PRoW Users

(High)


Significant

Minor Not

Significant

G. Field

Lane,

Cam

7,300m

SSW

(7,772)

Road Users / Nearby PRoW

(High)


Significant

Minor Not

Significant

H.

Frocester

Hill

4,60km

SSE

(5,083)

PRoW Low to

Negligible

Minor /

Moderate

Not

Significant

Minor Not

Significant

*distance in metres from Redline Boundary (and Stadium in brackets)

10.193 Those viewpoints which have been identified as significant are significant because they are

sensitive receptors located on, or close to, the Site. They are therefore predicted to experience

medium to high or high magnitude of visual change due to their proximity to, and relatively

unobstructed visibility of, the Revised Scheme.


December 2015

Page | 206

Summary of Significant Effects on Visual Resource

10.194 Residents of a small number of residential properties located adjacent to the Site, and people

using several short lengths of PRoW (both high sensitivity visual receptors) and public highway

in the vicinity of the Site, are predicted to be significantly affected visually as a result of

implementing the Revised Scheme, both during construction and early operation (Year 1) of the

development. However, adverse visual effects will be ameliorated by the embedded mitigation

including new planting which will reduce adverse effects and increase beneficial effects in the

longer term (Year 15 and beyond).

10.195 Moderate/Major to Major levels of significant adverse residual visual effects are predicted in

relation to short stretches of Eastington Footpath Nos 37 and 38 crossing the Development

Footprint, and public highway immediately adjacent to the Site, namely the A419, the M5

motorway and Grove Lane M5 overbridge. This level of effect would result from medium to

high magnitudes of visual change occurring initially at these high sensitivity receptors, reducing

to medium magnitude over time as the proposed embedded mitigation becomes established

over time.

10.196 The visual amenity of three dwellings adjacent to the Site, namely Westend House, Ivy Cottage

and Mole Cottage will experience major/moderate, direct adverse visual effects initially during

construction, reducing during operation to become moderate level and not significant in the

longer term. This level of effect would result from medium to high magnitudes of visual change

occurring initially at these high sensitivity receptors, reducing to low to medium magnitude over

time as the proposed landscape buffer / new planting matures. The predicted initial significant

visual effects are due to the visibility of the Revised Scheme (or part of, including the landscape

works) at close range from these receptors.

10.197 Other properties and settlements surrounding the Site and further afield, for example Westend,

Nupend, Chipmans Platt, Eastington and Claypits, and the remainder of the public highway and

PRoW network in the Study Area, including Eastington Footpath No.46 (Thames and Severn Way)

and Eastington Footpath No. 41 (near Westfield Bridge), will be affected visually to a moderate

or lesser degree, which is not significant in the EIA context.

10.198 No other visual receptors surrounding the Site are predicted to be affected to any significant

degree and the majority of receptors and people in the wider Study Area will be relatively

unaffected by the Revised Scheme. No significant visual effects are predicted to arise on the

Cotswold Way or any publicly accessible land such as commons, access land, National Trust

property, country parks and village greens.

10.199 A summary of likely significant effects of the Revised Scheme on the visual resource of the Site

and surrounding area is provided below in Table 10.8 based on the assessment describing the

magnitude of visual change and sensitivity of receptor provided at RS Appendix 10.4. It should

be noted that all visual receptors are assessed as high sensitivity except public highways which

are classified as low unless stated otherwise. A summary all visual effects (significant and non-

significant) is provided in Table 10.9 at the end of LVIA.

Table 10.8: Summary of Significant Effects on Visual Resource


December 2015

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Effect Receptor Distanc

e (m)*

Sensiti

vity

Magnitu

de of

Visual

Effect

Level of

Adverse

Effect at

Year 1

Significant

or not?

Level of

Adverse

Residual

Effect (Yr

15)

Significant

or not?

Effect on

views

and

visual

amenity

Westend

House

11

(219)

High Medium Moderat

e / Major

Significant Moderate Not

Significant

Effect on

views

and

visual

amenity

Mole

Cottage

19

(97)

High Medium Moderat

e / Major


Significant

Effect on

views

and

visual

amenity

Ivy

Cottage

18

(133)

High Medium Moderat

e / Major


Significant

Effect on

views

and

visual

amenity

PRoW

Eastingto

n

Footpath

No.37

On-site High High Major Significant Major/

Moderate

Significant

Effect on

views

and

visual

amenity

PRoW

Eastingto

n

Footpath

No.38

On-site High High Major Significant Major /

Moderate

Significant

Effect on

views

and

visual

amenity

M5 10

(100)

Low High for

approx.

250m

Low

overall

Moderat

e / Major

for

approx.

250m

north of

J13

Minor

overall

Significant

for

approx.

250m

Not

significant

overall

Moderate

to

Moderate

/ Major for

approx.

250m

north of

J13

Minor

overall

Significant

for

approx.

250m

Not

significant

overall

Effect on

views

and

visual

amenity

A419 0

(100)

Low High

between

Chipman

s Platt &

J13

Low

overall

Moderat

e / Major

between

Chipman

s Platt &

J13

Minor

overall

Significant

between

Chipmans

Platt & J13

Not

significant

overall

Moderate

to

Moderate

/ Major

between

Chipman’s

Platt & J13

Significant

between

Chipmans

Platt & J13

Not

significant

overall


December 2015

Page | 208

Effect Receptor Distanc

e (m)*

Sensiti

vity

Magnitu

de of

Visual

Effect

Level of

Adverse

Effect at

Year 1

Significant

or not?

Level of

Adverse

Residual

Effect (Yr

15)

Significant

or not?

Minor

overall

* approximate distance from Redline Boundary (distance to Stadium in brackets)

Commentary on night time effects

10.200 The Revised Scheme will introduce some new lighting into the area adjacent to the A419 between

the M5 J13 and the existing / planned development including WOS on the ‘fringe’ of Stonehouse.

This will extend the existing pattern of lighting along the A419 corridor as far as the M5.

10.201 Within the Revised Scheme area there will be variable levels of lighting associated with the new

stadium building and a new lit section of the A419 and M5 J13, in addition to the lowest practical

level of lighting required for parking and access. The latter will include use of lighting in the car

parking area only when in use, with parking unlit when not required. No lighting is proposed for

the practice pitches.

10.202 The lit elements will be set within the proposed framework of retained vegetation and newly

planted green spaces (refer RS Appendix 5.1 Revised Indicative Concept Plan, RS Figure 1.1

Indicative Concept Plan and RS Figure 5.3 Indicative Green Infrastructure Parameter Plan)

which will break up the light sources to create a mosaic of lighter and darker areas including dark

corridors for nature conservation.

10.203 The development as a whole is predicted to cause a localised increase in illumination in the

evening on match nights in winter months experienced in the context of existing / planned

development in the surrounding area including WOS. Lighting associated with the Revised

Scheme will be most readily perceptible in close / localised views – particularly in the vicinity of

Westend, Chipmans Platt and Nupend (western edge). The proposed bunds / screen planting

incorporating ‘dark bat corridors’ will limit both visual and light intrusion / spillage at adjacent

properties, such as those at Westend, and other visual receptors. More detail is provided in

Chapter 14 Lighting which assesses the ‘worst case scenario’ luminous intensity on neighbouring

properties as negligible and light intrusion (spill) as minor adverse. The latter is also below

industry guidelines, prior to the consideration and application of further mitigation measures. In

addition, building lighting will be switched off at night and accompanying sensitive design

measures will further control and minimise potential light pollution. These matters can be

secured by means of appropriate planning conditions.

10.204 Regarding the wider Study Area and medium to long range views, the predicted lighting effects

will relate to visibility of light sources and ‘sky glow’ as described in Chapter 14. Lighting

associated with all aspects of Revised Scheme will be seen in the context of existing lighting in

the surrounding area, as identified above and shown in RS Figures 10.10 (a-c) and RS Figure

10.13. From the AONB the most notable source of new light will be the occasional floodlighting

of the stadium. However, the use of floodlighting will be limited and only needed on certain


December 2015

Page | 209

evenings. All lighting will utilise downwards / directional lighting to minimise spill and light

pollution.

10.205 Commentary regarding the potential effect on landscape character at night time is provided in

RS Appendix 10.2 where the localised increase in illumination predicted in Chapter 14 is assessed

in the context of existing lighting sources described above and shown on RS Figures 10.10(a-c).

As a separate topic, a commentary on the cumulative landscape effects of lighting, particularly

in relation to the WOS development, is provided below, and in RS Appendix 10.5 Cumulative

Assessment Schedules.

10.206 Overall, whilst the Revised Scheme will introduce new forms of lighting visible from the

surrounding area, including from parts of the Cotswold AONB escarpment and foothills, it will be

viewed in the context of the relatively high levels of existing background lighting. These include

Stonehouse (and in the near future the now consented WOS), the M5, as well as a variety of

other significant local light sources. In addition, the Revised Scheme will be seen beyond existing

sources of significant lighting such as Dairy Crest (refer RS Figure 10.10c). The existing night time

environment is illustrated in RS Figure 10.13– see Viewpoint 9 Cotswold Way at Maiden Hill for

a representative view of the current night time environment and context of the Site as

experienced from one of the closest, elevated parts of the Cotswolds AONB. Further information

on lighting in respect to the Cotswolds AONB is also provided at RS Appendix 10.6 Cotswolds

AONB Position Statements.

10.207 It is important to note, as the night time photograph from Viewpoint 9 illustrates, that the

Revised Scheme lighting will be experienced in the context of the existing pattern of lit

development and transport corridors (refer RS Figure 10.10 (a-b)). It will avoid impinging on the

darker areas surrounding the Site and in the wider Study Area, helping to keep them free from

light pollution, including the fringes of the AONB as well as within the designated area itself.

Cumulative Effects

Introduction

10.208 The Cumulative Landscape and Visual Impact Assessment (CLVIA) deals with the potential

‘additional’ effect on the landscape and visual resource of the Study Area attributable to the

Revised Scheme when considered in combination with other existing and proposed

developments of a similar type and scale. Cumulative effects are understood to be the additional

effects which arise over and above those which are likely to result from the Revised Scheme

considered on its own.


10.209 The CLVIA considers significant existing and planned development (i.e. validated planning

applications and schemes at appeal) in the Study Area – the cumulative schemes. Also included

is the CCT Phase1b Proposals for restoration of the Stroudwater Canal, currently at the pre-

planning stage (refer RS Figure 18.1 Cumulative Schemes No.9 ‘Indicative Canal Realignment’).

10.210 Ten cumulative schemes situated in the Study Area which have the potential to cause cumulative

landscape and visual effects are included in the cumulative assessment as listed in Chapter 2,

Table 2.5. Cumulative effects generally are described in Chapter 18 Cumulative Effects which


December 2015

Page | 210

includes RS Figure 18.1 showing the location of the cumulative schemes in the Study Area. More

information on the distribution of cumulative schemes is provided in RS Appendix 10.9a Extract

of Stroud District Local Plan 2015 Proposals Map – Map 1.

Approach to Cumulative Assessment

10.211 The CLVIA identifies the ‘combined’ and ‘sequential’ effect of the Revised Scheme in conjunction

with the cumulative schemes and describes a) the potential cumulative landscape character

effects for individual character units relating to the various levels of LCA; and b) the potential

cumulative effects on views and visual amenity assessed from the representative viewpoints. The

likely cumulative effects arising during the construction and operational phases are considered,

with a distinction made between the effects at Year 1 of operation and Year 15 following

establishment and maturing of the proposed landscape mitigation – the residual cumulative

effect.

10.212 The mitigation measures that have been embedded into the design in order to avoid, reduce and

/ or offset potentially significant adverse landscape and visual effects, including cumulative

effects, include landscape works described in RS Appendix 10.7 and RS Figures 10.11c and

10.11d. These landscape measures, for example the proposed planted bund separating the

development from Westend / Grove Lane, will take time to establish and mature. Therefore, as

a rule of thumb, it is assumed that the proposed embedded landscape mitigation will not become

fully effective until Year 15 of operation, the point at which residual effects are predicted.

10.213 The methodology used to carry out the CLVIA is based on current guidance contained in GLVIA3,

informed by professional experience and judgement, as set out in RS Appendix 10.1. The CLVIA

is structured as follows:

• Cumulative Landscape Effects;

• Cumulative Visual Effects.

10.214 The following figures are provided in Volume 2 in support of the CLVIA:

• RS Figure 10.12a Cumulative Schemes and Landscape Character (SDC and National);

• RS Figure 10.12b Cumulative Schemes and Landscape Character (Gloucestershire and

Cotswolds AONB);

• RS Figure 10.12c Cumulative Schemes and Viewpoint Location with Revised Scheme ZTV.

10.215 A full assessment of cumulative effects is presented in RS Appendix 10.5 Cumulative Assessment

Schedules.

10.216 A summary of the significant adverse cumulative effects likely to arise during construction and

operation of the Revised Scheme, as set out below.

Cumulative Effects on Landscape

10.217 There will be no significant (and negligible non-significant) additional cumulative effects on the

landscape fabric of the Site, either during construction or operation.


December 2015

Page | 211

Regarding landscape character the West of Stonehouse (WOS) and Pike Lock cumulative schemes

have potential to generate significant adverse cumulative effects in conjunction with the Revised

Scheme due to their proximity to the Development Footprint. The other cumulative schemes

including Javelin Park, Bond's Mill Unit 27, Former Standish and Westridge Hospital Standish, and

Land Adjoining Station Road are located too far away from the Site to cause significant adverse

cumulative landscape effects. Westend Courtyard is of a type and scale, and configured in such

a way, so as to prevent adverse cumulative landscape effects from arising in conjunction with

the Revised Scheme. A full cumulative assessment is provided in RS Appendix 10.5.

10.218 The WOS scheme is a large scale mixed development (housing and employment) proposed on

land north of the A419 in the vicinity of Nastend, situated between Stonehouse and Chipmans

Platt. The employment uses will be located adjacent to Stonehouse (Oldends) and the mainline

railway whilst housing, open space and recreation uses will occupy the remainder of the WOS

site as far Chipmans Platt, Grove Lane and Westend. Pike Lock is a proposed three storey hotel

and restaurant development located east of Chipmans Platt roundabout, south of the A419.

10.219 The Revised Scheme on its own is predicted to significantly change the character of the

Development Footprint and immediate adjacent landscape falling within SDC’s LCT5 Rolling

Agricultural Plain (incorporating the LCT5a Escarpment Footslopes to the north, and LCT5b

Lowland Plain to the south), up to a distance of approximately 250m from the Development

Footprint, where uninterrupted views of the proposal exist.

10.220 It is anticipated that, when completed, the WOS development will have a similar to slightly

greater sphere of influence locally character wise (250-500m). A significant, moderate to

moderate / major, adverse residual cumulative effect on landscape character attributable to

the proposal is predicted in conjunction with WOS and Pike Lock within approximately 500m

of the Development Footprint, occurring in the Grove Lane area between Chipmans Platt and

Westend. This will be the result of a medium to high magnitude of cumulative landscape effect

during construction on the medium to high sensitivity Escarpment Footslopes (LCT5a), as shown

in RS Figure 10.8b, reducing to medium magnitude in the longer term (Year 15).

10.221 Regarding the medium sensitivity Lowland Plain (LCT5b), as the proposed landscape mitigation

establishes and matures during operation, the initial significant adverse cumulative effect arising

in combination with WOS will reduce to moderate and become a not significant adverse residual

effect by Year 15. The same level of not significant residual cumulative landscape effect would

apply in respect of SV6A Vale of Berkeley (Gloucestershire Landscape Assessment 2006). It

should be noted that the predicted significant cumulative landscape effects will be localised and

limited.

10.222 A broadly similar extent and levels (or slightly lower) of adverse cumulative landscape character

effect will apply in respect of the corresponding SALA landscape units (low / medium, medium

and high / medium sensitivity), both on and adjacent to the Site (Development Footprint), as

shown on RS Figure 10.8a. It is important to also consult RS Figure 10.5d which is provided to

help understand the relationship between the various levels of LCA, from the local IHCA and SDC

LCAs through to the national level NCAs.

Cumulative Effects on Visual Amenity


December 2015

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10.223 Significant adverse cumulative visual effects are predicted to arise during construction and

Year 1 of operation of the Revised Scheme, in conjunction with the WOS and Pike Lock

cumulative schemes, in the vicinity of Grove Lane / Westend / Chipmans Platt, up to a distance

of approximately 500m from the Development Footprint. These effects will result from a medium

magnitude of visual change when the Revised Scheme is visible in combination or sequentially

with WOS and Pike Lock from certain medium and high sensitivity visual receptors within

approximately 500m of the Site, for example PRoW EEA23 in the vicinity of Westend / Nupend

where moderate / major sequential cumulative visual effects are predicted as recorded in

relation to Viewpoint 6 at RS Appendix 10.5.

10.224 Localised, moderate / major, significant adverse cumulative visual effects are also likely to be

experienced by users of footpaths north of Eastington (see Viewpoint 8) during construction.

This temporary, short term effects would be attributable mainly to the proximity and strong

visual presence of the Land adjacent to Eastington Trading Estate and the proposed Stroudwater

Indicative Canal Realignment cumulative schemes, seen in conjunction with the Revised Scheme,

WOS and Pike Lock.

10.225 Upon commencement of operation, the embedded landscape mitigation having been

implemented, levels of adverse cumulative effects on views and visual amenity occurring

initially during construction (in combination and sequentially) in conjunction with the various

cumulative schemes (particularly WOS and Pike Lock) will be moderate or less and not

significant in the medium to longer term. No additional, significant adverse cumulative visual

effects are predicted elsewhere in the Study Area attributable to the Revised Scheme when

considered in combination with the other cumulative schemes listed in RS Figure 18.1, for

instance at the representative viewpoints shown on RS Figure 10.12c.

10.226 Other cumulative schemes such as Javelin Park, Bond's Mill Unit 27, Former Standish and

Westridge Hospital Standish, and Land Adjoining Station Road and are located too far away from

the Site to give rise to significant adverse cumulative visual effects, or are of such type and scale

and / or configured in such a way (for instance Westend Courtyard) so as to prevent or minimise

adverse cumulative visual effects.

Conclusion on Residual Cumulative Effects

10.227 Significant additional, adverse cumulative landscape and visual effects attributable to the

Revised Scheme are predicted to arise during construction up to Year 1 of operation within

approximately 0.5km of the Development Footprint in the general vicinity of Grove Lane from

Westend to Chipmans Platt. These short term, additional cumulative effects will result from the

combined and sequential visibility of the proposal in conjunction with WOS and Pike Lock

cumulative schemes.

10.228 The adverse cumulative effects will reduce over time as the proposed landscape mitigation

establishes and matures. Significant additional, adverse residual cumulative landscape

character effects are predicted to remain during operation with respect to a small area of the

Escarpment Footslopes (LCT5a) on and adjacent to the Development Footprint. However, other

cumulative landscape and visual effects predicted to be significant during construction will be

not significant during operation in the medium to long term.


December 2015

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10.229 Adverse cumulative effects potentially arising across the wider Study Area potentially arising in

conjunction with these and other cumulative schemes assessed and shown in RS Figure 18.1 are

predicted to be not significant.

Overall Conclusions

10.230 The Revised Scheme is predicted to have a significant adverse effect during construction and

operation on a small area of landscape and a limited number of visual receptors located on

and/ or immediately surrounding the Site within approximately 250m (up to 500m for

cumulative landscape effects) of the Development Footprint. Receptors predicted to be so

affected in the longer term comprise primarily a small portion of the Rolling Agricultural Plain

(LCT5 incorporating LCT5a Escarpment Footslopes and LCT5b Lowland Plain), onsite footpaths

EEA 37 and 38, and short stretches of the A419 and M5 (including Grove Lane overbridge)

adjacent the Development Footprint.

10.231 Due to the sensitive siting and design of the Revised Scheme the predicted residual significant

adverse residual effects will be localised and will not attain levels that might compromise local

landscape character or visual amenity, or prevent local residents and the public from enjoying

the landscape and visual environment. In addition, adverse effects will be ameliorated over time

as the proposed embedded landscape mitigation matures and the Revised Scheme becomes

assimilated into the landscape.

10.232 The new stadium will be placed within a sensitively designed ‘parkland’ setting so that local

landscape character and visual amenity is preserved as far as possible and potentially enhanced

in the longer term. The Revised Scheme has been rigorously designed and configured to ensure

that none of the significant adverse visual effects predicted to occur initially in relation to

residential amenity can be reasonably judged as unacceptable in terms of the public interest test.

No significant adverse effects are predicted to arise on the Cotswolds AONB and its setting, or

the Cotswold Way. In addition, the Thames and Severn Way will not be subject to any significant

residual adverse effects.

10.233 It is important not to overlook the care that has been taken in the design of the Revised Scheme

in order to respect the existing landscape and visual context. The design objective has been to

create an exciting stadium building set in attractive grounds that will provide a positive landscape

experience for visitors and passers-by, whilst at the same time integrating as seamlessly as

possible into its rural surroundings. This design rationale is central to the landscape mitigation

embedded within the Revised Scheme. The intention is to present the new stadium as a

memorable landmark feature in a ‘parkland’ setting at a ‘gateway’ location in a way that avoids

and minimises adverse effects as far as possible, while maximising the longer term benefit it

offers to Stroud District’s landscape and visual environment.


December 2015

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Table 10.9: Summary of Landscape and Visual Effects and Mitigation

*Significant effects are highlighted in bold.

** Predicted effects are assessed as adverse (negative) unless stated otherwise, for example where they will be beneficial (positive), or both adverse

and beneficial, for instance in cases where embedded mitigation (such as new planting) increasingly provides landscape and visual benefit over time.

Development Phase

O = Operational C = Construction

Nature of Effects

Short Term = S/T Medium Term = M/T Long term = L/T

Permanent = P Temporary = T

Direct = D Indirect = I


(Construction /

Operation)

Sensitivity of

Receptor

Magnitude of

Change (Year

1)

Level of

Adverse Effect

and

Significance* in

Year 1,

including

embedded

mitigation

Mitigation

(Embedded)

Enhancement Level of

Residual

Adverse

Effect** (and

Significance) in

Year 15 with

embedded

mitigation

Nature of effect

(short, medium

or long term;

permanent or

temporary;

direct and / or

indirect)

Landscape Effects

Site Landscape

Fabric

(Landform)

Physical effects

on landscape

fabric

C & O Low to Medium Low / Medium Minor /

Moderate

See RS Figure

5.6 and TBC Site

Levels.

See RS Figure

5.6 and TBC Site

Levels.

Minor /

Moderate

L/T, P, D

Site Landscape

Fabric

(Vegetation &

Boundary

Features)

Physical effects

on landscape

fabric

C & O Low to Medium Medium / High Moderate /

Major to

Moderate

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendix 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendix 10.7.

Moderate /

Minor to Minor

/ moderate

(Not Significant)

S/T, M/T & L/T,

P & T, D

Site Landscape

Fabric (Built

structures -

Barns)

Physical effects

on landscape

fabric

C & O Low None None N/A N/A N/A N/A


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Site Landscape

Fabric (Built

Structures –

Westfield

Bridge)

Physical effects

on landscape

fabric

C & O High None None N/A N/A N/A N/A

Site Landscape

Fabric (PRoW)

Physical effects

on landscape

fabric

C & O High Medium / High Major /

Moderate

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendix 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendix 10.7.

Moderate

(Not Significant)

S/T & L/T, P & T,

D

NCA 106:

Severn and

Avon Vales

Effect on

landscape

character /

value

C & O Medium Negligible Minor /

Negligible

See RS Appendix

10.3

See RS Appendix

10.3

Minor /

Negligible

S/T & L/T, P &

T, D & I

NCA 107:

Cotswolds

Effect on

landscape

character /

value

C & O Medium to High Negligible Minor to Minor

/ Negligible

See RS Appendix

10.3

See RS Appendix

10.3

Minor /

Negligible

S/T & L/T, P &

T, I

LCT SV6 Settled

Unwooded

Vale, LCA SV6A

Vale of Berkeley

Effect on

landscape

character /

value

C & O Medium High up to

250m from

Development

Footprint

Medium / Low

beyond 250m

Major /

Moderate

up to

approximately

250m from

Development

Footprint

Moderate /

Minor or less

beyond 250m

(Significant

within 250m)

See RS Appendix

10.3

See RS Appendix

10.3

Moderate /

Major up to

Approximately

250m from

Development

Footprint

Minor /

Moderate or

less beyond

250m

(Significant

within 250m)

S/T & L/T, P & T,

D & I

LCT SV2 Drained

Riverine

Farmland and

Effect on

landscape


Negligible

N/A N/A Minor /

Negligible

S/T & L/T, P &

T, I


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Grazed Salt

Marsh / LCA

SV2B Slimbridge

and New

Grounds

Marshes

character /

value

LCT SV11 Vale

Hillocks / LCA

SV11A Overton

and Barrow Hill

Effect on

landscape

character /

value


Negligible

N/A N/A Minor /

Negligible

S/T & L/T, P &

T, I

Escarpment

Footslopes

(Stroud No 5A)

Effect on

landscape

character /

value

C & O Medium to High High up to

250m from

Development

Footprint

Medium / Low

beyond 250m

Major /

Moderate to

Major

up to 250m

from

Development

Footprint

Moderate to

Moderate /

Minor

or less beyond

250m

(Significant

within 250m)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7

Moderate /

Major up to

250m from

Development

Footprint

Moderate /

Minor or less

beyond

250m

(Significant

within 250m)

S/T & L/T, P &

T, D & I

Lowland Plain

(Stroud No 5B)

Effect on

landscape

character /

value


250m from

Development

Footprint

Medium /

Low beyond

250m

Major /

Moderate

up to 250m

from

Development

Footprint

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Moderate to

Moderate /

Major up

to 250m from

Development

Footprint

S/T & L/T, P &

T, D & I


December 2015

Page | 217

Moderate /

Minor

or less beyond

250m

(Significant

within 250m)

Minor /

Moderate or

less

beyond

250m

(Significant

within 250m)

Frome River

Valley (Stroud

No 5C)

Effect on

landscape

character / value

C & O Medium to High Negligible within

250m and

elsewhere

Minor to Minor

/ Negligible

within 250m

and elsewhere

See RS Appendix

10.3

See RS Appendix

10.3

Minor to Minor /

Negligible within

250m and

elsewhere

S/T & L/T, P & T,

I

Wold Tops

(Stroud No. 1)

Effect on

landscape

character /

value

C & O High Negligible Minor N/A N/A Minor S/T & L/T, P & T,

I

Secluded

Valleys (Stroud

No. 3)

Effect on

landscape

character /

value


I

Escarpment

(Stroud No. 4)

Effect on

landscape

character /

value

C & O High Low Moderate /

Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

I

Severn Vale

Grazing

Marshes

(Stroud No.8)

Effect on

landscape

character /

value


Negligible

N/A N/A Minor /

Negligible

S/T & L/T, P & T,

I

Severn Vale

Hillocks (Stroud

No.7)

Effect on

landscape

character /

value


Negligible

N/A N/A Minor /

Negligible

S/T & L/T, P &

T, I


December 2015

Page | 218

Escarpment

Outlier / Cam

Longdown,

Peaked Down

and Downham

Hill (Cotswolds

No.1A).

Effect on

landscape

character /

value

C & O High Negligible Minor See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor S/T & L/T, P & T,

I

Escarpment /

Uley to Coopers

Hill (Cotswolds

No. 2C)

Effect on

landscape

character /

value


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

I

Rolling Hills and

Valleys /

Stinchcombe

and North

Nibley

(Cotswolds

No.3B).

Effect on

landscape

character /

value


I

High Wold /

Nympsfield and

Kingscote

Plateau

&Minchinhamp

ton Common.

Rodborough

and Amberley

Common

(Cotswolds No.

7A)

Effect on

landscape

character /

value


5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.


I

Settled

Unwooded Vale

/ Vale of

Gloucester

Fringe

(Cotswolds

No.18A)

Effect on

landscape

character /

value


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

I


December 2015

Page | 219

LCT 1

Stroud-water

settlement (Part

1.2)

Effect on

landscape

character /

value

C & O Medium to High Negligible on

western edge

and elsewhere

Minor to Minor

/ Negligible on

western edge

and elsewhere

See RS Appendix

10.3

See RS Appendix

10.3

Minor to Minor

/ Negligible

S/T & L/T, P & T,

I

LCT 4

Green Corridor:

Rural Frome

Vale

(Part 4.4)

Effect on

landscape

character /

value

C & O Medium to High Negligible within

250m and

elsewhere

Minor to Minor

/ Negligible

within 250m

and elsewhere

See RS Appendix

10.3

See RS Appendix

10.3

Minor to Minor

/ Negligible

S/T & L/T, P & T,

I

LCT 7

Meadow Mill

(Part 7.1)

Effect on

landscape

character /

value


/ Negligible

See RS Appendix

10.3

See RS Appendix

10.3

Minor to Minor

/ Negligible

S/T & L/T, P & T,

I

LCT 2

Core Vale

Settlement East

of Eastington

(Part 2.2)

Effect on

landscape

character /

value


/ Negligible

See RS Appendix

10.3

See RS Appendix

10.3

Minor to Minor

/ Negligible

S/T & L/T, P & T,

I

Cotswolds

AONB

Effect on

landscape

character /

value

C & O High Low reducing to

Negligible

Moderate /

Minor reducing

to Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate

reducing to

Minor

S/T & L/T, P & T,

I

Frampton Court

Registered Park

and Gardens

Effect on

landscape

character /

value


I

Visual Effects

Viewpoint 1.

A419 at M5

Junction 13

Effect on views

and visual

amenity

C & O Low Medium to Low Minor /

Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D


December 2015

Page | 220

Viewpoint 2.

Footpath at

Westfield

Bridge

Effect on views

and visual

amenity


Minor

See RS Appendix

10.4

See RS Appendix

10.4

Moderate /

Minor

S/T & L/T, P & T,

D

Viewpoint 3.

Footpath east

of Westend

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

D

Viewpoint 4.

A419 at

Chipmans Platt

roundabout

Effect on views

and visual

amenity

C & O Low Medium to Low Minor /

Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D

5. Viewpoint

Thames and

Severn Way

east of M5

Effect on views

and visual

amenity

C & O High Low / Negligible Minor /

Moderate

See RS Appendix

10.4

See RS Appendix

10.4

Minor /

Moderate

S/T & L/T, P & T,

D

6. Viewpoint

Footpath West

of Nupend

Effect on views

and visual

amenity

C & O High Medium to Low Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate to

Moderate /

Minor

S/T & L/T, P & T,

D

7. Viewpoint

Grove Lane M5

over bridge

Effect on views

and visual

amenity

C & O Medium Medium to High Moderate /

Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate to

Moderate /

Major

(Adverse and

Beneficial)

(Significant)

S/T & L/T, P & T,

D

8. Viewpoint

Footpath north

of Eastington

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate /

Minor

S/T & L/T, P & T,

D


December 2015

Page | 221

9. Viewpoint

Maiden Hill

(Cotswold Way)

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

D

10. Viewpoint

Haresfield Hill

(Cotswold Way)

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

D

11. Viewpoint

Selsey Common

(Cotswold Way)

Effect on views

and visual

amenity

C & O High Low to

Negligible

Minor /

Moderate

See RS Appendix

10.4

N/A Minor S/T & L/T, P & T,

D

12. Viewpoint

Cam Long Down

(Cotswold Way)

Effect on views

and visual

amenity

C & O High Negligible Minor See RS Appendix

10.4


D

13. Viewpoint

A38 at Claypits

Effect on views

and visual

amenity

C & O High for

property

Low for road

users

Low for

property

Negligible for

road users

Moderate /

Minor for

property

Minor /

Negligible for

road users

See RS Appendix

10.4

See RS Appendix

10.4

Minor /

Moderate for

property

Negligible for

road users

S/T & L/T, P & T,

D

14. Viewpoint

A38 / Thames

and Severn Way

intersection

Effect on views

and visual

amenity

C & O High for PRoW

Low for Road

Users

Negligible Minor for

property /

PRoW

Negligible for

road users

N/A N/A Minor for

property /

PRoW

Negligible for

road users

S/T & L/T, P & T,

D

15 Viewpoint

Footpath at

Doverow Hill

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

D

16. Footpath

west of West

Effect on views

and visual

amenity

C & O High High to Medium Major /

Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

See RS Figures

5.3, 10.11c &

10.11d and RS

Moderate /

Major (Adverse

& Beneficial

S/T & L/T, P & T,

D


December 2015

Page | 222

End Cross (EEA

38)

(Significant) Appendices 10.4

& 10.7.

Appendices 10.4

& 10.7.

(Significant)

A. St Micheal

and Angels

Church

Effect on views

and visual

amenity


10.4

See RS Appendix

10.4


D

D. A38

Whitminster

Ridge

Effect on views

and visual

amenity

C & O Low Low / Negligible Minor /

Negligible

See RS Appendix

10.4

See RS Appendix

10.4

Minor /

Negligible

S/T & L/T, P & T,

D

E. Barrow Hill Effect on views

and visual

amenity


Moderate

See RS Appendix

10.4

See RS Appendix

10.4


D

F. Little Dean,

Forest of Dean

Effect on views

and visual

amenity


10.4

See RS Appendix

10.4


D

G. Field Lane,

Cam

Effect on views

and visual

amenity


10.4

See RS Appendix

10.4


D

H. Frocester Hill Effect on views

and visual

amenity


Moderate

See RS Appendix

10.4

See RS Appendix

10.4


D

Residential

Properties (15

Properties)

1-6 Chimans

Platt & William

Morris College

(WMC), The

Old Chapel

House,

Sunnycroft, 1-4

West End

Cottages,

Mulgrove,

Westend Farm

Effect on views

and visual

amenity


Minor

See RS Appendix

10.4

See RS Appendix

10.4

Moderate /

Minor

To Minor /

Moderate

S/T & L/T, P & T,

D


December 2015

Page | 223

Residential

Properties (4

Properties)

Beech House, 1-

2 Cressignton

Cottages,

Whitminster

Court

Effect on views

and visual

amenity


Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

Minor /

Moderate

S/T & L/T, P & T,

D

Residential

Properties (11

Properties)

Bridle Path

Cottage, Rose

Cottage, Half

Acres, Elmcote,

Hill Crest,

Nupend Farm,

Nupend Court,

Sundial,

Nestings,

Rosetree,

Budloe)

Effect on views

and visual

amenity


5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.


D

Residential

Properties (6

Properties)

Yew Tree Villa,

St Loy Cottage,

Paradise, Yew

Tree Cottage,

Effect on views

and visual

amenity

C & O High Medium / Low Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

Moderate to

Moderate /

Minor

S/T & L/T, P & T,

D


December 2015

Page | 224

Grove Farm ,

Oakdene)

Residential

Property

Westend House

Effect on views

and visual

amenity

C & O High Medium Moderate /

Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

Moderate

(Not Significant)

S/T & L/T, P & T,

D

Residential

Properties (2

Properties)

Ivy Cottage,

Mole Cottage

Effect on views

and visual

amenity


Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES

Figure 5.6.

Moderate

(Not Significant)

S/T & L/T, P & T,

D

Fromebridge

Cluster of

properties

Effect on views

and visual

amenity


D

Claypits cluster

of properties

Effect on views

and visual

amenity

C & O High Low for fringe

properties

Low / Negligible

elsewhere

Moderate /

Minor for fringe

properties

Minor /

Moderate

elsewhere

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate for

fringe

properties

Minor

elsewhere

S/T & L/T, P & T,

D

Westend

settlement

Effect on views

and visual

amenity

C & O High Medium to Low

(or less) for

settlement

overall.

Moderate (or

less) for

settlement

overall

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Moderate /

Minor (or less)

for settlement

overall

S/T & L/T, P & T,

D


December 2015

Page | 225

Whitminster

settlement

Effect on views

and visual

amenity


D

Eastington

settlement

Effect on views

and visual

amenity


Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate

S/T & L/T, P & T,

D

Nupend

settlement

Effect on views

and visual

amenity

C & O High Low (or less) for

settlement

overall

Moderate /

Minor (or less)

for settlement

overall

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate (or

less) for

settlement

overall

S/T & L/T, P & T,

D

Nastend

settlement

Effect on views

and visual

amenity


D

Stonehouse

settlement

Effect on views

and visual

amenity


D

Leonard Stanley

settlement

Effect on views

and visual

amenity


D

Kings Stanley

settlement

Effect on views

and visual

amenity


D

Frampton on

Severn

settlement

Effect on views

and visual

amenity


D

Saul settlement Effect on views

and visual

amenity


D

Cotswold Way Effect on views

and visual

amenity

C & O High Negligible

overall

Minor overall

Moderate /

Minor at

See RS Figures

5.3, 10.11c &

10.11d and RS

See RS Figures

5.3, 10.11c &

10.11d and RS

Minor overall

Minor /

Moderate at

S/T & L/T, P & T,

D


December 2015

Page | 226

Low at Maiden

Hill &Haresfiled

Hill

Maiden Hill &

Haresfield Hill

Appendices 10.4

& 10.7

Appendices 10.4

& 10.7

Maiden Hill &

Haresfiled Hill

Thames and

Severn Way

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate

S/T & L/T, P & T,

D

Severn Way Effect on views

and visual

amenity


D

Gloucester and

Sharpness Canal

Effect on views

and visual

amenity


D

Wysis Way Effect on views

and visual

amenity


D

PRoW

Eastington

Footpath No.37

Effect on views

and visual

amenity

C & O High High Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Major/

Moderate

(Significant)

S/T & L/T, P & T,

D

PRoW

Eastington

Footpath No.38

Effect on views

and visual

amenity


(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Major /

Moderate

(Significant)

S/T & L/T, P & T,

D

PRoW Cluster

East of site

around Grove

Lane / Westend

Cross

Effect on views

and visual

amenity


Moderate

See RS Appendix

10.4

See RS Appendix

10.4

Minor /

Moderate

S/T & L/T, P & T,

D

PRoW Cluster

North east of

M5 to Nupend

Effect on views

and visual

amenity

C & O High Low to medium

(Footpaths No.

22 & 23).

Moderate

(Footpaths No.

22 & 23).

See RS Figures

5.3, 10.11c &

10.11d and RS

See RS Figures

5.3, 10.11c &

10.11d and RS

Moderate to

Moderate /

Minor

S/T & L/T, P & T,

D


December 2015

Page | 227

Low (Footpaths

No. 20,21,24)

Moderate /

Minor

(Footpaths No.

22 & 23).

Appendices 10.4

& 10.7

Appendices 10.4

& 10.7

(Footpaths No.

22 & 23)

Minor

(Footpaths No.

20, 21 & 24)

PRoW Cluster

South east of

site and along

Stroudwater

Canal

Effect on views

and visual

amenity

C & O High Low from

Westfield Bridge

Negligible from

all other parts of

these PRoW

Moderate /

Minor from

Westfield Bridge

Minor from all

other parts of

these PRoW

N/A See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate from

Westfield Bridge

Minor from all

other parts of

these PRoW

S/T & L/T, P & T,

D

PRoW No. 46

south of site

along River

Frome

(*Thames and

Severn Way)

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate

S/T & L/T, P & T,

D

PRoW Cluster

South of site

Alkerton /

Eastington

fringe paths

connecting to

River Frome

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate

S/T & L/T, P & T,

D

PRoW Cluster

North west of

M5 towards

Whitminster

Effect on views

and visual

amenity

C & O High Low / Medium Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Moderate /

Minor

S/T & L/T, P & T,

D

PRoW No.48

Claypits

Footpath

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

See RS Figures

5.3, 10.11c &

10.11d and RS

Minor /

Moderate

S/T & L/T, P & T,

D


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Appendices 10.4

& 10.7

Appendices 10.4

& 10.7

National Cycle

Route No.41

Effect on views

and visual

amenity


D

National Cycle

Route No.45

Effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate

S/T & L/T, P & T,

D

Grove Lane Effect on views

and visual

amenity

C & O Medium Low Minor /

Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Minor /

Moderate to

Minor

S/T & L/T, P & T,

D

M5 Effect on views

and visual

amenity

C & O Low High 250m

north of J13

Low

Overall

Moderate /

Major for 250m

north of J13

Minor

Overall

(Significant for

250m)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Moderate to

Moderate /

Major for 250m

Minor Overall

(Significant for

250m)

S/T & L/T, P, D

A38 Effect on views

and visual

amenity

C & O Low Low Minor N/A N/A Minor /

Negligible

S/T & L/T, P & T,

D

A419 Effect on views

and visual

amenity

C & O Low High between

Chipmans Platt

roundabout &

J13

Low Overall

Moderate /

Major between

Chipmans Platt

roundabout &

J13

Minor Overall

N/A See Green

Infrastructure

Plan

Moderate to

Moderate /

Major between

Chipmans Platt

round-about &

J13

S/T & L/T, P & T,

D


December 2015

Page | 229

(Significant

between

Chipmans Platt

roundabout &

J13)

Minor /

Negligible

Overall

(Significant

between

Chipmans Platt

roundabout &

J13)

Saul Visitor

Centre

Effect on views

and visual

amenity


D

Slimbridge

WWT

Observation

Tower

Effect on views

and visual

amenity


D

Common Land -

Stinchcombe

Golf Course

Effect on views

and visual

amenity


D

Common Land –

Selsey

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Common Land –

Rodborough

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Robinswoodhill

Country Park -

Effect on views

and visual

amenity


D

National Trust –

Area around

Haresfield

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

National Trust –

Area around

Rodborough

Common

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D


December 2015

Page | 230

Open access –

Cam Long Down

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Open access -

Coaley Peak

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Open access –

Haresfield

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Open access -

Coaley Peak

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Open access –

Haresfield

Effect on views

and visual

amenity


Moderate

N/A N/A Minor /

Moderate

S/T & L/T, P & T,

D

Cumulative Effects

NCA 106:

Severn and

Avon Vales

Cumulative

effect on

landscape

character /

value

C & O Medium Low / negligible

Minor See RS Appendix

10.3

See RS Appendix

10.3

Minor /

Negligible

S/T & L/T, P &

T, D & I

NCA 107:

Cotswolds

Cumulative

effect on

landscape

character /

value

C & O Medium to High Negligible Minor /

Moderate to

Minor

See RS Appendix

10.3

See RS Appendix

10.3


I

LCT SV6 Settled

Unwooded

Vale, LCA SV6A

Vale of Berkeley

Cumulative

effect on

landscape

character /

value

C & O Medium Medium / High

up to

500m from

Development

Footprint

Low reducing to

negligible

beyond 500m

Moderate /

Major up to

500m from

Development

Footprint

Minor /

Moderate

See RS Appendix

10.3

See RS Appendix

10.3

Moderate up to

500m from

Development

Footprint

Minor beyond

500m

S/T & L/T, P &

T, D & I


December 2015

Page | 231

reducing to

minor beyond

500m

(Significant

within 500m)

(Not Significant

within 500m or

elsewhere)

LCT SV2 Drained

Riverine

Farmland and

Grazed Salt

Marsh / LCA

SV2B Slimbridge

and New

Grounds

Marshes

Cumulative

effect on

landscape

character /

value


Negligible

N/A N/A Minor /

Negligible

S/T & L/T, P & T,

I

LCT SV11 Vale

Hillocks / LCA

SV11A Overton

and Barrow Hill

Cumulative

effect on

landscape

character /

value


Negligible

N/A N/A Minor /

Negligible

S/T & L/T, P & T,

I

Escarpment

Footslopes

(Stroud No 5A)

Cumulative

effect on

landscape

character /

value

C & O Medium to High Medium / High

up to

500m from

Development

Footprint

Low beyond

500m

Moderate /

Major to Major

–Moderate up

to 500m

Development

Footprint

Minor /

Moderate to

Moderate /

Minor beyond

500m

(Significant

within 500m)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7

Moderate to

Moderate /

Major up to

500m from

Development

Footprint

Minor /

Moderate to

Minor beyond

500m

(Significant

within 500m)

S/T & L/T, P & T,

D & I


December 2015

Page | 232

Lowland Plain

(Stroud No 5B)

Cumulative

effect on

landscape

character /

value

C & O Medium Medium/

High up to

500m from

Development

Footprint

Low beyond

500m

Moderate/

Major up to

500m from

Development

Footprint

Minor /

Moderate

beyond 500m

(Significant

within 500m)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Moderate up to

500m from

Development

Footprint

Minor beyond

500m

(Not Significant

within 500m or

elsewhere)

S/T & L/T, P &

T, D & I

Frome River

Valley (Stroud

No 5C)

Cumulative

effect on

landscape

character /

value

C & O Medium to High Low / Negligible

within 500m

Negligible

beyond 500m

Minor /

Moderate to

Minor within

500m

Minor to Minor

/ Negligible

beyond 500m

See RS Appendix

10.3

See RS Appendix

10.3

Minor within

500m

Minor /

Negligible

beyond 500m

S/T & L/T, P & T,

I

Wold Tops

(Stroud No. 1)

Cumulative

effect on

landscape

character /

value

C & O High Negligible Minor N/A N/A Minor /

Negligible

S/T & L/T, P & T,

I

Secluded

Valleys (Stroud

No. 3)

Cumulative

effect on

landscape

character /

value


Negligible

S/T & L/T, P & T,

I

Escarpment

(Stroud No. 4)

Cumulative

effect on

landscape

character /

value


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate to

Minor

S/T & L/T, P & T,

I


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Severn Vale

Grazing

Marshes

(Stroud No.8)

Cumulative

effect on

landscape

character /

value


Negligible

N/A N/A Negligible S/T & L/T, P & T,

I

Severn Vale

Hillocks (Stroud

No.7)

Cumulative

effect on

landscape

character /

value


Negligible

N/A N/A Negligible S/T & L/T, P & T,

I

Escarpment

Outlier / Cam

Longdown,

Peaked Down

and Downham

Hill (Cotswolds

No.1A).

Cumulative

effect on

landscape

character /

value


5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Negligible

S/T & L/T, P & T,

I

Escarpment /

Uley to Coopers

Hill (Cotswolds

No. 2C)

Cumulative

effect on

landscape

character /

value


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

I

Rolling Hills and

Valleys /

Stinchcombe

and North

Nibley

(Cotswolds

No.3B).

Cumulative

effect on

landscape

character /

value


Negligible

S/T & L/T, P & T,

I

High Wold /

Nympsfield and

Kingscote

Plateau

&Minchinhamp

ton Common.

Rodborough

and Amberley

Cumulative

effect on

landscape

character /

value


5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Negligible

S/T & L/T, P & T,

I


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Page | 234

Common

(Cotswolds No.

7A)

Settled

Unwooded Vale

/ Vale of

Gloucester

Fringe

(Cotswolds

No.18A)

Cumulative

effect on

landscape

character /

value


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Minor /

Moderate to

Minor

S/T & L/T, P & T,

I

LCT 1

Stroud-water

settlement (Part

1.2)

Cumulative

effect on

landscape

character /

value


/ Negligible

See RS Appendix

10.3

See RS Appendix

10.3

Minor /

Negligible

S/T & L/T, P & T,

I

LCT 4

Green Corridor:

Rural Frome

Vale

(Part 4.4)

Cumulative

effect on

landscape

character /

value

C & O Medium to High Low to

Negligible

Minor /

Moderate to

Minor

See RS Appendix

10.3

See RS Appendix

10.3


I

LCT 7

Meadow Mill

(Part 7.1)

Cumulative

effect on

landscape

character /

value

C & O Medium to High Low to

Negligible

Minor /

Moderate to

Minor

See RS Appendix

10.3

See RS Appendix

10.3


I

LCT 2

Core Vale

Settlement East

of Eastington

(Part 2.2)

Cumulative

effect on

landscape

character /

value

C & O Medium to High Negligible

Minor /

Negligible to

Minor

See RS Appendix

10.3

See RS Appendix

10.3

Minor /

Negligible to

Negligible

S/T & L/T, P & T,

I

Viewpoint 1.

A419 at M5

Junction 13

Cumulative

effect on views

and visual

amenity

C & O Low Low Minor See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D


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Viewpoint 2.

Footpath at

Westfield

Bridge

Cumulative

effect on views

and visual

amenity


Minor

See RS Appendix

10.4

See RS Appendix

10.4

Minor

(Adverse and

Beneficial)

S/T & L/T, P & T,

D

Viewpoint 3.

Footpath east

of Westend

Cumulative

effect on views

and visual

amenity

C & O High Low/Negligible Minor/

Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D

Viewpoint 4.

A419 at

Chipmans Platt

roundabout

Cumulative

effect on views

and visual

amenity

C & O Low Medium Moderate /

Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Minor /

Moderate

S/T & L/T, P & T,

D

5. Viewpoint

Thames and

Severn Way

east of M5

Cumulative

effect on views

and visual

amenity


Minor

See RS Appendix

10.4

See RS Appendix

10.4

Minor

(Adverse and

Beneficial)

S/T & L/T, P & T,

D

6. Viewpoint

Footpath West

of Nupend

Cumulative

effect on views

and visual

amenity


Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate to

Moderate /

Minor

(Not Significant)

A, S/T & L/T, P &

T, D

7. Viewpoint

Grove Lane M5

over bridge

Cumulative

effect on views

and visual

amenity

C & O Medium Low to

Negligible

Minor See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D

8. Viewpoint

Footpath north

of Eastington

Cumulative

effect on views

and visual

amenity

C & O High Low / Medium Moderate

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate /

Minor

S/T & L/T, P & T,

D


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9. Viewpoint

Maiden Hill

(Cotswold Way)

Cumulative

effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D

10. Viewpoint

Haresfield Hill

(Cotswold Way)

Cumulative

effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D

11. Viewpoint

Selsey Common

(Cotswold Way)

Cumulative

effect on views

and visual

amenity

C & O High Low to

Negligible

Minor /

Moderate

See RS Appendix

10.4


D

12. Viewpoint

Cam Long Down

(Cotswold Way)

Cumulative

effect on views

and visual

amenity


10.4

N/A Minor /

Negligible

S/T & L/T, P & T,

D

13. Viewpoint

A38 at Claypits

Cumulative

effect on views

and visual

amenity

C & O High for

property

Low for road

users

Low / Negligible Minor /

Moderate for

property, Minor

/ Negligible for

road users

See RS Appendix

10.4

See RS Appendix

10.4

Minor for

property

Negligible for

road users

S/T & L/T, P & T,

D

14. Viewpoint

A38 / Thames

and Severn Way

intersection

Cumulative

effect on views

and visual

amenity

C & O High Low to

Negligible

Minor/

Moderate

N/A N/A Minor S/T & L/T, P & T,

D

15 Viewpoint

Footpath at

Doverow Hill

Cumulative

effect on views

and visual

amenity


Minor

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


D

16. Footpath

west of West

End Cross (EEA

38)

Cumulative

effect on views

and visual

amenity

C & O High Medium to High Major/Moderat

e

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

See RS Figures

5.3, 10.11c &

10.11d and RS

Moderate

(Not Significant)

S/T & L/T, P & T,

D


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Appendices 10.4

& 10.7.

Appendices 10.4

& 10.7.

A. St Micheal

and Angels

Church

Cumulative

effect on views

and visual

amenity


10.4

See RS Appendix

10.4

Minor /

Negligible

S/T & L/T, P & T,

D

D. A38

Whitminster

Ridge

Cumulative

effect on views

and visual

amenity

C & O Low Negligible Negligible See RS Appendix

10.4

See RS Appendix

10.4

Negligible S/T & L/T, P & T,

D

E. Barrow Hill Cumulative

effect on views

and visual

amenity


10.4

See RS Appendix

10.4

Minor /

Negligible

S/T & L/T, P & T,

D

F. Little Dean,

Forest of Dean

Cumulative

effect on views

and visual

amenity


10.4

See RS Appendix

10.4

Minor /

Negligible

S/T & L/T, P & T,

D

G. Field Lane,

Cam

Cumulative

effect on views

and visual

amenity


Moderate

See RS Appendix

10.4

See RS Appendix

10.4


D

H. Frocester Hill Cumulative

effect on views

and visual

amenity


Minor

See RS Appendix

10.4

See RS Appendix

10.4

Minor /

Moderate

S/T & L/T, P & T,

D


December 2015

Page | 238

11 SOCIO-ECONOMICS

Summary

11.1 This chapter assesses the potential effect of the Revised Scheme on socio-economic conditions

in Stroud District. It assesses potential effects on the construction sector, total employment and

access to community facilities.

11.2 Stroud has a successful economy and strong labour market, with low rates of unemployment and

highly skilled residents. Recent trends show that employment in the District are slowly recovering

from the economic downturn. The construction sector is an important source of employment,

however the sector is mostly made up of small businesses and there are very few large

companies specialising in commercial construction which may limit the potential for a large

proportion of construction expenditure to be retained locally.

11.3 The New Lawn Stadium includes a private gym and fitness studio which are available to members,

and a conference room which is available for community use. Although the gym is well-used,

demand for the conference room is very low, with no regular community events using the room

at present. There are alternative gym facilities and a well used community centre located in the

centre of Nailsworth. There is also a bar within the New Lawn Stadium which is only open on

match days and for events held at the club. There are no pubs or restaurants in the immediate

vicinity of the ground which are highly dependent on the income generated through match day

supporters.

11.4 The Revised Scheme will provide some socio-economic benefits for Stroud District. The Revised

Scheme is expected to create 120 FTE jobs per annum during the construction phase, and 47

permanent FTE jobs once completed (of which 2 are net additional). The increased capacity and

attendances at the new stadium will result in some increase in expenditure in Stroud District but

this is likely to be negligible. There may also be socio-economic benefits from the new housing

which is proposed for the New Lawn site under a separate planning application. These benefits

have not been assessed in this ES.

11.5 The closure of the New Lawn stadium will result in the loss of some sporting facilities to local

communities, including the private gym and fitness studios. However local residents could use

alternative gym facilities available in Nailsworth. Therefore, there will be limited loss of

amenities for local residents.

Introduction

11.6 This chapter assesses the potential effect of the Revised Scheme on socio-economic conditions

in Stroud District. The assessment has been prepared by Regeneris Consulting, and includes the

following:

• The methodology for assessing the socio-economic effects;

• The baseline conditions currently existing in Stroud and in the area around the New Lawn

stadium and Revised Scheme, including the local population and economy, labour market

and community facilities;

• Design evolution – which describes any embedded mitigation measures in the design of

the Revised Scheme;

• The potential direct and indirect effects of the Revised Scheme, both positive and negative

(as well as mitigation measures if required and whether these are temporary or

permanent effects);


December 2015

Page | 239

• The cumulative effect of the Revised Scheme with a number of other proposed

developments on socio-economic conditions in the local area.


National Policy

National Planning Policy Framework

11.7 The National Planning Policy Framework89 (NPPF) sets out Government planning policies for

England and how these are expected to be applied.

11.8 The presumption in favour of sustainable development is central to the NPPF. It is identified as

“‘the golden thread running through both plan-making and decision taking” (Paragraph 14).

Three dimensions of sustainable development are defined by the NPPF in setting out the role of

the planning system:

• Economic: the planning system is able to perform an economic role through supporting

growth and innovation;

• Social: the planning system is able to perform a social role through supporting strong,

vibrant and healthy communities;

• Environmental: the planning system is able to perform an environmental role through

protecting and enhancing the natural, built and historic environment.

11.9 Of particular relevance to the assessment of socio-economic benefits of the Revised Scheme are

the "positive improvements" identified by NPPF which the planning system should seek to

achieve (Paragraph 9).

• Making it easier for jobs to be created in cities, towns and villages;

• Improving the conditions in which people live, work, travel and take leisure.

11.10 The NPPF makes clear that Local Planning Authorities should give significant weight to supporting

economic growth. They should:

• “proactively drive and support sustainable economic development to deliver the homes,

businesses and industrial units, infrastructure and thriving local places that the country

needs” (Paragraph 17);

• “plan proactively to meet the development needs of business” (Paragraph 20) and

encourage rather than impede sustainable growth.

Local Policy

11.11 This section summarises some of the key policies, strategy and guidance document which are

directly relevant to the assessment of socio-economic effects. Chapter 6 of the ES provides a full

planning policy assessment and RS Appendix 6.1 of the ES sets out the planning policy context.

Stroud District Local Plan, Adopted, November 201590

11.12 The Local Plan sets out the vision for the development of Stroud District up to 2031. The

development strategy outlines the following relevant objectives within the Emerging Local Plan:

• Generating the equivalent of two new jobs for every new allocated home built;

89 CLG (2012): National Planning Policy Framework, Department for Communities and Local Government 90 Stroud District Council (2015). Your District Your Future, Stroud District Local Plan, November 2015


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• Supporting the provision of 6,800 to 12,500 new jobs;

• At least 11,400 new homes;

• Regenerating key areas including the main town of Stroud;

• Supporting mixed use schemes to promote sustainable communities and reduce the

carbon footprint.

11.13 In order to achieve these objectives, the plan sets out six Core Policies as part of the development

strategy. The relevant policies to this socio-economic assessment are:

• CP2: Strategic growth and development locations. The policy identifies a number of

strategic locations for the delivery of new housing and employment land across Stroud

District;

• CP3: A hierarchy for growth and development across the District's settlements. The policy

identifies the town of Stonehouse as a first tier settlement, and aims to enhance its role

as an employment and service centre for the District. The towns identified as first tier will

be the main focus for delivering employment and housing. The Revised Scheme site is in

close proximity to Stonehouse, but falls just outside the designated growth area in the key

diagram accompanying policy CP3;

• CP4: Place making. The policy aims to create attractive, high quality developments

throughout the district for people to live, work and play. The policy aims to support local

community services, enhance the sense of place and create safe streets, homes and

workplaces.

Gloucestershire Local Enterprise Partnership Strategic Economic Plan, March 2014

11.14 Gloucestershire LEP has developed a Strategic Economic Plan91 (SEP) in order to make the case

for a £52m investment from the Single Local Growth Fund, in which it outlines its ambition to

create over 33,900 jobs (a 12% increase) and protect 2,100 jobs, build over 3,200 new homes

and grow the economy of Gloucestershire by £493m by 2021 (an increase of 4%).

11.15 The focus of the SEP is therefore largely on promoting business and enterprise, and providing the

necessary conditions for the existing business base to prosper, as well as attracting inward

investment. This resulted in the development of three key projects that will deliver this growth:

• Gloucestershire Growth Hub. The Hub will provide support services to businesses with

high growth potential, as well as entrepreneurs and start-ups, encouraging individuals into

apprenticeships and other employment routes.

• GREEN. The project aims to establish Gloucestershire as the centre of excellence in

Renewable Energy, Engineering and Nuclear skills.

• Gloucestershire Growth Zone. The Growth Zone is focused on ensuring provision of

employment land in the vicinity of the M5 motorway, which provides connectivity links

with the rest of the country and the LEP.


11.16 The assessment has been undertaken by Oliver Chapman at Regeneris Consulting. Oliver is an

Associate Director at Regeneris with ten years’ experience in economic development, specialising

in land and property economics. He has undertaken socio-economic impact assessments for a

number of large and complex projects and drafted the socio-economics chapters for

Environmental Statements and Preliminary Environmental Information Reports. This includes

91 Gloucestershire Local Enterprise Partnership (2014): Strategic Economic Plan, March 2014


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major energy projects, large housing developments and urban extensions and new stadium

developments (Scunthorpe United FC). Oliver also regularly provides evidence in relation to

economic matters at local plan examinations. He is therefore a competent expert to undertake

the assessment.

11.17 The assessment considers the expected temporary socio-economic effects during construction

of the Revised Scheme and the permanent effects once the development is completed and

occupied.

Study Area

11.18 Selecting suitable study areas for socio-economic assessments is complex because of the nature

of how labour markets and supply chains work, which in many cases extend over a wide

geographical area. These factors will play a key role in determining where potential socio-

economic effects will be generated.

11.19 The assessment has focused on the effects in the local authority area of Stroud District. The

reasons for selecting this area are as follows:

• This is where all of the direct jobs will be located (once operational) and therefore where

the majority of economic value will be generated;

• Data from the 2011 Census shows that 71% of the jobs located in Stroud District were

taken by residents of the District, meaning a high proportion of jobs may be expected to

be taken by local residents.

11.20 There will inevitably be some leakage of socio-economic effects outside this Study Area. This will

be as a result of residents from other districts taking jobs at the Revised Scheme, and firms from

outside Stroud District accessing supply chain opportunities during the construction and

operational phase. However, predicting where these effects might occur is subject to a large

degree of uncertainty.

11.21 Supply chain effects in particular could occur over a very wide area, and will be dependent on

the locations of firms which secure the largest contracts during the construction phase. The

latter will not be known until a procurement exercise has been undertaken. It is noted that

Ecotricity (the developers) have an intention to source local contractors wherever possible,

however the size of the construction project (with estimated costs of £31.6m) means there may

be a limited number of local suppliers with the capacity to secure the largest contracts. However,

it is not possible to say with any certainty the area from which these suppliers will be drawn.

11.22 Therefore, given the uncertainty in predicting where socio-economic effects will occur, Stroud

District is considered to be the most reasonable and practical Study Area for assessing socio-

economic effects. The full extent of Stroud District is shown in RS Figure 11.1.

Datasets

11.23 The datasets which are drawn upon in the socio-economic baseline and assessment are all from

secondary data sources or based on information provided by Forest Green Rovers (FGR) FC or

Ecotricity. No primary research or surveys were undertaken. The secondary data sources

include:

• Census 2001 and 201192

92 Office for National Statistics (2011) Census of Population. Accessed via nomisweb.co.uk October 2017


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• Office for National Statistics (ONS), Mid-Year Population Estimates, 201693

• ONS, 2014 Sub-National Population Projections (SNPP)94

• ONS, Annual Population Survey (APS), 201695

• Business Register and Employment Survey (BRES), 201696

• ONS UK Business Counts97

• Duedil Business Database98

Potential effects included in assessment

11.24 The main effects that are assessed in this socio-economics chapter are as follows:

• Temporary construction expenditure and employment. The Revised Scheme could

generate temporary employment and economic activity during the construction phase;

both directly through the employment on site and the supply chain of contractors.

• Permanent increase in employment levels in Stroud district. The increased capacity could

support additional direct, on site employment which could then generate off-site

multiplier effects. This includes the attraction of additional visitors to Stroud, whose

expenditure in the local economy could support additional employment. As this scheme

involves the relocation of an existing asset, the issue of displacement needs to be properly

assessed.

• Loss of recreational and sporting facilities. The closure of the New Lawn Stadium could

result in the loss of amenity for residents who use the facilities, which include a private

gym, bar and conference room.

11.25 The socio-economic assessment has analysed the potential effects of the development as a

whole. The methods for assessing each of the potential effects are as follows:

• Construction jobs. Effects have been calculated by drawing upon guidance published by

OFFPAT/Homes and Communities Agency99.. This provides official benchmarks for the

number of construction jobs per £1 million of expenditure for different types of

construction projects which have been adjusted to take account of inflation. The

construction cost estimates have been provided by Ecotricity.

• Permanent increase in employment levels. Evidence has been provided by Ecotricity and

FGR on the operational labour requirements of the proposed new stadium and facilities,

including a breakdown of job types and a split between full time and part time

employment. These have been combined with a wider literature review of multiplier

effects and the socio-economic effects of new stadium developments to estimate the

indirect economic effects.

93 Office for National Statistics (2016). Mid Year Population Estimates. Accessed via nomisweb.co.uk October 2017 94 Office for National Statistics (2015) 2014 Sub-national Population Projections. Accessed via nomiweb.co.uk during

October 2017 95 Office for National Statistics (2016). Annual Population Survey. Accessed via nomisweb.co.uk during October 2017 96 Office for National Statistics (2017). Business Register and Employment Survey. Accessed via nomisweb.co.uk

October 2017 97 Office for National Statistics (2017). UK Business Counts. Accessed via nomisweb.co.uk October 2017 98 Duedil (2017). Duedil Business Counts. Accessed via duedil.com October 2017 99 OffPAT and Homes and Communities Agency (2009): Guidance on Calculation Construction Jobs


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• Loss of facilities at The New Lawn stadium: Information has been provided by FGR on the

nature of current facilities at The New Lawn stadium and the usage of these facilities by

the local community.


11.26 The assessment of socio-economic effects has been based on a widely used and accepted

methodology which considers the sensitivity of the receptor and the magnitude of effect. These

are combined to arrive at an assessment of the significance of effect.

11.27 The following indicators have been defined as the key receptors for the Revised Scheme:

• Employment in the construction sector in Stroud District

• Total employment in Stroud District.

• Access to community facilities at The New Lawn stadium

11.28 The sensitivity of receptor is based on the importance attached to the receptor in local, regional

and national economic development and regeneration policy, and whether there is evidence of

underperformance across Stroud District. Examples of how sensitivity may be determined for a

particular feature are provided in Table 11.1: .

Table 11.1: Criteria for assessing sensitivity of socio-economic receptors

Sensitivity Criteria Example Criteria

High Receptor is given a high

priority in local, regional

and national economic

development and

regeneration policy.

Identification as a key thematic or spatial priority (as a result

of economic potential and/or need).

Evidence of major socio-economic challenges, under-

performance or vulnerability e.g. patterns of deprivation,

employment and wealth generation, employment forecasts,

exposure to socio-economic threats.

Or, evidence of major socio-economic opportunity e.g.

development of key sectors

Medium Receptor is given a

medium priority in local,

regional and national

economic development

and regeneration policy.

No identification as a key thematic or spatial priority (as a

result of economic potential and/or need), but nevertheless

a consideration identified in policy and strategy

Evidence of significant socio-economic challenges, under-

performance or vulnerability or evidence of significant socio-

economic opportunity.

Low Receptor is given a low

priority in local, regional

and national economic

development and

regeneration policy.

No identification as a thematic or spatial priority (as a result

of economic potential and/or need) in any regard

Evidence of economic prosperity, buoyancy and resilience

e.g. low levels of deprivation, relatively high employment

and wealth generation rates, relatively strong employment

forecasts.

11.29 Socio-economic effects magnitude will be determined by consideration of the predicted

deviation from baseline conditions. The criteria used for the assessment of magnitude of socio-

economic effects (both positive and negative) are shown in Table.2.

11.30 The assessment of magnitude of socio-economic effects requires an element of professional

judgement and cannot be made solely on the basis of percentage thresholds. This is for the

following reasons:

• A number of the potential effects cannot easily be quantified and therefore require a

qualitative assessment to be made (e.g. loss of community amenities);


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• Where potential effects can be quantified, the assessment may need to consider a number

of possible contextual indicators to assess the potential magnitude of effect in Stroud.

This is particularly the case for construction employment, where the jobs may be based in

Stroud but the contractor and workforce may be drawn from other locations. In this case,

the assessment would need to consider both the number of jobs that may be created and

the likelihood that local workers might be used.

11.31 When measuring the magnitude of effect of increases in total employment in Stroud, any

increase over 1% is considered to be high. An increase of between 0.5% and 1% is considered to

be medium. An increase of 0.1% to 0.5% is considered to be low, and anything below 0.1% is

negligible. These thresholds have been determined by reviewing average annual changes in

employment in Stroud over the last ten years.

Table 11.2: Criteria for assessing magnitude of socio-economic effects

Magnitude

of Effect

Description

High Proposals would cause a large change to existing environmental conditions in terms of

absolute and/or percentage change.

Medium Proposals would cause a moderate change to existing environmental conditions in

terms of absolute and/or percentage change.

Low Proposals would cause a slight change to existing environmental conditions in terms of

absolute and/or percentage change.

Negligible No discernible change in baseline environmental conditions

11.32 Magnitude and sensitivity is combined as shown in to determine the significance of the effect.

All socio-economic effects that are assessed as moderate or higher are regarded as significant

within the meaning of the EIA Regulations (shown in green in Table 11.3).

Table 11.3: Criteria for assessing significance of socio-economic effects

Magnitude


Se

nsi

tiv

ity

High Major Major Moderate Negligible

Medium Major Moderate Minor Negligible

Low Moderate Minor Negligible Negligible

Baseline Conditions

Population

11.33 Stroud District had a population of over 117,400 people in 2016100. The district has an ageing

population; more than 22% of residents are aged over 65 compared with a national average of

18%. The district has also seen significant growth in the number of retired people, increasing by

6,800 people (36%) between 2001 and 2016, compared with a national average of 26%. These

trends are set to continue; the latest sub-national population projections show the number

people aged 65 or over could increase by a further 10,300 people (40%) over the next fifteen

years.

100 ONS, Mid-year Population Estimates, 2016


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11.34 This ageing effect is expected to cause a modest fall in the number of people who are of working

age (16-64) and therefore most likely to be active in the labour market (see Graph11.1). There

are currently almost 70,500 residents aged 16-64 in Stroud District, representing 60% of the total

population of the district. This is projected to decrease by 200 people over the next fifteen years

(a 0.3% decrease).

Graph 11.1: Past and Future Population Change by Age Group in Stroud, 2001-2031

Source: ONS (2015): 2014 based sub-national population projections

Unemployment and Inactivity

11.35 Stroud has a healthy labour market, with high rates of participation. The economic activity rate

in Stroud District is very high, with nearly 90% of the working age population reporting that they

are either in work or actively seeking work101. This compares to 78% in England. Data from the

Annual Population Survey (APS) shows there are around 1,600 unemployed people in Stroud in

2017, representing an unemployment rate of circa 2.6%. Graph11.2 shows that this is

significantly lower than the national average (4.8%) and has fallen from a peak of 6.4% in 2009

(at the peak of the recession).

Graph 11.2: Unemployment Rate, 2005-2017

101 ONS, Annual Population Survey 2017. Subject to large margins of error.


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Source: ONS (2017): Annual Population Estimates model based estimates of unemployment

Employment

11.36 There were around 48,000 jobs based in Stroud District in 2016. The District experienced a slow

recovery from the economic downturn, with the number of jobs falling between 2009 and 2013.

Since then, the District has created 4,000 jobs and the level of employment is now 2,000 jobs

above the level it was at in 2009 (+2%). However, this rate of growth is still well below the UK

average (+10%).

Graph 11.3: Employment Change Index, 2009-2016 (2009=100)

Source: ONS (2016): Business Register and Employment Survey


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11.37 Table shows that manufacturing remains a very important source of employment in Stroud,

accounting for 21% of employment, which is more than double the national average. The area

has traditionally been associated with the cloth industry, and while the area still has a strong

base of textile manufacturers, this sub-sector has been overtaken by hi tech sectors such as

manufacture of computers and electronic products, which has grown by 1,000 jobs since 2010.

It is the strong performance of these highly skilled sub-sectors that have driven the recent growth

of Stroud’s manufacturing sector, and therefore bucked the trend of declining manufacturing

employment experienced in other parts of the country. The other sectors which have

contributed to recent growth are health and social care and construction which have both

created around 1,000 jobs since 2010.

Table 11.4: Employment by Sector in Stroud, 2010-2016

Employment

(2016)

Change

since

2010

Share of

employment

Agriculture, forestry & fishing102 75 25 0%

Mining, quarrying & utilities 1,500 800 3%

Manufacturing 10,000 1,000 21%

Construction 3,000 1,000 7%

Motor trades 900 100 2%

Wholesale 2,000 -250 4%

Retail 4,500 500 9%

Transport & storage 2,000 -1,000 3%

Accommodation & food services 3,500 500 8%

Information & communication 1,500 500 4%

Financial & insurance 350 -50 1%

Property 600 250 1%

Professional, scientific & technical 3,500 500 6%

Business administration & support

services

2,000 -250 4%

Public administration & defence 900 -350 2%

Education 3,500 -1,000 8%

Health 5,000 1,000 12%

Arts, entertainment, recreation &

other services

2,000 500 5%

Total 46,825 3,725 100%

Source: ONS (2016) BRES 2016. Note: Figures are rounded to the nearest hundred, and may not sum.

Construction Sector

11.38 The latest BRES data shows there were around 3,000 people employed in the construction sector

in Stroud District in 2016 (5.6% of employment). ABI data show that the sector grew rapidly in

the 2000s, creating around 1,000 new jobs between 1998 and 2008. This rate of growth slowed

after the economic downturn, but has grown rapidly in recent years, creating 1,000 jobs between

2010 and 2015.

102 SIC subclass 01000 farm agriculture is not estimated at district level and it is excluded from this analysis.


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11.39 The figure of 3,000 employees is likely to be a significant underestimate of the total size of the

sector as it excludes a large number of self-employed people who are not captured by

employment datasets. Data from the Census shows that there were around 4,900 Stroud District

residents working in the construction sector in 2011, of whom around 2,100 were self-employed

(43%). The majority of these self-employed people will be the proprietors of very small

construction businesses with no registered employees. ONS Business Counts data shows over

640 of the 690 construction businesses registered in Stroud employ fewer than ten employees,

with 560 employing fewer than five employees. The dataset shows there are only five businesses

in the sector employing more than 50 employees in 2015103, which suggests there are a limited

number of firms that might have the capacity to secure large contracts.

11.40 Analysis of the Duedil business dataset, which is based on Companies House records, shows that

the largest firms in the local construction sector include UK Power Solutions (a utility connections

company), Precast Concrete Structures Limited (specialising on the design, manufacture, and

erection of offsite modular building techniques), RF Gardiner (which specialises in buildings

maintenance and minor civils), Progressive Precast Erection Limited (related to Precast Concrete

Structures Limited), and Bowmore Estates Ltd.

11.41 Further analysis of BRES shows that there are only 150 employees in sub-sectors which specialise

in the construction of commercial buildings and 130 employees in civil engineering. These are

the services likely to be in greatest demand during the construction phase of the Revised Scheme.

However, a large proportion of employment is in skilled trades such as electrical installation and

plumbing which are also likely to be in demand.

Table 11.5: Construction Employment by Sub-sector, 2016

Employees % of employment

in sector

Electrical installation 530 18%

Specialised construction activities (other than

scaffold erection) not elsewhere classified

520 17%

Construction of domestic buildings 490 16%

Plumbing, heat and air-conditioning installation 360 12%

Other construction installation 210 7%

Joinery installation 150 5%

Other building completion and finishing 150 5%

Construction of commercial buildings 150 5%

Development of building projects 130 4%

Construction of other civil engineering projects

not elsewhere classified

130 4%

Painting 90 3%

Source: ONS (2016): BRES 2016. NB. Figures may not sum exactly due to rounding

Travel to Work

11.42 The district of Stroud has a low jobs density relative to its population, meaning a large

number of residents need to commute out of the district for work. The 2011 Census shows that

the district had a net outflow of around 7,200 workers leaving the area for work on a typical day

(see

Graph 11.4: ). These commuting patterns reflect the location of Stroud in between a number of

much larger employment centres, including Gloucester, Cheltenham and Bristol which account

103 ONS Business Counts data is rounded to the nearest 5 so the actual number will be between 3 and 7


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for a large proportion of the outflows. This has been identified as a key issue in the adopted

Local Plan104; bullet point 9 on page nine states “Many people who currently live in the District

commute out of it to work. One of the challenges is to ensure that new developments are planned

to ensure that they do not become simply dormitories for commuters.”

Graph 11.4: Commuting Flows and Top 10 Destinations and Residences, 2011

Source: ONS (2011): Census of Population 2011

Deprivation

11.43 Based on a standard measure of deprivation (Index of Multiple Deprivation 2015), Stroud ranked

as the 284th most deprived district in the country. This means that Stroud is among the 25% least

deprived districts in the country, reflecting its reputation as a desirable place to live. There are

however, a number of locations which have higher rates of deprivation, shown in darker shading

in RS Figure 11.2. These include areas close to the site for the Revised Scheme around

Stonehouse, which have higher levels of unemployment, lower average incomes and lower

quality of health than elsewhere in the district. The development West of Stonehouse which is

currently under construction may help to address some of these challenges.

Sports Facilities

11.44 Nailsworth Recreation Centre is Nailsworth’s only purpose built public recreation facility and is

available for use by a number of clubs for a wide range of sports activities, including badminton,

basketball and table tennis. The Recreation Centre also has a football pitch which is used by the

school and Taverners Football Club, with further football pitches located at the King George V

Playing Fields. Nailsworth Subscription Rooms also has a small sports hall which can be booked

for sports uses or exhibitions, plays and private parties. There are also private recreation facilities

at Nailsworth Tennis Club and Nailsworth Mill Bowling Green and a number of play areas and

other open spaces.

11.45 Stroud District Council runs four leisure centres, located at Dursley, Eastcombe, Stroud and

Stonehouse (close to the site of the Revised Scheme), but none in Nailsworth. There are two

gyms located in Nailsworth, one of which is within The New Lawn stadium development and

operates a number of classes as well as providing gym equipment. The other is Nailsworth

Strength and Fitness which is more centrally located.

104 Stroud District Council (2015). Your District Your Future, Stroud District Local Plan, November 2015


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Other Facilities in and around New Lawn

11.46 In addition to the gym facilities at The New Lawn, which can be accessed by the public, the

stadium also includes a large conference room that can accommodate up to 200 delegates. This

can be hired for conferences, weddings and other events, and can also be used by the local

community. However, FGRFC has reported that demand for these facilities is low, mainly due to

the location of the stadium which is inconvenient for many community users as it sits at the top

of a hill and is remote from the rest of the village facilities.

11.47 FGRFC has encouraged the community to use the facilities, and it has been used in the past for

events such as breakfast meetings and Slimming World, but there are no regular community

events at present. The club report that the local Arkell community centre attracts most of the

local community events, given that its prices are much lower and is more conveniently located.

11.48 There are no pubs or restaurants in the immediate vicinity of the ground, with the majority of

pubs located in the centre of Nailsworth town. This means that there are very few (if any)

establishments which are highly dependent on the income generated through match day

supporters. On match days, the vast majority of supporters use the Green Man bar which is built

in to the main stand and will be relocated to the new development. This bar used to be open to

the public seven days a week. However, this was not well used and lost money on a continual

basis, so is now only open on match days and for events held at the club.

Design Evolution

11.49 There are no embedded mitigation measures in the design of the Revised Scheme which are

relevant to socio-economics. However, there is potential to increase local economic benefits

during the construction stage if Ecotricity encourages contractors to work with local sub-

contractors wherever possible and to offer apprenticeship opportunities to Stroud residents.

Potential Effects

Construction Phase Effects: Employment created during construction

11.50 The total construction cost of the Revised Scheme is estimated to be £31.6m in current prices105.

This includes the stadium itself, partial dual carriageway, grass pitches, car parking, hard

surfacing, landscape works, and set up/ preliminaries. Using CLG/Offpat guidance106 on the level

of construction output per full-time equivalent (FTE) job, it is estimated that the Revised Scheme

would create around 120 FTE jobs over a five-year build period. These jobs will cover both on-

site and off-site roles, including those jobs created in contractor’s supply chain.

11.51 The baseline section shows that the construction sector is an important source of employment

for Stroud, employing around 3,000 people. The creation of 120 FTE jobs will represent a 4%

uplift in employment in the total construction sector in Stroud. Given the small number of large

firms in Stroud District, it is unlikely that a local business will secure the main contract during the

construction phase, meaning a large proportion of these economic benefits may occur outside

Stroud District. However, there are likely to be opportunities for local firms to secure lower value

contracts through the supply chains of the main contractors and opportunities for local workers

105 This is based on initial estimates provided by the applicant, but will be subject to revision as the plans are

developed 106 Office of Project and Programme Advice and Training (Offpat) and the Homes and Communities Agency (HCA)

(2009) Briefing Note on Calculating Construction Employment, HMSO, London


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to be used during construction. There are also likely to be some indirect benefits within Stroud

as a result of contractors and their workers spending money in the local economy. This includes

local hotels and restaurants if the contractors are from outside the area. The magnitude of effect

for Stroud District is assessed as low.

11.52 Though the sector is an important source for employment in Stroud, it is not identified as a high-

ranking priority in local economic development strategies. The sensitivity of the receptor is

therefore assessed as medium.

11.53 The significance of the effect is therefore assessed as minor beneficial, which is not considered

to be significant in EIA terms. This will be a temporary effect during the five-year construction

period. However, there may be some permanent positive effects if local residents receive

training or gain experience as a result of the Revised Scheme, potentially increasing their future

employability or earnings.

11.54 If contractors from outside Stroud District were appointed to deliver the largest construction

contracts, then Ecotricity could enhance local benefits by encouraging these contractors to work

with local sub-contractors wherever possible and to offer apprenticeship opportunities to

residents in Stroud seeking work in the construction sector, particularly young residents.

11.55 It should also be noted that the New Lawn is proposed for re-development of 90 new houses

with 30% being affordable, and that a commitment to this has already been made in the form of

a planning application. This would also generate additional construction employment. However,

the socio-economic effects/ benefits of this are not assessed in this ES as the housing application

is subject to separate consenting (and associated environmental assessment) procedures.

Completed Development: Employment supported by completed development

11.56 This section assesses the potential effects of the Revised Scheme on employment levels in Stroud

District. This includes the following:

• Direct effects: this captures those full and part time jobs based at the Revised Scheme;

• Indirect supply-chain effects: off-site jobs supported through the supply chain

expenditure of the occupier of the Revised Scheme (FGR);

• Induced effects: additional jobs supported through the local expenditure of employees of

FGRFC and its suppliers;

• Indirect visitor expenditure effects: additional jobs supported by the off-site expenditure

of visitors to the development.

11.57 The first three types of effect (direct, indirect and induced) are included in the majority of

economic appraisals of development schemes. The fourth type of effect (indirect visitor

expenditure effects) has been included to take account of the fact that the Revised Scheme could

increase the number of visitors to Stroud District.

Direct Effects (On-Site)

11.58 The proposed stadium development is replacing an existing stadium based within Stroud District

(The New Lawn Stadium). The assessment of socio-economic effects therefore needs to take

account of the jobs which are displaced from this site in order to estimate the net effect of the

development.

11.59 Table 11.6 provides a breakdown of staff at the existing New Lawn stadium and those expected

at the Revised Scheme and estimates the net additional FTE jobs. A large number of the jobs

which are created will be part time or casual positions. The assessment has assumed that all part


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time staff are equivalent to 0.5 FTEs, with the exception of match day casual staff, where each

job is equal to 0.1 FTE.

Table 11.6: Employment at Existing and Proposed Stadium

Existing Stadium Proposed Stadium

Total employees FTEs Total employees FTEs

Stadium 15 8.1 18 9.4

Green Man (casual) 8 0.5 9 0.6

Events General 2 2.0 2 2.3

Match Day Snacks

(casual)

6 0.5 7 0.6

Football Management 7 6.5 7 6.5

Gym 3 2.5 3 2.5

Football First Team 25 25.0 25 25.0

Total 65 45 70 47

11.60 Table 11.6 shows that the Revised Scheme could create 70 jobs in total, which are equivalent to

47 gross FTEs. After accounting for displacement, this results in two net additional FTEs.

Indirect Supply Chain and Induced Effects

11.61 The Revised Scheme may also support additional employment through indirect supply chain and

induced effects. HCA’s 2014 Additionality Guide107 recommends a local employment multiplier

of 1.38 for recreation developments. This is a composite multiplier which captures both indirect

supply chain and induced effects. However, given that the Revised Scheme is only expected to

create two net additional jobs, any multiplier effects will be negligible.

Indirect Visitor Expenditure Effects (Off-site)

11.62 The Revised Scheme could support additional off-site employment by attracting visitors to Stroud

District, who spend money in local shops, bars and restaurants. The main source of these visits

will be visiting away fans. Although the Revised Scheme could also lead to an increase in

attendances from home fans, it is assumed that the majority of these will be residents of Stroud

District and therefore their expenditure will not be net additional to the local economy.

11.63 FGR has attracted an average attendance of 2,234 per match so far in the 2017/18 season

(compared to 1,753 in the 2016/17 season before promotion), with an average away attendance

of 608 (roughly 20%). Future attendances will depend on a range of factors in addition to the

new stadium, including the performance of FGR in the football league. FGR predict that average

match attendances will increase to 4,350 by the 2030/31 season. Assuming that 20% of

attendees are away fans, this will mean average away attendances increase to 870.

11.64 The additional employment supported through an increase in indirect visitor expenditure effects

is likely to be low. A number of football visitor surveys have been reviewed as part of this

assessment108. These suggest that average off-site expenditure on food and drink for visiting

fans is around £10 per visitor. Even a large percentage increase in attendances will therefore

result in only a modest increase in expenditure over the course of the season, and would not be

expected to support an additional FTE job.

107 Homes and Communities Agency (HCA) (2014) Additionality Guide, 4th Edition, HMSO, London 108 For example, a study by the Campaign for Better Transport: Who are the champions of football travel? (2012/13

football seasons), based on a survey of more than 1,000 fans found that on average League 1 football fans spend £10

on match day travel.


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11.65 The loss of home fans’ match day expenditure may also potentially have a negative economic

effect at a local level (in Nailsworth). However, the baseline of this chapter showed that there

are very few pubs and restaurants in the immediate vicinity of the site which may be dependent

on match day revenue, with the majority of supporters using the facilities which are provided at

the New Lawn stadium (e.g. snack bars, Green Man pub) and will be relocated to the Revised

Scheme site. While there may be some home supporters using bars, restaurants and other

amenities in the town of Nailsworth, a large proportion of these are likely to be local people who

will spend their money in the local area anyway meaning there is likely to be no loss of income.

Total Operational Employment Effect

11.66 It is estimated that the total potential net additional effect on employment in Stroud from the

Revised Scheme is under 3 FTEs, including all direct, indirect and induced effects. The magnitude

of effect is therefore considered to be negligible, and not significant within the meaning of the

EIA Rgeulations.

Completed Development: Loss of Community Facilities at New Lawn

11.67 The relocation of FGR to a different site in Stroud means that there is the potential for the local

community around the existing New Lawn site to lose access to a range of community services

and facilities which were provided on site. However, as set out in the baseline section of this

chapter, community usage of most of these facilities, including the conference rooms and Green

Man bar, is very low. This is due to the location of the New Lawn at the top of a hill which is

remote from the town centre. The only facilities which are well used by local residents are the

gym and class studios.

11.68 The loss of these facilities will result in some loss of amenity for gym users. However, the baseline

of this chapter showed that there is another gym in Nailsworth which provides alternative

facilities. The magnitude of effect is therefore considered to be low. The sensitivity of receptor

is considered to be low since the gym is a privately owned facility and therefore not a strategic

priority for Stroud District Council. If there was a high level of local demand for private gym

facilities in Nailsworth as a result of the relocation of FGR, there is also the potential for the

market to respond through the creation of a new facility. The significance of effect is therefore

assessed as negligible, which is not significant in EIA terms.

Cumulative Effects

11.69 The assessment of socio-economic effects has also considered the cumulative effects of a

number of other specific developments in the surrounding area, as set out in Table 2.5 and RS

Figure 18.1. A number of the planning applications which have been submitted for these

proposed developments have not provided quantitative estimates of the socio-economic effects

of the schemes. There is therefore insufficient information to fully quantify the cumulative socio-

economic effects. However, the following points should be noted:

• All of the proposed schemes will create some temporary construction employment,

however these effects have only been quantified in two of the planning applications for

projects. These were West of Stonehouse (S.14/0810/OUT) which is estimated to create

2,025 direct person years of employment over a ten year construction period (average of

202 jobs per annum), and Land at Javelin Park (13/0001/INQUIR) which is estimated to

create 300 jobs over a three year construction period. In both cases it is understood that

work has now commenced on these sites. The other proposed developments are smaller

in scale and therefore likely to create fewer temporary jobs. They are also likely to be built


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out over different time periods, meaning any increase in construction employment may

occur at different points in time. It is also possible that a number of the contracts are

secured by firms which are not based in Stroud District, meaning some of the economic

benefits will be lost to the area. With these caveats in mind, the sensitivity of receptor

and magnitude of effect are both considered to be medium, meaning the significance of

effect is moderate beneficial, which is significant in EIA terms.

• A number of the developments will create permanent jobs located within Stroud District.

The commercial developments will create jobs directly through the provision of new

employment space, while residential-led developments could create jobs indirectly

through the expenditure of new residents. These effects are not quantified in any of the

planning applications except for Javelin Park which is estimated to create 40 jobs when

operational. It is not expected that any of the other developments will be in competition

with the Revised Scheme because they are targeted at different markets and will not

compete for the same customers or occupiers. Based on the nature of the proposals and

expert judgment about their potential for job creation, the magnitude of effect is assessed

as negligible. The sensitivity of receptor is also high meaning the significance of effect is

negligible which is not significant in EIA terms.

• The Revised Scheme is a sports facility which is complementary to residential led

developments, providing residents with opportunities to watch football and make use of

the club facilities such as the stadium bar.

Conclusions

11.70 The Revised Scheme is not expected to have any socio-economic effects which are significant

in EIA terms.

11.71 The main conclusions are as follows:

• Construction of the Revised Scheme is expected to create 120 FTE jobs in the construction

sector over a five year construction period.

• Once completed, the Revised Scheme is expected to create two net additional direct FTEs

in Stroud.

• The closure of the New Lawn stadium will result in a loss of some sporting facilities,

including the private gym and fitness studios. However local residents could use

alternative gym facilities available in Nailsworth. Other facilities at the New Lawn are not

well used by local residents. Therefore, there will be limited loss of amenities for local

residents.


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Table 11.7: Summary of Socio economics Effects and Mitigation


(Construction /

Operation)

Embedded

Mitigation

Sensitivity of

Receptor

Magnitude

of Change

Level of Effect and

Significance Prior to

Mitigation


Effect (and

Significance)

after

Mitigation

Nature of effect (short

term / medium term /

long term, permanent /

temporary, direct /

indirect)

Construction

employment

120 FTE jobs

created

Construction Medium Low Minor beneficial Minor

beneficial

Short-term temporary

Employment 2 net additional

FTE jobs created

Operational High Negligible Negligible Negligible Permanent

Community

facilities

Loss of private

gym facilities

Operational Low Low Negligible Negligible Permanent

Eco Park, Land at M5 Junction 13, West of Stonehouse | Environmental Statement

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12 TRANSPORT AND ACCESS

Summary

12.1 The potential effects of the Revised Scheme have been assessed in terms of transport. A

comprehensive Transport Assessment (TA) has been prepared and examines in detail the

transport effects of the Revised Scheme on the existing transport system and provides the basis

for this EIA.

12.2 During the construction phase of the Revised Scheme, construction traffic is expected to result

in around a 2% increase in total traffic on the A419, and 12% - 13% increase in HGV traffic. The

majority of construction traffic is expected to be routed via the A419 and M5 to the west of the

site; no construction traffic will be permitted to use Grove Lane or Spring Hill. The construction

period is medium-term and therefore only temporary in its effects. Mitigation measures to

address the transport effects associated with the construction of the Revised Scheme will be

coordinated and implemented by means of a Construction Traffic Management Plan which will

be secured by a planning condition.

12.3 The Revised Scheme during its operational phase will increase travel demand in the area before

and after an FGRFC match. A number of improvement measures are embedded in the proposal

including:

• Signalised junction on the A419;

• Pedestrian crossing phase of the A419 within the traffic signals;

• Dualling of the A419 from the M5 Junction 13 to Chipmans Platt;

• The creation of a new footway to the south of the A419 carriageway, connecting to

Chipmans Platt, the southern part of Stonehouse and the canal towpath;

• Bus and emergency vehicle entrance from Grove Lane;

• Pedestrian and cycle access from Grove Lane, including additional footway and crossing

points.

12.4 Measures to encourage walking, cycling and public transport are to be implemented through a

Travel Plan.

12.5 The traffic modelling indicates that journey times on the A419 corridor between the A38 and

Horsetrough roundabout could increase by up to 1 minute 37 seconds during the match arrival

and departure periods on a Saturday and up to 45 seconds during the weekday evening match

arrival period. This could be perceived as a moderate negative effect by existing road users,

although infrequent.

12.6 There could be a moderate negative effect in terms of severance, amenity, delay and fear and

intimidation to users of PROW Footpaths Eastington 37 and 38, and National Cycle Route 45

before and after a match. However, this effect will be infrequent.


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12.7 In terms of frequency, based on the 2017 – 2018 season, FGRFC home matches are expected to

occur approximately thirty times per year, or two to three times per month on average. Dates

and times of matches will be known in advance from the FGRFC website. Given the relative

infrequency of home matches, and the fact that the timing of a non-match related journey

(vehicular, by cycle or on foot) could be adjusted if required to minimise the effect on an

individual, the moderate negative effect before and after matches is considered acceptable.

12.8 On non-match days, pedestrians and cyclists could experience a moderate positive effect as a

result of the introduction of the traffic signal controlled crossing of the A419 and improvements

at Chipmans Platt roundabout. Drivers could experience a moderate positive effect as a result

of the dualling of the A419 between the M5 Junction 13 and Chipmans Platt.

12.9 It is concluded that the additional travel demand can be safely and satisfactorily accommodated

on the local transport network with the above improvement measures incorporated into the

proposals.

Introduction

12.10 This chapter considers the potential significant effects of the Revised Scheme in terms of

transport and access.

12.11 A comprehensive Transport Assessment (TA) has been prepared and forms RS Appendix 12.1 to

this ES. The TA includes more detailed traffic and transport information, and examines the

transport effects of the Revised Scheme on the existing transport system. It provides the basis

for this assessment.

12.12 This chapter and accompanying appendices replace previous documents in connection with Eco

Park.


12.13 The assessment, and the TA, has been carried out with reference to national and local policy

and guidance, itemised below.

National Planning Policy Framework, 2012 (NPPF)109

12.14 Paragraph 14 of the NPPF states that a presumption in favour of sustainable development should

be seen as a golden thread running through both plan-making and decision taking. When

development is likely to generate significant movement, the NPPF states that plans and decisions

should ensure that such developments are located “where the need to travel will be minimised

and the use of sustainable travel modes can be maximised. However, this needs to take account

of policies set out elsewhere in this Framework, particularly in rural areas.” (Paragraph 34.)

Paragraph 32 states that “development should only be prevented or refused on transport grounds

where the residual cumulative impacts of development are severe.”

109 DCLG (2012) National Planning Policy Framework. DCLG: London. Available:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf. Last accessed

23rd October 2017.


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Planning Practice Guidance, 2014110111

12.15 The Government’s Planning Practice Guidance to the NPPF was launched as a web-based

resource by DCLG in March 2014, and includes guidance on travel plans, transport assessments

and statements in decision-taking, as well as on Environmental Impact Assessment.

Highways England: The strategic road network – Planning for the future, 2015112

12.16 Since April 2015, Highways England has been responsible for operating, maintaining and

improving the strategic road network in England, which includes the M5 motorway. The

document ‘The strategic road network: Planning for the future’, published in September 2015,

describes the approach that Highways England takes to engaging in the planning system and the

issues considered in relation to draft planning documents and planning applications. Paragraph

101 explains that assessment should be carried out at opening year to determine the type and

extent of mitigation needed. Assessment at a later date is used to determine the risk which will

transfer to Highways England; this should be either a date 10 years’ after the registration of the

planning application (which was registered in 2016) or the end of the Local Plan period (2031),

whichever is later.

12.17 For this assessment the opening year is 2021, and the forecast year is 2031, the end of the Local

Plan period (see below).

Gloucestershire’s Local Transport Plan 2015-2031113

12.18 Gloucestershire County Council (GCC) adopted its fourth Local Transport Plan (LTP4) in June

2016. The overarching strategy acts as guidance on how GCC will manage the transport network

in Gloucestershire up to 2031. The overall vision of LTP4 is for a resilient transport network that

enables sustainable economic growth by providing door to door travel choices. The LTP is

structured around a transport picture of Gloucestershire based on a geographical patchwork of

travel corridors, each of which has distinctive transport opportunities and pressures. This is

addressed through six area Connecting Places Strategies (CPS).

12.19 The Stroud CPS explains that by concentrating development within or adjacent to the District’s

larger settlements, the strategy should make delivery of new and improved transport

infrastructure easier. Potential links to rail, bus and other forms of public transport and the

strategic road network are all maximised by choosing to locate major employment growth at the

larger settlement areas of Stroud, Cam and Stonehouse.

110 Department for Communities and Local Government (DCLG). (2014). Travel Plans, Transport Assessments and

Statements in Decision-Taking Guidance. DCLG: London. Available:

http://planningguidance.communities.gov.uk/blog/guidance/travel-plans-transport-assessments-and-statements.

Last accessed 23rd October 2017. 111 Department for Communities and Local Government (DCLG). (2017). Environmental Impact Assessment

Guidance. DCLG: London. Available: https://www.gov.uk/guidance/environmental-impact-assessment. Last

accessed 23rd October 2017. 112 Highways England. (2015). The strategic road network Planning for the future: A guide to working with Highways

England on planning matters. Birmingham: Highways England. Available:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/461023/N150227_-

_Highways_England_Planning_Document_FINAL-lo.pdf. Last accessed 23rd October 2017. 113 Gloucestershire County Council (GCC). (2016). Gloucestershire’s Local Transport Plan 2015-2031 Gloucester:

GCC. Available: http://www.gloucestershire.gov.uk/media/2190/1_-_overarching_strategy_june_2016-66789.pdf.

Last accessed 23rd October 2017.


December 2015

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12.20 Short term capital priorities (2015 – 2021) for Stroud CPS include improvements for the A419

corridor, Stonehouse. Long term capital priorities include access improvements to national cycle

route 45, Stroud. However, the Stroud CPS notes that the identification of priorities does not

reflect a commitment by GCC for funding.

Strategic Economic Plan for Gloucestershire (SEP), 2014114115

12.21 In 2012, the Government confirmed a significant change in the way funding of major transport

schemes is allocated. Responsibility for major schemes is now devolved to the Local Enterprise

Partnerships (LEPS) through new Strategic Economic Plans (SEPs). The LEP for Gloucestershire is

GFirst LEP.

12.22 Under the Gloucestershire Growth Deal, the Government has agreed to invest £4.4m by 2020 to

2021 via GFirst LEP for junction improvements and carriageway widening within the A419

Stonehouse corridor to support planned growth, improve access to jobs and support the efficient

movement of goods. According to information provided at the public share events held in June

2017, the aim is to commence construction during Summer 2018, and complete during Summer

2019.

12.23 The Eco Park project was successfully short listed for LEP Growth Deal funding in 2016.

Stroud District Local Plan 2015116 (SDLP)

12.24 SDLP 2015 was adopted by Stroud District Council (SDC) on 19 November 2015 and covers the

period 2015 to 2031.

12.25 Strategic objective SO4 under the heading ‘Economy and infrastructure’ is relevant to the Revised

Scheme. SO4 is aimed at “promoting healthier alternatives to the use of the private car and

seeking to reduce CO2 emissions by using new technologies and encouraging an integrated

transport system to improve access to local goods and services.”

12.26 Site Allocations Policy SA2 West of Stonehouse (WoS) allocates land between the Oldends

industrial estate and Grove Lane, immediately east of the Revised Scheme Site, for mixed use

development; a planning application (Reference 14/0810/OUT) received planning consent in

April 2016.

12.27 Delivery Policy EI11, on promoting sport, leisure and recreation, states that planning applications

for new sports, leisure, cultural and recreational facilities will be permitted provided that they

meet a number of criteria including those relating to accessibility by sustainable modes of

transport. The importance of transport networks which deliver a high level of accessibility to key

114 GFirst LEP. (2014). Strategic Economic Plan for Gloucestershire. Available: http://www.gfirstlep.com/about-

us/our-vision/strategic-economic-plan/. Last accessed 23rd October 2017. 115 Gloucestershire County Council (GCC), (2016). Stonehouse A419 Improvements. Gloucester: GCC. Available:

http://www.gloucestershire.gov.uk/roads-parking-and-rights-of-way/major-projects/stonehouse-a419-

improvements/. Last accessed 23rd October 2017. 116 Stroud District Council. (2015). Your district Your future Stroud District Local Plan Adopted November 2015.

Stroud District Council: Stroud. Available: http://www.stroud.gov.uk/docs/planning/planning_strategy.asp. Last

accessed 20th November 2015.


December 2015

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services and facilities is emphasised in Delivery Policy EI12 on promoting transport choice and

accessibility. Where appropriate, new developments will be required to connect into the

surrounding infrastructure and contribute towards new or improved walking, cycling and rail

facilities within the District and the provision of an integrated public transport network across

the District.

Eastington Neighbourhood Development Plan (NDP) 117

12.28 SDC brought the Eastington Neighbourhood Plan (NDP) into force on 27th October 2016, and it

now forms part of the statutory Development Plan for Stroud District.

12.29 Eastington NDP has four main themes, including Infrastructure. The infrastructure objectives

include:

• “to support development proposals that conserve or enhance the route, character,

function and recreational value of Public Rights of Way (PROW)

• to ensure any new development allows for adequate car and bicycle parking provision.”

12.30 Policy EP9: Public Rights of Way and Wildlife Corridors states that “new development should

protect the existing rights of way network and its ambiance. Where public footpaths or

bridleways are routed or realigned through new development, they should be designed as part of

landscaped wildlife corridors rather than being routed along estate road pavements as part of

the highway network.”


Qualifications and Experience

12.31 This chapter on Transport and Access has been prepared by Caroline Jane Mumford, Associate

Director of PFA Consulting Ltd, a civil engineering and transport planning consultancy of Stratton

Park House, Wanborough Road, Swindon.

12.32 Caroline Mumford has an MSc in Transportation and Traffic Planning, and is a chartered member

of the Institute of Logistics and Transport, a member of the Chartered Institution of Highways

and Transportation, and a member of the Transport Planning Society. She has over 30 years’

experience in the field of transport assessment and the preparation of transport chapters for

Environmental Statements.

Transport Assessment Methodology

12.33 The methodology for the assessment of traffic predicted to be generated by the Revised Scheme

is set out in the TA (RS Appendix 12.1) and summarised here.

Consultation

12.34 A transport scoping study for Eco Park was submitted to GCC and Highways England in August

2015. Comments were received from Highways England in late August 2015 and from GCC in

117 Eastington Parish Council (2016). Neighbourhood Development Plan 2015 – 2031. Available

https://www.stroud.gov.uk/media/208406/eastington-ndp-referendum-version_typos-correct-ready-for-adoption-

oct-2016.pdf Last accessed 22nd November 2017.


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September 2015. A draft of the Transport Assessment and ES Transport and Access Chapter were

submitted to GCC and Highways England via SDC in October 2015.

12.35 A TA and associated documents were submitted in support of the Eco Park application (Reference

S.16/0043/OUT) in January 2016. A number of consultations and discussions were subsequently

held with GCC and Highways England. Further submissions in response to discussions were made

in July 2016, September 2016, February 2017 and July / August 2017.

12.36 A transport scoping study for the Revised Scheme was submitted to GCC and Highways England

in mid-November 2017, and a response on behalf of Highways England was received in late

November.

12.37 The outcomes from all these consultations and discussions have been taken into account in the

preparation of the TA for the Revised Scheme (RS Appendix 12.1).

Existing Transport Conditions

12.38 Existing transport conditions in the vicinity of the Revised Scheme are described in Section 3 of

the TA (RS Appendix 12.1). This includes a summary of the traffic surveys undertaken during

September 2015, a review of road safety and a review of options for sustainable travel.

The Revised Scheme

12.39 The Revised Scheme, including means of access, is described in transport terms in Section 4 of

the TA (RS Appendix 12.1).

Trip Generation and Distribution

12.40 The methodology for the assessment of trip generation and distribution is described in Section 5

of the TA (RS Appendix 12.1). Trip generation by the Forest Green Rovers Football Club (FGRFC)

Stadium during a home match has been estimated for a full 5,000 capacity event as requested

during consultation to allow for the ‘worst case’. Modal split has been based upon surveys of car

occupancy at the current FGRFC New Lawn ground, and on an assessment of the potential for

walking, cycling and bus / coach travel to the Site.

12.41 Trip distribution has been based upon postcode data for advance ticket sales provided by FGRFC.

In terms of assignment, the road network in the immediate vicinity of the site is straightforward,

with limited route choice options. Distributed traffic has therefore been manually assigned to

the most logical route.

Effect on the Road Network

12.42 The methodology for the assessment of the effect on the road network is set out in Section 6 of

the TA (RS Appendix 12.1).

12.43 The traffic effect of the Revised Scheme on the operation of the surrounding highway network

has been assessed for the following time periods:

• Saturday 14:00 – 15:00 – match day arrivals

• Saturday 17:00 – 18:00 – match day departures

• Weekday 18:00 – 19:00 – match day arrivals


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12.44 Departures from weekday matches occur after 21:30 in the evenings, when background traffic

flows are low and fewer people are expected to use the PROW in the area, and this period has

therefore not been included in the assessment.

12.45 The assessment has been undertaken for the 2015 baseline, and for the 2021 opening year and

2031 forecast year without and with the Revised Scheme. The 2021 and 2031 baseline scenarios

include:

• Background traffic growth irrespective of the FGRFC Stadium and WoS development;

• Development WoS allocated in SDLP 2015 and consented in April 2016; and

• The A419 Stonehouse corridor improvements funded under the Gloucestershire Growth

Deal, expected to be completed in summer 2019.

12.46 In accordance with the Highways England document ‘The strategic road network: Planning for

the future’, the assessment at the 2021 opening year is used to determine mitigation

requirements, whilst the 2031 forecast year assessment provides an indication of the future

demands for the benefit of the highway authority.

12.47 Existing and predicted total two way traffic flows are set out on RS Figures 12.1 and 12.2 for a

Saturday and RS Figure 12.3 for a weekday.

12.48 Within the TA (RS Appendix 12.1), roundabouts have been modelled using the TRL software

program ‘Junctions 9’. The operational performance is summarised in Section 6 of the TA (RS

Appendix 12.1) for all approach arms and movements in terms of their Ratio of Flow / Capacity

(RFC), maximum queues in vehicles and maximum queuing delay in seconds per vehicle.

12.49 Traffic signal controlled junctions, including the proposed site access, have been modelled using

the JCT Consultancy software program LinSig. The operational performance is summarised in

Section 6 of the TA (RS Appendix 12.1) for all approach arms and movements in terms of their

Degree Of Saturation (DOS), average delay in seconds per Passenger Car Unit (PCU) and mean

max queue in PCUs. The practical reserve capacity (PRC) is also provided for each scenario.

12.50 During discussions on the Eco Park application both Highways England and GCC requested that a

micro-simulation model should be developed for the A419 corridor in the vicinity of the Site. An

S-Paramics micro-simulation model has been prepared covering the A419 from the A38 west of

the M5 to Horsetrough Roundabout in Stonehouse, based upon the traffic surveys undertaken

in September 2015 and described in Section 3 of the TA (RS Appendix 12.1). The report on the

S-Paramics traffic model forms RS Appendix 12.2 to this chapter.

12.51 The junctions assessed are identified on RS Figure 12.4.

Environmental Assessment Methodology

12.52 The EIA in relation to transport and access has been based upon the Guidelines for the

Environmental Assessment of Road Traffic (the IEMA Guidelines)118. The IEMA Guidelines

118 Institute of Environmental Management & Assessment (IEMA). (1993). Guidelines for the Environmental

Assessment of Road Traffic (IEMA Guidelines), 1993. IEMA: Lincoln


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suggest in Paragraph 3.15 that two broad rules-of-thumb can be used as a screening process to

delimit the scale and extent of the assessment. These are:

‘Rule 1 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%)

Rule 2 include any other specifically sensitive areas where traffic flows have increased by 10% or

more.’

12.53 These rules-of-thumb form the starting point for the assessment of effects. Paragraph 3.16 of

the IEMA Guidelines comments that projected changes in traffic flows of 10% or less create no

discernible environmental impact. Paragraph 3.20 explains that sensitive locations under Rule 2

include accident black-spots, conservation areas, hospitals, and routes with high pedestrian

flows.

12.54 Based upon these rules-of-thumb, and the findings of the TA (RS Appendix 12.1), the Study Area

for this chapter covers the A419 / A38 roundabout, Junction 13 on the M5, the A419 / Grove

Lane / Spring Hill roundabout at Chipmans Platt, Oldends Lane roundabout, Downton Road traffic

signals and Horsetrough roundabout together with the length of the A419 linking these junctions.

These junctions and the relevant section of the A419 can be identified on RS Figure 12.4.

12.55 The Revised Scheme is not intended to be accessible to the public except during matches.

12.56 The significance of the transport effects of the Revised Scheme is considered in the context of

the following subject areas, which are based on the IEMA Guidelines:

• Severance;

• Pedestrian Delay;

• Pedestrian Amenity;

• Fear and Intimidation;

• Driver Delay;

• Accidents and Safety.

12.57 Hazardous Loads have not been included because no hazardous loads are anticipated.

12.58 Air quality and dust effects are addressed in Chapter 13 and noise and vibration effects are

addressed in Chapter 15. Traffic data prepared as part of the TA work has been provided, and

used as the basis for the air quality and noise assessments.

12.59 The groups and special interests that may be affected by the Revised Scheme have been

considered and the following list of potential ‘receptors’ has been identified, based upon

Paragraph 3.20 of the IEMA Guidelines:

• Sensitive groups including children, the elderly and the disabled;

• Accident ‘black spots’;

• Highway corridor operating close to or over capacity;

• People walking;


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• People cycling;

• Sensitive locations – schools, hospitals and town centre.


12.60 To record the likely significant environmental effects of the Revised Scheme, the following

methodology has been adopted.

12.61 First a magnitude of change scale in respect of each of the transport and access subject areas is

defined in Table 12.1. This scale is based on the thresholds identified in the IEMA guidelines

supplemented by best practice and professional judgement.

Table 12.1: Magnitude of Change Scale

Subject Area

Magnitude of Change

Substantial Medium Minor Negligible

Severance

Change in traffic

flow of over 60%

Change in traffic

flow of 30% to

60%

Change in traffic

flow of 10% to

30%

Change in traffic

flow of less than

10%

Driver Delay

Change to journey

time that would

be noticeable to

all drivers

Change to journey

time that would

be noticeable to

most drivers

Change to journey

time that would

be noticeable to

some drivers

No change to

journey time or a

change that would

not be noticeable

to drivers

Pedestrian Delay

Change in traffic

flow of over 60%

Change in traffic

flow of 30% to 60

Change in traffic

flow of 10% to

30%

Change in traffic

flow of less than

10%

Pedestrian

Amenity

Change in traffic

flow of over 60%

Change in traffic

flow of 30% to

60%

Change in traffic

flow of 10% to

30%

Change in traffic

flow of less than

10%

Fear and

Intimidation

Change in traffic

flow of over 60%

Change in traffic

flow of 30% to

60%

Change in traffic

flow of 10% to

30%

Change in traffic

flow of less than

10%

Accidents and

Safety

Personal injury

accident rate

changed and

above national

average

Personal injury

accident rate

changed but

below national

average

Slight change to

personal injury

accident rate

No change to

personal injury

accident rate

12.62 A Sensitivity of Receptor Scale is defined in Table 12.2.


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Table 12.2: Sensitivity of Receptor Scale

High Medium Low / Negligible

Sensitive groups including

children, elderly and disabled

Accident ‘black spots’

Sensitive locations – schools,

hospitals and town centre

People walking

People cycling

Accidents at national average

Key highway junction operating

close to or over capacity

No sensitive groups or locations

No pedestrians or cyclist

Accidents below national

average

Key highway junction operating

within capacity

12.63 A matrix is then developed which identifies the significance of the effects as follows.

Table 12.3: Matrix for determining the level of effects



Ma

gn

itu

de

of

Ch

an

ge

/ e

ffe





12.64 As is highlighted in the table, Major and Moderate effects are considered significant within the

meaning of the EIA Regulations.

12.65 The significance of the effects is also assessed in relation to the sensitivity of the receptor,

whether the effects are temporary / short term or permanent / long term, and how frequently

they occur. Chapter 2 explains that short term has been considered as less than one year,

medium term effect as between one and ten years in duration, and long term as greater than

ten years.

Baseline Conditions

Site Description and Context

12.66 The Site is located on land adjacent to Junction 13 of the M5 Junction, west of Stonehouse near

Stroud (see also RS Figure 1.1). The Revised Scheme, described in more detail in Chapter 5, is for

a 5,000 capacity football stadium for Forest Green Rovers Football Club (FGRFC) to the north of

the A419. The proposal incorporates other ancillary uses (Use Class D2) within the stadium

structure itself, which will include, inter alia, cafes, bars, FGRFC Club Shop, changing rooms and

private gym for FGR team players. The proposal also includes two full-sized grass pitches (the

same size as the stadium pitch) and a goal practice area for First Team use only.

12.67 None of the outlets will be available to the public except during matches.

2015 Baseline


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12.68 Baseline information collected during the preparation of the TA (RS Appendix 12.1) is

summarised in Table 12.4.

Table 12.4: Baseline Information

Source Information

Site Visits / OS Mapping / Topographic

Survey

Existing Highway Network

Traveline South West Public Transport Information

Gloucestershire County Council Collision Data

Axiom Traffic Ltd Traffic Surveys

Forest Green Rovers Football Club Attendance Figures, Postcode Data for Advance Ticket

Sales

Existing Road Network

12.69 The A419 forms the main road corridor into Stonehouse and Stroud from the west. To the west

the A419 has a grade separated roundabout junction with the M5 (Junction 13) and, beyond the

M5, a roundabout junction with the A38 south of Whitminster. In this area the A38 runs parallel

to the M5 and provides an alternative route between Bristol and Gloucester. The M5, and the

section of the A38 entering Gloucester, form part of the strategic road network (SRN). To the

east the A419 continues to Cirencester, where it joins the A417 / A419 strategic route linking the

M4 at Swindon with the M5 at Gloucester.

12.70 The section of the A419 fronting the site, between the M5 and Chipmans Platt Roundabout, is a

single carriageway road subject to the national 60mph speed limit. There is no street lighting

and no footway along this section. Immediately adjacent to the site there are laybys which are

subject to a two hour waiting restriction between 8am and 6pm, with no return within four

hours. The layby on the northern side contains a snack waggon operating under licence from

SDC.

12.71 Chipmans Platt roundabout to the south east of the site forms the junction between the A419,

Spring Hill to the south and Grove Lane to the north, and is street lit. A service area is located at

this junction, and includes a filling station, a coffee shop and a hotel. Entrance is from the

roundabout, with exit on to Grove Lane to the north.

12.72 South east of Chipmans Platt, the A419 continues around the southern part of Stonehouse

through a number of junctions, including Oldends Lane, Downton Road and Horsetrough, to

Stroud.

12.73 North of Chipmans Platt, Grove Lane leads north and west to join the A38 at Whitminster. It

forms part of NCN Route 45. A weight restriction of 7.5t except for loading applies along the

whole length of Grove Lane from Chipmans Platt to the A38. At present, the southernmost

section of Grove Lane is a two-lane single carriageway, with street lighting as far as the service

area exit and a footway on the eastern side, and subject to a 50mph speed limit. The footway


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stops at the northern boundary of the service area compound, where Eastington Footpath 36

leads off to the north east. North of the service area exit (and north of the proposed WoS access),

the width of Grove Lane reduces to around 6 – 6.1m.

12.74 In future, from Chipmans Platt into the consented WoS development, Grove Lane is understood

to be proposed as a 6.75m wide road, suitable for use as a bus route. The WoS proposals for

Grove Lane are understood to include traffic calming features in the form of a Gateway north of

the WoS entrance, to inhibit rat running between Chipmans Platt and the A38.

12.75 A 40mph speed limit commences on the approach to the settlement of Westend, just to the

south of the Ecotricity landholding frontage. The speed limit returns to 50mph to the south east

of the bridge over the M5. Within Westend, and northwards to the A38, Grove Lane reduces in

width to 5m or less in places. Grove Lane has a priority junction with the A38 / School Lane at

Whitminster, with left turns out permitted only, although no physical measures to enforce this

are in place.

12.76 South of Chipmans Platt, Spring Hill / Alkerton Road leads south west to the village of Eastington

where it has a roundabout junction with Bath Road. Bath Road is the former A419 and leads

north west over the M5 to a traffic signal controlled junction with the A38.

Road Safety

12.77 Collision data have been obtained from GCC for the roads surrounding the Site. The collision data

cover a period of five years from 1 August 2012 to 31 July 2017. Collisions in the immediate

vicinity of the Site, excluding the M5 main carriageway, have been analysed. Out of 17 accidents,

six (all involving a moped / motorcycle, cyclist or pedestrian) resulted in serious injury and the

remainder resulted in slight injury. More details are given in the TA (RS Appendix 12.1).

12.78 A COBALT analysis of the collision records has been undertaken, to determine whether the

accident record is at, above or below the national average. The results are summarised in Table

12.5. Grove Lane is divided into a number of links in accordance with the speed limit, since

speeds affect the predicted accident rate.


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Table 12.5: Summary of COBALT analysis

Link / Junction Expected Accident Rate Actual Accident Rate

Link 1 A38 from Grove Lane to A419 0.2 0.6

Link 2 A419 from A38 to M5 0.3 0.0

Link 3 A419 from M5 to Chipmans

Platt

0.6 0.0

Link 4 Grove Lane (50mph, A419 to

Nupend)

0.0 0.0

Link 5 Grove Lane (40mph, Nupend -

Westend)

0.1 0.4

Link 6 Grove Lane (50mph, Westend

to A38)

0.2 0.0

Link 7 A38 from A419 to Frome

Bridge

0.4 0.2

Junction 1 - A38 / A419 Roundabout 3.4 0.0

Junction 2 - A38 / Grove Lane /

School Lane

1.4 0.4

Junction 3 - M5 Junction 13 3.2 1.0

Junction 4 - A419 / Grove Lane /

Spring Hill (Chipmans Platt)

5.2 0.6

12.79 The actual accident rate is at or below the expected (national average) accident rate for all links

and junctions, except for the A38 between Grove Lane and the A419, and for Grove Lane from

Nupend to Westend.

Existing Traffic Conditions

12.80 To establish existing traffic levels on the highway network in the Study Area, traffic surveys were

carried out by an independent specialist survey company in September 2015. The surveys were

undertaken during the afternoon of Saturday 12th September to cover a typical football match

period, and during the AM and PM peak periods on Tuesday 15 September. Hourly traffic flows

are summarised on RS Figure 12.1 for the Saturday match arrival time (14:00 – 15:00) on RS

Figure 12.2 for the Saturday match departure time (17:00 – 18:00) and on RS Figure 12.3 for the

weekday match arrival time (18:00 – 19:00).

12.81 Weekday FGRFC matches, which take place less frequently than Saturday matches, occur outside

the normal road network peak hours, when background traffic flows are lower. Existing total

two-way hourly traffic flows in the vicinity of the Revised Scheme are summarised in Table 12.6

for a Saturday and Table 12.7 for a weekday.


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Table 12.6: Summary of Saturday Total Two Way Hourly Traffic Flows

Location 14:00 – 15:00 17:00 – 18:00

A38 North of A419 1,034 808

A38 South of A419 1,294 1,183

A419 West of M5 840 725

A419 East of M5 1,281 1,270

Grove Lane 195 172

Spring Hill 358 346

Table 12.7: Summary of Weekday Total Two Way Hourly Traffic Flows

Location 08:00 – 09:00 17:00 – 18:00 18:00 – 19:00

A38 North of A419 974 952 698

A38 South of A419 1,476 1,583 1,068

A419 West of M5 1,125 1,133 736

A419 East of M5 1,787 2,274 1,539

Grove Lane 483 249 194

Spring Hill 699 698 445

12.82 Tables 12.6 and 12.7 confirm that hourly traffic flows on a Saturday are generally below those

during weekday peak hours, the exception being the A38 north of the M5 early on Saturday

afternoon. Table 12.7 shows that on a weekday, traffic flows during the hour 18:00 – 19:00,

when a significant proportion of traffic will arrive for a 19:45 kick-off, is well below the level in

the preceding hour 17:00 – 18:00.

12.83 Delay to traffic normally arises as a result of congestion at junctions. Traffic capacity and delay

in the 2015 base year has been analysed at the following junctions (identified on RS Figure 12.4)

which make up the Study Area:

• A419/A38 roundabout;

• M5 Junction 13 roundabout;

• A419/Spring Hill/Grove Lane roundabout (Chipmans Platt);

• A419 / Oldends Lane roundabout;

• A419 / Downton Road traffic signals;

• A419 / Bath Road / Ebley Road roundabout (Horsetrough).

12.84 The analysis was undertaken using the Junctions 9 ARCADY module for the roundabouts, and

LinSig for the Downton Road traffic signals; more details are contained in the TA (RS Appendix

12.1). In summary, on a Saturday afternoon and on a weekday evening after the main peak hour

all junctions are operating within capacity without significant queues or delays.


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12.85 In addition, the existing operation of the A419 corridor from the A38 to Horsetrough roundabout

was analysed with an S-Paramics microsimulation model. More details are contained in the S-

Paramics Report (RS Appendix 12.2). This includes a summary of eastbound and westbound

journey times between the A38 and Horsetrough roundabout for each scenario, reproduced in

Tables 12.11 and 12.2 below.

Walking and Cycling

12.86 There is currently no footway or cycleway alongside the A419 fronting the site.

12.87 PROW Footpath Eastington 37 crosses the A419 into the Site towards the eastern boundary, then

dividing into two paths, Eastington 37 and Eastington 38 (see RS Figure 10.2). No formal crossing

of the A419 is provided.

12.88 National Route 45 of the National Cycle Network, which links Chester with Salisbury via

Gloucester, Cirencester and Swindon, runs along Grove Lane to the north east of the Site, and

then south along Spring Hill south of Chipmans Platt for a short distance (see RS Figure 10.6

accompanying the LVIA). It offers a route for pedestrians and cyclists, largely off road, to

Stonehouse and Stroud.

Public Transport

12.89 Although no regular bus services directly pass the site at present, there are a number of bus

services in the area. Service 61 routes from Cheltenham to Dursley, via Stonehouse and Cam &

Dursley train station. It operates on a day time frequency of around 60 minutes on a weekday

and a Saturday, with one evening service in each direction. It travels along the A419 to Chipmans

Platt before turning south along Spring Hill towards Eastington. Service 64 starts in Stonehouse,

routeing to Bussage via Stroud. It also operates on a frequency of around 60 minutes throughout

the daytime on a weekday and a Saturday. Service 66S/66E routes between Gloucester and

Stroud, via Stonehouse High Street. It operates at a daytime frequency of 30 minutes in each

direction on a weekday and a Saturday, and hourly in the evenings.

12.90 Stonehouse station is approximately 4km to the east of the Site on the Gloucester to London line

and is served by the Great Western Railway. Cam & Dursley Station is located approximately

10km by road to the south of the Site; it is situated on the Bristol to Birmingham line and is

currently also served by the Great Western Railway. A feasibility study has been undertaken into

the reopening of the Stonehouse Bristol Road station, a little over 2km from the Site on the

Bristol to Birmingham line. The location for this station is safeguarded in the SDLP 2015.

2021 and 2031 Baseline

12.91 The opening year for this assessment is 2021; the FGRFC Stadium is assumed to be open for the

start of the 2021 - 2022 season. The forecast year is 2031, the end of the SDLP period.

Background traffic flows have been factored to 2021 and 2031 based upon the National

Transport Model (NTM) adjusted using TEMPRO (NTEM Dataset 7.0). This takes account of

changes in car ownership as well as local planning forecasts regarding housing and employment.

More details are given in Section 6 of the TA (RS Appendix 12.1).

12.92 Policy SA2 of SDLP 2015 allocates land to the west of Stonehouse for mixed use development;

planning application Reference S. 14/0810/OUT for up to 1,350 dwellings and 9.3 ha employment


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plus local centre and primary school received consent in April 2016. The location of the WoS Site

is identified on RS Figure 18.1 of this ES. Traffic generation by the WoS development, derived

from the submitted WoS TA and subsequent documents, forms part of the 2021 and 2031

baselines.

12.93 The transport effects of other committed development in Stroud District, shown on RS Figure

18.1, are taken into account through the application of TEMPRO growth factors.

12.94 Improvements to the A419 corridor to be funded under the Gloucestershire Growth Deal are also

assumed to form part of the 2021 and 2031 baselines.

12.95 Hourly traffic flows in the 2021 and 2031 baselines including WoS are summarised on RS Figure

12.1 for the Saturday match arrival time (14:00 – 15:00), on RS Figure 12.2 for the Saturday match

departure time (17:00 – 18:00) and on RS Figure 12.3 for the weekday match arrival time (18:00

– 19:00).

12.96 Individual junction modelling was repeated for the 2021 and 2031 baselines. More details are

provided in the TA (RS Appendix 12.1). However, on both a Saturday afternoon and a weekday

evening all junctions assessed operated satisfactorily in the 2021 and 2031 baselines, without

significant queues or delays.

12.97 The operation of the A419 corridor from the A38 to Horsetrough roundabout was assessed with

an S-Paramics microsimulation model for the 2021 and 2031 baselines. More details are

contained in the S-Paramics Report (RS Appendix 12.2). This includes a summary of eastbound

and westbound journey times between the A38 and Horsetrough roundabout for each scenario,

reproduced in Tables 12.11 and 12.12 below.

Design Evolution

12.98 The planning application is an outline application, with all matters reserved save for access.

Consultations with GCC and Highways England, from prior to the submission of the original Eco

Park application in January 2016, have been taken into account in the development of the

Revised Scheme transport and access proposals.

12.99 The principal vehicle access will be from a new traffic signal junction on the A419 east of the M5

Junction 13. The proposed access includes the dualling of the A419 between the M5 Junction 13

and Chipmans Platt roundabout. The proposed layout for the access and dualling (Drawing

E191/01 Rev B) is reproduced in the TA (RS Appendix 12.1).

12.100 The provision of the access will result in the loss of the existing laybys on this section of the A419.

However, it has been agreed with GCC that the laybys can be re-provided on the A419 to the

west of the M5. More details are provided in the TA (RS Appendix 12.1).

12.101 The existing public footpath (Eastington Footpath 37) which crosses the A419 to the east of the

proposed access will be incorporated into a pedestrian crossing phase at the site access traffic

signals.


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12.102 The proposed improvements also include a footway on the south side of the A419 from the

proposed access to Chipmans Platt, providing a link to the southern part of Stonehouse, and on

to Stroud via the canal towpath.

12.103 A second vehicular entrance for buses/ coaches and emergency vehicles only is proposed from

Grove Lane, as indicated on the Concept Plan (RS Figure 1.1 of this ES). This entrance will include

‘bus only’ signage plus an ANPR camera to enforce the restriction, and may be gated when not

in use. It will enable buses serving the WoS development to divert through the Site on match

days, without joining the flow of traffic entering via the main entrance from the A419. Coach

parking will be provided on site for away supporter coaches. The proposed layout for this

entrance (Drawing E191/05) is reproduced in the TA (RS Appendix 12.1).

12.104 A pedestrian and cycle access will be provided adjacent to the bus access from Grove Lane, and

will be kept open at all times to allow continued use of Eastington Footpath 38 as well as access

to the Stadium from the WoS development. A footway will be continued along Grove Lane to

connect with the WoS proposals. Crossing points will be located to the north of the proposed

entrance on Grove Lane, and at Nupend.

12.105 The public footpaths through the Revised Scheme will be re-assessed at the Reserved Matters

stage, and there is an intention that they will be incorporated into green links and landscape

corridors as appropriate, in accordance with Policy EP 9 of the Eastington NDP. This will ensure

improved integration into the landscape.

12.106 Within the Site, the area around the Stadium will be vehicle free during matches, as indicated on

the Concept Plan (RS Figure 1.1).

12.107 A total of 1,700 parking spaces is currently proposed within the Revised Scheme Site to cater for

the 5,000 capacity Stadium. This number of parking spaces is based upon the estimated modal

split for travel to the Stadium, discussed below.

12.108 Electric vehicle charging points will be provided within the parking area.

12.109 Up to 100 cycle parking spaces will be available initially, with scope to increase this number if

demand requires.

12.110 In summary, there is much embedded mitigation associated with the Revised Scheme for traffic

and transportation. This includes:







• Pedestrian and cycle access from Grove Lane including additional footway and crossing

points;

• Car and cycle parking;


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• Vehicle free area adjacent to the Stadium during matches;

• Electric vehicle charging points.

12.111 Without the embedded mitigation described above, the effects below would have greater

significance. However, with the embedded mitigation, most effects are reduced as the

embedded mitigation has reduced the sensitivity of the receptor or the magnitude of change

that the receptor might experience. In some cases, the embedded mitigation results in positive

effects at non-match times.

Potential Effects

Sensitivity of Receptors

12.112 The rule-of-thumb described in the EIA Methodology above suggests that highway links with an

increase in traffic flows of more than 30%, or more than 10% in specifically sensitive areas, should

be included in the assessment.

12.113 By reference to Table 12.2, Sensitivity of Receptor Scale, and Section 12.3, there are no sensitive

groups or locations and no pedestrian or cycle routes running alongside the A419 in the vicinity

of the Revised Scheme Site, west of Chipmans Platt roundabout. The sensitivity of the receptor

adjacent to the A419 in terms of sensitive groups or locations and pedestrians and cyclists is

therefore negligible. Only increases in traffic of more than 30% are relevant, in the light of the

rule-of-thumb described above.

12.114 However, Public Footpath Eastington 37 runs approximately north – south and crosses the A419

east of the access to the Revised Scheme. By reference to Table 12.2, the sensitivity of the

receptor in terms of Footpath 37 where is crosses the A419 is medium, so that increases in traffic

of more than 10% are considered relevant.

12.115 National Cycle Route 45 crosses the A419 from Spring Hill to Grove Lane at Chipmans Platt

roundabout and continues along Grove Lane, and may be used by walkers and cyclists. By

reference to Table 12.2, National Cycle Route 45 can be regarded as a receptor of medium

sensitivity, so that increases in traffic of more than 10% are relevant.

12.116 The accident rate on the A419 in the vicinity of the Revised Scheme, including the A38, M5 and

Chipmans Platt junctions, and on the 50mph sections of Grove Lane, is below the expected

national average (Table 12.5). By reference to Table 12.2 the sensitivity of the receptor in

relation to accidents and road safety on the A419 is low or negligible, so that only increases in

traffic of more than 30% are relevant.

12.117 Table 12.5 indicates that the accident rate on the 40mph section of Grove Lane from Nupend to

Westend is above the national average, as is the accident rate on the A38 between Grove Lane

and the A419. By reference to Table 12.2, the sensitivity of these two sections of road in terms

of road safety is high so that increases in traffic of more than 10% are relevant.

12.118 The Government has agreed to fund junction improvements within the A419 Stonehouse

Corridor under the Gloucestershire Growth Deal. By implication, Chipmans Platt, Oldends Lane,

Downton Road and Horsetrough are key junctions operating close to capacity during weekday


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peak hours, and by reference to Table 12.2 can be regarded as a receptor with medium sensitivity

at peak periods, so that increases in traffic of more than 10% would be relevant. However, on a

Saturday and during a weekday evening after the peak hour the junctions along the A419 corridor

operate within capacity, as demonstrated within the TA (RS Appendix 12.1). Sensitivity can be

regarded as low or negligible, so that increases in traffic of more than 30% are relevant.

Construction

Traffic Estimates

12.119 Construction of the Revised Scheme will give rise to deliveries of materials and products that will

be transported by Heavy Goods Vehicles (HGVs). It is intended that excavated material will be

retained within the Site, to minimise HGV movements.

12.120 Construction, and associated deliveries, are expected to take place on weekdays and on Saturday

mornings only. More details of the construction schedule and associated traffic arrangements,

including phasing, routing, and more precise estimated vehicle numbers, will be identified at the

Reserved Matters stage and included as appropriate in a Construction Traffic Management Plan

which can be secured by condition.

12.121 However, at present it is estimated that there could be 100 HGV movements (50 in, 50 out) daily

at the peak of construction, with fewer on a Saturday. It is likely that a restriction might be placed

on HGV deliveries during peak hours. Assuming an 8-hour day for deliveries, this amounts to 6 –

7 HGVs or 12 to 14 HGV movements per hour or approximately one HGV movement every 4 to 5

minutes.

12.122 In addition, there will be construction employees on site, the number varying according to

construction activity. Again, more details will be available at a later stage in the planning process.

At this stage it is estimated that there could be 130 people on site at the peak, fitting out the

Stadium. This would give rise to a maximum of 260 vehicle movements per day (130 in, 130 out).

However, many construction companies transport their employees in work buses, particularly

for a development of this scale, and the employee vehicle trip generation is expected to be well

below this in practice. Furthermore, peak hours for travel to and from construction sites

generally occur before the peak hours for the normal road network peak hours. For example, a

condition of the WoS planning consent (Reference S.14/0810/OUT) restricts demolition or

construction works outside a building to 07:30 – 18:30 on Mondays to Fridays, and 08:00 – 17:00

on a Saturday. The expectation is that construction work will commence at around 07:30 – 08:00,

before the morning peak hour. In the location of the Revised Scheme, where there are few

existing buildings to be affected, construction may commence earlier than this.

12.123 The construction period is expected to be two to three years, or medium term as set out in

Chapter 2 of this ES, so that the effect of construction traffic will be temporary.

Increase in Traffic

12.124 Daily traffic flows on the A419 in 2015, as set out in the TA (RS Appendix 12.2), are summarised

in Table 12.8, together with the predicted increases arising from construction traffic. For this

assessment it is assumed that all construction employees will be on site on Saturday morning,

but that that HGV movements will reduce to 50 (25 in, 25 out).


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Table 12.8: Increase in Daily Traffic Flows during Construction

Two Way Daily Traffic on A419 East of M5 (07:00 – 19:00)

Total Traffic HGVs

Existing Construc

tion

(Employ

ee plus

HGV)

Total %

Increase

Existing Construc

tion

(HGV)

Total %

Increase

Weekda

y

19,468 360 19,828 1.8% 812 100 912 12.3%

Saturda

y

14,082 310 14,392 2.2% 374 50 424 13.4%

12.125 Construction of the Revised Scheme is expected to result in increases of only 1.8% to 2.2% in

total traffic and 12.3% to 13.4% in HGV traffic on the A419. Construction traffic will not be

permitted to use Grove Lane or Spring Hill.

Severance, Pedestrian Delay, Pedestrian Amenity, and Fear and Intimidation

12.126 There are no existing buildings or pedestrian and cycle routes adjacent to the A419 between the

site access and the M5. Assuming that PROW Footpath Eastington 37 remains open (across the

A419) during construction, construction traffic is not expected to affect either this footpath or

National Cycle Route 45 where they cross the A419, as these recreational routes lie to the east

of the proposed site access, and construction traffic will primarily be routed from the M5 west

of the site access. By reference to Table 12.2, the sensitivity of the receptor in relation to

severance, pedestrian delay, pedestrian amenity, and fear and intimidation is negligible. By

reference to Table 12.1, the magnitude of the change in HGV traffic flow during construction is

expected to be minor (and negligible in terms of the change in total traffic flow). By reference

to Table 12.3, the level of the effect on Footpath Eastington 47 and NCN Route 45, where they

cross the A419, in terms of severance, pedestrian delay and amenity, fear and intimidation due

to traffic during construction would be negligible and therefore not significant within the

meaning of the EIA Regulations.

12.127 However, there is a possibility that it may become necessary to temporarily close PROW

Footpaths Eastington 37 and Eastington 38 within the Revised Scheme Site during construction.

The need or otherwise will be assessed as part of a Recreational Impact Assessment in a more

detailed Reserved Matters Applications.

12.128 If the footpaths remain open within the site during construction, since construction traffic will

be introduced in the vicinity of Footpaths Eastington 37 and 38 where there is currently no traffic

at all, by reference to Table 12.2 the sensitivity of the receptor is medium, and by reference to

Table 12.1 the magnitude of change would be substantial. By reference to Table 12.3 the level

of the effect in terms of severance, pedestrian delay and amenity, fear and intimidation due to

traffic during construction would be moderate and therefore significant within the meaning of

the EIA Regulations, but would be temporary.

Driver Delay


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12.129 Few construction companies are located within Stonehouse or Stroud, and the majority of

construction traffic is expected to be routed via the A419 and the M5 to the west of the site. By

reference to Table 12.2, the sensitivity of the receptor here is low.

12.130 The rule-of-thumb described in the EIA Methodology above suggests that highway links with an

increase in traffic flows of more than 30% should be included in the assessment or more than

10% in specifically sensitive areas. The A419 is not a sensitive receptor, and the increase in both

total and HGV traffic due to construction is well below the suggested level of 30%.

12.131 By reference to Table 12.1, the magnitude of the change in driver delay during construction is

expected to be minor to negligible. By reference to Table 12.3, the level of effect in relation to

driver delay during construction is minor and therefore not significant within the meaning of

the EIA Regulations.

Accidents and Safety

12.132 The accident rate on the A419 in the vicinity of the Revised Scheme Site is below the national

average (Table 12.5). As discussed above by reference to Table 12.2, the sensitivity of the

receptor in relation to accidents and road safety on the A419 is low or negligible.

12.133 Properly managed construction traffic should not result in any change to the accident rate, and

by reference to Table 12.1 the magnitude of change in relation to personal injury accidents will

be negligible. By reference to Table 12.3, the level of effect in relation to accidents and safety

during construction is negligible, and therefore not significant within the meaning of the EIA

Regulations.

12.134 The above effects during construction are summarised on Table 12.15 at the end of this chapter.

Operation

Traffic Estimates

12.135 The FGRFC Stadium is intended to be open for the start of the 2021 - 2022 season. The opening

year for this assessment is therefore 2021; the forecast year is 2031, the end of the SDLP period.

As explained above, assessment is required at opening year to determine the type and extent of

mitigation needed. Assessment at a later date is used to determine the risk which will transfer

to the highway authority.

12.136 As set out within the FGRFC website,119a total of thirty matches are currently (as at the end of

November) programmed during the 2017 – 2018 season: twenty two on a Saturday; six on a

normal weekday evening; and two on Bank Holidays. Two of these are pre-season friendly

matches, twenty three are League matches, and five are cup / trophy matches; more matches

may be added to the programme depending on progress in the League and FA Cups.

12.137 FGRFC has achieved promotion from the National League to League 2 for the 2017-2018 season.

Attendance at home games at the New Lawn this season (up to the end of November 2017), as

obtained from the FGRFC website, is summarised in Table 12.9.

119 https://www.forestgreenroversfc.com/games/results-fixtures/first-team/2017-18


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Table 12.9: Match Attendance at The New Lawn, 2017 – 2018 Season

Date Against Attendance Notes

Saturday 22 July Bristol Rovers 1,589

Saturday 29 July Kidderminster

Harriers

Not available

Saturday 5 August Barnet 3,171

Tuesday 8 August MK Dons 1,608 League Cup

Saturday 19 August Yeovil 2,615

Tuesday 29 August Newport County 1,090 LeagueTrophy

Saturday 9 September Exeter 2,909

Tuesday 12 September Lincoln City 1,887

Friday 22 September Swindon 3,305

Saturday 30

September

Accrington Stanley 2,594

Saturday 14 October Newport County 2,864

Saturday 28 October Morecambe 2,515

Tuesday 31 October Swansea City Not available League Trophy

Saturday 4 November Macclesfield 1,387 FA Cup

Saturday 18 November Crewe 2,221

Saturday 25 November Cheltenham Not available

Average Attendance 2,234

Note: Average attendance excludes Kidderminster Harriers, Swansea City and Cheltenham, for

which data are not available

12.138 The maximum attendance so far is 3,305 against ‘local’ side Swindon, with an average of 2,234.

However, to take the worst case for this assessment, a full 5,000 capacity stadium has been

assumed. The methodology for the assessment of trip generation by mode is set out in Section

5 of the TA (RS Appendix 12.1) and is based upon the following assumptions:

4% home supporters walk or cycle (170 walk / cycle in total)

800 home and away supporters travel by bus / coach

10% arrive by taxi or other lift, and don’t need to park, but vehicle makes a return

journey at both the start and end of the match

Private car occupancy 2.2


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12.139 Since the estimate is for a full stadium, the predicted traffic flows are the same in both 2021 and

2031. Vehicle trip generation and parking demand for a 5,000 capacity match are summarised

in Table 12.10.

Table 12.10: Predicted Vehicles and Parking Demand: 5,000 Capacity Match

Total Crowd Total Cars One

Way Lifts & Taxis Parking Demand

5,000 1,882 188 1,694

12.140 Saturday matches commence at 15:00, and weekday evening matches at 19:45. Not all traffic

arriving for a match arrives in the hour before the start, and not all traffic leaves in the hour after

the finish. Arrival and departure profiles have been based upon the observed profiles at the

existing New Lawn ground and are:

Saturday

14:00 – 15:00 67.1% 1,389 vehicle trips (total two way)


Weekday


12.141 RS Figure 12.1 shows the predicted total two-way traffic flows in 2021 and 2031 without and

with the Revised Scheme for the Saturday arrival peak hour (14:00 – 15:00); RS Figure 12.2 shows

the predicted traffic flows for the Saturday departure peak hour (17:00 – 18:00) and RS Figure

12.3 shows the predicted traffic flows for the weekday arrival period (18:00 – 19:00). As

explained above, the WoS development and relevant highway improvements are included in

both 2021 and 2031.

Increase in Traffic

12.142 RS Figure 12.5 shows the percentage change in traffic flows with a Saturday home match in 2021

and 2031, and RS Figure 12.6 shows the percentage change for weekday evening match arrivals.

The greatest percentage impact occurs in the 2021 opening year; the percentage impact reduces

slightly in 2031, since the background traffic flows are greater as a result of general traffic growth.

This assessment therefore focusses on the effect in 2021.

12.143 The Magnitude of Change Scale in Table 12.1 sets out bands for change in traffic flow: less than

10%; 10% to 30%; 30% to 60%; and over 60%. Table 12.11 groups the road links within the Study

Area into these bands, based upon RS Figures 12.5 and 12.6.

Table 12.11: Summary of Percentage Change in Traffic Flows by Road Link

Saturday Weekday

14:00 – 15:00 17:00 – 18:00 18:00 – 19:00

Less than 10% A38, Grove Lane, M5

on slips, Bath Road

A38, Grove Lane, M5

off slips, Bath Road

A38, Grove Lane, M5

on slips, Bath Road

10% - 30% A419 West of M5 A419 West of M5

A419 West of M5,

M5 off slips, A419

from M5 to Site

Access


December 2015

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30% - 60%

M5 off slips, A419

from Site Access to

M5, A419 from

Chipmans Platt to

east of Horsetrough,

Spring Hill

M5 on slips, A419

from M5 to Site

Access, A419 from

Chipmans Platt to

Oldends Lane, A419

east of Horsetrough,

Spring Hill

M5 from Site Access

to Chipmans Platt,

A419 from Chipmans

Platt to east of

Horsetrough, Spring

Hill

Over 60%

A419 from Site

Access to Chipmans

Platt

A419 from Site

Access to Chipmans

Platt, A419 from

Oldends Lane to

Horsetrough

12.144 Increases in traffic on the A38, on Grove Lane and on Bath Road in Stonehouse are predicted to

be below 10%, and by reference to Table 12.1 and to the Rules of Thumb included in the IEMA

Guidelines (see Section 12.3 above) the magnitude of change is negligible, and there will

therefore be no discernible environmental impact in transport and access terms. These road

links are all therefore excluded from the assessment below.

12.145 Predicted increases in traffic on the A419 west of the M5 lie in the range 10% - 30% for all time

periods assessed. By reference to Table 12.2, the sensitivity of this section of the A419 as a

receptor is low to negligible, having no publicly accessible development or footways / cycleways

alongside, and no personal injury accidents over the past five years. By reference to Table 12.1

the magnitude of change is minor, and by reference to Table 12.3 the level of effect is minor to

negligible and therefore not significant within the meaning of the EIA Regulations. No further

assessment has therefore been undertaken for this road link.

12.146 Predicted increases in traffic on the A419 between the M5 and the site access lie in the range

20.1% to 34.0% for the periods analysed. By reference to Table 12.2, the sensitivity of this

section of the A419 as a receptor is low to negligible, having no publicly accessible development

or footways / cycleways alongside, and no personal injury accidents over the past five years. By

reference to Table 12.1 the magnitude of change is minor to medium, and by reference to Table

12.3 the level of effect is minor and therefore not significant within the meaning of the EIA

Regulations. No further assessment has therefore been undertaken for this section of the A419.

12.147 Predicted increases in traffic on the A419 between the site access and Chipmans Platt exceed

60% in both the match arrival and departure periods on a Saturday, and lie in the range 30% to

60% in the match arrival period on a weekday evening. Public Footpath Eastington 37 crosses

this section of the A419, and by reference to Table 12.2 the sensitivity of the receptor is therefore

medium. By reference to Table 12.1 the magnitude of change is medium to substantial, and by

reference to Table 12.3 the level of effect is moderate and therefore significant within the

meaning of the EIA Regulations. Further assessment has therefore been undertaken for this

section of the A419.

12.148 Predicted increases in traffic on the A419 between Chipmans Platt and Horsetrough generally lie

in the range 30% - 60% in both the Saturday match arrival and departure periods, and in the

weekday match arrival period. The exception is the section between Oldends Lane and


December 2015

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Horsetrough with a predicted increase of just over 60% in the Saturday match departure period.

Pedestrian and cycle facilities are provided in the vicinity of these sections of road, including NCN

45 which crosses the A419 to the east of Chipmans Platt roundabout. During match arrival and

departure periods, with a full 5,000 capacity Stadium, some junctions along the A419 corridor

are likely to be operating at close to capacity (see RS Appendix 12.1). By reference to Table 12.2

the sensitivity of the receptor is therefore medium. By reference to Table 12.1 the magnitude

of change is medium to substantial, and by reference to Table 12.3 the level of effect is moderate

and therefore significant within the meaning of the EIA Regulations. Further assessment has

therefore been undertaken for the A419 east of Chipmans Platt to Horsetrough.

12.149 Predicted increases in traffic on Spring Hill south of Chipmans Platt lie in the range 30% - 60% in

both the Saturday match arrival and departure periods, and in the weekday match arrival period.

NCN 45 uses this section of Spring Hill. By reference to Table 12.2 the sensitivity of the receptor

is therefore medium. By reference to Table 12.1 the magnitude of change is medium, and by

reference to Table 12.3 the level of effect is moderate and therefore significant within the

meaning of the EIA Regulations. Further assessment has therefore been undertaken for Spring

Hill.

12.150 For comparison, on the day of a match there can be a significant increase in traffic within the

residential areas in the vicinity of the existing FGRFC ground at The New Lawn in Nailsworth.

Based upon automatic traffic counts (ATCs) undertaken on Nympsfield Road in September and

October 2015, this can range from 300 – 400 additional vehicles each way for an average match

to 700 – 800 additional vehicles each way for the match against Cheltenham Town, with an

attendance of 3,127. This includes those parking on site or at Nailsworth Primary School, and

those searching for parking in surrounding streets. This compares with background traffic flows

of some 4,300 – 4,800 vehicles per day on Nympsfield Road, and is an issue for residents and

supporters alike.

12.151 The hourly increases in traffic on Nympsfield Road on two match days in September 2015, based

upon the ATCs, are summarised in Table 12.12 for the Saturday arrival and departure and

weekday arrival periods.


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Table 12.12: Increases in Match Traffic on Nympsfield Road approaching The New Lawn

Saturday

Direction

26.09.15 03.10.15 Difference

% Increase

Time v Gateshead No Match

14:00 – 15:00 Westbound (arrivals) 368 162 +206 127%

17:00 - 18:00 Eastbound (departures) 383 156 +227 146%

Tuesday

Direction

22.09.15 29.09.15 Difference % Increase

v Cheltenham No Match

18:00 – 19:00 Westbound (arrivals) 571 227 +344 152%

12.152 The increase in traffic in each case is well over 100%. Although there is a primary school adjacent

to the New Lawn, hours of operation do not coincide. However, footways are provided along

Nympsfield Road, so by reference Table 12.2 the sensitivity of the receptor is medium, and by

reference to Table 12.1 the magnitude of change is substantial. If the assessment were being

undertaken for The New Lawn, by reference to Table 12.3 the level of effect would be moderate

and therefore significant within the meaning of the EIA Regulations.

Severance, Pedestrian Delay, Pedestrian Amenity, and Fear and Intimidation

12.153 This section of the assessment considers the effect on road links as follows, based upon the

analysis above:

• A419 from the Site access to Chipmans Platt

• A419 east of Chipmans Platt

• Spring Hill

A419 from the Site access to Chipmans Platt

12.154 In relation to people walking on Footpath Eastington 37 as it crosses the A419, the increase in

traffic on Saturday afternoon before and after matches is predicted to be over 60%, and on a

weekday evening lies in the range 30% to 60%. By reference to Table 12.1, the magnitude of

change is medium to substantial. By reference to Table 12.2, the sensitivity of the receptors in

relation to severance, pedestrian delay, pedestrian amenity, and fear and intimidation is

medium. By reference to Table 12.3, the level of the effect on severance, pedestrian delay,

pedestrian amenity, and fear and intimidation for users of Eastington Footpath 37 as it crosses

the A419 is moderate and therefore significant within the meaning of the EIA Regulations,

permanent but infrequent i.e. approximately thirty times a year or two to three times a month

on average. Dates and times of matches will be known in advance from the FGRFC website, so

that use of the footpath during busy periods could be avoided if required. As part of the Revised

Scheme a signal controlled crossing of the A419 will be provided as a permanent feature. This

could be regarded as a positive effect by users of the footpath.

12.155 Footpaths Eastington 37 and 38 which cross the site are to be kept open during operation.

Immediately before and after matches the transport and access effect of the development on

these footpaths will be as in the paragraph above, i.e. moderate and therefore significant within

the meaning of the EIA Regulations, but infrequent i.e. approximately thirty times a year or two

to three times a month on average. Dates and times of matches will be known in advance from

the FGRFC website, so that use of the footpaths during busy periods could be avoided if required.


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A419 East of Chipmans Platt

12.156 As set out above, predicted increases in traffic on the A419 between Chipmans Platt and

Horsetrough generally lie in the range 30% - 60% in both the Saturday match arrival and

departure periods, and in the weekday match arrival period, apart from the section between

Oldends Lane and Horsetrough which has a predicted increase of just over 60% in the Saturday

match departure period. By reference to Table 12.1, the magnitude of change is medium to

substantial. The sensitivity of the receptors in relation to severance, pedestrian delay, pedestrian

amenity, and fear and intimidation is medium (Table 12.2), as the A419 is crossed by National

Cycle Route 45 at Chipmans Platt, and footways are provided along some sections of the route.

By reference to Table 12.3, the level of the effect on severance, pedestrian delay, pedestrian

amenity, and fear and intimidation immediately before and after matches is moderate and

therefore significant within the meaning of the EIA Regulations. However, the effect is

infrequent i.e. approximately thirty times a year or two to three times a month on average.

Furthermore, improvements to NCN Route 45 where it crosses the A419 are included in the

GFirst LEP funded A419 corridor improvements at Chipmans Platt. Improvements to NCN 45

more generally form part of the Revised Scheme.

Spring Hill

12.157 The maximum increase in traffic on Spring Hill before and after a match is predicted to lie in the

range 30% - 60% for all time periods. The magnitude of change is medium (Table 12.1). NCN

Route 45 runs along the northern end of Spring Hill, and may be used by both cyclists and

pedestrians. The sensitivity of the receptor is therefore medium (Table 12.2). The level of the

effect on severance, pedestrian delay, pedestrian amenity, and fear and intimidation

immediately before and after a match is moderate and therefore significant within the meaning

of the EIA Regulations (Table 12.3). However, the effect is infrequent i.e. approximately thirty

times a year or two to three times a month on average. Furthermore, a shared pedestrian / cycle

route is to be provided along the northern part of Spring Hill as part of the GFirst LEP funded

A419 corridor improvements. A pedestrian crossing point over Spring Hill is proposed as part of

the Revised Scheme, together with a footway linking Spring Hill to Eastington Footpath 37 just

east of the proposed Site access.

Driver Delay

12.158 The predicted change in driver delay has been estimated with the S-Paramics micro simulation

model. Journey times along the A419 in each direction between the A38 and Horsetrough

roundabout are summarised in Table 12.13 for each Saturday afternoon scenario and in Table

12.14 for the weekday evening arrival period. More details of the S-Paramics model are given in

RS Appendix 12.2.


December 2015

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Table 12.13: Summary of Saturday Modelled Journey Times, A419 from A38 to Horsetrough

Scenario

Saturday Match Arrivals and Departures (Minutes: Seconds)

14:00 – 15:00 17:00 – 18:00

A419

Westbound

A419

Eastbound

A419

Westbound

A419

Eastbound

2015 Baseline 07:00 06:24 07:03 06:22

2021 Baseline 06:47 06:30 06:47 06:25

2021 with

Revised Scheme

07:26 07:17 07:11 07:51

Change + 0:39 +0.47 +0.24 +1:26

2031 Baseline 06:52 06:33 06:49 06:28

2031 with

Revised Scheme

07:38 07:25 07:15 07:55

Change +0.46 +0.52 +0.26 +1:37

Note: minor differences between 2021 and 2031 journey times partly due to varying model runs

Table 12.14: Summary of Weekday Modelled Journey Times, A419 from A38 to Horsetrough

Scenario

Weekday Match Arrivals (Minutes: Seconds)

18:00 – 19:00

A419 Westbound A419 Eastbound

2015 Baseline 06:52 06:31

2021 Baseline 06:45 06:38

2021 with Revised Scheme 07:08 07:22

Change +0:23 +0:44

2031 Baseline 07:23 06:45

2031 with Revised Scheme 07:14 07:30

Change -0.09 +0.45

Note: minor differences between 2021 and 2031 journey times partly due to varying model runs

12.159 It is noted that journey times show a slight improvement westbound between the 2015 baseline

and 2021 baseline scenarios, as a result of the GFirst LEP funded A419 corridor improvements,

currently expected to be in place in 2019.

12.160 The Revised Scheme is predicted to result in increased journey times, or delay, in 2021 of 39 to

47 seconds during the Saturday match arrival period, and 24 seconds to 1 minute 26 seconds in

the Saturday match departure period, depending on the direction of travel. This will increase

slightly by 2031, because of the effect of background traffic growth.

12.161 During the weekday evening arrival period, the Revised Scheme is predicted to result in increased

journey times, or delay, in 2021 of 23 to 44 seconds during the weekday evening match arrival

period, depending on the direction of travel. In 2031, heading westbound towards the M5,

journey times show a slight improvement with the Revised Scheme, as a result of the dualling

proposals.


December 2015

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12.162 It is envisaged that the change in journey time before and after a match will be noticeable to

most drivers, because it will be clear from the level of activity that a match is taking place, and

the magnitude of change is therefore medium (Table 12.1). During match arrival and departure

periods, with a full 5,000 capacity Stadium, some junctions along the A419 corridor are likely to

be operating at close to capacity (see RS Appendix 12.1). The sensitivity of the receptor can

therefore be regarded as medium (Table 12.2), and the level of effect as moderate and therefore

significant within the meaning of the EIA Regulations (Table 12.3). However, the effect is

infrequent i.e. approximately thirty times a year, or two to three times per month on average.

Dates and times of matches will be known in advance from the FGRFC website, so that the timing

of a journey could be adjusted accordingly if required.

12.163 The proposed access arrangements include the dualling of the A419 from the M5 Junction 13 to

Chipmans Platt. This dualling is expected to be of benefit to drivers outside match periods.

Accidents and Safety

12.164 The accident rate on the A419 in the vicinity of the Revised Scheme is below the national average

(Table 12.5). The sensitivity of the receptor in relation to accidents and road safety on the A419

is therefore low or negligible (Table 12.2).

12.165 The traffic signal controlled Site access has been designed to serve the development, in

accordance with guidance in the Design Manual for Roads and Bridges120. It includes a pedestrian

crossing of the A419, and a new footway along the south side of the A419 between the Site

access and Chipmans Platt roundabout. The proposed layout will be the subject of a Road Safety

Audit at each relevant stage of the design.

12.166 No change to the personal injury accident rate is therefore expected as a result of the

development and by reference to Table 12.1 the magnitude of change in relation to accidents

and safety is negligible. By reference to Table 12.3, the level of the effect on accidents and safety

is negligible and therefore not significant within the meaning of the EIA Regulations.


Construction

Construction Traffic Management Plan

12.167 Mitigation and enhancement of the effects of construction will be achieved through controls

imposed by planning conditions, health and safety requirements and good construction site

practices. The mitigation and enhancement measures to address the transport effects

associated with the construction of the Revised Scheme will be co-ordinated and implemented

by means of a Construction Traffic Management Plan which can be secured by a planning

condition. More details of construction phasing and logistics, and more precise estimated

construction vehicle numbers, will be identified at the Reserved Matters stage and included as

appropriate in the Construction Traffic Management Plan.

12.168 Mitigation and enhancement measures during construction are likely to include:

120 Highways England: Design Manual for Roads and Bridges (DMRB), WilliamsLeatag, (2017) Available at:

http://www.standardsforhighways.co.uk/ha/standards/dmrb/. Last accessed October 2017.


December 2015

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• Appropriate signing of the delivery route to ensure vehicles use the approved route to and

from the site. No construction vehicles will be permitted to use Grove Lane or Spring Hill.

• Warning signs for vehicles and pedestrians as appropriate

• Co-ordination of delivery times to ensure that as far as possible deliveries take place

outside peak periods

• Layout of construction compound to allow adequate space for goods vehicle manoeuvring

and ensure that vehicles are not required to wait on the public highway

• Temporary traffic management for short periods if delivery of oversized loads may cause

obstruction to the public highway

• Design of the site access to ensure that vehicles have appropriate visibility upon leaving

the site

• Wheel washing facilities for vehicles leaving the site, and road sweeping when necessary

Operation

Embedded Mitigation Measures

12.169 A number of measures are embedded in the design in transport terms, as described in Section

12.4 above. These have been taken into account in the assessment above.


12.170 In the interests of sustainability and to ensure the Revised Scheme accords with national and

local planning policy, measures to encourage walking, cycling and the use of public transport will

be implemented through a Travel Plan for Forest Green Rovers Football Club (FGRFC).

12.171 An Outline Travel Plan (OTP) has been prepared for submission with the planning application,

and is attached at RS Appendix 12.3. The full Travel Plan can be secured by condition.

12.172 To encourage sustainable travel, the following measures are proposed:

• Public transport information available through FGRFC’s website;

• As required additional buses to/ from local supporter hotspots including Stonehouse,

Stroud and Nailsworth;

• As required shuttle buses to/ from Stonehouse and Cam & Dursley rail stations;

• Bus and coach drop off areas within the Site;

• Supporter carshare link via FGRFC’s website;

• Safe linkage to pedestrian routes from Stonehouse and WoS;

• Vehicle free area around the Stadium;

• Convenient cycle parking.

12.173 The interim target set out in the Outline Travel Plan is:

• Cars parked are not to exceed 34% of the total match attendance

12.174 This target will be refined in consultation with GCC following a baseline travel survey; the

baseline travel survey will be conducted between three and six months after opening of the

FGRFC Stadium.

Assessment of residual effects


December 2015

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12.175 An assessment of the significance of the effects likely to arise as a result of the Revised Scheme,

assuming a full 5,000 capacity Stadium and after the mitigation and enhancement measures have

been employed, is included in Table 12.15. Major and moderate effects are considered

significant for the purposes of the EIA Regulations.

12.176 The aim is for measures identified in the FGRFC Travel Plan to constrain growth in car travel to

the Revised Scheme in the future, rather than to alter the residual transport effects as assessed.

12.177 The residual effects considered significant in relation to the EIA Regulations can be summarised

as:

Construction

• Construction traffic - PROW Footpaths Eastington 37 and 38: moderate, negative but

medium term / temporary (severance, pedestrian delay, pedestrian amenity, fear and

intimidation).

Operation - Match Day

• Increase in traffic at Site entrance and within site – PROW Footpaths Eastington 37 and

37: Moderate, negative, long term but infrequent (severance, pedestrian delay,

pedestrian amenity, fear and intimidation);

• Increase in traffic at Chipmans Platt – NCN Route 45 and Spring Hill: Moderate, negative,

long term but infrequent (severance, pedestrian delay, pedestrian amenity, fear and

intimidation);

• Increase in traffic on A419 Corridor: Moderate, negative, long term but infrequent (driver

delay).

Operation - Non-Match Day

• Provision of crossing at signalised site access – PROW Footpath Eastington 37: Moderate,

positive, long term (severance, pedestrian delay, pedestrian amenity, fear and

intimidation);

• Pedestrian/ cyclist improvements - NCN Route 45 and at Chipmans Platt roundabout:

Moderate, positive, long term (severance, pedestrian delay, pedestrian amenity, fear and

intimidation);

• Dualling of A419 between A419 and Chipmans Platt: Moderate, positive, long term (driver

delay).

12.178 In terms of match day frequency, as stated above a total of thirty home matches are currently

(as at the end of November) programmed during the 2017 – 2018 season: twenty two on a

Saturday; six on a normal weekday evening; and two on Bank Holidays. This equates to two to

three home games per month on average. Two of these are pre-season friendly matches, twenty

three are League matches, and five are cup / trophy matches; a small number of additional

matches may be added to the programme depending on progress in the League and FA Cups.

12.179 Dates and times of matches will be known in advance from the FGRFC website, so that the timing

of a journey (vehicular, by cycle or on foot) could be adjusted accordingly to minimise the effect

on an individual if required.


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Cumulative Effects

12.180 Section 12.4 explains that the consented development on the land West of Stonehouse (Policy

SA2 in SDLP 2015) is included in the 2021 baseline, as are improvements to junctions within the

A419 Corridor to be funded by GFirst LEP under the Gloucestershire Growth Deal.

12.181 Traffic generated by the remaining developments identified in Table 2.5 and Chapter 18 of this

ES is taken into account through the application of traffic growth factors obtained from the NTM

adjusted using TEMPRO (NTEM Dataset 7.0). The TEMPRO program is based on the National Trip

End Model and takes into account changes in car ownership, and local planning forecasts

regarding housing and employment.

12.182 The access to the Revised Scheme has been designed to accommodate future traffic flows

allowing for committed developments. There are therefore no further cumulative effects to be

taken into account during operation.

Conclusions

12.183 This chapter assesses the potential effects of the Revised Scheme in terms of transport.

12.184 A comprehensive Transport Assessment (TA) has been prepared and forms RS Appendix 12.1 to

this chapter. The TA examines in detail the transport effects of the Revised Scheme on the

existing transport system and provides the basis for this assessment.

12.185 During the construction phase of the Revised Scheme it is estimated that there may be up to 100

HGV movements and 260 employee vehicle movements per day. The majority of construction

traffic is expected to be routed via the A419 and M5 to the west of the site; no construction

traffic will be permitted to use Grove Lane or Spring Hill. The construction period is medium-

term and therefore temporary in its effects. Mitigation and enhancement measures to address

the transport effects associated with the construction of the Revised Scheme will be co-ordinated

and implemented by means of a Construction Traffic Management Plan which will be secured by

a planning condition.

12.186 The Revised Scheme during its operational phase will increase travel demand in the area before

and after FGRFC home matches. A number of improvement measures are embedded in the

proposal including:







• Pedestrian and cycle access from Grove Lane including additional footway and crossing

points.


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12.187 In the interests of sustainability and to ensure the Revised Scheme accords with national and

local planning policy, measures to encourage walking, cycling and public transport are to be

implemented through a Travel Plan. An Outline Travel Plan (OTP) has been prepared for

submission with the planning application, and forms RS Appendix 12.3 of the ES. The full Travel

Plan can be secured by condition.

12.188 The traffic modelling indicates that journey times on the A419 corridor between the A38 and

Horsetrough roundabout could increase by up to around 1 minute 26 seconds during the match

arrival and departure periods in the opening year on a Saturday and up to 44 seconds during the

weekday evening match arrival period. This could be perceived as a moderate negative effect,

although infrequent.

12.189 There could be a moderate negative effect in terms of severance, amenity, delay and fear and

intimidation to users of PROW Footpaths Eastington 37 and 38, and National Cycle Route 45

before and after a match. However, this effect will be infrequent.

12.190 In terms of frequency, FGRFC home matches are expected to occur around 30 times per year, or

two to three times per month on average. Dates and times of matches will be known in advance

from the FGRFC website. Given the relative infrequency of home matches, and the fact that the

timing of a non-match related journey (vehicular, by cycle or on foot) could be adjusted if

required to minimise the effect on an individual, the moderate negative effect before and after

matches is considered acceptable.

12.191 On non-match days, pedestrians and cyclists could experience a moderate positive effect as a

result of the introduction of the traffic signal controlled crossing of the A419 and improvements

at Chipmans Platt roundabout. Drivers could experience a moderate positive effect as a result

of the dualling of the A419 between the M5 Junction 13 and Chipmans Platt.

12.192 It is concluded that the additional travel demand can be safely and satisfactorily accommodated

on the local transport network.


December 2015

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Table 12.15: Residual Transport Effects


Phase

Embedded

Mitigation

Sensitivity/

importance of

receptor

Magnitude

of change

Level of

Effect (and

Significance)

prior to

additional

mitigation


(and Significance)

after mitigation/

enhancement

Nature of

effect

Key highway

junction

operating close to

capacity:

A419 Corridor

Driver Delay

Construction

(Weekdays,

and Saturday morning)

Excavated

material to

be retained on site where

possible

Low / Medium Minor Minor/ not

significant

Deliveries to

take place

outside peak hours where

possible

Construction

Traffic

Management Plan/

Minor/ not significant

Negative,

Medium

Term

People

walking on

PROW Footpaths

Easington 37

& 38

Severance,

pedestrian

delay, pedestrian

amenity, fear

& intimidation

Construction

(Weekdays,

and Saturday morning)

PROW to be

kept open as

far as possible

Medium Substantial Moderate/

significant

No

construction

to take place on Saturday PM, Sunday

or Bank Holidays

Construction

Traffic

Management Plan

Moderate /

significant

Negative,

Medium

Term

Road network

users

Accidents

and safety

Construction

(Weekdays, and Saturday

morning)

Site access to

be provided in

accordance with

standards

Low/

negligible

No change

anticipated - Negligible

N/A N/A Construction

Traffic Management

Plan

Negligible / not significant

Negligible

People

walking on PROW

Footpath Easington 37 as it crosses

A419

Severance,

pedestrian delay,

pedestrian amenity, fear

&

intimidation

Operation

(Match)

Signal

controlled crossing of

A419 embedded in

proposals

Medium Substantial Moderate / significant

Travel Plan

to encourage sustainable

travel

N/A

Moderate /

significant

Negative,

Long Term, Infrequent

(during FGRFC match)

Positive, Long Term (No FGRFC

match)


December 2015

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People

walking on PROW

Footpaths

Easington 37 & 38 within

Site

Severance,

pedestrian delay,

pedestrian

amenity, fear &

intimidation

Operation

(Match)

PROW to be

kept open

Medium Medium Moderate /

significant

Travel Plan


travel

N/A

Moderate/

significant

Negative,


(during

FGRFC match)

People

walking or

cycling on Spring Hill

Severance,

pedestrian

delay, pedestrian

amenity, fear

& intimidation

Operation

(Match)

Pedestrian

crossing and

additional footway

embedded in

proposals


significant

Travel Plan

to encourage

sustainable travel

N/A Moderate /

significant

Negative,

Long Term,

Infrequent (during FGRFC

match)

Positive, Long Term

(No FGRFC match)

People

walking or cycling on

Cycle Route

45 at Chipmans

Platt

Severance,

pedestrian delay,

pedestrian

amenity, fear &

intimidation

Operation

(Match)

Improvement

s to NCN 45 associated

with Revised

Scheme

Medium Medium to

Substantial

Moderate/

significant

Travel Plan


travel

N/A Moderate /

significant

Negative,


(during

FGRFC match)

Positive,

Long Term (No FGRFC

match)

Key highway

junctions

operating within

capacity:

A419 Corridor

Driver Delay

Operation

(Match)

Dualling of

A419

between M5 Junction 13

and

Chipmans Platt

embedded in

proposals


significant

Travel Plan

to encourage

sustainable travel

N/A

Moderate /

significant

Negative,

Long Term,

Infrequent (during FGRFC

match)

Positive, Long Term

between M5 J13 and

Chipmans

Platt (No FGRFC


December 2015

Page | 291

match)

Road network

users

Accidents

and safety

Operation

(Match)

Site Access to

be provided

in accordance

with

standards

Low or

negligible

No change

anticipated -

Negligible

Negligible Travel Plan

to encourage

sustainable travel

N/A Negligible / not significant

Negligible


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13 AIR QUALITY AND DUST

Summary

13.1 An air quality assessment report was prepared for the Eco Park development in 2015; this is a

Revised Scheme for the Forest Green Rovers Football Club (FGRFC) stadium only development.

The Revised Scheme is not located within or near to a declared Air Quality Management Area

(AQMA).

Construction Phase

13.2 During the construction phase, effects of the Revised Scheme may potentially arise due to

fugitive dust emissions. The risk of dust effects assessed according to a widely used method

published by the Institute of Air Quality Management (IAQM). Mitigation measures appropriate

to the construction phase will be secured by a Dust Management Plan (DMP) agreed with Stroud

District Council (SDC); therefore, significant residual effects in EIA terms are not anticipated.

Operational Phase

13.3 A dispersion modelling assessment of the operational phase air quality effects associated with

emissions from the increase in traffic on local roads associated with the Revised Scheme has

been carried out, the results of which are summarised below:

Effect of the Revised Scheme on Local Air Quality

13.4 The predicted nitrogen dioxide (NO2) and particulate matter (PM10 and PM2.5) concentrations at

all the assessed existing receptors, and for all modelled scenarios, will not exceed the relevant

air quality objectives. As a result of the development (operational in 2021 including cumulative

development), there is a ‘negligible’ air quality effect predicted with respect to annual mean NO2,

PM10 and PM2.5 at all modelled existing sensitive receptors. Therefore, the air quality effects of

the development on local air quality are not significant in EIA terms.

13.5 Fixed energy source details are not available at this stage of the project for the Revised Scheme.

Once identified (Reserved Matters stage) these sources may require additional assessment.

Effect of Future Air Quality on the Revised Scheme Sensitive Receptors

13.6 None of the modelled proposed receptors are predicted to experience pollutant concentrations

above the short term NO2, annual mean NO2, PM10 or PM2.5 objectives. It is considered that

increased exposure to poor air quality at the Revised Scheme is unlikely and therefore, the air

quality effect of the development may be considered not significant in EIA terms.

13.7 Operational phase mitigation is not required. However, good practice enhancement measures

to reduce the effect of emissions to air at sensitive receptors are recommended to ensure the

air quality effects are minimised. These include good design principles, and measures to help

minimise vehicular trips and encourage more sustainable modes of travel.


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Introduction

13.8 This chapter reviews existing air quality conditions at the Revised Scheme with respect to air

quality standards and objectives, national planning policy guidelines and local policies. The

assessment methodology and likely effect of the Revised Scheme upon surrounding existing

sensitive receptors and the effect of future local air quality upon the Revised Scheme receptors

during both the construction and operational phases have been described in this chapter. If

significant effects are expected, mitigation measures will be proposed to minimise significant

effects on local air quality. The mitigation already built into the Revised Scheme as part of the

Design Evolution will also be considered. The likely residual effects on air quality following the

implementation of any mitigation or enhancements are then described. Cumulative effects of

surrounding proposed developments have also been considered and an explanation of how the

scheme will be designed to consider the air quality effects on relevant receptors provided.

13.9 This chapter is accompanied by the technical air quality assessment report (RS Appendix 13.1)

which contains the technical details including those on the guidance used, assessment approach,

and isopleths plots. The isopleths plots can also be found on RS Figure 13.4, 13.5 and 13.6. These

figures show the variation in concentration of NO2, PM10 and PM2.5 and highlight the level of

dispersion with distance from the roads. As the development is for commercial use, the NO2

concentrations within the Revised Scheme are compared against the short-term objective of

200µg/m3.


Air Quality Strategy

13.10 UK air quality policy is published under the umbrella of the Environment Act 1995121, Part IV and

specifically Section 80, the National Air Quality Strategy. The latest Air Quality Strategy for

England, Scotland, Wales and Northern Ireland – Working Together for Clean Air, published in

July 2007 sets air quality standards and objectives for ten key air pollutants to be achieved

between 2003 and 2020122.

13.11 The Air Quality Framework Directive (1996)123 established a framework under which the

European Commission (EC) could set limit or target values for specified pollutants. The directive

identified several pollutants for which limit or target values have been, or will be set in

subsequent ‘daughter directives’. The framework and daughter directives were consolidated by

Directive 2008/50/EC on Ambient Air Quality and Cleaner Air for Europe124, which retains the

existing air quality standards and introduces new objectives for fine particulates (PM2.5).

Air Quality Standards

121 Environment Act 1995 [Online] http://www.legislation.gov.uk/ukpga/1995/25/part/IV [Accessed 28th November

2017] 122 DEFRA (2007) The Air Quality Strategy for England, Scotland, Wales and Northern Ireland [Online] Available from:

www.defra.gov.uk [Accessed: 28th November 2017] 123 European Council Directive 96/62/EC 27 September 1996 on ambient air quality assessment and management 124 The European Council Directive 2008/50/EC 21 May 2008 on ambient air quality and cleaner air for Europe

[Online]

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:152:0001:0044:en:PDF [Accessed: 28th

November 2017]


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13.12 Many of the air quality standards in the United Kingdom are derived from EC directives and are

adopted into English law via the Air Quality (England) Regulations 2000125 and Air Quality

(England) Amendment Regulations 2002126. The Air Quality Limit Values Regulations 2003127 and

subsequent amendments implement the EU Air Quality Framework Directive into English Law.

Directive 2008/50/EC was translated into UK law in 2010 via the Air Quality Standards

Regulations 2010128.

13.13 The relevant129 objectives for England and Wales to protect human health are summarised in

Table 13.1. The objectives present the level to which the standards are expected to be achieved

by a certain date. A Department for Environment, Food and Rural Affairs (Defra) report130

published in 2009 found that measurements of hourly NO2 are unlikely to be exceeded where

the annual mean concentrations are below 60µg/m3.

Table 13.1: Air Quality Objectives Relevant to the Revised Scheme

Substance Averaging

period

Exceedances allowed per year Ground level concentration limit

(µµµµg/m3)

Nitrogen

dioxide (NO2)

1 calendar

year

- 40

1 hour 18 200

Particles

(PM10)

1 calendar

year

- 40

24 hours 35 50

Fine particles

(PM2.5)

1 year N/A 25*

Note: *Target date is 01.01.2020.

The Environment Act

13.14 The set of air quality standards are to be used in the review and assessment of air quality by local

authorities under Section 82 of the Environment Act (1995). If exceedances are measured or

predicted through the review and assessment process, the local authority must declare an AQMA

under Section 83 of the Act, and produce an Air Quality Action Plan (AQAP) to outline how air

quality is to be improved to meet the objectives under Section 84 of the act.

Planning Policy

13.15 The land use planning process is a key means of improving air quality, particularly in the long

term, through the strategic location and design of new developments. Any air quality concern

125 Environmental Protection, 2000. Air Quality (England) Regulations 2000

http://www.legislation.gov.uk/uksi/2000/928/contents/made 126 Environmental Protection, England, 2002. The Air Quality (England) (Amendment) Regulations 2002

http://www.legislation.gov.uk/uksi/2002/3043/contents/made 127 Environmental Protection, 2003. The Air Quality Limit Values Regulations 2003

http://www.legislation.gov.uk/uksi/2003/2121/contents/made 128 Environmental Protection, 2010. The Air Quality Standards Regulations 2010

http://www.legislation.gov.uk/uksi/2010/1001/contents/made 129 Relevance, in this case, is defined by the scope of the assessment. 130 Department for Environment, Food and Rural Affairs, 2009. Part IV of the Environment Act 1995: Local Air Quality

Management: Technical Guidance LAQM.TG(09).


December 2015

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that relates to land use and its development can, depending on the details of the Revised

Scheme, be a material consideration in the determination of planning applications.


13.16 In March 2012 the National Planning Policy Framework131 (NPPF) was published, superseding the

bulk of previous Planning Policy Statements with immediate effect. The NPPF was intended to

simplify the planning system and includes a presumption in favour of sustainable development.

13.17 Section 11 of the NPPF deals with Conserving and Enhancing the Natural Environment, and states

that the intention is that the planning system should prevent “development from contributing to

or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil,

air, water or noise pollution or land instability” and goes on to state that “new development

[should be] appropriate for its location’ and ‘the effects (including cumulative effects) of pollution

on health, the natural environment or general amenity, and the potential sensitivity of the area

or Revised Scheme to adverse effects from pollution, should be taken into account.”

13.18 With specific regard to air quality, the NPPF states that, “Planning policies should sustain

compliance with and contribute towards EU [European Union] limit values or national objectives

for pollutants, taking into account the presence of Air Quality Management Areas and the

cumulative impacts on air quality from individual sites in local areas. Planning decisions should

ensure that any new development in Air Quality Management Areas is consistent with the local

air quality action plan”.

Local Planning Policy

13.19 The Stroud District Local Plan132 was adopted in 2015. The plan contains Deliver Policy ES5

regarding air quality and states, “Development proposals which by virtue of their scale, nature or

location are likely to exacerbate existing areas of poor air quality, will need to demonstrate that

measures can be taken to effectively mitigate emission levels in order to protect public health and

well being, environmental quality and amenity. Mitigation measures should demonstrate how

they will make a positive contribution to the aims of any Air Quality Strategy for Stroud District

and may include:

1. Landscaping, bunding or separation to increase distance from highways and junctions

2. possible traffic management or highway improvements to be agreed with the local

authority

3. abatement technology and incorporating site layout / separation and other conditions in

site planning

4. traffic routing, site management, site layout and phasing

5. managing and expanding capacity in the natural environment to mitigate poor air quality.”

13.20 The Eastington Neighbourhood Development Plan133 (made in October 2016) now forms part of

the Development Plan for the local planning authority. Whilst there are no specific policies

relating to air quality, the overarching Neighbourhood Development Plan is in line with higher

level planning policy including the NPPF which has a presumption in favour of sustainable

development. The NPPF Paragraph 7 defines sustainability in terms of:

131 Department for Communities and Local Government, 2012. National Planning Policy Framework. 132 Stroud District Council, 2015. Stroud District Local Plan. 133 Eastington Parish Council, 2016. Neighbourhood Development Plan 2015-2031


December 2015

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“an environmental role – contributing to protecting and enhancing our natural, built and historic

environment; and, as part of this, helping to improve biodiversity, use natural resources

prudently, minimise waste and pollution, and mitigate and adapt to climate change including

moving to a low carbon economy.”

13.21 Further information in relation to planning policy is provided in Chapter 6 – Planning Policy

Context.

Guidance Documents

Guidance on the Assessment of Dust from Demolition and Construction

13.22 The IAQM published a guidance document in 2014134 on the assessment of construction phase

impacts. The guidance was produced to provide advice to developers, consultants and

environmental health officers on how to assess the impacts arising from construction activities.

The emphasis of the methodology is on classifying sites according to the risk of impacts (in terms

of dust nuisance, PM10 impacts on public exposure and impact upon sensitive ecological

receptors) and to identify mitigation measures appropriate to the level of risk identified.

Local Air Quality Management Review and Assessment Technical Guidance135

13.23 Defra has published technical guidance for use by local authorities in their air quality review and

assessment work. This guidance, referred to in this document as LAQM.TG(16), has been used

where appropriate in the operational phase assessment presented herein.

Land-Use Planning & Development Control: Planning for Air Quality136

13.24 Environmental Protection UK (EPUK) and the IAQM jointly published a revised version of the

guidance note ‘Land-Use Planning & Development Control: Planning for Air Quality’ in 2017

(herein the ‘EPUK-IAQM’ guidance) to facilitate the consideration of air quality in the land-use

planning and developmental control process. It provides a framework for air quality

considerations within local development control processes, promoting a consistent approach to

the treatment of air quality issues within development control decisions.


Project team

13.25 Srinivas Srimath is the Director of Air Quality at RSK and has over twenty five years’ experience

of engineering and environmental projects relating to infrastructure development, pollution

prevention and control and air quality assessment. His work experience covers numerous

industrial, local authority and environmental planning related assessments that have sought to

minimise the environmental effects of developments and devise suitable environmental

improvement policies and plans. He has completed a number of detailed air quality assessments

in support of planning applications, Environmental Statements and Environmental Permit

134 The Institute of Air Quality Management, 2014. Guidance of the Assessment of dust from demolition and

construction [pdf] [Online] Available at: http://iaqm.co.uk/text/guidance/construction-dust-2014.pdf [22nd

November 2017]. 135 Department for Environment, Food and Rural Affairs, 2016. Part IV of the Environment Act 1995: Local Air Quality

Management: Technical Guidance LAQM.TG(16). 136 Institute of Air Quality Management and Environmental Protection UK, 2017. Land-Use Planning & Development

Control: Planning for Air Quality v1.2. [Online] Available at http://www.iaqm.co.uk/text/guidance/air-quality-

planning-guidance.pdf [22nd November 2017].


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applications for nationally significant infrastructure development projects. He is experienced in

preparing and presenting evidence at public inquiries. Over a period of two years, he has

developed an air quality assessment system (for urban and highly trafficked areas) for a project

funded by the European Commission that covers several of Europe’s most populous areas where

traffic, domestic and industrial activities inter-relate. He is a full member of the IAQM and one

of the Working Group members of this Institute set up to develop guidance to assess dust

impacts from mineral extraction sites. He is the lead consultant and technical reviewer for the

work presented in this chapter.

13.26 Christina Higgins is a Senior Consultant with over three years’ experience in undertaking and

managing air quality assessments. She is an associate member of the IAQM and the Institute of

Environmental Sciences (IES). She has undertaken the air quality impact assessment work

presented in this chapter.

Consultation and Scoping Overview

13.27 As part of the scoping phase of the EIA for the original Eco Park scheme, a Scoping Report was

prepared in July 2015 (RS Appendix 1.3). Subsequently a Scoping Opinion was issued (RS

Appendix 1.2).

13.28 A summary of the main Scoping Opinion representations for the original scheme still relevant to

air quality assessment for the Revised Scheme are provided below:

Table 13.2: Scoping Responses

Consultee Issue Raised

Location in

Chapter where

addressed

Stroud District Council

Scoping Response

dated 30/09/15

The proposal could generate substantial traffic unless

alternative sustainable transport is established. There

is the potential for an increase in car borne pollutants

and bearing in mind the surrounding residents it is felt

that this should be included in the scope. This may

impact on ecology and the aquatic environment.

Potential Effects

13.29 Whilst these comments were provided for the original Eco Park scheme, they have been carried

forward as part of the assessment for the Revised Scheme. Additionally, SDC were consulted on

the availability of the latest monitoring data to undertake the assessment. As the Redline

Boundary remains unchanged from the previous application, further consultation regarding the

assessment methodology was not considered necessary.

13.30 The approach taken for assessing the potential air quality effects of the Revised Scheme during

the construction and operational phases is summarised below:

• Baseline characterisation of local air quality;

• Qualitative impact assessment of the construction phase of the development;

• Quantitative assessment of operational phase effects of the Revised Scheme using an

advanced dispersion model under the following three scenarios:

o ‘Base case’ scenario representing the ‘existing’ air quality situation in 2016;


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o ‘Without Development’ scenario (2021, the expected year of opening with other

committed/consented development but without the Revised Scheme in place);

o ‘With Development’ scenario (2021, the expected year of opening with other

committed/consented development and with the Revised Scheme in place).

• Recommendation of mitigation measures, where appropriate, to ensure any adverse

effects on air quality are minimised;

Identification of residual effects resulting from the Revised Scheme

Construction Phase Assessment Methodology

13.31 There are no formal assessment criteria to measure the significance of construction dust. As a

result, the construction phase effects have been assessed as per the IAQM guidance. The

construction dust assessment methodology is presented in RS Appendix 13.1 and described

below.

13.32 The first step in the assessment is to determine whether there is a need for a detailed

assessment. An assessment is said to be required where there are human and/ or ecological

receptors within certain distances of the site:

• a ‘human receptor’ within:

o 350m of the boundary of the site; or

o 50m of the route used by construction vehicles on the public highway, up to 500m

from the site entrance(s).

• an ‘ecological receptor’:

o 50m of the boundary of the site; or

o 50m of the route(s) used by construction vehicles on the public highway, up to 500m

from the site entrance(s).

13.33 Construction of the Revised Scheme may lead to the release of fugitive dust. There are human

receptors within 350m of the Redline Boundary of the site and within 50m of the trackout137

route; therefore, construction dust may have the potential to cause annoyance in the local area.

13.34 Human receptors include residential properties, hospitals, schools, commercial buildings, parks

and footpaths. Ecological receptors in terms of air quality include, Special Areas of Conservation

(SAC), Sites of Special Scientific Interest (SSSI) and local Nature Reserves. No designated

ecological receptors or Key Wildlife Sites (KWS) have been identified within 50m of the Redline

Boundary or the anticipated trackout route. The receptors considered in the assessment can be

seen on RS Figure 13.1.

13.35 Due to the presence of sensitive receptors within the distances identified in the IAQM guidance,

an assessment of construction dust effects is considered to be required. A qualitative assessment

of construction effects has been undertaken to identify the potential risk of dust effects and the

level of mitigation required to reduce these effects.

137 Trackout is defined as the transport of dust and dirt from the construction / demolition sites onto public road

network, where it may be deposited and then re-suspended by vehicles using the network.


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13.36 The potential dust emission magnitude is defined as Small, Medium, Large and is based on the

scale and nature of works during the construction phase. The activities are separated into

demolition, earthworks, construction and trackout and assessed individually.

Demolition

13.37 The dust emission magnitude category for demolition is varied for each site in terms of timing,

building type, duration and scale. Examples of the potential dust emission classes are provided

in the guidance as follows:

• Large: Total building volume >50,000m3, potentially dusty construction material, on-site

crushing and screening, demolition activities >20m above ground level;

• Medium: Total building volume 20,000m3 – 50,000m3, potentially dusty construction

material, demolition activities 10m – 20m above ground level;

• Small: Total building volume <20,000m3, construction material with low potential for dust

release, demolition activities <10m above ground, demolition during wetter months.

Earthworks

13.38 The dust emission magnitude category for earthworks is varied for each site in terms of timing,

geology, topography and duration. Examples of the potential dust emission classes are provided


• Large: Total site area >10,000m2, potentially dusty soil type (e.g. clay), >10 heavy earth

moving vehicles active at any one time, formation of bunds >8m in height, total material

moved >100,000 tonnes;

• Medium: Total site area 2,500 – 10,000m2, moderately dusty soil type (e.g. silt), 5 – 10

heavy earth moving vehicles active at any one time, formation of bunds 4 – 8m in height,

total material moved 20,000 – 100,000 tonnes;

• Small: Total site area < 2,500m2, soil type with large grain size (e.g. sand), <5 heavy earth

moving vehicles active at any one time, formation of bunds <4m in height, total material

moved <10,000 tonnes, earthworks during wetter months.

Construction

13.39 The dust emission magnitude category for construction is varied for each site in terms of timing,

building type, duration, and scale. Examples of the potential dust emissions classes are provided


• Large: Total building volume >100,000m3, piling, on site concrete batching;

• Medium: Total building volume 25,000 – 100,000m3, potentially dusty construction

material (e.g. concrete), piling, on site concrete batching;

• Small: Total building volume <25,000m3, construction material with low potential for dust

release (e.g. metal cladding or timber).

Trackout

13.40 Factors which determine the dust emission magnitude class of trackout activities are vehicle size,

vehicle speed, vehicle number, geology and duration. Examples of the potential dust emissions

classes are provided in the guidance as follows:

• Large: >50 Heavy Duty Vehicles (HDV) (>3.5t) trips in any one day, potentially dusty surface

material (e.g. high clay content), unpaved road length >100m;


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• Medium: 10 – 50 HDV (>3.5t) trips in any one day, moderately dusty surface material (e.g.

high clay content), unpaved road length 50 – 100m;

• Small: <10 HDV (>3.5t) trips in any one day, surface material with low potential for dust

release, unpaved road length <50m.

Definition of the Sensitivity of the Area

13.41 The sensitivity of the area is defined for dust soiling, human health and ecosystems as Low,

Medium or High. The sensitivity of the area takes into account the following factors:

• The specific sensitivities of human and ecological receptors in the area;

• The proximity and number of those receptors;

• In the case of PM10, the local background concentration;

• Site-specific factors, such as whether here are natural shelters such as trees, to reduce the

risk of wind-blown dust.

13.42 High sensitivity human and dust soiling receptors include residential properties, hospitals and

schools. High sensitivity ecological receptors in terms of air quality include Special Areas of

Conservation (SAC).

13.43 Medium sensitivity human and dust soiling receptors include offices, commercial buildings,

places of work and parks. Medium sensitivity ecological receptors include Sites of Special

Scientific Interest (SSSI).

13.44 Low sensitivity human and dust soiling receptors include playing fields, farmland, footpaths and

short term car parks. Low sensitivity ecological receptors include Local Nature Reserves.

13.45 No designated ecological receptors have been identified within 50m of the Revised Scheme or

the anticipated trackout route. Therefore, following the IAQM guidance, ecological receptors

have been screened out of the assessment and are not considered further.

13.46 There are several human receptors within 350m of the Revised Scheme and within 50m of the

trackout route. In particular, properties along Grove Lane R9 and R10 are in close proximity to

the Revised Scheme.

13.47 Based on the receptor sensitivity value assigned, the number of receptors and distance from the

Revised Scheme, a sensitivity classification for the area can be defined for each construction

activity in terms of dust soiling, human health and ecological effects. The tables below show how

the effect is calculated.

Table 13.3: Sensitivity of the area to dust soiling effects on people and property

Receptor Sensitivity Number of Receptors Distances from the Source (m)

<20 <50 <100 <350

High >100 High High Medium Low

10-100 High Medium Low Low

1-10 Medium Low Low Low

Medium >1 Medium Low Low Low

Low >1 Low Low Low Low


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Table 13.4: Sensitivity of the area to Human Health Effects

Receptor Sensitivity Annual

Mean

PM10

Conc.

Number

of

Receptors

Distances from the Source (m)

<20 <50 <100 <200 <350

High >100 High High High Medium Low

>32µg/m3 10-100 High High Medium Low Low

1-10 High Medium Low Low Low

28-32

µg/m3

>100 High High Medium Low Low



24-28

µg/m3

>100 High Medium Low Low Low


1-10 Medium Low Low Low Low

<24µg/m3 >100 Medium Low Low Low Low

10-100 Low Low Low Low Low

1-10 Low Low Low Low Low

Medium - >10 High Medium Low Low Low

- 1-10 Medium Low Low Low Low

Low - >1 Low Low Low Low Low

Table 13.5: Sensitivity of the area to Ecological Effects

Receptor Sensitivity Distances from the Source (m)

<20 <50

High High Medium

Medium Medium Low

Low Low Low

Definition of the Significance of the Effect

13.48 The dust emission magnitude classification and the sensitivity of the area are used to determine

a potential significance for each construction activity, before the application of mitigation. Tables

13.6 to 13.8 indicate the method used to assign the overall level of significance for each

construction activity.

Table 13.6: Significance of Dust Effects from Demolition

Sensitivity of Area Dust Emission Magnitude

Large Medium Small

High High Medium Medium

Medium High Medium Low

Low Medium Low Negligible

Table 13.7: Significance of Dust Effects from Earthworks/Construction


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Large Medium Small


Medium Medium Medium Low

Low Low Low Negligible

Table 13.8: Significance of Dust Effects from Trackout


Large Medium Small


Medium Medium Low Negligible

Low Low Low Negligible

13.49 The IAQM guidance does not recommend assigning the significance of construction activities

without mitigation. However, in EIA terms, high, medium, low and negligible are equivalent to

major, moderate, minor and negligible. Only those effects identified as high and medium are

considered to be significant within the meaning of the EIA Regulations, low and negligible are

considered not significant.

Definition Potential Mitigation and Residual Effects

13.50 Mitigation is divided into general measures, applicable to all sites and measures specific to

demolition, earthworks, construction and trackout. The mitigation recommended will build on

any embedded mitigation identified during the design evolution. Mitigation is only required

when significant effects are calculated. When effects are not significant, mitigation is not

required in accordance with the EIA regulations. However, enhancement measures will be

considered where appropriate.

Operational Phase Assessment Methodology

Need for operational effects assessment

13.51 The EPUK-IAQM guidance identifies various thresholds to determine whether an air quality

assessment is likely to be required for the operational phase of any development. The

assessment can be a qualitative assessment or a detailed assessment involving dispersion

modelling of emissions to air as determined by the consultation with the local authority. Based

on the number of vehicles generated, it is considered that an assessment of operational phase

air quality assessment is required. Following the consultation made with SDC, the requirement

to undertake a detailed operational assessment has been established.

13.52 A dispersion modelling assessment of operational phase effects on local air quality and at

sensitive receptor locations has been undertaken. The Study Area for the road traffic emissions

dispersion modelling was based on roads predicted to be affected by the Revised Scheme and

other cumulative development traffic generation, as identified on RS Figure 13.1.

13.53 There are two types of air quality effects considered for the Revised Scheme:


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• The effect of existing sources in the local area on the Revised Scheme (governed by

background pollutant levels and proximity to sources of air pollution);

• The effect of the Revised Scheme on the local area.

13.54 The magnitude of effects has been determined by the predicted ground level pollutant

concentrations. Sensitivity of the area has been determined by the presence of worst-case

exposed sensitive receptor locations. The significance of effects has been determined as per the

EPUK-IAQM guidance and is further described in the sections below.

Identifying the Significance of Effects

13.55 A dispersion modelling study has been conducted using an advanced model, ADMS-Roads. It is

widely used and validated within the UK and Europe. The model allows for the skewed nature of

turbulence within the atmospheric boundary layer. ADMS-Roads facilitates the prediction of

ground level concentrations of pollutants of concern at multiple receptor locations. The

predicted pollutant concentrations have then been compared with relevant air quality objectives

to identify the significance of effects and the level of mitigation required to reduce the potential

effects.

13.56 The effects of a development are usually assessed at selected ‘receptors’. In accordance to the

EPUK-IAQM guidance, the significance of effects is derived by the percentage of change in

pollution concentration relative to an Air Quality Assessment Level (AQAL) and long term average

pollutant concentration at receptor, as presented in Table 13.9.

13.57 Selected receptors according to the EPUK-IAQM guidance include residential receptors where

long term concentrations will be the appropriate air quality assessment level (1 calendar year

averaging period limit value). This is due to the extended period of time people will spend in their

residential properties and surrounding area. Conversely, any commercial developments assessed

will be compared to short term air quality assessment levels (24-hour averaging period limit

value) due to the reduced period of time spent in these types of areas.

Table 13.9: Effect Descriptors for Individual Receptors

Long term average

concentration at

receptor in

assessment year

% Change in concentration relative to Air Quality Assessment Level (AQAL)

1-2 2-5 5-10 >10

75% or less of AQAL Negligible Negligible Slight Moderate

79 – 94% of AQAL Negligible Slight Moderate Moderate

95 – 102% of AQAL Slight Moderate Moderate Substantial

103 – 109% of AQAL Moderate Moderate Substantial Substantial

110% or more of AQAL Moderate Substantial Substantial Substantial

13.58 A significant environmental effect is considered if the percentage of change in pollution

concentration relative to the AQAL is Moderate or Substantial.

Model Scenarios

13.59 Three scenarios have been modelled to predict the change in air quality as a consequence of the

Revised Scheme. The scenarios are as follows:


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• Scenario 1 (S1) - Base case scenario representing the ‘existing’ air quality situation in 2016;

• Scenario 2 (S2) - Without Development scenario for the future operation year (2021)

including any other committed/consented developments;

• Scenario 3 (S3) - With Development scenario for the future operation (2021) with the

Revised Scheme and including any other committed/consented developments (cumulative

effects).

Meteorological Data

13.60 Hourly sequential meteorological data has been employed in the dispersion model. Data was

recorded in 2016 at the Gloucestershire Airport meteorological monitoring station which is

located around 18km away from the Revised Scheme site.

Verification

13.61 The dispersion model results were ‘verified’ by comparison with monitoring data and adjusted

according to the procedure descried in LAQM.TG(16). The verification procedure is detailed at

Annex D of RS Appendix 13.1. The model was verified against the diffusion tube located at Mole

Cottage, Grove Lane, as illustrated on RS Figure 13.1.

Traffic Data

13.62 The transport consultants for the development scheme, PFA Consulting Ltd., provided the traffic

data for use in the model. The data provided is presented in Annex C of RS Appendix 13.1, and

described as follows:

• Scenario 1 – 2017 traffic data based on traffic counts taken at the relevant roads on 15th

September 2015. The transport consultants provided a TEMPRO growth factor to convert

2017 flows to 2016.

• Scenario 2 – 2021 opening year traffic data including traffic data from all other committed

developments.

• Scenario 3 – 2021 opening year traffic data including traffic data from all other committed

developments and the Revised Scheme.

13.63 The committed developments included within the traffic data are:

• Land West of Stonehouse

• Javelin Park

• Bond’s Mill Unit 27

• Westend Courtyard

• Land Adjacent to Eastington Trading Estate

• Land Adjoining Station Road

Receptor Locations

13.64 The receptors included in the Study Area, to a certain extent, are determined by the traffic data

provided for the modelling study. Sensitive receptor locations (for example, residential

properties) included in the assessment represents the worst-case exposed locations. The

receptors chosen include both existing receptors, such as at residential properties close to the

roads deemed to be affected by the Revised Scheme, and future receptors within the Revised


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Scheme. The receptors and roads included in the model are summarised in Table 13.10 and

illustrated in RS Figure 13.1. D3, D4, D6 and D8 – D11 are future onsite commercial receptors.

D1, D2, D5, D7 and D12 are future offsite receptors. R1, R3 – R14, R16 and R17 are residential

receptors and R18 is a school receptor.

Table 13.10: Receptors Included in the Dispersion Modelling Assessment

Receptor ID Receptor Location

Grid reference Height (m)

X Y

D1

Northwest area of Redline

Boundary, north of M5 377603 206664 1.5

D2

Within Redline Boundary–

south of M5 and A419 377847 206721 1.5

D3


south of M5 and north of

A419 377932 206812

1.5

D4



A419 377969 206716

1.5

D5


south of M5 and A419 377716 206591 1.5

D6



A419 378026 207005

1.5

D7


south of M5 and A419 377914 206687 1.5

D8



A419 378131 206547

1.5

D9



A419 - close to Grove Lane 378173 206907

1.5

D10



A419 378305 206390

1.5

D11



A419 - close to Grove Lane 378436 206612

1.5

D12


south of M5 and A419 377889 206383 1.5

R1

Residential property close

to A419 378264 206325 1.5

R2

Commercial property close

to Grove Lane 378463 206306 1.5

R3


to Spring Hill 378398 206080 1.5

R4


to Spring Hill 378322 205982 1.5

R5


to Spring Hill 378171 205862 1.5


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Receptor ID Receptor Location

Grid reference Height (m)

X Y

R6


to Spring Hill 378175 205810 1.5

R7


to Spring Hill 378116 205774 1.5

R8


to Spring Hill 377963 205530 1.5

R9


to Grove Lane 378402 206731 1.5

R10


to Grove Lane 378324 206817 1.5

R11


to Grove Lane 378275 206956 1.5

R12


to Grove Lane 378289 207000 1.5

R13


to A38 377400 207543 1.5

R14


to A38 377296 207457 1.5

R15

Commercial property close

to M5/A419 junction 377710 206880 1.5

R16

Residential property on

Bristol Road 379894 205225 1.5

R17

Residential property on

Downtown Road 380485 204870 1.5

R18 School on Ebley Road 381389 204722 1.5

V1

Verification site - Mole

Cottage, Grove Lane 378290 206899 2.0

*Verification site (Mole Cottage, Grove Lane diffusion tube)

Baseline Conditions

13.65 Existing or ‘baseline’ air quality refers to the existing concentrations of relevant substances

present in ambient air. These substances may be emitted by various sources, including road

traffic, industrial, domestic, agricultural and natural sources. Baseline air quality data employed

in this study have been obtained from diffusion tube monitoring stations maintained by SDC and

from the Local Air Quality Management (LAQM) Support website maintained by Defra.

13.66 According to SDC’s 2016 Air Quality Progress Report, there were no automatic monitoring

stations operating within the district. NO2 was monitored using passive diffusion tubes at 25

sites.

13.67 The annual average NO2 concentrations obtained at monitoring locations within 6km from the

Revised Scheme are reproduced in Table 13.11. These data show that there were no

exceedances of the annual mean standard for NO2 at the listed monitoring locations.

Table 13.11: Annual Average Measured Pollutant Concentrations at Monitoring Sites Nearest to

the Revised Scheme Site


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Site Approx. distance from

Redline Boundary(km)

2015 Annual Average

NO2 (µg/m3)

2016 Annual Average

NO2 (µg/m3)

Stonehouse –

Mole Cottage,

Grove Lane

0.3 NA 16.7

10 Bristol Road 2.7 20.9 NA

Haresfield – The

Lodge 4.3 NA 24.1

Cainscross – 22

Westward Road 5.6 29.5 29.1

Cainscross – 2 The

Rosaries Paganhill

Lane

5.6 37.5 35.4

Hardwicke –

Trevose 5.6 NA 34.6

Air quality objective (annual mean) 40µg/m3

13.68 In addition to the local monitoring data, estimated background air quality data available from

the LAQM Support website are also used to establish likely background air quality conditions at

the Site. The LAQM website provides estimated annual average background concentrations of

NOx, NO2 PM10 and PM2.5 on a 1km2 grid basis (see Section 4.4 of RS Appendix 13.1). No

exceedance of annual average air quality objectives for human health, for NO2 or PM10 is

predicted at background locations.

13.69 As no background automatic monitoring is undertaken at the Site, the estimated background

pollutant concentrations from the LAQM website for 2016 (with in-square A-road and motorway

contributions removed to avoid ‘double counting’) will be used in the assessment as identified in

Table 13.12. This is considered representative of local air quality conditions at the Site.

Table 13.12: Baseline air quality conditions to be used in model

Assessment

Year

Estimated Annual Average Pollutant Concentrations Derived from the LAQM

Website

Annual Average

NOX (µg/m3)

Annual Average

NO2 (µg/m3)

Annual Average

PM10 (µg/m3)

Annual Average

PM2.5 (µg/m3)

2016 14.0 10.3 16.2 11.1

Air Quality

Objective 30^ 40 40 25

^ air quality objective designated for the protection of vegetation and ecosystems only.

13.70 The baseline air quality estimated at the Site does not exceed the relevant air quality objectives

for NOx, NO2, PM10 and PM2.5.

2017 Traffic Baseline

13.71 The opening year for this assessment is 2017, when the Revised Scheme is assumed to be in

place. Background traffic flows have been factored to 2017 based upon the National Transport

Model (NTM) adjusted using TEMPRO (NTEM Dataset 6.2). This takes account of changes in car

ownership, as well as local planning forecasts regarding housing and employment. More details

are provided in Chapter 12 and the accompanying Transport Assessment (RS Appendix 12.1).


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13.72 Policy SA2 of Stroud District Local Plan 2015 allocates land to the West of Stonehouse for mixed

use development including residential, employment and community uses, and a planning

application (Reference S. 14/0810/OUT) has been granted with work now commencing on site

following the approval of Reserved Matters. The location of the site is identified on RS Figure

18.1 of this ES, and traffic generated by this development is included in the 2017 baseline traffic

forecasts.

13.73 As part of the West of Stonehouse development, improvements to Chipmans Platt roundabout,

which form part of the A419 Stonehouse Corridor scheme approved under the Gloucestershire

Growth Deal, will be brought forward. The improvements include widening to two lane entry

and exit on each of the A419 approaches. The West of Stonehouse proposals also include

improvements to the northbound on-slip to the M5 at Junction 13. This will upgrade the slip

road to current standards but is not expected to have a significant effect on junction capacity.

Both of these schemes are assumed to be in place in the 2017 Baseline. The remaining schemes

which form part of the Gloucestershire Growth Fund A419 Corridor Improvement lie outside the

Study Area for this Chapter.

Design Evolution

Embedded Mitigation/Enhancements

13.74 Mitigation measures that have been identified and adopted as part of the evolution of the project

design (embedded into the project design) and that are relevant to air quality are as follows:

• The provision and compliance with a Green Travel Plan which will have examined all

options for sustainable travel to and from the Site.

• Source energy from renewable energy sources, including the provision of on-site

renewable energy production;

• Principal benchmark to be adopted will be BREEAM;

• The provision of a footway/cycleway on the south side of the A419, that would link

Stonehouse to the Revised Scheme helping to encourage people to walk and cycle.

• Sustainable construction;

• Encourage procurement of energy-efficient equipment;

• Construction site operative awareness and training in sustainable practices.

Potential Effects

Construction Phase

13.75 Construction activities, including the transport of material to and from the Revised Scheme may

cause dust nuisance and deterioration of air quality, albeit for a limited period. The scale of the

Revised Scheme is considered to be ‘medium’ and there are sensitive receptors located within

20m of the Revised Scheme on Grove Lane. Appropriate mitigation or enhancement measures

to reduce dust and air quality effects will be implemented through a DMP.

Exhaust Emissions from Plant and Vehicles

13.76 The operation of vehicles and equipment powered by internal combustion engines results in the

emission of exhaust gases containing the pollutants NOx, PM10, volatile organic compounds

(VOCs), and carbon monoxide (CO). The quantities emitted depend on factors such as engine

type, service history, pattern of usage and fuel composition. The operation of site equipment,


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vehicles and machinery will result in emissions to atmosphere of exhaust gases, but such

emissions are unlikely to be significant, particularly in comparison with levels of similar emission

components from vehicle movements on the local road network surrounding the Site.

13.77 Construction traffic will comprise haulage/ construction vehicles and vehicles used for workers’

trips to and from the Site. The estimated number of car and Heavy Goods Vehicle (HGV)

movements from the Revised Scheme associated with construction traffic are 260 and 100,

respectively. As construction phase impacts are temporary and local to the Site, further

assessment is not considered necessary. Traffic management would be dealt with via the DMP

to reduce air quality impacts.

13.78 It is noted that as shown on the Indicative Construction Compound Plan (RS Figure 5.4), the

construction compound will be located in the southern parts of the Revised Scheme and is not in

proximity to the sensitive receptors along Grove Lane.

13.79 The cumulative effect of construction traffic will not be significant and the effect will be low due

to the distance of the other committed developments to the Revised Scheme site.

Fugitive Dust Emissions

13.80 Fugitive dust emissions arising from construction activities are likely to be variable in nature and

will depend upon the type and extent of the activity, soil type and moisture, road surface

conditions and weather conditions. Periods of dry weather combined with higher than average

wind speeds have the potential to generate more dust.

13.81 Construction activities that are considered to be the most significant potential sources of fugitive

dust emissions are:

• Demolition of existing buildings and the size reduction and handling of materials;

• Earth moving, due to the handling, storage and disposal of soil and subsoil materials;

• Construction aggregate usage, due to the transport, unloading, storage and use of dry and

dusty materials (such as cement and sand);

• Movement of heavy site vehicles on dry or untreated haul routes;

• Movement of vehicles over surfaces where muddy materials have been transferred off-

site (for example, on to public highways).

13.82 Fugitive dust arising from construction and demolition activities is mainly of a particle size greater

than the PM10 fraction (that which can potentially impact upon human health), however it is

noted that demolition and construction activities may contribute to local PM10 concentrations.

Appropriate dust control measures can be highly effective for controlling emissions from

potentially dust generating activities identified above, and adverse effects can be greatly reduced

or eliminated.

Potential Dust Magnitude

13.83 With reference to the IAQM guidance criteria, the dust emissions magnitude for demolition,

earthworks, construction and trackout activities are summarised in Tables 13.13 to 13.16. Risk

categories for the four construction activities are summarised in Table 13.17. Worst case

assumptions have been made throughout.

Table 13.13: Summary of Dust Emissions Magnitude of Demolition Activities (Before mitigation)


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Demolition Criteria Dust Emissions Class Evaluation of the Effects

Total volume of buildings to be

demolished Small <20,000m3

On-site crushing and screening Medium Yes, on-site crushing and screening

proposed

Height of demolition activities

above ground Small <10m above ground

Dust potential of demolition

materials Medium Potentially dusty construction materials

Overall Rating Medium Worst case

Table 13.14: Summary of Dust Emissions Magnitude of Earthworks Activities (Before mitigation)

Earthworks Criteria Dust Emissions Class Evaluation of the Effects

Total site area Large >10,000m2

Soil type Large Clay

Earth moving vehicles at any one

time Medium

Maximum of 5-10 heavy earth moving

vehicles active at any one time

Height of bunds Small <4m

Total material moved Large > 100,000 tonnes material to be moved

Work times Medium Earthworks proposed in all seasons

Overall Rating Large Worst case

Table 13.15: Summary of Dust Emissions Magnitude of Construction Activities (Before

mitigation)

Construction Criteria Dust Emissions Class Evaluation of the Effects

Total building volume Large > 100,000m3

On-site concrete batching or

sandblasting proposed Small None proposed

Dust potential of construction

materials Medium Potentially dusty materials


Table 13.16: Summary of Dust Emissions Magnitude of Trackout Activities (Before mitigation)

Trackout Criteria Dust Emissions Class Evaluation of the Effects

Number of HDV>3.5t per day Large >50 heavy vehicles per day

Surface type of the site Medium Mix of hard and soft

Length of unpaved road Small <50m unpaved roads


Table 13.17: Summary of Dust Emission Magnitude of the Site (Before mitigation)

Construction Activities Dust Emissions Class

Demolition Medium

Earthworks Large

Construction Medium

Trackout Medium


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13.84 The construction activities have the potential to have a significant effect on the surrounding

environment. Therefore, the sensitivity of the area must be evaluated to determine whether the

construction activities will have a significant effect in relation to the level of sensitivity of the

area.

Sensitivity of the Area

13.85 As per the IAQM Guidance, the sensitivity of the area takes into account a number of factors;

consideration is given to human and ecological receptors from the effect of the construction of

the Revised Scheme and the trackout route proposed.

13.86 RS Figure 13.2 shows a map indicating the construction buffer and RS Figure 13.3 shows the

trackout buffer for identifying the sensitivity of the area. It is noted that the majority of

construction traffic is expected to be routed via the A419 and M5 to the west of the Site; no

construction traffic will be permitted to use Grove Lane or Spring Hill, as per Chapter 12. Table

13.18 presents the determined sensitivity of the area with the factors itemised which have

helped to define this.

13.87 Construction activities are relevant up to 350m from the Revised Scheme whereas trackout

activities are only considered relevant up to 50m from the edge of the road, as per the guidance.

Only 20m and 50m buffers have been included for trackout for this reason.

13.88 The table below details the receptor sensitivity to dust soiling and human health. Receptor

sensitivity is determined by the types of receptors present near the Revised Scheme. High

sensitivity receptors include residential dwellings, hospitals and schools. The overall sensitivity

of the area is then calculated with reference to Table 13.18.

Table 13.18: Sensitivity of the area

Potential

Effect

Sensitivity of the surrounding area

Demolition Earthworks Construction Trackout

Annoyance

from Dust

soiling

Receptor

sensitivity High High High High

Number of

receptors 1-10 1-10 1-10 1-10

Distance from

the source <20m <20m <20m <20m

Sensitivity of

the area Medium Medium Medium Medium

Risk to

Human

health

Receptor

sensitivity High High High High

Annual mean

PM10

concentration

<2424c3 <2424c3 <2424c3 <2424c3

Number of

receptors 1-10 1-10 1-10 1-10

Distance from

the source <20m <20m <20m <20m

Sensitivity of

the area Low Low Low Low


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Potential

Effect

Sensitivity of the surrounding area


Risk to

Ecology

Receptor

sensitivity There are no designated ecologically sensitive sites within 50m

of the Site or proposed trackout routes. Distance from

the source

Sensitivity of

the area Negligible

13.89 Grove Lane properties are the closest receptors to the Revised Scheme. It is likely that residents

at these properties will receive the largest effects associated with the construction phase.

Mitigation should be geared towards ensuring the effect of dust soiling and to human health is

minimised as much as possible for the residents along Grove Lane.

Significance of Effects

13.90 The dust emission magnitude summarised in Table 13.17 have been combined with the

sensitivity of the area in Table 13.18 to determine the potential effects of construction activities

before mitigation. The potential of dust effects from construction activities is identified in Table

13.19. Site specific mitigation measures to reduce construction phase effects are defined based

on this assessment.

Table 13.19: Summary of the Potential Effect from Construction Activities (prior to mitigation)

Potential Effect Dust Effect on Receptors


Dust soiling Medium Medium Medium Medium

Human health Low Low Low Low

Ecological Negligible Negligible Negligible Negligible

13.91 In EIA terms, the construction activities will not have a significant effect on human health and

the local ecology. However, there will be a significant effect on the surrounding environment as

a result of dust soiling if no mitigation measures are put into place.


Construction phase

13.92 Further to the embedded mitigation relevant to air quality summaries in the Design Evolution

section, the following mitigation measures will be adopted in order to further minimise

significant effects and non-significant effects of dust soiling on air quality.

13.93 The detailed specification of mitigation measures in the DMP will depend on the selection of

construction techniques and programme. However typical recommended mitigation measures for

construction phase effects are likely to include:

Site Planning

• No bonfires on site;


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• Plan site layout – plant/vehicles/dust-generating activities should be located away from

sensitive receptors as far as practicable;

• All site personnel to be trained in awareness of site environmental controls;

• Trained and responsible manager on site during working hours to maintain logbook and

carry out site inspections.

Construction Plant and Traffic Emissions

• No idling vehicles on site;

• Vehicle wheel washing facilities to be provided at site exit;

• All loads/vehicles-entering site to be covered;

• Prevention of site runoff of mud and water;

• On-road vehicles to comply with emissions standards;

• All non road mobile machinery to use ultra low sulphur diesel where available and be fitted

with exhaust after-treatment, where appropriate;

• Minimise vehicle speeds and movements on site.

Site Activities

• Use water as a dust suppressant as appropriate;

• Cover, seed or fence stockpiles to prevent wind whipping;

• Minimise dust-generating activities as far as is practicable;

• Ensure any cutting equipment has water suppression or suitable local exhaust ventilation

system.

Operational Phase

13.94 Sensitive receptors have been selected at residential properties located along the A38, M5, A419,

Spring Hill and Grove Lane. Annex D of RS Appendix 13.1 presents the predicted NO2, PM10 and

PM2.5 concentrations for all of the assessed scenarios at the assessed receptor locations. Table

13.20 shows the comparison of annual mean NO2 concentrations under the ‘S2 Without

development 2021’ and ‘S3 With Development 2021’ scenarios at the assessed existing receptor

locations. The percentage changes in annual mean NO2 concentrations relative to the air quality

objective and the classification of effect magnitudes with reference to the EPUK-IAQM guidance

are also presented.

13.95 The maximum annual mean NO2 increase and air quality effect as a result of the development is

predicted to be 1.3µg/m3 at R16 (residential property Bristol Road) (3.3% change relative to the

Air Quality Assessment Level (AQAL)). This 3.3% change corresponds to a ‘negligible’ air quality

effect, as the existing concentration is <75% of the AQAL. RS Figure 13.4 presents the annual

mean NO2 concentration isopleth for the ‘S3 With Development 2021’ scenario.

Table 13.20: Comparison of Predicted Long-Term NO2 Concentrations between the ‘S2 Without

development 2021’ and ‘S3 With Development 2021’ Scenarios


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Receptor

ID

Without Development

2021

With Development

2021 Change

Predicted

Effect

(µg/m3) % of AQAL (µg/m3) % of AQAL (µg/m3)A % Change

NO2

concentra

tion

relative to

AQALA

D1 - - 19.9 - - - -

D2 - - 23.0 - - - -

D3 - - 24.0 - - - -

D4 - - 24.6 - - - -

D5 - - 23.2 - - - -

D6 - - 29.7 - - - -

D7 - - 20.9 - - - -

D8 - - 24.6 - - - -

D9 - - 15.4 - - - -

D10 - - 21.3 - - - -

D11 - - 15.0 - - - -

D12 - - 13.6 - - - -

R1 16.3 40.8 16.8 42.0 0.5 1.2 Negligible

R2 19.5 48.7 20.0 50.1 0.6 1.4 Negligible

R3 16.6 41.4 17.0 42.4 0.4 1.0 Negligible

R4 18.0 44.9 18.4 46.0 0.4 1.1 Negligible

R5 14.4 36.0 14.6 36.6 0.2 0.6 Negligible

R6 15.6 39.0 15.9 39.8 0.3 0.8 Negligible

R7 16.7 41.7 17.0 42.6 0.4 0.9 Negligible

R8 18.1 45.2 18.5 46.3 0.4 1.1 Negligible

R9 16.6 41.5 16.7 41.7 0.1 0.2 Negligible

R10 17.2 43.1 17.3 43.3 0.1 0.2 Negligible

R11 18.5 46.2 18.6 46.5 0.1 0.2 Negligible

R12 22.4 56.1 22.5 56.3 0.1 0.2 Negligible

R13 20.7 51.9 20.9 52.2 0.2 0.4 Negligible

R14 15.6 38.9 15.6 39.1 0.1 0.2 Negligible

R15 18.9 47.3 19.1 47.8 0.2 0.4 Negligible

R16 24.5 61.2 25.8 64.5 1.3 3.3 Negligible

R17 20.1 50.1 20.8 52.1 0.8 1.9 Negligible

R18 18.3 45.9 18.4 46.1 0.1 0.3 Negligible AChange based on unrounded values

13.96 The predicted PM10 and PM2.5 concentrations at all the assessed receptors and under all scenarios

will not exceed the relevant air quality objectives. With reference to the EPUK-IAQM guidance,

the Revised Scheme will have a ‘negligible’ predicted effect upon annual mean PM10 and PM2.5

concentrations, as all concentration changes are equal to or less that 0.7% of the standard and

existing concentrations are likely to be ‘well below’ (<75%) the relevant AQALs. Isopleths for the

‘S3 With Development 2021’ scenario for annual mean PM10 and PM2.5 concentration are

presented on RS Figure 13.5 and RS Figure 13.6, respectively.

13.97 In regard to exposure, future receptors within the Revised Scheme have been assessed. As the

Revised Scheme is commercial only the short-term NO2 objective applies to receptors. Short-

term NO2 refers to the 1 hour mean objective which is relevant for commercial sites where

exposure time is limited to the working hours.

13.98 No exceedances at any receptors have been predicted with the maximum short-term

concentration being 45.6µg/m3 at receptor D6 (D6 being adjacent to the M5 motorway and


December 2015

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therefore representing worst case within the Revised Scheme). This is below the air quality

objective of 200µg/m3 and therefore exposure to future receptors within the Revised Scheme is

considered to not be significant.


Operational Phase Mitigation

13.99 The assessment demonstrates that the operational phase air quality effects of the Revised

Scheme are negligible and therefore, not significant following the embedded mitigation

discussed under the Design Evolution heading above. The provision and compliance with an

Outline Travel Plan (as included in RS Appendix 12.2), which has examined all options for

sustainable travel to and from the Site, will help to encourage travel by more sustainable

methods of transport. The following measures are proposed:

• Public transport information available through FGRFC’s website;

• As required additional buses to/ from local supporter hotspots including Stonehouse,

Stroud and Nailsworth;

• As required shuttle buses to/ from Stonehouse and Cam & Dursley rail stations;

• Bus and coach drop off areas within the Site;

• Supporter carshare link via FGRFC’s website;

• Safe linkage to pedestrian routes from Stonehouse and West of Stonehouse;

• Vehicle free area around the Stadium;

• Convenient cycle parking.

13.100 These enhancement measures should reduce any potential adverse effect further.

13.101 Fixed energy source details are not available at this stage of the project for the Revised Scheme.

Once identified (Reserved Matters stage) these sources may require additional assessment.

Residual Effects

13.102 With the proposed mitigation measures (in relation to the significant effect of the construction

phase on dust soiling) and enhancements (in relation to the operational phase where no

significant effects were found) in place, the significance of the residual effects is considered to

be ‘not significant’. Table 13.21 located at the end of the chapter summarises the residual effects

before and after mitigation during the construction and operational phase.

Cumulative Effects


13.103 Due to the separation distance between the Revised Scheme site and the other committed

developments nearby and also due to different traffic routes, it is not considered likely that

cumulative effects during the construction phase are significant. Furthermore, the potential

effects of this development during the construction phase will be temporary i.e. only during the

construction and demolition period. The estimated number of car and HGV movements from the

Revised Scheme are 260 and 100, respectively. The cumulative effect of construction traffic was

not assessed within the scope of this report. However, construction traffic is localised to the

roads nearby the Revised Scheme.


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13.104 With regards to nearby residential receptors, there is potential for a significant effect as a result

of dust soiling during the construction phase if the Revised Scheme construction activities occur

at the same time as the Land West of Stonehouse developments. In such an eventuality, traffic

management would be dealt with via the DMP and necessary legal agreements for each of the

respective developments. This will ensure no significant effect. The same assessment will apply

when considering both the effect on human health and ecology.

Operational Effects

13.105 The Baseline Conditions section explains that the proposed development on the land West of

Stonehouse (Policy SA2 in Stroud District Local Plan 2015) is included in the 2017 baseline.

Improvements to Chipmans Platt roundabout and to the northbound on slip to the M5 at

Junction 13, which lie within the Study Area, are also assumed to be implemented. The proposals

for the land West of Stonehouse also include contributions towards public transport, and it is

assumed that the Revised Scheme can build upon these.

13.106 Traffic generated by the remaining developments identified in Chapter 18 of this ES is taken into

account through the application of traffic growth factors obtained from the NTM adjusted using

TEMPRO (NTEM Dataset 6.2). The TEMPRO program is based on the National Trip End Model

and takes into account changes in car ownership, and local planning forecasts regarding housing

and employment.

13.107 The access to the Revised Scheme has been designed to accommodate future traffic flows

allowing for committed developments. There are therefore no further cumulative effects to be

taken into account during operation. The assessment found that the cumulative effect of traffic

will not be significant in relation to air quality during the operational phase.

Conclusions

13.108 With the implementation of the proposed construction phase mitigation measures (detailed in

Annex F of RS Appendix 13.1), the residual effects are considered to be negligible.

13.109 The modelled proposed receptors are not predicted to experience pollutant concentrations

above the annual mean NO2, PM10 or PM2.5 objectives; hence, it is not considered that there

would be a risk of increased exposure at the Site. The Revised Scheme is predicted to have a

‘negligible’ air quality effect on all of the surrounding sensitive receptors and proposed

receptors.

13.110 The potential for dust effects on receptors was predicted to be a maximum of ‘medium’ during

the construction phase without mitigation. With mitigation in place the construction phase effect

will not be significant. However, residential receptors located near to the Revised Scheme should

be considered within the Air Quality Management Plan during the construction phase as the

largest effect will be seen at these. Site specific enhancements have also been assigned to

reduce the effect for general site activities and construction activity-specific activities.

13.111 The principal air quality effects once the Revised Scheme is complete and operational is likely to

be emissions from increased road traffic associated with the scheme. An assessment of

operational effects has been undertaken using the latest version of the ADMS-Roads

atmospheric dispersion model.


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13.112 Concentrations of the key pollutants (NO2, PM10 or PM2.5) were predicted at the most relevant

receptor locations for the base year 2016, and for the year 2021. The air quality effects of the

Revised Scheme on existing receptors and the effect of future local air quality upon the Revised

Scheme receptors have been assessed.

13.113 The predicted pollutant concentrations have been verified and adjusted against the measured

concentrations.

Effect of the Development on Local Air Quality

13.114 No exceedance of any of the relevant air quality objectives was predicted at any of the assessed

existing receptor locations under any of the assessed scenarios. As a result of the development

(S3 2021 With Development), there is a ‘negligible’ air quality effect predicted with regard to

annual mean NO2, PM10 or PM2.5 on existing sensitive receptors assessed, as per the EPUK-IAQM

guidance. This effect will also be very infrequent given the number of games FGR play at home

every year. Therefore, the effect will not be significant in EIA terms.

Effect of Future Air Quality on the Proposed Sensitive Receptors

13.115 The predicted long-term PM10 and PM2.5 and short-term NO2 and PM10 concentrations, at all of

the assessed receptors within the Development Footprint will not exceed the relevant air quality

objectives under any of the assessed scenarios.

13.116 The Revised Scheme is designed for commercial use and therefore the short-term NO2 objective

applies to the Revised Scheme receptors (rather than the annual mean NO2 objective). No

exceedance of the short-term NO2 air quality objective has been predicted at any of the proposed

receptor locations within the Redline Boundary or the Revised Scheme. Therefore, the effect will

not be significant in EIA terms.

13.117 In view of the above, and with reference to EPUK-IAQM guidance, the Revised Scheme is

considered to have no significant effects on local air quality including those at the existing and

proposed receptor locations.


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Table 13.21: Summary of Air Quality and Dust Effects and Mitigation

Receptor Effect Development Phase Sensitivity/

importance of

receptor

Magnitude change Level of Effect (and

Significance) prior

to mitigation

Mitigation Enhancement Level of Effect (and

Significance) after

mitigation

Nature of Effect

Residential

receptors (R1, R3 to

R14, R16, and R17)

and School

Receptor (R18)

Dust Soiling Construction Residential

dwelling/ School

Sensitivity high.

N/A Medium effect /

significant

Implement a

construction phase

air quality

management plan

N/A Dust levels

acceptable / not

significant

Negative, Medium

Term

Residential


R14, R16 and R17)

and School

Receptor (R18)

Human Health Construction Residential

dwelling/ School

Sensitivity high.

N/A Low effect / not

significant

N/A Implement a

construction phase

dust management

plan

Dust levels

acceptable / not

significant

Negative, Medium

Term

Residential


R14, R16 and R17)

and School

Receptor (R18)

Exhaust Emissions Construction Residential

dwelling/ School.

Sensitivity high.


significant

N/A Implement a

construction phase

dust management

plan

Dust levels and

exhaust emissions

acceptable / not

significant

Negative, Medium

Term

Commercial

receptors (R2, R15)

Human Health /

Dust Soiling /

Exhaust Emissions

Construction Commercial

dwelling Sensitivity

low.


significant

N/A Implement a

construction phase

dust management

plan

Dust levels and

exhaust emissions

acceptable / not

significant

Negative, Medium

Term

All residential

receptors (R1, R3-

R14, R16 and R17)

and School

Receptor (R18)

Exposure to NO2,

PM10 and PM2.5

from exhaust

emissions

Operational Residential

dwelling/ School.

Sensitivity high.

Negligible Not significant Embedded

mitigation (see

Design Evolution)

N/A Air quality levels

acceptable / not

significant

Negative, Long

Term

Commercial

receptors (R2, R15)

Exposure to NO2,

PM10 and PM2.5

from exhaust

emissions

Operational Commercial sites.

Sensitivity low.


mitigation (see

Design Evolution)


acceptable / not

significant

Negative, Long

Term


December 2015

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Future receptors

within the Redline

Boundary (D1 to

D12)

Exposure to NO2,

PM10 and PM2.5

from exhaust

emissions

Operational Commercial sites.

Sensitivity low.


mitigation (see

Design Evolution)


acceptable / not

significant

Negative, Long

Term


December 2017

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14 LIGHTING

Summary

14.1 This chapter describes the assessment work undertaken by Hopkins Coats Associates (HCA) to

detail and describe the likely significant environmental effects of the proposed external lighting,

in association with the Revised Scheme. This chapter assesses artificial lighting in all areas of the

Development Footprint, as well as the additional lighting required along the A419.

14.2 The lighting impact assessment also assesses the potential effects on the existing adjacent

properties, users of the M5 and A419 carriageways, as well as other sensitive receptors such as

the existing Industrial Heritage Conservation Area (IHCA) and local wildlife.

14.3 The lighting strategy produced should be considered as a provisional design in accordance with

the Institution of Lighting Professionals (ILP). The provisional design is based on the Indicative

Concept Plan (RS Figure 1.1), along with the indicative parameter plans (RS Figures 5.1 to 5.3)

and the Indicative Construction Compound Plan (RS Figure 5.4) submitted with this

Environmental Statement (ES). The lighting impact assessment has also been undertaken in

accordance with the parameters set out by the ILP. In the event that planning permission is

granted, a final design will need to be generated in accordance with the parameters set out by

the ILP at a later date, to discharge the Reserved Matters. For this Revised Scheme, a provisional

lighting scheme has been generated for the entire development requiring artificial light. This

includes the Development Footprint applied for in outline, and the access arrangements applied

for in full.

14.4 The Development Footprint consists of a stadium and two training pitches for the Forest Green

Rovers Football Club (FGRFC) together with supporting ancillary facilities (such as changing

rooms, food and drink outlets, Club shop etc., public realm and car parking areas).

14.5 The existing Redline Boundary (which also includes the development parcels south of the A419

and west of the M5), contains no artificial light sources and has a negligible lighting effect on the

surrounding area. There is some light spill into the existing undeveloped site within the Redline

Boundary from adjacent properties. This is particularly noticeable around the William Morris

College (WMC) car park, where light spills from the car park into the Redline Boundary.

Stadium Lighting

14.6 The development will introduce an addition to the existing sky glow when the stadium lighting is

in operation (i.e. during evening matches). The increase in sky glow has been identified as a major

adverse effect in accordance with Table 14.3 below. This in turn has been identified as a

significant environmental effect within the meaning of the Environmental Impact Assessment

(EIA) Regulations. However, in terms of frequency, based on the 2017 – 2018 season, FGRFC

home matches are expected to occur approximately thirty times per year, or two to three times

per month on average, with not all of these taking place in the evening or a time of year when

stadium lighting will create the same significant effect (for example, during lighter evenings).

Significant effects caused by sky glow are thus infrequent.

Site wide Lighting (other than the Stadium)


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14.7 The provisional lighting scheme also shows that minimal light will be spilled into the bat corridors

designated for the Revised Scheme (as identified on RS Figure 5.3), which has been categorised

as a minor negative effect in accordance with Table 14.3. This in turn is deemed not significant

in EIA terms. Light intrusion, threshold increment, and luminance intensity are assessed as minor

negative or negligible effects in accordance with Table 14.3 and not EIA significant.

14.8 Mitigation and enhancement measures have been suggested to minimise the above effects.

These accord with mitigation methods recommended by the ILP. This includes the use of LED

lighting with specialist optics to further mitigate the backward spill of light. This, in tandem with

back shields, will help to eradicate the light spill into sensitive areas.

14.9 The use of an additional screened fence around the periphery of the site could be considered.

Particular attention should be made to areas observing the highest level of light spill, as identified

on RS Figure 14.5.

14.10 Following the implementation of mitigation and enhancement measures, whilst an overall

negative lighting effect remains on what is currently an unlit environment, in accordance with

Table 14.3, this is to be considered not significant in EIA terms.

Introduction

14.11 This chapter presents the findings of an assessment of baseline artificial lighting levels and

predicted effects on the local area resulting from the proposed lighting design assumed for the

Revised Scheme. The assessment covers the effects of artificial lighting from the Revised Scheme

on existing residential properties, motorists along the M5 and A419, the IHCA and local wildlife.

The Development Footprint will have year-round use and it is important for the lighting strategy

to provide adequate safe illumination levels for users of the facilities while minimising light spill

to existing residential and ecological receptors around the perimeter of the Site.

Lighting legislation and Guidance

14.12 This lighting impact assessment has been written by HCA, a Chartered Building Services

Engineering Consultancy registered with the Charted Institution of Building Services Engineers

(CIBSE). Specifically, this assessment has been carried out by Peter Hopkins. Peter has a Bachelor

Degree in Engineer, 7 years’ experience as a Consultant Engineer; 3 years of which as a Partner

at HCA.

Governing regulations and guidance documents

14.13 The Revised Scheme must comply with the Building Regulations amongst other governing

guidance documents and regulations (typically stipulated by the Building Regulations) as noted

below. These documents evaluate task areas, illuminance levels and allowable negative effects.

The guidance documents considered in this lighting assessment are detailed below:

• British Standards Institution, 2013, BS 5489-1, ‘Light of roads and public amenity areas’

• British Standards Institution, 2014, BS EN 12464-2, ‘Light and lighting. Lighting of work

places. Outdoor work places’

• British Standards Institution, 2007, BS EN 12193, ‘Light and lighting. Sports lighting’

• British Standards Institution, 2015, BS EN 13201-2, ‘Road Lighting. Performance

requirements’


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• Chartered Institution of Building Services Engineers, 2006, LG04, ‘Lighting Guide 04: Sports

Lighting’

• Chartered Institution of Building Services Engineers, 2016, LG06/16, ‘Lighting Guide 06:

The Exterior Environment’

• Bat Conservation Trust, 2014, ‘Artificial lighting and wildlife – Interim Guidance:

Recommendations to help minimise the impact artificial lighting’

• Bat Conservation Trust, 2009, ‘Bats And Lighting In The UK Bats and the Built Environment

Series’

• International Commission on Illumination, 2003, CIE 150, ‘Guide on the Limitation of the

Effects of Obtrusive Lighting from Outdoor Lighting Installations’

• Institution of Lighting Professionals, 2011, GN01, ‘Guidance Notes for the Reduction of

Obtrusive Light’

• Institution of Lighting Professionals, 2013, PLG02, ‘The Application of Conflict Areas on the

Highway’

• Institution of Lighting Professionals, 2013, PLG04, ‘Guidance on Undertaking

Environmental Lighting Impact Assessments’

14.14 Site usage/ task areas and associated illuminance levels, together with the relevant guidance

documents are as defined in Table 14.1 and as detailed on RS Figure 14.2. There are a number

of different task areas/ uses for the Revised Scheme. Artificial lighting is required to allow users

of each task area to see hazards, orientate themselves, recognise other users and to help them

feel more secure. Each use/ task area requires a different level of illumination governed by its

associated governing guidance document. Provisional task areas are identified in RS Figure 14.3.

Table 14.1: Guidance Illumination Levels for Each Task Area

Task area Illumination

level

Standard Other notes

Public car

park

20 lux average

0.25 uniformity

BS 5489-1 clause

7.4.8.3 table 5.

Car park areas likely to contain heavy traffic

(vehicular and pedestrian) at certain times.

Private

roads

15 lux average

0.40 uniformity

BS EN 13201 class

CE3

Roads likely to have conflict areas138 as

motorised traffic will intersect pedestrians at

certain times.

General

roads

15 lux average

0.40 uniformity

BS EN 13201 class

CE3

Roads likely to have conflict areas as

motorised traffic will intersect pedestrians at

certain times.

Footpaths

and

amenity

areas

5 lux average

1 lux minimum

maintained

BS 5489-1 clause

A3.3.1 table A5.

Footpath and amenity areas likely to be

conflict areas.

Principal

club

stadium

200 lux average

0.7 uniformity

LG04 section 3.23. Association football pitch class II (suitable for

principal/ small club).

A419 dual

carriageway

20 lux average

0.4 uniformity

BS EN 13201-2

section 5.

Class CE2 following recommendations of

transport consultant.

138 A Conflict area shall be as defined in section 7.5 of BS5489 as “Conflict areas are typically junctions, intersections,

roundabouts and pedestrian crossings, where significant streams of motorised traffic intersect with each other or with

other road users such as pedestrians and cyclists.” Road users will intersect other road users as well as pedestrians

and cyclists in the Development Footprint.


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14.15 This lighting assessment has been written in accordance with the ILP PLG 04 guidance document,

and illumination levels have been designed in accordance with the documents identified above.

Guidance on Permissible Lighting Levels

14.16 The allowable environmental conditions are detailed in ILP PLG04. It is suggested (although it is

to be clarified by the Local Planning Authority at Reserved Matters stage) that the environmental

zone of the development area is E2 (Low District Brightness, see Table 14.2). Environmental zone

E2 has been deduced based on the location of the site, acknowledging that the Cotswolds AONB

is located approximately 2km away from the north-eastern site boundary. Given the relatively

close proximity to the AONB, the environmental conditions identified in Table 14.2 must be

adhered to as far as practicable. The ILP PLG04 guidance document suggests the following

lighting constraints in E2 environmental zones.

Table 14.2: Obtrusive Light Limitations for Exterior Lighting Installations

Environmental

Zone

Sky

Glow

ULR

(Max)

%

Lighting

intrusion (into

windows) Ev

(lux)

Luminance

intensity I

Candelas (cd)

Building luminance L (cd/m2)

Pre-

curfew

Post-

curfew

Pre-

curfew

Post-

curfew

Pre-curfew

E2 Low district

brightness.

Rural, small

village,

relatively dark

urban

location.

2.5 5 1 7,500 500 5

14.17 The terms in the table have the following meanings:

ULR upward light ratio of installation

Ev vertical illuminance in lux (centre of windows)

I light source intensity

L luminance

14.18 The curfew is the time after which stricter requirements for control of obtrusive light apply (likely

to be a condition imposed by the local planning authority at Reserved Matters stage). The

Revised Scheme has a provisional curfew time of 21:00. The FGR stadium (and associated

ancillary areas) will be allowed to extend on this curfew time in exceptional circumstances; such

as for periodic evening matches or extra time in knock out tournaments. Hours of operation of

the Development Footprint are explored in further detail later in this chapter.



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14.19 In March 2012, The National Planning Policy Framework (NPPF) was published, superseding the

majority of previous Planning Policy Statements with immediate effect. The National Planning

Policy Framework was intended to simplify the planning system and includes a presumption in

favour of sustainable development. Section 11 of the NPPF deals with Conserving and Enhancing

the Natural Environment, and states that the intention is that the planning system should

prevent ‘development from contributing to or being put at unacceptable risk from, or being

adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability’

and goes on to state that ‘new development [should be] appropriate for its location’ and ‘the

effects (including cumulative effects) of pollution on health, the natural environment or general

amenity, and the potential sensitivity of the area or proposed development to adverse effects

from pollution, should be taken into account.’

Stroud District Local Plan (2015)139

14.20 The adopted Stroud District Local Plan contains the following reference to lighting or light

pollution.

“Policy ES3: Permission will not be granted to any development which would be likely to lead to,

or result in an unacceptable level of Environmental pollution to water, land or air.”

Eastington Parish Council Neighbourhood Development Plan

14.21 The Eastington Parish Council (Eastington PC) Neighbourhood Development Plan (NDP), 2016,

does not suggest any constraints pertaining to artificial lighting.

Statutory Documents

14.22 The Clean Neighbourhoods and Environment Act 2005140 has made light pollution a statutory

nuisance under the Environmental Protection Act 1990, which came into force on 6th April 2006.

Section 79 of the Environmental Protection Act 1990 has been amended to include artificial light

emitted from premises that potentially could be prejudicial to health or a nuisance.


Consultation

14.23 HCA initially provided a lighting assessment in September 2016 for a Further Environmental

Information (FEI) document. This was in response to a number issues raised by SDC via their

appointed consultants, Arup, as part of the original Eco Park submission in January 2016. The

scope and content of the assessment provided by HCA in September 2016 was confirmed as

appropriate. This assessment follows the same format and methodology as that previous

assessment.

Methodology

139 Stroud District Local Plan (2015) 140 The Clean Neighbourhoods and Environment Act 2005


December 2017

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14.24 In order to assess the environmental effects of the proposed lighting scheme, a baseline

condition survey has been completed. This is detailed further in the baseline conditions section

of this chapter.

14.25 Potential sensitive receptors have been defined as:

• The existing adjacent properties;

• Users of the M5 and A419 carriageways;

• The existing Industrial Heritage Conservation Area (IHCA);

• Local wildlife.

14.26 Each receptor has been considered in this assessment.

14.27 Construction will predominantly be carried out during daytime hours where natural light is

available. Overnight lighting will likely be required for security purposes only within the

construction compound (likely to observe less than 5lux around the periphery of the construction

compound, see also RS Figure 5.4). The short-term lighting effects are likely to be negligible and

therefore the construction phase can be assessed as level 4 (none/ negligible) in accordance with

ILP’s recommendations. In view of this conclusion, for the purposes of this EIA, the potential

effects have been confined to, and evaluated based on, the final construction/ occupation of the

entire site (i.e. Operational effects only).

14.28 The provisional design has been assessed to ensure that the Revised Scheme is not excessively

illuminated; but is still designed in accordance with the guidance documentation previously

identified. This includes the consideration of achieving minimum and average illumination levels,

as well as conformity with minimum uniformity levels. These levels are identified in Table 14.1.

Constraints have also been thoroughly considered (and discussed under the Design Evolution

heading below), and mitigation methods are discussed and applied, as required, later in this

chapter.

14.29 The provisional lighting design has been modelled as a ‘worst case’. Therefore, enhancements

have not been considered in the Site wide horizontal contour plots, although all embedded

mitigation (such as the earth bund along the northern and eastern Redline Boundary) has been

included. Worst-case has been modelled to reflect both the needs of EIA, as well as to

demonstrate that a considerate lighting strategy can be attained without the requirement of

extensive enhancement measures. Enhancement measures will be assessed in the horizontal

contour plots in full at Reserved Matters stage.

14.30 In the worst-case areas, where light spill has been observed, a localised strategy has been

modelled to discuss the mitigation measures required to overcome the spill as far as possible,

and demonstrate their compliance with the guidance documentation. Digital models have been

generated using Relux Pro lighting calculation software.

Describing Different Lighting Effects

14.31 Lighting effects fall into several different types which can be identified as spilled light, light

intrusion, increase in luminance intensity to neighbouring properties, intrusive threshold

increments to adjacent highways and increase in sky glow.


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14.32 Spilled light – Spilled light is the unwanted spill of light away from the area which is being

illuminated (task area). Spilled light can be considered a nuisance if it were to trespass on to third

party land.

14.33 Light intrusion – Light intrusion is light that trespasses into windows of properties lying adjacent

to the Development Footprint. This is typically as a consequence of spilled light.

14.34 Intrusive threshold increment – The threshold increment is a measure of the loss of visibility

that is caused by the glare from obtrusive lighting installations. In particular, the threshold

increment effects on users of the adjacent highways (M5 and A419).

14.35 Increase in luminance intensity – Luminance intensity is similar to the intrusive threshold

increment, as the luminance intensity causes the loss of visibility caused by glare.

14.36 Sky Glow – Sky glow is, as suggested by the name, the glowing of the sky directly above an area

that is being illuminated. This is typically a consequence of light reflecting from the lit area back

up into the sky. The amount of sky glow being observed depends on a number of parameters,

including level of illumination and weather conditions.


Institution of Lighting Professionals Criteria for the Assessment of Lighting Effects

14.56 The effects of each phase of the Revised Scheme (prior to mitigation and enhancement) are to

be assessed in accordance with the criteria from the ILP outlined in Table 14.3 (which is

extracted from Figure 12 of ILP PLG04). Each environment (unique to each phase) is to be

assessed based on the below.

Table 14.3: Reference categories for positive and negative lighting effects (from Figure 12 from

ILP PLG04)

14.57 ILP PLG04 does not define the terms used in the above table. Therefore, terms such as significant,

substantial, minor etc. all remain subjective and open to interpretation. These terms do not

Nature Ref Level Description Remedial works

Positive 1 Major/

substantial

beneficial

effects

Significant improvement in

night environment and/ or

reductions in glare, spill

light and sky glow

2 Moderate

beneficial

effects

Noticeable improvement in

night environment and/ or


light and sky glow etc.

3 Minor beneficial

effects

Slight improvement in night

environment and/ or


light and sky glow

Neutral 4 None/

negligible

No significant effect or

overall effects balancing out

Negative 5 Minor adverse

effects

Slight increase in visibility of

site, glare, and sky glow etc.

Develop appropriate

levels and type of

mitigation 6 Moderate

adverse effects

Noticeable increase in

visibility of site, glare and

sky glow etc.

7 Major adverse

effects

Significant issues with

increase in visibility of site,

glare, and sky glow etc.


December 2017

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directly correspond to the EIA terms significant and non-significant. Each potential effect is

evaluated in its own right and given an EIA significance designation later in this chapter.

14.58 The effects observed in the following assessment are prior to mitigation and enhancement

measures being applied, and will pertain to those that are identified as negative effects as noted

in the table above. The embedded mitigation, such as the planted bund, has been included in the

assessment.

14.59 It should be reiterated that this provisional strategy has been modelled using standard fittings.

Where required, further mitigation measures or enhancements are to be applied at final design

stage as part of Reserved Matters applications. Possible mitigation and enhancement measures

are discussed later in this chapter.

On-site Survey Methodology

Study Area

14.60 The Study Area for the Site survey is defined as the Redline Boundary and immediate environs.

Time, date and weather

14.37 The baseline condition lighting assessment was carried out by HCA, on 26th July 2016,

commencing the study at 22:00. The weather, as described by the Met Office, was 17°C and

overcast with good visibility. The stars and the moon were not visible during the survey. The

weather started to deteriorate towards the end of the survey, as it started to precipitate.

14.38 The conditions defined above were adequate for the onsite survey to proceed.

Measuring methodology

14.39 The Site survey was carried out over the Development Footprint north of the A419, and the area

of the Redline Boundary south of the A419 and east of the M5. No baseline survey was

undertaken west of the M5. The survey was conducted in accordance with ILP PLG04.

Measurements were taken at key points (i.e. sensitive areas predominantly around the periphery

of the Site, see RS Figure 14.1). Horizontal readings were taken at a height of 1.5m. At each point,

in accordance with ILP PLG04, vertical measurements were also taken from each cardinal

direction, at the same height.

14.40 A fixed height monopole was used to ensure that readings were taken at consistent heights. The

measuring equipment (to the specification noted below), measures ‘live’ illuminance levels. The

equipment was left in place until a steady illuminance reading was observed on the output

screen.

Measuring equipment

14.41 An ISO-TECH ILM 1337 light meter was used at the locations noted in RS Figure 14.1 and Table

14.4. The light meter was previously calibrated in July 2016, just prior to the survey (see RS

Appendix 14.1 for calibration certificate).

Baseline Conditions


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14.42 This section details the existing site conditions. The existing site comprises of agricultural land.

There are no existing artificial light sources within the Development Footprint, although there

are some external light sources which trespass (spill) into the Development Footprint.

14.43 In accordance with the ILP PLG04, a baseline condition assessment was carried out.

Sensitive receptors

14.44 Potential sensitive receptors have been defined as:

• The existing adjacent properties: There are existing properties running adjacent around

the periphery of the Redline Boundary. These areas will most likely be vulnerable to light

spill and light intrusion;

• Users of the M5 motorway: The M5 carriageway and adjoining junction 13 are unlit.

Although an average illumination spill from the carriage way (for users of the carriageway)

is low, the intrusive light from users of the carriage way was notable;

• Users of the A419: The A419 carriage way running adjacent to the Site is also unlit.

Observations were as identified for the M5 carriageway;

• IHCA: The IHCA extends and includes part of the Redline Boundary south of the A419,

although the Development Footprint is away from the IHCA and north of the intervening

A419. The IHC currently comprises of agricultural land and does not contain any artificial

light within the Redline Boundary;

• Local wildlife: Local wildlife has been identified in the area. This detailed further in RS

Chapter 8.

Table 14.4: Illumination levels observed at the locations identified on RS Figure 14.1

Position

number

Description Sensitive

receptor

Position Illuminance (lux)

Easting Northing Horizontal North East South West

1

North corner

area south of

A419

Dark

corridor 377868 206726 0.22 0.04 0.08 0.08 0.04

2

Middle of

north western

Redline

Boundary of

area south of

A419

Dark

corridor

377750 206626 0.10 0.06 0.06 0.06 0.02

3

Western

corner of area

south of A419

Dark

corridor 377700 206560 0.09 0.02 0.02 0.05 0.06

4

Middle of

southern

Redline

Boundary of

area south of

A419

Dark

corridor

377882 206402 0.08 0.02 0.03 0.03 0.04

5

Southern

corner of area

south of A419

Dark

corridor &

WMC

378027 206268 0.05 0.03 0.02 0.02 0.02


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6

Corner of

existing

carpark

Dark

corridor &

WMC

378107 206354 0.08 0.05 0.01 0.02 0.04

7 Adjacent to

WMC

WMC &

residential

premises

378206 206293 0.06 0.04 0.06 0.05 0.05

8

Middle of

dwelling

boundary

Residential

premises 378225 206317 0.05 0.04 0.04 0.02 0.03

9

Eastern corner

of area south

of A419

Residential

premises 378261 206363 0.07 0.03 0.04 0.04 0.09

10

Southern

corner of area

north of A419

Dark

corridor 378298 206394 0.06 0.04 0.05 0.02 0.03

11

Corner

adjacent to

Westend

House

Dark

corridor &

residential

premises

378386 206711 0.06 0.03 0.04 0.03 0.02

12

Corner

adjacent to St.

Lay Cottage

Dark

corridor &

residential

premises

378290 206802 0.06 0.04 0.01 0.02 0.02

13

Reading

adjacent to

Mole cottage

Dark

corridor &

residential

premises

378220 206870 0.07 0.03 0.03 0.03 0.03

14

North western

boundary of

area north of

A419

Dark

corridor 378012 206979 0.10 0.03 0.04 0.05 0.06

Summary of results

14.45 The Site survey found that there was minimal light intrusion into the Redline Boundary area; light

intrusion originating from buildings and highways surrounding the Site. The recorded horizontal

illuminance levels (i.e. levels of light travelling vertically onto the horizontal plane) were relatively

consistent, with little variance, across the entire area. An average horizontal illuminance of 0.08

lux was observed. A relatively high level of light intensity originating from the WMC carpark was

also observed.

14.46 Similarly, the cardinal illumination measurements141 (light travelling horizontally north, east,

south and west onto the vertical planes) were also relatively consistent and low averaging less

than 0.5 lux; as detailed on Table 14.4. This indicates a low level of intrusive light into the Site.

Additional observations from Redline Boundary

14.47 As noted earlier in this chapter, the existing Redline Boundary does not contain any artificial light

sources. Light ingress on the Redline Boundary is via adjacent buildings, developments, carparks

and highways (in addition to natural light). Light ingress can be considered negligible.

141 The Cardinal illumination measurement is the measurement of illumination observed on the vertical plane due

north, east, south and west at the same point as the measurement of the horizontal plane; perpendicular to the

horizontal plane.


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14.48 Dwellings adjacent to the Development Footprint also provide negligible light intrusion into the

Development Footprint. This is reinforced by readings 11, 12 and 13 detailed in the Table 14.4.

14.49 Although the light spill into the Redline Boundary is generally minimal, an unexpected level of

luminaire intensity was observed from the adjacent WMC car park.

14.50 No other significant light spill Into the Redline Boundary was observed. Intrusive light spill from

the Easting Trading Estate was anticipated directly south of the Redline Boundary. However

intrusive light was not discovered originating from this direction.

14.51 Other light spill into the Site was deemed insignificant and predominantly came from dwellings

with building mounted flood lights in various positions around the Redline Boundary.

14.52 Sky glow was experienced in all cardinal directions (sky glow being observed in the north, east,

south and westerly directions relative to the Site), and was found to be most intense towards

Stroud (east). This is believed to originate from Dairy Crest, and is illustrated in RS Figures 10.13,

as well as on the light pollution maps at RS Figure 10.10

Baseline summary

14.53 In summary, the existing Redline Boundary contains no artificial light sources and has a negligible

lighting effect on the surrounding area. Minimal light spill was observed into the Redline

Boundary, with the majority of spill into the Redline Boundary coming from WMC car park.

Intrusive light from the car park was also identified.

14.54 Sky glow was experienced in all directions, but predominantly in the direction of Stonehouse/

Stroud, Easington and Frampton.

Design Evolution

14.55 This section identifies the Revised Scheme and proposes a provisional lighting scheme. The

lighting scheme has been generated to achieve the levels set out in RS Figure 14.3.

Site Constraints to lighting

14.56 A number of constraints have been identified as considered in the design. Constraints are

detailed below.

Ecological Constraints

14.57 An Ecological assessment has been undertaken as part of this Revised Scheme (Chapter 8). A

number of potential ecological constraints have been identified and these have been considered

in the lighting design forming part of this assessment. In particular, this has focused on the need

for ‘bat corridors’ that follow the perimeter of the Development Footprint (RS Figure 1.1). Such

constraints are identified on the Ecological Designations (RS Figure 8.6).

Other Constraints

14.58 Further landscape site constraints are discussed in the LVIA chapter (Chapter 10). Other

constraints having an influence on the potential lighting scheme are summarised below:

• Buildings/ structures on the FGR site are restricted to a maximum height of 19.5m AFFL

(including luminaire columns etc.);


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• Mitigation against light spill into adjacent dwellings, farms, streams etc.;

• Limiting the threshold increment to adjacent highways;

• Environmental conditions to comply with Table 14.2.

The Provisional Lighting Scheme

14.59 The provisional lighting scheme has been designed to eliminate potential significant

environmental lighting effects identified as part of this assessment through luminaire selection,

location and orientation. The lighting scheme should be considered as a ‘worst case’, to achieve

the requirements set out in the previously discussed guidance. This is due to lack of enhancement

measures implemented in the provisional design model.

14.60 As previously discussed, the scheme has been modelled in this way to demonstrated that a

considerate lighting scheme (generating minimal significant effects) is possible without the use

of mitigation measures. This lighting scheme has not been generated for construction and should

be considered as original investigation/ provisional design in accordance with ILP PLG04.

14.61 In reality, the final design, submitted with the Reserved Matters Application, will consider the

use of all the mitigation and enhancement methods as discussed later in this chapter. This will

reduce the residual effects created by the use of the standard fittings evaluated in this

assessment.

14.62 It should be reiterated that the whole site will be subject to final design to discharge Reserve

Matters Applications at a later date.

Methods of mitigation for the provisional design

14.63 The provisional design has considered the embedded mitigation only; the bund with planting.

Spilled light into dark corridors and nearby residential receptors is predominantly been avoided

by the use of the embedded mitigation (a bund with planting).

Revised Scheme and Horizontal lighting contours

14.64 The Revised Scheme is set out in RS Figure 1.1. It is this Revised Scheme which the lighting

strategy has been designed against. The development has been modelled across three design

drawings. The Development Footprint, A419 road only and both the road and Development

Footprint modelled together.

14.65 RS Figure 14.3 identifies the horizontal lighting contours for the Development Footprint. RS

Figure 14.4 identifies the horizontal lighting contours for the A419 road. RS Figure 14.5 identifies

the horizontal lighting contours of both the Development Footprint and the A419.

Development Footprint Site

14.66 The current architectural design for the stadium identifies a canopy and seating arrangement

that fully encloses the playing field. This surround acts as a screen and ensures that light does

not spill away from the field and into potentially sensitive areas. The canopy will not mitigate

against sky glow. Although the luminaires specified will not produce upward light, light is

reflected from the playing surface upward towards the sky. The sky glow generated by the

stadium is evaluated in more detail later in this chapter.


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A419 Road

14.67 In consultation with the transport consultants, the dual carriageway has been designed to ensure

that the average illuminance levels and minimum uniformity levels have been achieved in

accordance with class CE2 as defined in the British Standards. Column heights are restricted as

stipulated with the Site constraints.

Summary of provisional design

14.68 Having identified the sensitive receptors as noted earlier in this chapter, the provisional lighting

design identified six potential negative effects across the Development Footprint:

• Spill light into bat corridors;

• Spill light into neighbouring properties;

• Light intrusion into neighbouring properties;

• Increase in luminance intensity to neighbouring properties (especially to sensitive

receptors);

• Intrusive threshold increment to adjacent highways;

• Increase in sky glow.

14.69 All potential effects are discussed below.

Potential effects

14.70 The potential effects observed in this section are prior to mitigation or enhancements being

applied.

14.71 It should be reiterated that this provisional strategy has been modelled using standard LED

fittings. Mitigation or enhancement measures are to be fully applied at final design stage prior

to a Reserved Matters Application, in accordance with ILP guidance. Possible measures of

mitigation/ enhancement are discussed later in this chapter.

Construction phase effects

14.72 As noted previously under the Methodology section, construction will predominantly be carried

out during daytime hours where natural light is available. Overnight lighting will likely be required

for security purposes only within the construction compound (likely to observe less than 5lux

around the periphery of the construction compound, see also RS Figure 5.4). The short-term

lighting effects are likely to be negligible, and therefore the construction phase can be assessed

as level 4 (none/ negligible) in accordance with ILP’s recommendations and therefore not EIA

significant. In view of this conclusion, for the purposes of this EIA, the potential effects have been

confined to, and evaluated based on, the final construction/ occupation of the entire site (i.e.

Operational effects only). Construction phase effects are not therefore considered further in this

chapter.

Operational (Post Construction) Phase

14.73 There are a number of potential residual effects as a consequence of this development. The

potential negative lighting effects have been identified upon review of the proposed lighting

scheme, and are as follows:


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• Spill light into bat corridors;


• Light intrusion into neighbouring properties;


receptors);



14.74 Each environmental effect is to be assessed against Table 14.3, with the effects identified below.

Methods of mitigation and/ or enhancement are discussed later in this chapter.

Spilled Light

14.75 Dark Corridors: Spilled light into dark corridors has predominantly been avoided by the use of

the embedded mitigation (the bund with planting). The worst case of light spill has been

observed adjacent to the bus route as it leaves the Site via the northern access route.

14.76 Bat corridors are shown as observing less than 0.5lux. This complies with the guidance

documents previously identified and is therefore considered as a minor adverse effect in

accordance with Table 14.3; and not significant in EIA terms.

14.77 Roads: Minimal light spill from the road into the Development Footprint has been observed.

However, it is likely that no more than 5 lux will be observed in the borders/ hedges offering

segregation between the carriageway and the Site.

14.78 Neighbouring Properties: The worst case of spill light has been observed adjacent to the bus

route as it leaves the Site at Grove Lane.

Light intrusion into neighbouring properties and windows

14.79 Although the area adjacent to the northern site entrance (bus route) off Grove Lane will

experience the worst case of spill light as noted in the preceding section, Westend House will be

subject to the worst case of light intrusion into a neighbouring property, given its proximity to

site when compared other neighbouring properties.

14.80 Light intrusion is the light observed at ‘window height’ on the vertical plane (as defined in ILP

PLG04). This is modelled digitally by locating a vertical measuring plane in the position of the

windows subject to the light intrusion.

14.81 RS Figures 14.6 and 14.8 details the indicative light spill and intrusion before any mitigation or

enhancements have been considered, and confirms that less than 1lux is being observed prior to

applying any mitigation or enhancement measures. As detailed in Table 14.2, up to 1lux light

intrusion is permitted post curfew. Therefore, this level of light intrusion falls below the post-

curfew threshold in areas of Low District Brightness. This can be described as a minor adverse

effect in accordance with Table 14.3; and not significant in EIA terms.

Increase in luminous intensity on neighbouring properties

14.82 Section 2.7.5 of CIE150 notes that luminous intensities do not need to be calculated where

‘luminaires cannot be seen from directions of concern due to permanent physical obstructions

such as high opaque fence, retaining wall or evergreen trees with dense foliage.’


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14.83 The receptor most sensitive to luminous intensity is Westend House adjacent to the main car

parking area of the Development Footprint. It is unlikely that luminaires will be seen from the

neighbouring property in question, due to the planted bund and other permanent physical

obstructions (see Chapter 10). The receptor is also unlikely to experience this effect due to the

position and orientation of the luminaires themselves. Therefore, a calculation is not required.

14.84 Due to the fact that the most sensitive receptor to light intrusion does not require a calculation,

the luminous intensity on neighbouring properties therefore can be considered as a negligible

effect in accordance with Table 14.3 and not significant in EIA terms.

Intrusive threshold increment to adjacent highways

14.85 The threshold increment is a measure of the loss of visibility that is caused by the glare from

obtrusive lighting installations on users of the adjacent highways (M5 and A419).

14.86 The majority of the Site will be enclosed by the planted bund to the detail identified in Chapter

10. There is also significant existing vegetation along the A419. Users of the adjacent highways

(M5 and A419) will not have direct line of sight on the luminaires due to the obstructions

mentioned above (see also RS Figure 10.14, Visualisations). Therefore, users of the adjacent

highways shall not perceive glare or intrusive light from Revised Scheme.

14.87 The effect associated with the threshold increment can therefore be considered as a negligible

effect in accordance with Table 14.3, and therefore not significant in EIA terms.

Increase in sky glow

14.88 The existing undeveloped Development Footprint does not contain any artificial light sources.

The future site will contain a large number of luminaires and this will have a negative effect on

sky glow.

14.89 The greatest contributor to sky glow will be the stadium flood lighting, although it should be

stressed that the stadium lighting will normally be switch off; unless a game is in progress in low

levels of ambient lighting.

14.90 The anticipated upward light ratio (ULR) for the stadium has been calculated at 14.6% (calculated

in accordance with section 5.5 of CIE 150). This is in excess of the recommendations set out in

ILP guidance (as noted in Table 14.2, where the maximum ULR in an area of Low District

Brightness is 2.5%). Furthermore, Table 14.2 notes that the calculated ULR for the FGR Stadium

would only be allowable in Zone E4 (high district brightness areas), where a maximum of 15%

ULR is acceptable. Due to the very intermittent nature of the ULR, the maximum allowable ULR

for sports pitches and stadiums are to be considered and agreed on a case by case basis with the

Local Planning Authority.

14.91 Given the non-compliance with the ILP guidance, sky glow should be considered as a major

adverse environmental effect in accordance with Table 14.3, and therefore significant in EIA

terms – albeit the actual occurrence of such an effect is infrequent. Mitigation measures, to

reduce the effect are discussed later in this chapter.

Summary Potential Effects on Sensitive Receptors.


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14.92 The provisional design has identified above the following effects associated with each sensitive

receptor.

Table 14.5: Effects on sensitive receptors

Sensitive

receptor

Potential effects Description Significance of

effect in EIA

terms

Existing

adjacent

properties

Light Spill

Light intrusions

Light intensity

The embedded mitigation has reduced the

effect.

Not significant

Users of

adjacent

carriageways

(M5 and

A419)

Intrusive

threshold

increment

Users do not have direct line of sight of

lumianires and therefore cannot observe the

intrusive threshold increment.

Not significant

IHCA Light Spill

The IHCA is not within the vicinity of the

Development Footprint and will not observe

the potential effect identified.

Not significant

Local wildlife Light Spill Light spill is within the requirements set out by

the governing documents.

Not significant

All receptors Sky Glow It is likely that sky glow will be observed from

all receptors. Although very infrequent, the

Stadium sky glow ULR is calculated at 14.6%.

This is above the Obtrusive Light Limitations

for Exterior Lighting Installations specified for

areas of Low District Brightness of 2.5%.

Significant.

Summary of potential effects

14.93 Sky glow has been identified as a significant effect in EIA terms. Methods of mitigation are

discussed in more detail in the following section.

14.94 Light spill, light intrusion, threshold increment and illuminance intensity are considered as not

significant in EIA terms. Nevertheless, measures of enhancement should be considered in an

attempt to further minimise these effect as far as possible.

Mitigation and Enhancement

14.95 This section of the lighting chapter discusses potential mitigation and enhancement measures

that can be used to minimise the potential effects discussed above.

14.96 Any one of the methods below are considered an appropriate means of mitigation or

enhancement to reduce the effects discussed earlier in this chapter, and are in accordance with

the ILP guidance documents:


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• Luminaire selection;

• Back shields/ louvers;

• Screened fences;

• Bunds;

• Limited operational hours.

14.97 The measures are described in more detail below.

Luminaire selection

14.98 Luminaires have been selected for compliance with the recommended guidance documents,

including the Bat Conservation Trust guidance documents; as detailed in RS Appendix 14.2.

14.99 Standard luminaires have somewhat rudimental optics. Modern LED luminaires, such as the

Thorn Area Flood LED Pro, are much more efficient in directing the output light towards the task

to further mitigate illuminance intensity. It is recommended that this class of luminaire is

specified when the final lighting strategy is being developed.

Back shield/ louvres

14.100 Back shields have been considered as an enhancement only and were not part of the tested

provisional lighting scheme in RS Figures 14.3 -14.5 as they are not embedded mitigation. This

has allowed the study to identify the areas subject to the worst possible lighting spill; utilising

the embedded mitigation only. Back shields and louvres are options that can be fitted to

luminaires to limit the direction of light and prevent it from intruding into adjacent receptors. RS

Appendix 14.2 details an example of a hooded luminaire accessory and louver accessory that can

be used to control the direction of light from the luminaires.

14.101 The use of back shields/ louvers will allow light to travel in the direction of the task area only.

This will drastically reduce the amount of light being spilled into sensitive areas, which has been

assessed as a minor negative effect.

14.102 RS Figure 14.7 considers the enhancement of a luminaire back shield, in addition to the

embedded mitigation already considered. The vertical measuring plane in this instance identifies

less than 0.5lux being observed as intrusive light (whereas prior to use of the back shield the

vertical measuring plane identified 1lux of intrusive light).

Screened fences

14.103 Screened fence lines can be created by utilising planted trees/ bushes or by the installation of a

prefabricated fence. The planting of trees/ bushes will clearly have a lesser environmental effect

than a prefabricated alternative.

Building of bunds

14.104 A 2m high earth bund will be constructed around the Site as detailed on the RS Figure 1.1 and

detailed in the landscape Chapter 10. In addition to the bund; bushes, shrubs and trees will be

planted on and around the bund in an attempt to create a natural screen with the intention of

reducing the effects of protruding light and noise. This is also detailed in Chapter 10.


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14.105 The bund has been designed so that the top and the bank facing towards the Site are to observe

a degree of light spill. This is an attempt to obstruct light ingress into neighbouring land and dark

corridors (where the dark corridor is assumed to be the bund bank corridor facing away from the

Site). Therefore, the bund bank facing away from the Site is restricted to the illuminance levels

stipulated in the guidance documents (for dark corridors). The dark corridor should achieve an

increase of illuminance as a result of the Revised Scheme of less than 0.5lux, in accordance with

Bat Conservation Trust guidance documents.

Limiting hours of operation/ enhancing lighting control

14.106 Limiting the hours of operation of the external lights is a more controlled way to limit the

negative effects of the new lighting scheme. The lighting models/ drawings considered in this

lighting assessment/ scheme are static and do not consider the dynamic operation of the Site. In

reality, the control methods should be adopted as part of the future strategy and secured by

condition, as appropriate.

14.107 Further controls may include limiting the hours of operation, the use of dimmable lights, active

control based on movement etc. The practicality of using such control should be evaluated in

more detail at design/ Reserved Matters stage.

14.108 It is assumed that a site manager/ facilities manager will have overriding control over the lighting

on the Site; and that all luminaires will be deactivated when the Site is not in use. It is likely that

areas of the Site will contain security barriers to prevent access to car parks, training pitches etc.

It is also envisaged that the facilities manager will be responsible for deactivating private lighting

when the Site is not in use.

14.109 The task zones identified in RS Figure 14.3 are to have the following modes of operation:

Cark park areas

14.110 Private car parks are to be operational via a photocell and time clock arrangement. The car park

lighting will switch on upon call from the photocell and will switch off at a limiting time dictated

by the Site curfew. The facilities manager will be able to override the operation of the lights

should the car park not be in use prior to the curfew.

14.111 Car park areas will have barriers preventing the public from using all car parks unless made

accessible by the facilities manager. Lighting circuits shall be interlocked to the entrance barrier

whereby the lighting will remain switched off until the barrier is opened. Once opened, the car

park lighting will operate in the same way as other public car parks (i.e. upon activation of the

photocell). On closure of the barrier, the lighting will switch off.

Roads

14.112 Street lighting for the roads will likely be required to be switched on only when the Site is in use

by FGR, or on match days. The facilities manager will have overriding control over the road

lighting and will switch off the lights when the Site is no longer in use.

Footpaths

14.113 Footpaths are generally used in private areas. These areas shall have a similar control strategy as

the roads.

A419 Dual carriageway and Junction 13


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14.114 The A419 carriageway shall be modified so that it is dualled. This road will require illuminating

through the entire duration of the night. Luminaires to the carriageway will switch on at dusk by

call from the photocell, and will switch off at dawn again by call from the photocell.

Principal club (mid-level competition) stadium

14.115 The stadium pitch lighting will normally be off. This will only be switched on in low ambient

lighting conditions during matches and any other agreed exceptional circumstance. Luminaires

will be manually controlled to ensure that lighting is not switched on unnecessarily or switched

off whilst a match is in progress. This will be controlled by the facilities manager. The curfew will

be as described earlier and will be manually enforced.

14.116 Further controls could be considered to ensure that the stadium lighting is deactivated when not

in use. Such controls may include an alarm (whether that be email, text etc.) alerting the facilities

manager when the stadium lighting is active after the curfew time.

Residual effects

14.117 This section identifies the residual effects after enhancement methods have been applied.

Residual effects of spill into dark corridors

14.118 Although not identified as a significant effect, the worst case of spill into a dark corridor has been

investigated further as described above and detailed in RS Figure 14.6 and 14.7. The

enhancement measure considered in RS Figure 14.7 considers the use of back shields/ louvers,

as well as the embedded mitigation of the planted bund.

14.119 RS Figure 14.7 shows that with embedded mitigation (the planted bund) and enhancement

(luminaire back shields) in place, a residual spill level of less than 0.5lux is observed.

Residual effects of sky glow

14.120 Sky glow is considered as a potential significant effect in EIA terms. The anticipated upward light

ratio (ULR) for the stadium has been calculated at 14.6% (calculated in accordance with section

5.5 of CIE 150). This is in excess of the recommendations set out in ILP guidance (as noted in

Table 14.2, where the maximum ULR in an area of Low District Brightness is 2.5%). Due to the

very intermittent nature of the ULR, the maximum allowable ULR for sports pitches and stadiums

are to be considered and agreed on a case by case basis with the Local Planning Authority.

14.121 The principal method of mitigation against ULR/ sky glow is to limit the hours of operation of

these facilities. The stadium lighting will normally be off, and therefore falls in line with the

requirements of Table 14.2. Stadium lighting will be activated when a match is being played in

low levels of ambient light. This is typically due to weeknight matches or tournament matches.

When these matches are not in progress, the stadium lighting will be switched off.

14.122 By way of comparison with the current season, a total of thirty home matches are currently (as

at the end of November) programmed during the 2017 – 2018 season. These include 22 on a

Saturday, two on Bank Holidays, and six on a normal weekday evening.

Summary of enhancement/ mitigation measures and residual effects


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14.123 All mitigation methods recommended by the ILP have been considered and utilised to some

extent in this scheme; whether considered as embedded mitigation or enhancement.

14.124 The Site will benefit from embedded mitigation by way of a planted bund.

14.125 The hours of operation across the Site will be limited by the curfew time defined earlier in this

chapter. Artificial light sources causing the more onerous adverse effects will be subject to more

stringent hours of operation as discussed above.

14.126 Sky glow has been identified as the only significant effect, in EIA terms. This is mitigated in part

by limiting the use of the stadium. Lighting of this will normally be switch off. When switched on,

the ULR will likely be above the recommendation of the ILP, although this will be verified upon

final design. The maximum allowable (intermittent) ULR should be discussed and agreed with the

Local Planning Authority.

Cumulative Effects

14.127 Cumulative developments considered as part of this assessment are illustrated on Figure 18.1

and detailed in Table 2.5.

14.128 Due to an assumed lighting design shown with no upward light and sharp cut-off characteristics

to minimise light spill beyond the Redline boundary, no significant cumulative effects are

anticipated. It is anticipated that the other developments (if granted planning permission) in

Table 2.5 would have similar lighting mitigation and enhancement measures secured both by

design and suitably worded planning conditions, therefore minimising their own potential

lighting effects.

Conclusions

14.129 The existing Redline Boundary contains no artificial light sources and has a negligible lighting

effect on the surrounding area. Some light is spilling into the Redline Boundary area from

adjacent properties, with the majority of spill into the Redline Boundary coming from WMC car

park.

14.130 The Revised Scheme will introduce light and this will have an overall negative lighting effect on

the currently unlit environment (when all luminaires are switched on). Potential effects due to

lighting have been identified as:

• Spill light into dark corridors;



receptors);



14.131 Spilled light into dark corridors has been identified as a minor adverse effect and therefore not

significant in EIA terms. Enhancement by utilising back shields on lighting will further reduce any

effects. Such measures of enhancement will be modelled as part of the final design.

14.132 Spilled light into neighbouring properties has been identified as negligible and therefore not

significant in EIA terms. Although some light spilled into such areas, levels are below the


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maximum levels recommended by the ILP as identified in Table 14.2. Performance against this

table will be enhanced further by utilising additional enhancement methods.

14.133 Increase in luminance intensity to neighbouring properties has been identified as negligible and

therefore not significant in EIA terms. Neighbouring properties will not be subject to a direct line

of sight of the luminaires.

14.134 Intrusive threshold increment to adjacent highways have been identified as negligible, and

therefore not significant in EIA terms, as road users will not have a direct line of sight of the

luminaires.

14.135 Increase to sky glow has been identified as a significant effect in EIA terms. This is mitigated in

part by limiting the hours of operation of the stadium. The acceptable intermittent ULR should

be agreed with the local planning authority. It should be reiterated that the stadium lighting will

only be switched on whilst a game is in progress in low levels of ambient light.

14.136 It may be possible to eradicate the light spill into dark corridors by way of utilising back shields.

This should be considered further upon final design of the lighting scheme, in accordance with

ILP guidance.

14.137 Sky glow poses the only significant environmental lighting effect on the local area. Sky glow is

predominantly controlled by limiting the hours of operation, which can be agreed with the local

planning authority. It is also suggested that the ULR is again reviewed upon issue of the final

design.


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Table 14.6: Summary of Lighting Effects and Mitigation

Receptor Effect

Phase

(Construction

/ Operation)

Embedded

Mitigation

Sensitivity of

Receptor

Magnitude

of Change

Level of Effect

and

Significance

Prior to

Mitigation


(and

Significance)

after

Mitigation

Nature of

effect (short

term /

medium term

/ long term,

permanent /

temporary,

direct /

indirect)

Existing

adjacent

properties

Light spill Operation Planted bund Not significant Embedded

mitigation

Back shields Not significant n/a

Existing

adjacent

properties

Light

intrusion

Operation Planted bund Not significant Embedded

mitigation

n/a Not significant n/a

Existing

adjacent

properties

Light

intensity


mitigation


XXXVIII. Users of

adjacent

highways

Intrusive

threshold

increment


mitigation


IHCA Light spill Operation Planted bund Not significant Embedded

mitigation


Local wildlife Light spill Operation Planted bund Not significant Embedded

mitigation


All receptors Sky glow Operation Planted bund Significant Limiting hours

of operation

n/a Significant Long term,

but very

infrequent in

occurrence


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15 NOISE AND VIBRATION

Summary

15.1 The noise and vibration assessment considers noise and vibration generated during the

construction of the Revised Scheme and noise during its operation. Operational noise has been

calculated for five scenarios that would occur in isolation of each other; namely: crowd noise

during a football match, noise from the use of the training pitches, noise from any fixed plant

associated with the stadium, vehicular noise from the use of the car park and the change in road

traffic noise from vehicles using the existing highway network.

15.2 The assessment has been based on worst case assumptions that will result in noise levels at the

higher end of the range anticipated. The maximum noise level events from the stadium are most

likely to occur when goals are scored during matches. However, the duration and frequency of

these events is very limited – during 2017 there will have been an average of three home games

per month and three goals per game.

15.3 The noise level impacts have been calculated and assessed at five of the nearest noise-sensitive

receptors to the Revised Scheme, including William Morris College (WMC) and associated

Chipmans Platt. WMC is a specialist facility offering work-related learning and independence for

young people with autistic spectrum and learning difficulties. It is recognised that sudden noise

events of sufficient amplitude and character has the potential to disturb some people with

autism. Therefore, this assessment has included additional criteria that accounts for the

potential different magnitude of noise that can affect some people with autism.

15.4 Baseline noise data gathered for the 2016 application has been supplemented with a further

survey comprising two locations between Wednesday 28th June and Tuesday 4th July 2017.

Introduction

15.5 This chapter presents the findings of an assessment of the potential effects of noise and vibration

at existing and future receptors surrounding the Revised Scheme. The assessment follows

nationally and locally recognised policies, standards and guidelines to determine the potential

significance of any effects during the construction and operational phases of the proposals, and

the suitability of the site for the proposed stadium and supporting facilities.


Legislation

Control of Pollution Act 1974142

15.6 Section 60 of this Act relates to the ‘Control of Noise on Construction Sites’ and Section 61 relates

to ‘Prior Consent for Work on Construction Sites’. These sections include the serving of notices

and the formation of agreements specifying acceptable levels of noise, hours of operation,

working methods and use of specific plant and noise mitigation.

Policy

142 Statutory Instruments, (1974) ‘Control of Pollution Act’, SI


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Noise Policy Statement for England143

15.7 Noise Policy Statement for England (NPSE) advises that noise impacts should be assessed on the

basis of adverse and significant adverse effect but does not provide any specific guidance on

assessment methods or noise limits.

15.8 The NPSE introduces the concepts summarised in Table 115.1 that can be applied when

considering the significance of noise impacts, which are applied by the World Health

Organization.

Table 15.1: Observed Effect Levels

Effect Level Activities

No Observed Effect Level

(NOEL)

This is the noise level below which no effect can be detected. In simple

terms, below this level of noise, there is no detectable effect on health

and quality of life due to the noise being assessed.

Lowest Observed Adverse

Effect Level (LOAEL)

This is the level of noise above which adverse effects on health and

quality of life can be detected.

Significant Observed Adverse

Effect Level (SOAEL)

This is the level of noise above which significant adverse effects on

health and quality of life occur.

15.9 The document advises that it is not possible to have 'a single objective noise based measure…

that is applicable to all sources of noise in all situations'. It further advises that the sound level at

which an adverse effect occurs is likely to be different for different noise sources, for different

receptors at different times.

National Planning Policy Framework144

15.10 National Planning Policy Framework (NPPF) sets out the Government's planning policies and how

these are expected to be applied. In relation to noise and vibration, NPPF section 11 Paragraph

109 states:

‘The planning system should contribute to and enhance the natural and local environment

by:

• preventing both new and existing development from contributing to or being put at

unacceptable risk from, or being adversely affected by unacceptable levels of soil,

air, water or noise pollution or land instability’

15.11 Whilst Paragraph 123 states:

‘Planning policies and decisions should aim to:

• avoid noise from giving rise to significant adverse impacts on health and quality of

life as a result of new development;

• mitigate and reduce to a minimum other adverse impacts on health and quality of

life arising from noise from new development, including through the use of

conditions;

• recognise that development will often create some noise and existing businesses

wanting to develop in continuance of their business should not have unreasonable

143 Noise and Nuisance Team DEFRA, (2010) ‘Noise Policy Statement for England’, DEFRA 144 Department for Communities and Local Government, (2012) ‘National Planning Policy Framework’, DCLG


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restrictions put upon them because of changes in nearby land uses since they were

established; and

• identify and protect areas of tranquillity which have remained relatively undisturbed

by noise and are prized for their recreational and amenity value for this reason.’

Planning Practice Guidance145

15.12 Online Planning Practice Guidance (PPG) has been published to provide greater details in relation

to the relevance of noise to the planning process following the introduction of the NPPF and

NPSE.

15.13 This guidance states, under the heading 'How to Determine the Noise Impact', that the following

should be considered by local authorities:

• whether or not a significant adverse effect is occurring or likely to occur;

• whether or not an adverse effect is occurring or likely to occur; and

• whether or not a good standard of amenity can be achieved.

15.14 In line with NPSE, this includes identifying where noise exposure is above or below the significant

observed adverse effect level and the lowest observed adverse effect level for a given situation,

during both construction and operation of the Revised Scheme.

15.15 Further guidance on each of the various observed effect levels set out in the NPSE is provided in

the table detailed in the section headed 'How to Recognise when Noise could be a concern?’

which is reproduced below.

Table 15.2: Observed Effects

Perception Examples of outcomes Increasing effect

level

Action

Not

noticeable

No effect No Observed

Effect

No specific

measures

required

Noticeable

and not

Intrusive

Noise can be heard, but does not cause any change

in behaviour or attitude. Can slightly affect the

acoustic character of the area but not such that

there is a perceived change in the quality of life.

No specific

measures

required

Lowest Observed Adverse Effect Level

Noticeable

and

Intrusive

Noise can be heard and causes small changes in

behaviour and/or attitude, e.g. turning up volume

of television; speaking more loudly; closing

windows for some of the time because of the noise.

Potential for non-awakening sleep disturbance.

Affects the acoustic character of the area such that

there is a perceived change in the quality of life.

Observed Adverse

Effect

Mitigate and

reduce to a

minimum

Noticeable

and

disruptive

The noise causes a material change in behaviour

and/or attitude, e.g. having to keep windows

closed most of the time, avoiding certain activities

during periods of intrusion. Potential for sleep

disturbance resulting in difficulty in getting to

Significant

Observed Adverse

Effect

Avoid

145 Department for Communities and Local Government, (2014) ‘Planning Practice Guidance, Noise’, DCLG (web

based guidance, update date 24/12/2014)


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Perception Examples of outcomes Increasing effect

level

Action

sleep, premature awakening and difficulty in

getting back to sleep. Quality of life diminished due

to change in acoustic character of the area.

Noticeable

and

disruptive

Extensive and regular changes in behaviour and/or

inability to mitigate effect of noise leading to

psychological stress or physiological effects, e.g.

regular sleep deprivation/awakening; loss of

appetite, significant, medically definable harm, e.g.

auditory and non-auditory.

Unacceptable

Adverse Effect

Prevent

15.16 It is important to note that no specific noise parameters are defined in the text or target noise

levels provided.

15.17 Under the heading 'What factors influence whether noise could be a Concern?’, the subjective

nature of noise is discussed. It is stated that there is no simple relationship between noise levels

and the impact on those affected. This depends on how various factors combine in particular

situations, these include:

• the source and absolute level of the noise together with the time of day it occurs.

Some types and level of noise will cause a greater adverse effect at night than if

they occurred during the day - this is because people tend to be more sensitive to

noise at night as they are trying to sleep. The adverse effect can also be greater

simply because there is less background noise at night;

• for non-continuous sources of noise, the number of noise events, and the frequency

and pattern of occurrence of the noise;

• the spectral content of the noise (i.e. whether or not the noise contained particular

high or low frequency content) and the general character of the noise (i.e. whether

or not the noise contains particular tonal characteristics or other particular

features). The local topology and topography should also be taken into account

along with the existing and, where appropriate, the planned character of the area.

15.18 More specific factors to consider when relevant:

• Consideration should also be given to whether adverse internal effects can be

completely removed by closing windows and, in the case of new residential

development, if the proposed mitigation relies on windows being kept closed most

of the time. In both cases a suitable alternative means of ventilation can be found in

the Building Regulations.

• In cases where existing noise sensitive locations already experience high noise

levels, a development that is expected to cause even a small increase in noise may

result in a significant adverse effect occurring even though little to no change in

behaviour would be likely to occur.

• If external amenity spaces are an intrinsic part of the overall design, the acoustic

environment of those spaces should be considered so that they can be enjoyed as

intended.

• Some commercial developments including fast food restaurants, night clubs and

public houses can have particular impacts, not least because activities are often at


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their peak in the evening and late at night. Local planning authorities will wish to

bear in mind not only the noise that is generated within the premises but also the

noise that may be made by customers in the vicinity.

Stroud District Council Local Plan (Policy ES3)146

15.19 Policy ES3 of the Stroud District Council Local Plan details the requirements to maintain the

quality of life within environmental limits. Permission will not be granted to any development

which would be likely to lead to, or result in, an unacceptable level of:

• Noise, general disturbance, smell, fumes, loss of daylight or sunlight, loss of privacy

or an overbearing effect;

• Noise sensitive development in locations where it would be subject to unacceptable

noise levels;

15.20 These core policies are also included within CP14 of the same Local Plan, which specifies the

requirements of every building and development project in Stroud in order to achieve the highest

quality with regards to construction and design.

Guidance

Professional Practice Guidance on Planning and Noise ProPG147 2017

15.21 ProPG Planning & Noise is a recently published document aimed at providing practitioners

guidance on a recommended approach to the management of noise in the context of the

planning system. The document was published jointly by the three professional bodies in the

acoustics industry: Acoustics and Noise Consultants (ANC); the Institute of Acoustics (IOA); and

the Chartered Institute of Environmental Health (CIEH).

15.22 Whilst the guide is focussed on new residential development being affected by transport noise,

the principle of the guidance is considered helpful to this assessment. Its primary goal is to assist

in the delivery of sustainable development by promoting good health and wellbeing through the

effective management of noise. It seeks to do this by encouraging good acoustic design processes

in and around proposed new residential development, having particular regard to national policy

on planning and noise.

15.23 ProPG highlights the importance of considering noise as an early part of development design,

with the aim to avoid mitigation that appears to be a last resort and could have consequential

non-acoustic effects.

British Standard (BS) 5228:2009+A1:2014

15.24 British Standard 5228-1:2009+A1:2014148 'Code of practice for noise and vibration control on

construction and open sites - Part 1: noise' (BS 5228-1) provides guidance on a range of

considerations relating to construction noise including the legislative framework, general control

measures, example methods for estimating construction noise levels and example criteria which

may be considered when assessing the significance of any impacts.

146 Stroud District Council, (2015), ‘Stroud District Local Plan’, SDC. 147 ANC, IOA, CIEH, (2017), ‘ProPG: Planning & Noise’, ANC, IOA, CIEH. 148 British Standards Institution, (2014) ‘BS 5228-1:2009+A1:2014 Code of practice for noise and vibration control on

construction and open sites - Part 1: Noise’, BSI Standards.


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15.25 Similarly, BS 5228- 2:2009+A1:2014149 'Code of practice for noise and vibration control on

construction and open sites - Part 2: vibration' (BS 5228-2) provides general guidance on

legislation, prediction, control and assessment criteria for construction vibration. These

standards have been adopted as the relevant method to predict and assess the impacts of

construction noise and vibration.

British Standard (BS) 4142:2014150

15.26 Current Government advice to Local Planning Authorities in both England and Wales makes

reference to BS 4142 as being the appropriate guidance for assessing commercial operations and

fixed building services plant noise. This British Standard provides an objective method for rating

the likelihood of complaint from industrial and commercial operations. It also describes means

of determining noise levels from fixed plant installations and determining the background noise

levels that prevail on a site.

15.27 The assessment of impacts is based on the subtraction of the measured background noise level

from the rating level determined. The rating level is the source noise level (either measured or

predicted) corrected for tone or character (if necessary). The difference is compared to the

following criteria to evaluate the impact:

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

adverse impact, depending on the context;

• a difference of around +5 dB indicates is likely to be an indication of an adverse

impact, depending on the context; and

• where the rating level does not exceed the background noise level, this is an

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

context.

15.28 This method is only applicable for external noise levels.

BS 8233: Sound Insulation and Noise Reduction for Buildings151

15.29 BS 8233:2014 ‘Guidance on sound insulation and noise reduction for buildings’ (BS 8233) is

intended to be used routinely where noise sources are brought to existing noise-sensitive

buildings, such as housing. However, the scope of the document states it ‘does not provide

guidance on assessing the effects of changes in the external noise levels to occupants of an

existing building’. The proposed guidance criteria are to satisfy most people. It is also stated that

‘it is necessary to remember that people vary widely in their sensitivity to noise, and the levels

suggested might need to be adjusted to suit local circumstances.’

15.30 BS 8233 provides guidance for control of noise in and around buildings, and suggests appropriate

criteria and limits for different situations. BS 8233 provides desirable internal ambient noise

levels for spaces in residential dwellings and non-domestic buildings when they are unoccupied.

The main guidance criteria are reproduced below in Table 1.3.

Table 15.3: Indoor Ambient Noise Levels in Spaces for Dwellings

149 British Standards Institution, (2014) ‘BS 5228-2:2009+A1:2014 Code of practice for noise and vibration control on

construction and open sites - Part 2: Vibration’, BSI Standards. 150 British Standards Institution, (2014), ‘BS 4142 - Method for rating and assessing industrial and commercial sound’,

BSI Standards. 151 British Standards Institution, (2014) ‘BS 8233 - Guidance on Sound Insulation and Noise Reduction for Buildings’,

BSI Standards.


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Activity Location Daytime

(0700 to 2300)

Night-time

(2300 to 0700)

Resting Living room 35 dB LAeq, 16 hr -

Dining Dining room / area 40 dB LAeq, 16 hr -

Sleeping (daytime resting) Bedroom 35 dB LAeq, 16 hr 30 dB LAeq, 8 hr

Listening Meditation / relaxation area 30 – 35 dB LAeq, T -

15.31 Supplementary Note 2 and 4 to Table 4 within BS 8233 are copied below for reference:

NOTE 2 - The levels shown in Table 4 are based on the existing guidelines issued by the

World Health Organization…

NOTE 4 - Regular individual noise events (for example, scheduled aircraft or passing

trains) can cause sleep disturbance. A guideline value may be set in terms of SEL or

LAmax, F depending on the character and number of events per night.’

15.32 No guidance is provided in terms of daytime maximum event noise levels. At night maximum

event noise levels are advised to be considered but no actual adverse effect level is provided.

15.33 BS 8233 provides recommendations for external noise levels. It recommends that for external

areas that are used for amenity space, such as gardens and patios, it is desirable that the external

noise levels do not exceed 50 dB LAeq,T, with the upper guideline value of 55 dB LAeq,T which would

be acceptable in noisier environments.

15.34 Guidance is also provided in terms of steady ambient noise levels in occupied rooms of non-

domestic buildings where speech communication is important. The noise levels advised in Table

15.4.4 are the internal steady state ambient noise levels that permits ‘normal voice’ or ‘raised

voice’ to be reliably audible at a certain distance between the speaker and the listener.

Table 15.4: Reliable speech communication levels

Distance between speaker and

listener, m

Normal voice noise level, dB(A) Raised voice noise level, dB(A)

1 57 62

2 51 56

4 45 50

8 39 44

World Health Organization Guidelines (2000 and 2009)

15.35 The World Health Organization (WHO) has published a series of guidelines that relate to

acceptable levels of noise from a health perspective. These are detailed in two separate

documents, the WHO ‘Guidelines for Community Noise’152, 2000 and the WHO ‘Night Noise

Guidelines for Europe’153, 2009. The Guidelines for Community Noise set out the following

criteria in Table 15. that relate to noise levels experienced in outdoor living areas (e.g. gardens).

Table 15.5: Guideline values for noise levels in outdoor areas during the day

152 World Health Organization, (2000) ‘Guidelines for Community Noise’, WHO. 153 World Health Organization, (2009) ‘Night Noise Guidelines for Europe’, WHO.


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Specific

Environment

Health Effect Guideline Values

dB LAeq, 16 hr

Outdoor

living area

Serious annoyance, daytime and evening 55

Moderate annoyance, daytime and evening 50

15.36 The WHO ‘Night Noise Guidelines for Europe’ provide further criteria that relate external noise

levels at dwellings to specific health impacts during the night-time (2300 hours to 0700 hours).

The Revised Scheme will not be operational during the night-time, therefore, this guidance is not

considered to be relevant to this assessment.

Building Bulletin 93154

15.37 BB93 has been compiled by various acoustic education experts and is based on the available

research (prior to publication) regarding all aspects of inclusion of pupils in mainstream

education.

15.38 Section 0.4 of BB93 defines the term ‘children having special hearing or communication needs’

as encompassing but not limited to the following:

• children with permanent hearing impairment

• speech, language and communication difficulties

• visual impairments

• fluctuating hearing impairments caused by conductive hearing loss

• attention deficit hyperactivity disorders (ADHD)

• an auditory processing disorder or difficulty

• being on the autistic spectrum

15.39 Section 0.4.1 of BB93 refers to ‘special school accommodation and special units attached to

mainstream schools’ and provides guidance on the required acoustic conditions being dependent

‘on a pupil’s individual special needs and may be accommodated by a specialist provision (e.g. a

quiet room for private study and communication, or an assisted listening device for participation

in general teaching), or by improving the general acoustic conditions of teaching and learning

spaces.’ The acoustic criteria for these types of accommodation should be specifically signed off

as they may vary from the starting point guidance criteria which may not be suitable for the

particular needs of the children in some types of accommodation.

15.40 The guidance design criteria for external noise intrusion contained in BB93 are listed in Table 15..

Table 15.6: External noise intrusion school design criteria for autistic spectrum teaching and

learning

Type of space Upper limit for new

build

Upper limit for

refurbishment

Allowance if naturally

ventilated

Classroom 30 dB LAeq, 30 min 35 dB LAeq, 30 min +5 dB

SEN* Calming 35 dB LAeq, 30 min 35 dB LAeq, 30 min +5 dB

*Note SEN stands for pupils with Special Educational Needs

15.41 BB93 also states ‘In order to protect students from regular discrete noise events, e.g., aircraft or

trains, indoor ambient noise levels should not exceed 60 dB LA1,30mins’. This is an important design

154 Building Bulletin 93, (2015) ‘Acoustic Design of Schools: Performance Standards’, DfES


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criterion to be considered in conjunction with the Table 15. levels for general ambient noise. It

can’t be directly compared to LAFmax,T dB values, although, an LAFmax,T dB value will always be

greater than the LA1,T dB value for the time period ‘T’.

Acoustics of Schools155

15.42 Acoustics of Schools is a design guide providing further details of methods of achieving the BB93

design criteria for new built education developments. It has been produced by acoustic experts

in the UK and Chapter 6 of the document provides additional considerations for ‘children having

special hearing or communication needs’.

15.43 Pertinent guidance statements included in Acoustics of Schools are:

‘Noise not only masks the speech signal, making it difficult to understand what is being

said, but also leaves a pupil tired from the effort required to listen. It is therefore essential

that attention be given to creating a quiet classroom. This requires insulation against noise

from outside the school, sound insulation between rooms, control of noise from plant and

equipment inside the classroom, and control of reverberant noise within the room. These

will help to ensure that a good signal to noise level can be achieved. Typically a signal to

noise level of at least +20 dB is considered desirable.’

‘Effective acoustic absorption within the teaching space is required which will lead to short

reverberation times, particularly at low frequencies. This is essential to ensure that

reverberant sound does not build up when pupils are working in groups, or more than one

person is talking at any one time.’

15.44 A summary comparison of the guidance from the British Association of Teachers of the Deaf

(BATHOD) and American Speech- Language Hearing Association (ASHA) is presented in Acoustics

of Schools and shown in Table 15.7.

Table 15.7: Comparison of BATHOD and ASHA guidance for acoustic conditions in classrooms

Acoustic parameter British Association of Teachers

of the Deaf

American Speech- Language

Hearing Association

Unoccupied sound level ≤ 35 dBA ≤ 35 dBA

Reverberation time

(unoccupied)

≤ 0.4 s across frequencies 125 Hz

to 4000 Hz

≤ 0.6 s for smaller rooms

(< 10,000 ft3)

≤ 0.7 s for larger rooms (≥ 10,000

and ≤ 20,000 ft3)

Signal to noise ratio > 20 dB across the frequency

range 125 Hz to 750 Hz

> 15 dB across the frequency

range 750 Hz to 4000 Hz

≥ 15 dB

Research papers relating noise affecting persons with autism

15.45 Two research papers, both prepared in the United States of America (USA), which bear some

relevance to the potential behavioural aspects of persons with autism that can be attributed to

noise influences, have been reviewed.

Exploratory Survey

155 IOA, ANC, (2015) ‘Acoustics of Schools: a design guide’, IOA, ANC.


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15.46 A paper titled ‘Noise and autism spectrum disorder in children: An exploratory survey’156 was

published in February 2017. The aim of the study was to explore ‘existing empirical research on

the impact of noise on children with ASD’ and to provide ‘recommendations regarding design

features that can contribute to noise reduction’ in schools. (Note ASD stands for Autism Spectrum

Disorder).

15.47 Pertinent findings included in ‘Noise and autism spectrum disorder in children: An exploratory

survey’ are:

‘Children with autism may demonstrate unique sensory profiles that influence the way they

perceive and process different stimuli in the environment. However, few researchers have

carefully examined the specific ways in which the acoustic environment of a facility may be

modified to accommodate such unique sensory needs.’

‘By modifying the built environment in acoustically friendly ways, the treatment and

education of children with autism may be greatly enhanced.’

‘There remains a significant knowledge gap in the current scientific literature as to how to

build acoustically friendly environments for children with ASD. Specifically, the authors

advocate for a controlled investigation of the behaviours of children with autism that

might be specifically correlated with certain acoustical environments. Common behaviours

reported by various caregivers related to noise in the environment have included fear

responses such as covering ears, distractibility, and self-stimulatory behaviours., By

understanding how behaviours are affected by environmental features such as carpet,

walls, ceilings, furniture, and other stimuli, we can begin to create more therapeutic and

academically compatible settings for children with autism in the school environment.’

15.48 The survey concludes that the classroom design and room acoustics potentially play a significant

role as well as control of external noise intrusion.

Observational Study

15.49 A paper titled ‘An Observational Study of Classroom Acoustical Design and Repetitive Behaviours

in Children With Autism’157 was published in 2016. The objective of the study was to ‘explore the

impact of acoustical design on children with autism in school classrooms’ and ‘Specifically, the

connection between repetitive behaviours and ambient noise levels in school classroom

environments was observed in four classrooms’.

15.50 The observational survey undertaken analysed different behaviours associated with noise

exposure in individuals with autism in three types of “classrooms”; the quiet or normal (41 to 55

dB LAeq,T range inside a classroom); the loud (55 to 70 dB) and; the potentially damaging (>70 dB).

15.51 Pertinent findings included in ‘An Observational Study of Classroom Acoustical Design and

Repetitive Behaviours in Children With Autism’ are:

156 Shireen M. Kanakri, Mardelle Shepley, James W. Varni, Louis G. Tassinary (2017), ‘Noise and autism spectrum

disorder in children: An exploratory survey’, Research in Developmental Disabilities 63 (2017) 85-94 157 Shireen M. Kanakri, Mardelle Shepley, Louis G. Tassinary, James W. Varni, Haitham M. Fawaz (2016), ‘An

Observational Study of Classroom Acoustical Design and Repetitive Behaviours in Children With Autism’,

Environment and Behaviour 1-27


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‘Overall, as noise increased, both the number (and type) of behaviours as well as their

frequency increased.’

‘The most frequently occurring behaviour for the normal classroom was repetitive motor

movement followed by repetitive speech.’

‘At higher noise levels other types of behaviours start to be observed, such as covering ears

(linked to anxiety), blinking eyes (that is a way to measure social disengagement) and

hitting others.’

‘Recommendations for noise control in environments for children with autism include

acoustical tiles, draperies, resilient flooring, padded seating, sound-absorbing ceiling

materials, and distance from fluorescent lighting… Finally, it is recommended that sound

proofing elements be installed to reduce echoes and noise levels in spaces where a long

attention span is desirable.’

‘Although the data indicate that a positive relationship exists between decibel level and

general behavioural occurrences, disaggregation of the data illustrates the variability that

exists with regard to specific decibel ranges. Repetitive motor movements, repetitive

speech, producing loud sounds, covering ears, blinking eyes, complaining, and hitting

others occurred much more frequently in the loud range (55-70 dB). For the potentially

damaging range (>70 dB), repetitive speech and covering ears occurred much more

frequently than in the lower ranges, whereas repetitive motor movements decreased.

Notably, at the damaging range, the increased behaviours are those overt behaviours that

would signal direct distress, whereas the loud, but not damaging range, is the range that

elicits non-direct expressions of distress.’

‘Overall, findings suggest that attention to acoustic design and modifications to existing

environments are essential to providing a supportive educational environment.’

‘Specific recommendations for modifications could include use of a better HVAC system or

alternative methods of air regulation; egg cartons fixed to the walls, carpet, and other

sound-absorbing materials on the floors; a buffer between classrooms and exterior spaces;

and attention to whether access to natural views enhances well-being or increases

acoustic problems. Efforts should be made to keep the average sound level at

approximately 50 dB or below.’

‘It should be considered that idiosyncratic needs of individuals cannot all be met, and

design that perfectly accommodates every individual need is not feasible.’

‘It remains though, that acoustics appear to be one of, if not the most, important factor in

a well-designed environment for individuals with autism.’

15.52 The paper provides an indication that an ambient internal noise level of approximately LAeq,T 50

dB is considered a reasonable level to avoid significant increases in observed adverse behaviour

of persons with autism. Furthermore, designing for or trying to perfectly accommodate every

individual is not feasible.

Calculation of Road Traffic Noise (1988)158

15.53 In England and Wales, the standard method for predicting road traffic noise levels is given in the

Calculation of Road Traffic Noise 1988 (CRTN). This methodology utilises a number of input

158 Department of Transport Welsh Office, (1988) ‘Calculation of Road Traffic Noise’, HMSO


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parameters (e.g. road traffic flow, composition, speed, gradient road, road surface, distance of

receptor from road etc.) to enable predictions of noise levels due to road traffic to be produced.

This method enables the calculation of average levels over a period of either 18 hours or 1 hour.

Predictions are produced in terms of LA10, as this is considered the measurement descriptor that

best describes road traffic noise.

Design Manual for Roads and Bridges (2011)159

15.54 The Design Manual for Roads and Bridges (DMRB) was originally published by the Department of

Transport in 1993 and sets out procedures for undertaking the design of road schemes. Volume

11, Section 3, Part 7 sets out a methodology for assessing the impacts of noise and vibration.

This methodology can be applied to the assessment of new road schemes or schemes that result

in changes in traffic flows on existing road links. The most recent revision of this section of the

Design Manual for Roads and Bridges was published in November 2011 with a Design Manual

Road Bridges Interim Advice Note (DMRB IAN) published in 2015. The DMRB IAN provides noise

speed bands that are to be used when predicting road traffic noise for motorways and urban/

rural roads. It is therefore this version of the guidance that is referred to in this assessment.

15.55 Table 3.1 of the DMRB, reproduced below in Table 15., provides guidance on the magnitude of

short term road traffic noise impacts, such as those that would be experienced due to short term

construction traffic flows. DMRB defines ‘short term’ as when the project is opened, which has

been taken to be the year of opening i.e. 12 months.

Table 15.8: Classification of magnitude of short term road traffic noise impacts

Noise Change, dB LA10, 18 hr Magnitude of Impact

0 No change

0.1 – 0.9 Negligible

1.0 – 2.9 Minor

3.0 – 4.9 Moderate

5.0+ Major

15.56 Similarly, Table 3.2 of DMRB, reproduced below in Table 15., provides the following criteria

relating to long term changes in road traffic noise levels, such those that could be experienced

during the operational phase of the Revised Scheme. DMRB defines ‘long term’ as typically 15

years after the project is opened.

Table 15.9: Classification of magnitude of long term road traffic noise impacts

Noise Change, dB LA10, 18 hr Magnitude of Impact

0 No change

0.1 – 2.9 Negligible

3.0 – 4.9 Minor

5.0 – 9.9 Moderate

10.0+ Major


159 The Highways Agency, (2011) ‘Design Manual for Roads and Bridges, Volume 11, Section 3, Part 7, Traffic Noise

and Vibration’, HA.


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Methodology

15.57 This noise assessment has been carried out by Richard Carter of Hoare Lea. Richard is an

Associate Director with Hoare Lea running the environmental noise group, which has a focus on

environmental impact assessments. Richard is a bachelor of Mechanical Engineering, holds a

post-graduate diploma in Acoustics and Noise Control, is a Chartered Engineer, a Chartered

Environmentalist and a member of the Institute of Acoustics. He has over 20 years of experience

working on technical engineering projects and has specialised in environmental acoustics since

2005.

Consultation

15.58 Consultation took place with Stroud District Council Environmental Protection Department on

26th October 2017 via email. The Environmental Protection Manager confirmed that the Council

was in broad agreement of the overall assessment method on 2nd November 2017. Discussion

continued on the subject of the day-time LAmax criteria adopted for WMC. Further information

was provided in this regard to SDC until no further questions were raised. SDC reserved

judgement on this issue until receipt of the finalised ES Chapter.

Study Area

15.59 The Study Area encompasses the Development Footprint and adjacent land in the direction of

nearby noise sensitive receptors. This includes properties off Grove Lane, the Hotel near to the

junction of Grove Lane and the A419 and William Morris College and Chipmans Platt. Receptors

and land beyond these properties need not be considered in detail provided that acceptable

noise levels can be achieved at these closer areas.

Construction Phase

15.60 Construction noise has been predicted using the calculation methodology identified in BS 5228-

1, indicative construction methodology, and sound power levels for different plant items as

presented in the Appendices to BS 5228-1. At this stage, the specific construction methodology

for the development has not been identified and therefore an indicative construction schedule

has been used for the assessment, based on worst-case assumptions, development phasing and

with plant operating at closest approach to the nearest receptors.

15.61 The construction works have been split into the following phases of works:

• Earthworks – assumed to be undertaken throughout the Development Footprint;

• Foundations – assumed to be undertaken at the location of the proposed stadium;

• Access road – roads extending off A419 into the stadium carpark;

• General construction - assumed to be undertaken throughout the Development Footprint

buildings and facilities.

15.62 The tables within RS Appendix 15.5 present the source inputs for construction noise divided into

phases of the works and the different stages of each phase.

15.63 In addition to noise generated through construction activity within the Development Footprint,

consideration has been given to construction traffic noise. The basic noise level has been

calculated for the section of the A419 between the site access and the M5 Junction 13 in

accordance with the Calculation of Road Traffic Noise (CRTN). A correction for Heavy Goods

Vehicles (HGV) has been applied to the basic noise level. Two scenarios were calculated based

on the existing road Average Annual Weekday Traffic (AAWT) flow and % HGV and a second with


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the peak anticipated daily construction traffic added to this. The difference in the basic noise

level with HGV corrections was considered to represent the likely difference in road traffic noise.

Operational Phase

15.64 Five key operational scenarios have been considered in this assessment:

• Crowd noise during a football match;

• Noise from the use of training pitches;

• Noise from any fixed plant associated with the stadium;

• Vehicle noise from the use of the carpark; and

• Changes in road traffic noise from vehicles using the existing highway network.

15.65 A 3-dimensional acoustic model has been constructed as a tool for understanding noise

propagation of the sources across the Development Footprint and assessment Study Area to

evaluate noise levels incidents on the façades of the nearest noise sensitive receptor locations.

The acoustic model has been generated using the CadnaA software package which calculates

propagation based on the principles of ISO 9613-2 or CRTN. Topographical information used in

the model is from Ordnance Survey OpenData topographical survey drawings. Due to the nature

of the noise source, continuous crowd noise and maximum levels have been predicted during a

game at full capacity to represent the constant and occasional louder events associated with

stadium noise using the LAeq, 2hour and LAmax noise parameters respectively.

15.66 Data presented for an ARUP Acoustics study (2007)160 inside the existing Anfield stadium during

two Premiership football matches has been used to provide confidence in the sound power data

used in the noise model. This study is included in RS Appendix 15.6 for convenience. Particular

regard was given to the second match between Liverpool and Aston Villa on 11th January 2003

as the score was 1-1 and therefore included a goal by the home team, Liverpool. The match was

attended by 43,210 people, with a stadium capacity at the time of approximately 45,000. Whilst

it is recognised that there are several factors influencing ambient and maximum crowd noise at

football matches, it is proven161 that the change in level is proportional to the number of people

within the crowd, N, at a rate of 10 logN.

15.67 The stadium was modelled as a 3-dimensional object with the seating defined as an area source

of sound power LWA 91.4 dB / m2 of seating for steady noise and LWA 107.4 dB / m2 for louder

event Lmax noise. The noise source used for the predictions of steady crowd noise from a 5,000

capacity attendance is based on the sound power level of a male voice ‘as loud as possible

without strain’ assuming 5,000 people constantly creating this level of noise for the entire

assessment period. The proposed Forest Green Rovers Football Stadium (FGRFC) stadium

building construction was refined and discussed in detail with Zaha Hadid Architects. This results

in the stadium construction itself representing an effective screen for sources of noise within it,

equivalent to a solid barrier with a height of 11 m. This was included in the 3D model.

15.68 A receptor was placed within the noise model at an equivalent location to S3 used in the ARUP

Acoustics study to compare the modelled noise levels with those measured during a game with

high levels of crowd noise. Table 15.10 presents a comparison of the ARUP measured noise level

corrected from 43,210 to 5,000 people using -9 dB with the noise level modelled for the Revised

160 Stadium Internal Noise Survey New Anfield 66143/PBA, ARUP Acoustics, 15 May 2007 161 Prediction of Crowd Noise, Hayne et al, 2006


December 2017

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Scheme. The match noise used in the model equates to the highest LAeq, 30 secs data measured and

the LAmax event noise is 4 dB higher in the noise model, presenting a worst case.

Table 15.10: Comparison of noise model data with measured data during Aston Villa vs Liverpool

at Anfield 11/01/2003

Noise parameter A-weighted sound pressure level, dB

ARUP S3 S3 corrected

to 5,000

Hoare Lea

noise model

Difference

Match LAeq 90 81 - -

Highest LAeq, 30 secs 102 93 93 0

Lowest LAeq, 30 secs 77 68 - -

LAmax 114 105 109 +4

15.69 The Training Pitches comprise two full-size grass external pitches and a penalty and goal practice

area. These have been modelled using the CadnaA software package as area sources. The sound

power of the training pitches used in the noise model is LWA 70 dB / m2 for steady noise and LWA

88 dB / m2 for the higher maximum event noise. As a worst case assumption, all three training

spaces have been modelled to be in use at the same time.

15.70 Exact details of any plant that is likely to be installed to service the Revised Scheme is not yet

known. At this stage the most pragmatic approach would be to set appropriate noise limits for

any such plant so as to minimise any impacts.

15.71 The stadium Car Park has also been modelled using the CadnaA software package as an area

source based on representative measurements of vehicle manoeuvres in a car park. The model

includes car movement with a sound power level of LWA 86.7 dB per vehicle and cars manoeuvring

with a sound power level of LWA 68.8 dB. It is assumed that in half an hour 1,800 vehicles drive

around the car park and carryout a manoeuvre for the entire period as a worst-case.

15.72 Traffic flows for the various development scenarios have been provided by PFA Consulting

Limited. In accordance with DMRB, traffic data has been provided for the following scenarios:

• Scenario 1 – 2017 traffic data based on Annual Average Weekday Totals

• Scenario 2 – 2036 design year, 15 years after opening, including general traffic growth and

committed development

• Scenario 3 – 2036 design year with scenario two above and the Revised Scheme assuming

a worst case of a full 5,000 capacity match.

15.73 The traffic consultants have advised that the %HGV movements would be consistent throughout

each scenario. The committed developments included within the traffic data are listed in Table

2.5 and illustrated in RS Figure 18.1.

15.74 This assessment uses the 3-dimensional acoustic model of the road traffic flow Scenarios 2two

and 3three to calculate the change in road traffic noise as a result of the Revised Scheme. The

change in road traffic noise has been taken as the traffic noise during a 5,000 capacity match

(Scenario 3) less the traffic noise without a match (Scenario 2) during the design year.


Approach


December 2017

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15.75 The assessment criteria takes into account the following:-

• A consideration of the ‘significance of effect’, which takes into account the sensitivity of

receptor and magnitude of change based on guidance criteria within BS 4142, BS 8233 and

DMRB, the latter relating to a relative difference in noise between a future baseline level

and development level; and

• Mitigation requirements from the various guidance documents and legislation, such as

sound insulation trigger levels within BS 5228.

Value of Receptor Sensitivity

15.76 The example for sensitivity within the IEMA Noise Assessment Guidelines has been followed to

provide the criteria for sensitivity as follows.

Table 15.11: Receptor Sensitivity

Sensitivity Criteria

High

Receptors where occupants or activities are particularly susceptible to noise. Examples

include: residences, quiet outdoor areas used for recreation, conference facilities,

auditoria/studios, schools in daytime, hospitals/residential care homes and religious

institutions e.g. churches or mosques.

Medium

Receptors moderately sensitive to noise, where it may cause some distraction or

disturbance. Examples include: offices, restaurants and sports grounds where spectator

noise is not a normal part of the event and where quiet conditions are necessary (e.g. golf

or tennis).

Low

Receptors where distraction or disturbance from noise in minimal. Examples include

residences and other buildings not occupied during working hours, factories and working

environments with existing high noise levels and sports grounds where spectator noise is

a normal part of the event.

15.77 The area surrounding the development is a combination of transport corridors, residential

dwellings, educational buildings and agricultural land. This includes William Morris College

(WMC) which contains some individuals which are particularly susceptible to noise and as such

is classed as being of the highest sensitivity. For the purposes of the assessment of noise, all

receptors included are considered of high sensitivity. In addition, the nature of noise and the

magnitude of effects has been considered separately for residential dwellings and the buildings

associated with WMC, and this is discussed below.

Magnitude of Effect

15.78 The ‘magnitude of effect’ is used to describe a numerical impact in effect terms, and is used

differently for each of the various aspects of change to the noise environment. Table 15.2 and

Table 15.14 presents a summary of the criteria for effect based on appropriate guidance set out

at the beginning of this chapter for construction noise and operational noise respectively. Table

15.13 presents a summary of the criteria for effect for construction vibration based on Table B.1

of BS 5228-2.

Table 15.12: Magnitude of effect criteria for external construction noise impacts


December 2017

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Effect

(negative)

Criteria

Construction Noise Construction Traffic

Noise

Major

> 82 dB LAeq, 10 hour

Trigger level for temporary rehousing, or reasonable cost thereof,

as set out in E.4 of BS 5228. Considered to be the Unacceptable

Adverse Effect Level.

Change in LA10, 18 hour

of 5 dB or more

Moderate

> 72 dB LAeq, 10 hour ≤ 82 dB LAeq, 10 hour

Trigger level for noise insulation works, or cost thereof, as set out

in E.4 of BS 5228 and therefore the onset of SOAEL.


of 3.0 – 4.9 dB

Minor


Most stringent threshold value for impact given in Annex E of BS

5228 for example methods relevant to Revised Scheme.

Considered to be between LOAEL and SOAEL.


of 1.0 – 2.9 dB

Negligible


Noise is likely to be audible, but unlikely to change behaviour.

Considered as the onset of LOAEL.


of 0.1 – 0.9 dB

No Impact ≤ 55 dB LAeq, 10 hour

Construction noise may be audible

No change in

LA10, 18 hour

Positive

Impact N/A N/A

Table 15.13: Magnitude of effect criteria for external construction vibration impacts

Effect

(negative) Criteria

Major

> 10 mm.s-1

Vibration is likely to be intolerable for any more than a very brief exposure to this level in

most building environments. Considered to be the Unacceptable Adverse Effect Level.

Moderate

> 1.0 mm.s-1 ≤ 10 mm.s-1

It is likely that vibration of this level in residential environments will cause complaint, but

can be tolerated if prior warning and explanation has been given to residents and therefore

considered to be the onset of SOAEL.

Minor

> 0.3 mm.s-1 ≤ 1.0 mm.s-1

Vibration might be just perceptible in residential environments. Considered to be between

LOAEL and SOAEL.

Negligible

> 0.14 mm.s-1 ≤ 0.3 mm.s-1

Vibration might be just perceptible in the most sensitive situations for most vibration

frequencies associated with construction. At lower frequencies, people are less sensitive to

vibration. Considered as the onset of LOAEL.

No Impact ≤ 0.14 mm.s-1

The level of vibration is not likely to be perceptible even in the most sensitive situations.

Positive

Impact N/A

Table 15.14: Magnitude of effect criteria for external operational noise impacts at residential

receptors

Effect

(negative)

Criteria

Fixed Plant Noise Stadium, Training Pitch and Car

Park Noise Operational Traffic

Major 10 dB or more above existing

background noise (LA90)

10+ dB exceedance of

prevailing noise


of 10 dB or more


December 2017

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Effect

(negative)

Criteria

Fixed Plant Noise Stadium, Training Pitch and Car

Park Noise Operational Traffic

Moderate 5.0 – 9.9 dB above existing


5.0 – 9.9 dB exceedance of

prevailing noise


of 5-9.9 dB

Minor 3.0 – 4.9 dB above existing



prevailing noise


of 3-4.9 dB

Negligible 0.1 – 2.9 dB above existing



prevailing noise


of 0.1-2.9 dB

No Impact Rating level below existing


No exceedance of prevailing

noise

No change in LA10, 18

hour

Positive

Impact N/A N/A N/A

15.79 Further consideration has been given to WMC as a nearby sensitive receptor. Whilst its

sensitivity is classified as the highest (see Table 15.11), additional consideration has been given

to the potential noise impacts upon the residences of this location. WMC is a specialist college

promoting work-related learning and independence for young people with autistic spectrum and

learning difficulties. It should be noted that several receptors were positioned at WMC covering

multiple buildings and floors. The assessment presents the data from the receptor with the

highest predicted noise level as a worst-case.

15.80 The following additional operational daytime magnitude of effect criteria set out in Table 15.15

for external noise events and internal noise has been developed from the aforementioned

guidance documentation and papers and has been applied at WMC and associated residential

properties at Chipmans Platt only. In the absence of any guidance of the magnitude of effect of

daytime maximum noise levels (LAmax), the relevant criteria have been based on the measured

LAmax noise level already experienced near to WMC which are described in the baseline section

of the present Chapter.

Table 15.15: Magnitude of effect criteria for noise impacts at WMC and Chipmans Platt

Effect

External Criteria Internal Criteria

Maximum Noise

Level

Ambient noise

contribution to

classroom

Event noise

contribution to

classroom

Ambient noise

contribution to

resting space

Major

More than two

events > LAFmax,T

79 dB in a day

> 55 dB LAeq,30min > 70 dB LA1,30min > 50 dB LAeq,T

Moderate

More than six events

> LAFmax,T 75 dB

occurring in a day

> 50 dB to 55 dB

LAeq,30min

> 65 dB to 70 dB

LA1,30min

> 45 dB to 50 dB

LAeq,T

Minor

Any number of

events > LAFmax,T

61 dB in a day

40.1 dB to 50 dB

LAeq,30min

60.1 dB to 65 dB

LA1,30min

40.1 dB to 45 dB

LAeq,T

Negligible LAFmax,T 54 dB to

61 dB

35.1 dB to 40 dB

LAeq,30min

≤ 60 dB LA1,30min 35.1 dB to 40 dB

LAeq,T

No Impact < LAFmax,T 54 dB ≤ 35 dB LAeq,30min N/A ≤ 35 dB LAeq,T

Positive

Impact N/A N/A N/A N/A


December 2017

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Significance of Effect

15.81 The nearest receptors to the development are classed as ‘high’ sensitivity. As this assessment

considers one level of sensitivity, the normal approach to significance cross referencing

sensitivity and magnitude of impact has been substituted with a dual approach. Impacts are

considered significant within the meaning of the EIA Regulations if the magnitude of effect is

either moderate or major as highlighted in Table 15.16 below. Mitigation will be applied where

a significant effect has been assessed.

Table 15.16: Matrix of Significance



Ma

gn

itu

de

of

Ch

an

ge

/ e

ffe

ct

Major Significant Significant Not Significant Not Significant

Moderate Significant Not Significant Not Significant Not Significant

Minor Not

Significant

Not Significant Not Significant Not Significant

Negligible Not

Significant

Not Significant Not Significant Not Significant

Baseline Conditions

15.82 Baseline noise measurements were in 2015, and further measurements were undertaken at the

end of June and the start of July in 2017.

2015 baseline measurements

15.83 The 2015 measurements were taken between Thursday 3rd and Friday 4th September 2015. Four

unattended noise monitoring stations were installed towards the north and south of the then

proposed previous site Redline Boundary, and at nearest receptors. In addition, attended

measurements were taken during the daytime at four locations representing road noise at

boundaries of the site.

15.84 Further details of the 2015 survey and results can be found in Chapter 15 and RS Appendix 15.1

of the ES which accompanied the 2015 planning application RS Appendix 15.2 and RS Appendix

15.3. A summary of the relevant baseline data is provided below in Table 15..

Table 15.17: 2015 Baseline Noise Levels

Location Time Period LAeq, T dB LA90, T dB LA10, T dB LAFmax, T dB* LA10, 18h dB**

MP2 07.00 – 23.00 53.4 50.3 54.0 81.6 53.8

23.00 – 07.00 50.5 44.7 51.6 73.4

MP3 07.00 – 23.00 57.0 54.8 58.1 81.8 57.8

23.00 – 07.00 50.8 44.0 50.8 76.8

MP4 07.00 – 23.00 54.5 51.2 55.5 74.4 55.3

23.00 – 07.00 48.0 40.2 45.5 72.9


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Location Time Period LAeq, T dB LA90, T dB LA10, T dB LAFmax, T dB* LA10, 18h dB**

MP7 10.02 – 13.02 58.6 47.1 62.6 82.2 n/a

2017 baseline measurements

15.85 Additional measurements were carried out in 2017 between Wednesday 28th June and Tuesday

4th July. Two unattended noise monitoring stations were installed near to William Morris College

to the south of the site Redline Boundary and near to Westend House to the north of the site

Redline Boundary. Table 15.18 lists the 2017 survey locations and noise sources heard locally

and RS Figure 15.1 illustrates all the survey locations used in this assessment.

Table 15.18: Summary of Measurement Locations

Location Location description Coordinates (E, N) Description of noise environment

L1

South of site the Redline

Boundary near to

previous MP3 location

and William Morris

College

378188, 206333

Road traffic noise from vehicles using

the A419 with possible contribution

from the M5 was dominant. Other

sounds heard include birds, wind

disturbed vegetation, intermittent

aircraft and occasional cattle.

L2

North east of the site

Redline Boundary near

to previous MP2

location and Westend

House

378368, 206748

Noise from motor vehicles passing on

the local road was dominant when

these events took place. In the

absence of passing vehicles noise from

the M5 motorway and birds were the

dominant observed sources.

15.86 For both locations L1 and L2 the microphones of the sound level meters were mounted

approximately 1.4 m above the ground and at least 5 m from any other acoustically reflective

surface. The measurement systems were field calibrated before and after the measurements

and no significant drift was recorded.

15.87 A summary of the 2017 baseline survey results is presented below in Table 15.19, separated into

weekday and weekend results. The daytime is defined as between the hours of 07.00 and 23.00

and the night-time between the hours of 23.00 and 07.00.

Table 15.19: 2017 Baseline Noise Levels

Location Time Period LAeq, T dB LA90, T dB LA10, T dB LAFmax, T dB LA10, 18h dB

L1

Week daytime 56.9 52.7 57.1 84.2 56.8

Week night-time 51.8 46.2 53.0 72.5

Weekend daytime 53.5 50.0 54.6 74.2 54.1

Weekend night-time 49.1 42.7 50.2 73.3

L2

Week daytime 52.9 49.1 53.9 80.7 54.3

Week night-time 48.4 43.0 50.0 71.1

Weekend daytime 52.3 48.6 53.7 74.6 53.5

Weekend night-time 48.7 42.5 50.2 71.2


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15.88 The maximum noise events measured during the 2015 and 2017 baseline surveys at MP3 and L1

respectively has been combined to provide a broader data-set of the LAmax noise events near

WMC. RS Figure 15.3.6 in RS Appendix 15.3 graph (see Figure 15.3.6 of the appendix) illustrates

the data. A summary of the modelled baseline road traffic noise is illustrated in RS Figure 15.7.

15.89 To provide a representative noise source for the training pitches, a review of available data and

further measurements at Durdham Downs in Bristol were undertaken. During the survey four

simultaneous football matches were played on external grass pitches. The measurements were

undertaken on the evening of 6th April 2017 by Hoare Lea at a distance of 20 m from the side of

the nearest of the four pitches. The activity noise included shouts from players and instructions

from the referee (including use of a whistle) but there were very few spectators or people moving

about on the side lines making any noise. The measured levels were LAeq,T 51 dB and LAFmax,T 68

dB.

15.90 To provide a representative noise source for the carpark, noise measurements at the carpark of

155 Aztec West offices in Bristol were undertaken. The level of noise resulting from a range of

activities were measured. These covered the typical noisy activity associated with vehicles within

a carpark: car doors and boots opening and closing, car engines starting, idling and pulling away

and manoeuvring in and out of parking bays.

Design Evolution

15.91 Embedded mitigation measures that have been identified and adopted as part of the evolution

of the project design (embedded into the project design) that are relevant to noise are as follows:

• Appropriate design and positioning of the development, including the location of outdoor

sports provisions away from William Morris College;

• Careful positioning and orientation of the stadium to balance site constraints and to

minimise noise impacts at nearby noise-sensitive receptors;

• Close collaboration between the architects and acoustic engineers to ensure the design

and fabric of the stadium minimises the noise breaking out, including a solid barrier behind

the seating area up to a height of 11 m above pitch level;

• A 2 m high earth bund acoustic barrier running from the road access to the A419 along the

southern and eastern boundaries of the carpark, continuing north toward the M5 and

around the eastern and northern edge of the northern most training pitch.

Potential Effects

15.92 The noise assessment in relation to both construction and operation phases has identified no

significant environmental effects at any of the receptor locations. Therefore, in accordance with

the EIA Regulations, which require ESs to focus on the significant environmental effects (as well

as to accord with the approach taken in other chapters of this ES), information describing how

the non-significant effects were assessed is detailed in RS Appendix 15.4. Table 15.20 at the end

of this chapter summarises noise effects before and after any mitigation or enhancements. RS

Figures 15.2 to 15.8 are referenced in RS Appendix 15.4 when assessing non-significant effects.

15.93 Furthermore, the non-significant effects identified will only occur over a short-term, in particular

those associated with operational impacts. The assessment considers the likely greatest level of

noise during a football match in a 30 second period, which is most likely to be linked to a goal


December 2017

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from the home team. T and therefore, this may not occur during a match, or may occur three or

four times. We understand that matches will be are typically fortnightly; therefore, it is unlikely

that the effects reported will occur regularly. In addition, there will be a planning condition that

will prevent the use of the stadium for other uses, such as music concerts.


15.94 No significant effects have been identified, and therefore in accordance with the EIA Regulations,

no mitigation measures are required beyond those embedded mitigation measures incorporated

into the scheme design. Below are recommended enhancement measures to further control or

reduce noise during the construction and operation phases of the Revised Scheme.

15.95 A detailed Construction Management Plan should be drafted, and this can be secured by

condition, to maintain best practice procedures during the construction phase in line with BS

5228, and this can be secured by condition. Such measures will include well maintained

equipment, mobile equipment positioned away from receptor locations and where provided,

silencers or soundproof enclosures to construction equipment to be utilised and properly

maintained. The Construction Management Plan is to also include a section on the management

of traffic to and from the construction site, to restrict vehicles using smaller roads such as Grove

Lane. In addition, it can be seen in RS Figure 5.4, the Indicative Construction Compound Plan,

that it has been designed to locate construction noise sources away from sensitive receptors

along Grove Lane.

15.96 The stadium should produce and adhere to an Operational Noise Management Plan. The plan

should include measures to monitor and control noise from spectators, the stadium public

address system and training sessions. Again, this should be secured via planning condition, see

RS Appendix 6.1.

Residual Effects

15.97 Table 15.20 details the significance of the effects likely to arise as a result of the development

after enhancement measures have been employed. There will be no significant effects (and thus

no residual effects) as a result of the development.

Cumulative Effects


15.98 At this stage it is not envisaged that the construction of any other large-scale development will

coincide with the construction of the Revised Scheme. We understand that construction of the

West of Stonehouse development has commenced and that all major construction works, such

as ground remediation and sub-structure works will be complete before any construction will

take place for the Revised Scheme. Therefore, no significant cumulative effects are anticipated

during the construction phase.

Operational Effects

15.99 The cumulative effects of the Revised Scheme in terms of noise impact are restricted to the long-

term impacts in changing road traffic levels. Road traffic noise levels calculated from flow data

provided by PFA, the appointed traffic consultant, have included vehicles accessing the Revised

Scheme plus further committed developments in the area. Therefore, the road traffic noise


December 2017

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assessment carried out in this Chapter includes the cumulative effects from other committed

developments as part of the baseline, and are not predicted to be significant. Information on

committed developments in the area is provided in Chapter 12, Table 2.5 and RS Figure 18.1.

15.100 In development terms, the cumulative effect of the proposed stadium, training pitches and car

park noise will not be significant.

Conclusions

15.101 A baseline noise survey has been undertaken to identify appropriate noise criteria and to

compare with potential future noise levels as a result of the development proposals.

15.102 Noise and vibration from the construction phase has been predicted and assessed. Absolute

noise levels and changes to the baseline noise from construction and operation of the

development have been predicted and assessed.

15.103 The maximum noise level events from the stadium will only are most likely to occur when goals

are scored during matches. However, the duration and frequency of these events is very limited

– in 2017 there will have been an average of three home games per month and three goals per

game (this excludes June during which there were no home games and goal data for December

which is not yet available). Although not found to be significant it is important to recognise that

these effects are predicted to only occur on average for approximately 1.5 minutes per game (30

seconds per goal) around three times per month.

15.104 Noise generated by the operation of the Revised Scheme has been calculated at nearby receptor

locations. Consideration has been given to noise generated during a football match with 5,000

spectators, training sessions, the use of the car park and changes in noise from vehicles using the

local road network.

Significant residual effects

Construction phase

15.105 Based on mitigation embedded within the design no significant adverse effects are predicted

during the construction phase of the development.

Operational phase

15.106 Based on mitigation embedded within the design no significant adverse effects are predicted

during the operational phase of the development.


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Table 15.20: Summary of Noise and Vibration Effects and Mitigation


(Construction

/ Operation)

Embedded

Mitigation

Sensitivity

of

Receptor

Magnitude

of Change

Level of Effect

and

Significance

Prior to

Mitigation


Effect (and

Significance)

after

Mitigation

Nature of effect (i.e.

short term / medium

term / long term,

permanent /

temporary, direct /

indirect)

William

Morris

Colleage

and

Chipmans

Platt

Construction noise Construction Not applicable. High Minor Not

significant

Not

applicable

CEMP Not

significant

Negative, medium term,

direct Construction vibration Negligible

Construction traffic Negligible

Stadium noise highest LAeq, 30 Sec Operation Stadium design

and location

and 2 m high

earth bund.

Minor Operational

Management

Plan for

stadium and

training

pitches

Negative, permanent,

direct, in-frequent, short

duration.

Stadium noise event LAmax Minor

Training pitch noise LAeq, T No impact

Training pitch event noise LAmax Negligible

Car park noise No impact

Fixed plant noise Negligible

Road traffic noise Negligible Not applicable

Grove

Lane

Dwellings

nearby

Construction noise Construction Not applicable. Minor CEMP Negative, medium term,

direct Construction vibration Minor

Construction traffic Negligible

Stadium noise highest LAeq, 30 Sec Operation Stadium design

and location

and 2 m high

earth bund.

Minor OMP for

stadium and

training

pitches

Negative, permanent,

direct Training pitch noise LAeq, T No impact

Car park noise Negligible

Fixed plant noise Negligible

Road traffic noise No impact Not applicable


December 2017

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16 CLIMATE CHANGE

Summary

16.1 An assessment has been undertaken of the potential effects of the Revised Scheme on climate

change (‘climate change mitigation’) and of the vulnerability of the Revised Scheme to climate

change (‘climate change adaptation’).

16.2 As this is an amended application, this EIA has been carried out in accordance with the 2011 EIA

Regulations. However, it should be noted that the 2017 Regulations now contain additional

matters which were not required to be assessed in the 2011 Regulations – which includes an

assessment of Climate Change relevant to the project concerned. As these matters are clearly

important, whilst this ES will be determined in line with the 2011 Regulations, the additional

matters which would have been required under the 2017 Regulations have also been assessed.

The scope of this EIA is explained in more detail within Chapter 2.

16.3 The assessment has been undertaken in accordance with published guidance on considering

climate change in EIA and consequently reviews how climate change has been considered at all

stages of project progression and assessment. This includes, for example, the review of

alternatives and the project design, how baseline environmental conditions may change with a

changing climate, and the resilience of mitigation measures to climate change. As advised in

guidance, it is informed by an understanding of future climate change scenarios (for the south-

west of England) and of the potential range of effects associated with these projections. These

projections suggest that, in future, the Site and its surroundings will experience warmer, drier

summers and warmer wetter winters. Whilst heavy rain days are likely to increase throughout

the year, there is still considerable uncertainty with respect to likely changes in both wind speed

and storm frequency/intensity.

16.4 The applicant is committed to implementing a range of outlined design, and additional

mitigation, measures to aspire to deliver a ‘carbon neutral’ development (which achieves net

zero carbon emissions) or ‘a carbon negative’ development (which removes more carbon

emissions from the atmosphere than it creates). Adopting a precautionary approach to the

assessment, it is assumed that the development will be ‘carbon neutral’ rather than ‘carbon

negative’. On the assumption that a robust and verified carbon accounting approach is adopted,

and the development can be constructed and operated as a carbon neutral development, it is

therefore considered that the Revised Scheme will have no significant effects in relation to

climate change mitigation.

16.5 It is not anticipated that the scale of projected climate change identified will fundamentally alter

baseline conditions or the effect judgements included in this ES. It is also not considered that

the Revised Scheme will materially affect the ability of receptors to respond to climate change.

Overall, with the design and mitigation measures proposed, the Revised Scheme is considered

to be resilient to projected climate change. It is therefore considered that the Revised Scheme

will have no significant effects in relation to climate change adaptation.

Introduction


December 2017

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16.6 Over recent decades, climate change has become a more important environmental, social and

economic policy concern. Consequently, climate change is also seen to be an important

consideration in relation to project level assessment and decision-making. The 2017 EIA

Regulations162 therefore require:

“A description of the likely significant effects of the development on the environment

resulting from, inter alia: (f) the impact of the project on climate (for example the nature

and magnitude of greenhouse gas emissions) and the vulnerability of the project to climate

change”.


Regulations163. However, it should be noted that the 2017 Regulations now contain additional


assessment of Climate Change relevant to the project concerned. As these matters are clearly

important, whilst this ES will be determined in line with the 2011 Regulations, the additional

matters which would have been required under the 2017 Regulations have also been assessed.

The scope of this EIA is explained in more detail within Chapter 2.

16.8 This chapter therefore considers the following:

(i) The potential effects of the Revised Scheme on climate change, with measures included in

the project to reduce the emissions of greenhouse gases (GHGs) referred to as climate

change mitigation (not to be confused with ‘EIA mitigation’);

(ii) The vulnerability of the Revised Scheme to climate change, with measures included in the

project to ensure resilience to climate change referred to as climate change adaptation.

16.9 The chapter makes significant reference to other chapters within this ES and also to other

documents which support the planning application, including the Design and Access Statement.

As a consequence, the structure of this chapter differs in part from other assessment chapters.


16.10 This section sets out legislation, policy and related assessments at the international, national and

local level, with respect to both climate change mitigation and adaptation. It also outlines

guidance relevant to the undertaking of this assessment.

International Agreements

16.11 In December 2015, the adoption of the ‘Paris Agreement’ was established through the twenty

first session of the Conference of Parties (COP21), which outlined the motives of UNFCCC164

member states to refocus and meet the ambitions of climate change targets first introduced in

the ‘Kyoto Protocol’ in 1992. The Paris Agreement165stresses the “urgency of accelerating the

implementation of the Convention and its Kyoto Protocol” and within this, ensuring that the long

term temperature goals are met.

162 The Town and Country Planning (Environmental Impact Assessment) Regulations 2017. 163 The Town and Country Planning (Environmental Impact Assessment) Regulations 2011. 164 The United Nations Framework Convention on Climate Change. 165 UNFCCC (2015) Adoption of the Paris Agreement, 21st Conference of the Parties, Paris, United Nations.


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16.12 Article 2 of the Paris Agreement sets out the ambition of holding the increase of global average

temperature to “well below 2°C” and to pursue efforts to limit temperature increase to 1.5 °C. It

was acknowledged that to achieve these ambitions, there is a requirement to ensure Parties

reach global peaking of greenhouse gas emissions as soon as possible and do so by employing

means that allow pathways toward “low greenhouse gas emissions and climate-resilient

development”.

16.13 On 5 October 2016, the threshold for entry into force of the Paris Agreement was achieved, with

at least 55 countries, which account for at least 55% of the world’s greenhouse gas emissions,

ratifying the Agreement. The Paris Agreement entered into force on 4th November 2016 and the

UK ratified the Agreement on 18th November 2016.

UK Context

16.14 The UK Climate Change Act became law in November 2008166. This legislation sets legally binding

targets for reducing emissions of greenhouse gases by 2020 and 2050. The Act makes it the duty

of the Secretary of State to ensure that the net UK carbon account for the year 2050 is at least

80% lower than the 1990 baseline.

16.15 The Climate Change Act established the principle of five year ‘carbon budgets’, with a carbon

budget referring to a permitted level of greenhouse gas emissions in the UK over a five year

period. The carbon budgets run to 2032 (2008- 2012, 2013-2017, 2018-2022, 2023-2027, and

2028-2032). The levels of the first three carbon budgets were approved by Parliament in May

2009, and are now set in law. The fourth carbon budget (2023 -2027)167 became law at the end

of June 2011 and requires greenhouse gas emissions to be reduced by at least 50% in the fourth

budget period, relative to 1990 levels. The fifth carbon budget168 became law in July 2016 and

requires greenhouse gas emissions to be reduced by 57% by 2030169.

16.16 The Climate Change Act also established the Committee on Climate Change as an independent

statutory body to advise the UK and Devolved Governments on setting and meeting carbon

budgets and preparing for climate change. In June 2017, the Committee on Climate Change

published ‘Meeting Carbon Budgets – 2017 Progress Report to Parliament’170. The Report states

that whilst good progress has been made to date, progress is stalling. Since 2012, emissions

reductions have been largely confined to the power sector, whilst emissions from transport and

building stock are rising. It is argued that effective new strategies and policies are urgently

needed to ensure emissions continue to fall in line with the commitments agreed by Parliament.

16.17 The Climate Change Act 2008 also requires the Government, on a five-yearly cycle, to compile an

assessment of the risks for the UK arising from climate change, and then to develop an adaptation

programme to address those risks and deliver resilience to climate change on the ground. In

January 2017, the government published the second risk assessment171, which identified six

priority risk areas:-

166 Climate Change Act, 2008. 167 The Carbon Budget Order 2011 (SI 2011 No.1603). 168 The Carbon Budget Order 2016 (SI 2016 No.785). 169 2030 is selected as the mid-point – see for example https://www.theccc.org.uk/2016/07/20/fifth-carbon-budget-

infographic/ 170 Committee on Climate Change (2017) Meeting Carbon Budgets: Closing the policy gap. 2017 Report to Parliament. 171 HM Government (2017) UK Climate Change Risk Assessment 2017.


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• Flooding and coastal change risks to communities, businesses and infrastructure;

• Risks to health, well-being and productivity from high temperatures;

• Risks of shortages in the public water supply, and for agriculture, energy generation and

industry;

• Risks to natural capital, including terrestrial, coastal, marine and freshwater ecosystems,

soils and biodiversity;

• Risks to domestic and international food production and trade;

• New and emerging pests and diseases, and invasive no-native species affecting people,

plants and animals.

16.18 The updated risk assessment will be followed by an updated national adaptation programme in

2018.

National Planning Context

16.19 The National Planning Policy Framework (NPPF) was published in March 2012 and aims to deliver

sustainable development. In achieving this goal, the NPPF requires developments to “mitigate

and adapt to climate change.” Section 10 of the NPPF ‘Meeting the challenge of climate change,

flooding and coastal change’ emphasises the planning system’s pivotal role in sustainable

development through “minimising vulnerability and providing resilience to the impacts of climate

change”.

16.20 Furthermore, Paragraph 99 of the NPPF states:

“Local Plans should take account of climate change over the longer term, including factors

such as flood risk, coastal change, water supply and changes to biodiversity and landscape.

New development should be planned to avoid increased vulnerability to the range of

impacts arising from climate change. When new development is brought forward in areas

which are vulnerable, care should be taken to ensure that risks can be managed through

suitable adaptation measures, including through the planning of green infrastructure.”

16.21 The national Planning Policy Guidance (PPG) was published in June 2014 and recognises that the

planning system can “increase resilience to climate change impact through the location, mix and

design of development”.

Local Context

16.22 The site is located within the administrative boundary of Stroud District Council, with the Council

adopting their Local Plan172 in November 2015. Made in 2016, the Eastington Neighbourhood

Development Plan173 is also a material planning consideration.

16.23 Climate change is considered in a number of the Local Plan policies, as identified below.

16.24 Core Policy CP14: High Quality Sustainable Development addresses climate change by requiring

all new developments to achieve the following:

• “Sustainable construction techniques ...[that include] measures to minimise energy use and

maximise renewable energy production;

172 Stroud District Council (2015) Stroud District Local Plan. 173 Eastinton Parish Council (2016) Neighbourhood Development Plan 2015-2031.


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• No increased risk of flooding on or off the site, and inclusion of measures to reduce the

causes and impacts of flooding as a consequence of that development;

• Attractive accesses on foot and by cycle and suitable connections with existing footways,

bridleway, cycleways, local facilities and public transport”.

16.25 Delivery Policy ES1: Sustainable construction and design requires the “consideration of climate

change adaptation” to be evidenced in planning applications as the policy states that

“Sustainable design and construction will be integral to new development in Stroud District”.

16.26 Delivery Policy ES2: Renewable or low carbon energy generation supports proposals that

maximise the generation of energy from renewable or low carbon sources, provided that the

installation would not have significant adverse impact (either alone or cumulatively) and includes

an impact statement that demonstrates a number of stated factors.

16.27 Delivery Policy ES6: Providing for biodiversity and geo-diversity states that all new developments

should “enable and not reduce species” ability to move through the environment in response to

predicted climate change, and to prevent isolation of significant populations of species.

16.28 With respect to climate change mitigation, the Eastington Neighbourhood Development Plan

provides policy support for developments encouraging sustainable means of transport,

promoting the development of small scale renewable energy developments (with appropriate

safeguards) and supporting the planting of new trees and hedges.

Guidance Documents

16.29 This chapter has been written with reference to the following guidance documents:

• The Environmental Impact Assessment Guide to Assessing Greenhouse Gas Emissions

and Evaluating their Significance (IEMA , 2017a);

• The Environmental Impact Assessment Guide to Climate Change Resilience and

Adaptation (IEMA, 2015);

• The Environmental Impact Assessment Guide to Delivering Quality Development (IEMA,

2016);

• Delivering Proportionate EIA: A Collaborative Strategy for Enhancing UK Environmental

Impact Assessment Practice (IEMA, 2017b).


16.30 This chapter has been written by LUC, an environmental consultancy established over 50 years

ago. LUC’s EIA experience dates back to the 1970s when the concept was first introduced in the

UK and, since this time, the Company has prepared over 100 ESs, across a range of sectors, and

has undertaken over 100 independent ES reviews on behalf of local authorities. The Company

has also undertaken EIA research projects at the national and European level and has prepared

EIA good practice guidance. LUC has also secured the Institute of Environmental Management

and Assessment (IEMA)’s Quality Mark, which demonstrates the Consultancy’s commitment to

best EIA practice and preparation of ESs of a very high standard. As part of the requirements as

EIA Quality Mark registrants, LUC is required to submit all of their ESs to IEMA for independent

review.


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16.31 The chapter has been authored by Joanna Wright MA MSc MIEMA, a full Member of the Institute

of Environmental Management & Assessment (IEMA) and a Chartered Environmentalist. Joanna

is a Director of Environmental Planning at LUC with over 24 years of professional EIA experience.

In addition to holding an MSc degree in Environmental Impact Assessment, Joanna also qualified

recently to provide EIA input in relation to climate change, having successfully completed a

Postgraduate Diploma in Carbon Management at the University of Edinburgh.

16.32 IEMA guidance stresses that climate change should be an integrated consideration within the

EIA, including, for example, in the review of alternatives and the project design, how baseline

environmental conditions may change with a changing climate and the resilience of mitigation

measures to climate change. It should be informed by an understanding of future climate change

scenarios and of the potential range of effects associated with these projections. The remaining

sections of this chapter therefore focus on climate change projections for the area in which the

Revised Scheme is located and the consideration given to climate change mitigation and

adaptation in the ES and other documentation supporting the planning application, with

reference to a ‘checklist’ of requirements, compiled using the above IEMA guidance.

The Study Area

16.33 With respect to the Study Area, this assessment considers the effects of the scheme on global

climate, with specific reference to the climate changes expected in the UK. These have been

defined using the UK’s climate change projections (UKCP09), which allow climate changes to be

projected at the regional level; in this case, south-west England. The effects of a changing climate

on the scheme have largely been assessed in relation to the site as defined by the Redline

Boundary and its immediate surrounds. In the case of flood risk, the Study Area (see RS Figure

9.1) extends to approximately 250m downstream of the Redline Boundary for direct impacts

(ensuring appropriate consideration of the River Frome).

Consultation

16.34 Given the timing of the introduction of the 2017 EIA Regulations, the proposed approach to

addressing climate change was not set out in the EIA Scoping Report for the project, which

continues to be considered in accordance with the 2011 EIA Regulations. However, this is not

considered to represent a significant assessment limitation, since established climate change

projections have been adopted and that relevant assessment guidance has been followed.

Assessment of Significance

Climate Change Mitigation

16.35 With respect to climate change mitigation and effect significance, as yet, there are no established

thresholds for assessing the significance of an individual project’s contribution to climate change.

However, the IEMA EIA Guide to Assessing Greenhouse Gas Emissions states the following (in

section 6):

“GHG emissions have a combined environmental effect that is approaching a scientifically

defined environmental limit, as such any GHG emissions or reductions from a project might

be considered to be significant…..Therefore in the absence of any significance criteria or a

defined threshold, it might be considered that all GHG emissions are significant and an EIA

should ensure the project addresses their occurrence by taking mitigating action”.


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16.36 Appendix C of the IEMA guidance also refers to the following principles (taken from IEMA, 2016):

• “Where GHG emissions cannot be avoided, the EIA should aim to reduce residual significance of a project’s emissions at all stages”

• “Where GHG emissions remain significant, but cannot be farther reduced… approaches to

compensate the project’s remaining emissions should be considered.”

16.37 The IEMA guidance also suggests that in the absence of defined GHG thresholds, the

performance of a development could be measured against a benchmark, for example an un-

mitigated ‘standard’ development.

16.38 Furthermore, the IEMA EIA Guide to Assessing Greenhouse Gas Emissions also states the

following (in Appendix C):

“When evaluating significance, all new GHG emissions contribute to a significant negative

environmental effect; however; some projects will replace existing development that have higher

GHG profiles. The significance of a project’s emissions should therefore be based on its net impact,

which may be positive or negative.”

16.39 For the purposes of this assessment, the above guidance has been interpreted as outlined in

Table 16.1 below.

Table 16.1: Defining significance for climate change mitigation

Significance of

Effect

Criteria

No significant

effect

The project will aspire to achieve net zero carbon emissions (i.e. it is a

‘carbon neutral development’).

Positive effect

(major,

moderate, minor

significance)

The project will remove more carbon emissions from the atmosphere than it

creates (i.e.it is a ‘carbon negative development’). Further evaluation against

established thresholds and/or other benchmarks for performance will be required

to determine whether this is of major, moderate or minor significance. If a project

is replacing an existing development, this may include comparison against the GHG

profile of the development that is being replaced.

Negative effect

(major,

moderate, minor

significance)

The project will create more carbon emissions than it removes from the

atmosphere (i.e. it is a ‘carbon positive’ development), Further evaluation against

established thresholds and/or other benchmarks for performance will be required

to determine whether this is of major, moderate or minor significance. If a project

is replacing an existing development, this may include comparison against the

GHG profile of the development that is being replaced.

Climate Change Adaptation

16.40 With respect to climate change adaptation and effect significance, section 6.2.5. of IEMA’s

Environmental Impact Assessment Guide to Climate Change Resilience and Adaptation explains

that in determining significance, account should be taken of the susceptibility or resilience of a

receptor to climate change as well as the value of the receptor. A high value receptor that has

very little resilience to changes in climatic conditions should be considered more likely to be

significantly affected than a high value receptor that is very resilient to changes in climatic

conditions. If there is uncertainty about how a receptor will adapt to a changing climate, then a

precautionary approach should be adopted.


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Approach to Identifying Likely Climate Change Scenarios

16.41 In considering future climate change scenarios, IEMA guidance recommends the use of the UK

Climate Projections Website, which is managed by the Met Office and the Environment

Agency174. ‘Probabilistic’ projections are provided for a range of variables including temperature,

precipitation and sea level rise. Wind speed and storm frequency/ intensity are considered

separately as global modelling information is currently more limited.

16.42 Whilst the current projections175, UKCP09, date back to 2009 and are due to be updated in 2018,

the Climate Projections website states that UKCP09 continues to provide a valid assessment of

the UK’s future climate over land. However, when considering decisions that are sensitive to

projected future changes in summer rainfall, additional information should also be used176.

16.43 The UKCP09 projections for temperature and precipitation are presented for the UK as a whole

and also on a regional basis, with the Revised Scheme located within the South West England

administrative region. The UK projections consider three variables:

(i) Timeframe: the projections are presented for three overlapping time periods (2020s,

2050s and 2080s)177

(ii) Probability: The projections are provided as probability distributions rather than single

values, with figures provided for 10, 50 and 90% probability, in addition to the lowest and

highest projected figures.

(iii) Emission scenario: Three scenarios have been adopted; ‘low’, ‘medium’ and ‘high’

emissions178. All scenarios are considered to be equally plausible.

16.44 Table 16.2 below explains the assumptions made in applying the UKCP09 projections to the

Revised Scheme.

Table 16.2: Assessment assumptions

Variable

Assumptions Rationale

Timeframe 2080s This is considered a realistic timeframe given the design

life of the Project and is consistent with timeframes

adopted elsewhere for the purposes of assessment, such

as in the Flood Risk Assessment (see Chapter 9 and

associated documents).

Probability Probability of 50%

with 10% and 90%

range also provided.

The UK Climate Projections Website states that:

• By providing a range of results rather than single best

estimate values, a clearer picture can be provided

174 http://ukclimateprojections.metoffice.gov.uk/ 175 UKCP09 provides ‘projections’ rather than ‘predictions’ because the results are conditional on certain

assumptions that cannot be quantified, such as the likelihood that an assumed pathway of future emissions of

greenhouse gases will turn out to be correct. 176 From the 5th Coupled Model Inter-comparison Project (CMIP5) archive which informed the most recent

Intergovernmental Panel on Climate Change assessment (Intergovernmental Panel on Climate Change (IPCC) AR5). 177 For example, the ‘2020s’ actually refers to the period 2010-2039 whilst the ‘2020s’ actually refers to the time

period 2070 – 2099. 178 These equate to the IPCC scenarios B1, A1B and A1FI respectively.


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Variable

Assumptions Rationale

regarding the level of confidence in different

outcomes.

• Projections in the 10-90% probability level range

should be used for decision-making. There is limited

confidence in the extreme values beyond these

ranges.

Emission scenario Medium Whilst all three scenarios considered equally plausible,

to provide a ‘balanced and appropriate’ assessment, the

medium scenario has been taken forward.

The Revised Scheme and Consideration of Scope of Climate Change

16.45 Table 16.3 below outlines the consideration to be given to climate change mitigation and

adaptation in the ES and other documentation supporting the planning application, with

reference to the coverage advised in the IEMA guidance documents.

Table 16.3: Scope of climate change factors to be considered in the ES and other supporting

documents

Relevance to

EIA

Coverage required179

Policy

context

Are there relevant sector-specific GHG strategies and targets that should be

recognised by the EIA in addressing GHG emissions?

Are there any local and national climate change adaptation plans?

Baseline with

changing

climate

Confirm climate change parameters adopted for baseline and assessment (time

period/emissions scenario/ probability level selected).

Are there readily identifiable thresholds beyond which the scale of change will

fundamentally alter the baseline (e.g. move from wetland to grassland)?

Review of

alternatives:

Has the review of alternatives considered likely contribution to GHG emissions?

Has the review of alternatives considered resilience to climate change?

Project

Design:

Has climate change mitigation and adaptation been considered as part of the project

design?

Has GHG emission mitigation formed part of the project brief (e.g. reducing the

extent of new build, using low carbon technologies, materials and products and

reducing resource consumption generally)?

Is there an overall judgement on the resilience of the project to climate change - both

change in average conditions and extreme events (e.g. design features and

construction materials).

179 Reflecting advice provided in the two IEMA guidance documents on climate change and EIA.


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Impact

assessment:

What are project impacts on measures to reduce climate change? Are project impacts

worse, the same, less than without climate change?

Will the project alter the baseline and/or ability of receptors to respond to climate

change?

Will the value of the receptor change under the influence of climate change?

Is there a statement on the sensitivity of environmental receptors to climate change

(high/moderate/low sensitivity)?

Will the scale/geographic spread of impact change due to the sensitivity of the

baseline to climate change?

Has an assessment of GHG emissions been undertaken if appropriate (to agreed

methodology)?

Mitigation

and

monitoring:

Are there ’carbon mitigation measures’ (e.g. consideration of energy demand/

management, technology or process improvements, management of transport and

travel demands, planting/ afforestation)?

What measures are required to ensure the project is resilient to climate change and

how will these be monitored?

Are mitigation measures ‘climate proof’?

Is/should carbon management considered in any Environmental Management Plan

proposals?

Summary and

NTS:

IEMA guidance recommends that findings relating to the consideration of climate

change are summarised.

Baseline Conditions with Changing Climate

16.46 Table 16.4 below outlines the projected changes in temperature, precipitation and wind speed

and storms by the 2080s, assuming a medium emissions scenario.

Table16.4: Projected climate change

LXXXVIII. Climat

e Variable

LXXXIX.

Projected Change

Temperature Temperatures in the South-West are projected to increase, with projected

increases in summer temperatures greatest. The central estimate of increase in

winter mean temperature is 2.8ºC; it is very unlikely to be less than 1.6ºC and is

very unlikely to be more than 4.3ºC. The central estimate of increase in summer

mean temperature is 3.9ºC; it is very unlikely to be less than 2.1ºC and is very

unlikely to be more than 6.4ºC.

Precipitation Winter rainfall is projected to increase and summer rainfall is most likely to

decrease. The central estimate of change in winter mean precipitation is 23%; it is

very unlikely to be less than 6% and is very unlikely to be more than 54%. The

central estimate of change in summer mean precipitation is -24%; it is very unlikely

to be more than -50% and is very unlikely to be more than 6%.


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LXXXVIII. Climat

e Variable

LXXXIX.

Projected Change

Central estimates are for heavy rain days (rainfall greater than 25mm) over most

of the lowland UK to increase by a factor of between 2 and 3.5 in winter, and 1 to

2 in summer.

With respect to the continued validity of UKCP09 projections for summer rainfall

(see above), whilst the full range of summer rainfall outcomes from UKCP09 are

considered to remain valid in informing planning decisions, it is possible that there

is a somewhat larger chance of an increase, and a smaller risk of substantial future

reductions in summer rainfall, especially for England and Wales180.

Wind speed

and storms

Whilst there is considerable uncertainty with respect to wind speed, there are

small changes in projected wind speed181. Wind speed in summer is projected to

vary by -0.2 to +0.2ms-1 whilst wind speed in winter is projected to vary by -0.3 to

+0.1ms-1.

There is no evidence within the UKCP09 projections of an increase in the frequency

or intensity of storms across the UK. However, it is important to note that there

are still large uncertainties in the future predictions of storms182

16.47 With respect to the baseline for climate change mitigation, greenhouse gas emissions associated

with the construction and operation of the existing facility have not been quantified. However,

it is noted that whilst a previous application to demolish the existing football stadium and re-

develop the site for housing and community uses has been withdrawn (S.17/0850/OUT), it is

expected that this application will be resubmitted and would be dependent on the replacement

facilities being provided as part of the Revised Scheme.

16.48 With respect to climate change adaptation, all environmental topic area authors were provided

with a summary of the climate change projections and were asked to consider the relevance of

this for their baseline descriptions. It is not considered that baseline conditions will be materially

influenced by the projected climate change for the following assessments:

• Socio-Economics (Chapter 11): it is assumed that, at a national/regional level, appropriate

measures will be put in place to ensure flood risk is managed and does not have long term

impacts on economic activity or human welfare. Temperatures are likely to increase and

this is considered below in relation to the potential for crowd overheating.

• Transport & Access (Chapter 12): it is assumed that, at a national/ regional level,

appropriate measures will be put in place to ensure flood risk is managed and does not

have long term impacts on transport infrastructure. Increased summer temperatures may

cause some disruption and discomfort, although this will be temporary in nature and

should be balanced against the likelihood that freezing conditions in winter will be less

likely.

180 Defra, DECC, Met Office and Environment Agency (April 2016) Is UKCP09 still an appropriate tool for adaptation

planning? Land Projections. 181 Met Office and Environment Agency (November 2010) UKCP09: Probabilistic projections of wind speed. 182 Met Office and Environment Agency (undated) UKCP09: Technical Note on Storm Projections.


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16.49 With respect to Archaeology and Cultural Heritage (Chapter 7), given that there are only small

changes in projected wind speed and that there is no evidence of an increase in the frequency or

intensity of storms, baseline conditions are not anticipated to change materially for above ground

heritage features. The possible exception to this is damage as a consequence of the projected

increase in days with heavy rain.

16.50 With respect to sub-surface features, professional guidance recognises the potential effects of

changes in hydrology upon sub-surface archaeological remains, and particularly water-logged

remains. The Historic England publication ‘Preserving Archaeological Remains: Decision-Taking for

Sites under Development’ (2016) sets out key issues in this regard in Chapter 4 ‘Water Availability

and Stresses’. Superficial geological deposits, particularly palaeoenvironmental deposits, may be

subject to quite localised groundwater conditions, making them sensitive to change. Organic

remains may sometimes be preserved in anaerobic conditions, below localised water tables, with

de-watering occurring not only near-surface, but also in deeper strata. However, as the geology

within the Redline Boundary does not contain superficial geological deposits, and does not have

potential for sealed organic or other palaeoenvironmental remains, the baseline conditions with

respect to sub-surface features are not expected to alter as a consequence of any climate related

changes. The possible exception to this is the exposure of previously undiscovered archaeological

remains through erosion, as a consequence of projected warmer temperatures and/ or an increase

in days with heavy rain.

16.51 With respect to Ecology and Nature Conservation (Chapter 8), Natural England’s ‘Climate Change

Risk Assessment and Adaptation Plan’183 sets out the risks and threats posed by current climate

change projections. In association with the RSPB, Natural England has also published a Climate

Change Adaptation Manual which details the potential effects of climate change on different

habitat types.184

16.52 There are no protected habitats within the Development Footprint, and the majority of the habitat

is lowland neutral agriculturally improved and semi-improved grassland divided by mature

hedgerows. Natural England’s Climate Change Adaptation Manual identifies both lowland

grasslands and hedgerows as having low sensitivity to climate change.

16.53 Increased rainfall and flooding events, coupled with rising temperatures, are also likely to modify

UK flora over time, with shifts in species’ ranges. All bat species will potentially benefit from higher

temperatures and more insect food; although an increase in heavy rain days in summer could

prove detrimental. Milder winters may also cause them to leave their hibernation sites early.

Higher temperatures may also benefit slow worm and grass snake.

16.54 With respect to hydrology, the historic flood records referred to in Chapter 9 identify two isolated

events in the vicinity of the Northern and Southern Site areas, an unknown flood event within the

Development Footprint to the north of the A419, and a flood event from artificial drainage on the

A419. By contrast, a total of 18 flood events are recorded within the area west of the M5

motorway or at the neighbouring Eastington Maintenance Compound.

183 Natural England (2015) Climate Change Risk Assessment and Adaptation Plan (NE612). 184 Natural England (2014) Climate Change Adaptation Manual – Evidence to support nature conservation in a

changing climate (NE546).


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16.55 The modelling of flood risk for the Revised Scheme includes a 25% increase in peak river flows

and a 40% increase in rainfall intensity over a 60 year development design lifetime, in accordance

with the Environment Agency’s Climate Change Allowances Guidance185.

16.56 With respect to the Landscape and Visual Assessment (Chapter 10), the Landscape Institute’s

position statement on climate change186 acknowledges that changes in average temperatures,

precipitation and extreme weather events will have an effect on the landscape. However, whilst

a change in rainfall and rising temperatures are anticipated, it is not considered that this will

appreciably change the baseline landscape conditions.

16.57 With respect to Air Quality and Dust (Chapter 13), the baseline air quality estimated at the Site

does not exceed the relevant air quality objectives for NOx, NO2, PM10 and PM2.5 An increase in

dry and hot weather in summer is expected to lead to an increase in PM10 (dust) concentrations,

particularly re-suspended dust which is coarse in size when compared to vehicle exhaust

particles. With regards to ultrafine particles and gaseous pollutants, their concentrations tend

to be lower because of favourable conditions for dispersion and dilution of their emissions. An

increase in winter rainfall and/or in heavy rain days (rainfall greater than 25mm) could lead to a

possible decrease in pollutant concentrations, with a decrease in summer rainfall leading to a

possible increase in concentrations. However, it is not anticipated that baseline air quality at the

Site will fail to meet relevant air quality objectives as a consequence of projected climate change.

16.58 Given that there are only small changes in projected wind speed and that there is no evidence of

an increase in the frequency or intensity of storms, baseline conditions are not anticipated to

change materially for Major Accidents and Disasters (Chapter 17).

Review of Alternatives

16.59 Chapter 4 provides an outline of the main alternatives considered for the future location of the

Forest Green Rovers Football Club. At the outset, it is important to note that the main driver for

finding a new site is that the existing location cannot accommodate a growing football club in

line with long term sustainability objectives.

16.60 With respect to climate change mitigation, the criteria for reviewing alternatives included access

by public transport. With respect to climate change resilience, Flood Zones 2 and 3 were

removed from the area of the search for the project.

Project Design

16.61 Chapter 4 provides an overview of the project’s design evolution whilst Chapter 5 describes the

development for which planning permission is being sought. Further information is also provided

in the Design and Access Statement which supports the planning application.

16.62 The following measures have been incorporated into the project design to seek to reduce the

generation of greenhouse gases through the production and use of construction materials, and

energy usage:

• The stadium design is predominantly of cross-laminated timber construction, which has a

lower carbon footprint than a stadium constructed of steel and concrete. The limited

185 https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances 186 Landscape Institute (2008) Landscape architecture and the challenge of climate change: Position Statement.


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amounts of steel required will have a high recycled content, whilst the concrete will

contain recycled components such as fly ash and furnace slag.

• To avoid resource wastage, the roof support structure aims for minimal material usage,

whilst the sustainable materials strategy will also see the use of locally sourced products.

Consideration will be given to constructing some internal site roads of KWS Infra recycled

‘plastic roads’.

• An aim for internal rooms within the stadium to meet ‘Passivhaus’ standards, which have

excellent thermal performance and air-tightness, with mechanical ventilation to minimise

heating/ energy demand.

• The facility has been designed to ensure the maximum use of natural daylight, limited

use of artificial lighting (both internal and external), and to use both energy efficient

lighting technology (such as the use of LEDs) and sustainable occupant controls to

minimise energy consumption.

• Whilst not included in the current layout, it is intended that a biomass boiler and small

anaerobic digestion plant will be incorporated at the detailed design stage (Reserved

Matters), with a separate planning application submitted if required.

• The design team is also reviewing options for incorporating solar panels into the final

design.

16.63 Natural England’s ‘Climate Change Risk Assessment and Adaptation Plan’187 recognises that

climate change offers opportunities as well as threats. The Plan states, for example, that:



(sense of place, biodiversity and other ecosystem services).” (page 10)

16.64 Landscaping is an important component of the project design. This includes the translocation of

existing native species hedgerows and new tree planting to create a ‘parkland’ setting for the

stadium (see RS Appendix 10.7) and RS Figures 10.11c and 10.11d. This will sequester (capture

and store) carbon and also create shade for cooling.

16.65 Ultimately, the aim is that over time the Revised Scheme will be a carbon neutral or carbon

negative development.

Potential Effects

Climate Change Mitigation

16.66 Sources of greenhouse gas emissions associated with the Revised Scheme include the following:

(i) Direct CO2 and NOx emissions from vehicles and plant during construction, operation and

decommissioning;

187 Natural England (2015) Climate Change Risk Assessment and Adaptation Plan (NE612).


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(ii) Indirect emissions arising from the demand for energy produced using fossil fuels (e.g.

electricity for heating, cooling and lighting); and

(iii) ‘Embodied carbon’ in the materials and systems which form temporary and permanent

structures, arising as a result of the extraction and manufacture of materials, fabrication,

transport to site, waste and the future demolition and potential for re-use.

16.67 With respect to the potential for likely significant effects, the following are ’scoped in’ for more

detailed consideration:

(i) Direct CO2 and NOx emissions associated with vehicle movements during the operational

phase;

(ii) Indirect emissions arising from the demand for energy produced using fossil fuels during

the operational phase;

(iii) Embodied carbon in the permanent structures forming part of the Revised Scheme.

Direct Emissions

16.68 Transport accounts for around a quarter of UK greenhouse gas emissions with government policy

seeking to reduce these emissions by promoting public transport choices, supporting the market

for innovative forms of transport and encouraging a move to cleaner and lower carbon

vehicles188. The highest levels of vehicle movements associated with the stadium will occur on

match days, with the transport and access assessment (Chapter 12) assessing a maximum case

of a full 5,000 capacity attendance. For a crowd of 5,000, this suggests a total of 1,694 car

movements one way.

16.69 Mitigation for CO2 and NOx emissions has been identified and included in the project to reduce

overall car movements and encourage alternative modes of transport includes:

• A signal controlled pedestrian and cycle crossing of the A419, with a combined footway /

cycleway on the south side of the A419. This will link to National Cycle Network (NCN)

Route 45 at Grove Lane, which connects eastwards towards Stroud.

• A scheme for improvements to NCN Route 45 from Stonehouse.

• A bus-only connection between the Revised Scheme and Grove Lane to enable buses

serving the West of Stonehouse (WOS) development to serve the stadium.

• A full Park & Ride service from all appropriate locations (such as the railway station and

Nailsworth) on match days.

16.70 Reducing the overall number of vehicle movements will reduce direct CO2 and NOx emissions

associated with the operational phase of the development when compared with the level of

‘unmitigated’ emissions.

Indirect Emissions

16.71 The primary objective is to reduce overall energy demand, which will reduce indirect emissions

arising from energy produced using fossil fuels. The proposed measures are outlined above

188 https://www.gov.uk/government/policies/transport-emissions


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under ‘Project Design’. It is also proposed to incorporate small scale renewable energy

generation into the project (see ‘Project Design’ above).

16.72 Energy use will also be monitored, recorded and reported during both the construction and

operational phases. BREEAM (the Building Research Establishment Environmental Assessment

Method) will be used to ensure that the design measures outlined above under ‘Project Design’

are carried through into the construction phase, with an aspiration for achieving the

‘outstanding’ standard. BREEAM is part of The Code for a Sustainable Built Environment which is

a strategic international framework for the sustainability assessment of the built environment.

The Code defines an integrated approach to the design, construction, management, evaluation

and certification of environmental, social and economic impacts across the full life cycle of the

building projects. It includes consideration of energy performance.

16.73 Reducing overall energy demand and generating energy from renewable sources will reduce

indirect emissions of greenhouse gas emissions when compared to the level of ‘unmitigated’

emissions.

Embodied Carbon

16.74 The stadium design includes a number of measures to reduce embodied carbon. As noted above,

BREEAM (the Building Research Establishment Environmental Assessment Method) will be used

to ensure that the design measures outlined above under ‘Project Design’ are carried through

into the construction phase.

16.75 During construction, a Site Waste Management Plan will also be used to design out waste, reduce

waste generated on site, and implement procedures to sort and reuse/ recycle construction

waste on and off site.

16.76 Incorporating measures to reduce embodied carbon will reduce emissions of greenhouse gas

emissions when compared with the level of ‘unmitigated’ emissions.

Residual Effects

16.77 The level of anticipated greenhouse gas emissions has not been calculated at this stage, as the

detailed design will be secured under future Reserved Matters applications. It is not therefore

possible to compare the GHG profile of the Revised Scheme against the profile of the existing

facility. The applicant is committed to implementing a range of measures to aspire to deliver a

‘carbon neutral’ or ‘carbon negative’ development, and these are outlined in this chapter. This

is considered to accord with the principle of adopting a proportionate approach to assessment

(see IEMA, 2017b), particularly given the level of detailed design information available at this

stage.

16.78 Adopting a precautionary approach to the assessment, it is assumed that the development will

aspire to be ‘carbon neutral’ rather than ‘carbon negative’. On the assumption that a robust and

verified carbon accounting approach is adopted at a later stage, and the Development can aspire

to be constructed and operated as a carbon neutral development, it is considered that the

Revised Scheme will have no significant effects in relation to climate change mitigation.

Climate Change Adaptation


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16.79 Taking account of those receptors identified above, under ‘baseline conditions’, as potentially

susceptible to a changing climate, this section gives further consideration as to whether or not

the Revised Scheme is likely to affect impact judgements and/ or ability to adapt to climate

change in relation to the following:

• Flood risk, hydrology and drainage;

• Ecology and nature conservation;

• Landscape and visual amenity;

• Socio-economics (spectator welfare).

Flood risk, hydrology and drainage

16.80 Chapter 9 explains that in the Severn River Basin District, wetter winters and more rain falling in

wet periods may increase river flooding for rivers and tributaries. More intense rainfall causes

more surface runoff, increasing localised flooding and erosion. In turn, this may increase pressure

on drains, sewers and water quality. Rising river levels may increase local flood risk inland or

away from major rivers because of interactions with drains, sewers and smaller watercourses.

16.81 To reflect the Environment Agency’s Flood Risk Assessments: Climate Change Allowances, an

allowance of a 40% increase in the rainfall intensity values for the period 2060 to 2115 will be

included in the detailed design of the drainage, to ensure that there is no flooding to properties

during high rainfall events.

16.82 Furthermore, the incorporation of SuDS (Sustainable Drainage Systems) infiltration features into

the surface water drainage network will also assist in ensuring adaptation to climate change (see

RS Appendix 9.1). This will include the use of permeable surfaces for all parking areas and

footpaths in addition to other SuDs elements such as swales and ponds.

16.83 Projected climate change is already reflected in the effects. Whilst flood risk receptors are

considered as of high value, measures will be incorporated to help to ensure that there are no

significant effects on the Revised Scheme’s ability to adapt to climate change.

Ecology

16.84 Given the low sensitivity of identified receptors, it is not anticipated that projected climate

change will materially alter predicted effects on habitats. Whilst of higher value, given the

timescale in question and the projected rate of change, it is not anticipated that projected

climate change will materially alter predicted effects on protected species.

16.85 Notwithstanding this, habitat management measures can be introduced to assist habitats and

species adapt to the anticipated change. Such measures form part of the SuDS proposals

(embedded mitigation) for the Revised Scheme, which will be the subject of detailed design at

the Reserved Matters Application stage. This will include details of climate change adaption

measures at this particular location, for example by specifying suitably resilient plant species or

pollinator species suitable for invertebrates shifting their range northward, so as to exploit the

opportunity climate change presents to create valuable new habitats, in accordance with Natural

England Guidance. Ensuring a resilient habitat management plan will help to ensure that there

are no significant effects on the Revised Scheme’s ability to adapt to climate change.

Landscape and visual amenity


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16.86 It is not anticipated that the projected climate change will materially alter predicted landscape

and visual effects. Landscape design measures will be introduced to adapt to the anticipated

change in rainfall and temperature, as outlined in the proposed landscape strategy (RS Appendix

10.7), which will be the subject of detailed design at the Reserved Matters Application stage. As

discussed above under ‘ecology’, this will include details of measures to cope with climate change

at this particular location, for example by specifying suitably resilient plant species, so as to

exploit the opportunity climate change presents to create ‘valuable new landscapes’, in line with

Natural England guidance. Ensuring a resilient landscaping plan will help to ensure that there are

no significant effects on the Revised Scheme’s ability to adapt to climate change.

Socio-economics (spectator welfare)

16.87 Summer temperatures are projected to increase by between is 2.1ºC and 6.4ºC (with a central

estimate of 3.9ºC). To manage the increased risk of potential crowd ‘overheating’, which is only

a potential risk at the start of the football season, measures will include the provision of drinking

water fountains and public announcements encouraging people to remain hydrated and to stay

in the shade if possible. Ensuring adequate measures are in place to respond to potential

spectator heat stress will help to ensure that there are no significant effects on the Revised

Scheme’s ability to adapt to climate change.

Wider Mitigation and Monitoring

16.88 A review of the wider resilience of the mitigation measures which are identified in Chapter 19 in

relation to predicted significant effects has not identified any concerns in relation to their

resilience to climate change, noting that this is already being considered in the SuDs drainage

design and the proposed Green Infrastructure Plan/ landscaping strategy. This also applies to

other enhancement measures identified elsewhere in the ES in relation to non-significant effects.

16.89 With respect to monitoring the Revised Scheme’s resilience to climate change, it is noted that

the UK climate change projections will be updated on a regular basis over the lifetime of the

Revised Scheme, with the next updates due in 2018. These should be reviewed to ensure that

the Revised Scheme remains resilient, with particular attention paid to revised projections for

wind, storms and extreme events, where uncertainty is currently greatest.

Cumulative Effects

16.90 Chapter 2 outlines the list of committed developments which have been identified for

cumulative assessment.

16.91 With respect to climate change mitigation, climate change is, in essence, a cumulative effect and

all greenhouse gas emissions from projects are arguably significant. All the developments listed

in Chapter 2 will involve the generation of direct, indirect and embodied greenhouse gas

emissions during construction and further emissions during operation. It is not possible to

compare the level of these emissions against a ‘baseline’ of those associated with the previous

use of the sites and/ or any existing developments which would be replaced by the committed

developments. It is, however, noted that application 13/0001/INQUIR relates to the

development of an Energy from Waste (EfW) facility, a low carbon technology.

16.92 In accordance with the criteria set out earlier in this chapter, as all emissions are arguably

significant, it is important that all developments include climate change mitigation measures.

Whilst not all of these developments are subject to EIA, and the requirement to consider climate

in EIA is a recent one, all planning applications are subject to review against Local Plan policy


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which states that “Sustainable design and construction will be integral to new development in

Stroud District” (Delivery Policy ES1) and requires consideration of access on foot and bicycle and

public transport (Core Policy CP14). On this basis, it is considered appropriate to assume that

any applications that are consented include ‘reasonable’ measures to avoid, reduce and/or offset

the generation of greenhouse gas emissions.

16.93 With respect to climate change adaption, this is largely a project specific consideration, namely

the resilience of the project in question to climate change and the extent to which projected

climate change could alter the predicted impact judgements. More widely, in relation to

potential interactions with other developments, and following the same logic with respect to

required compliance with planning policy, it is noted that Core Policy CP14: High Quality

Sustainable Development requires all new developments to achieve “no increased risk of flooding

on or off the site, and inclusion of measures to reduce the causes and impacts of flooding as a

consequence of that development” whilst Delivery Policy ES1: Sustainable construction and

design requires the “consideration of climate change adaptation”.

Conclusions

Climate change mitigation

16.94 The applicant is committed to implementing a range of outlined measures to aspire to deliver a

‘carbon neutral’ or ‘carbon negative’ development. Adopting a precautionary approach to the

assessment, it is assumed that the development will be ‘carbon neutral’ rather than ‘carbon

negative’. On the assumption that a robust and verified carbon accounting approach is adopted,

and the Revised Scheme can be constructed and operated as a carbon neutral development, it is

considered that the Revised Scheme will have no significant effects in relation to climate change

mitigation.

Climate change adaptation

16.95 It is not anticipated that the scale of projected climate change identified will fundamentally alter

baseline conditions or the effects included in this ES. It is also not considered that the Revised

Scheme will materially affect the ability of receptors to respond to climate change. Overall, with

the design and mitigation measures proposed, the Revised Scheme is considered to be resilient

to projected climate change. It is therefore considered that the Revised Scheme will have no

significant effects in relation to climate change adaptation.


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17 MAJOR ACCIDENTS AND DISASTERS

Summary

17.1 An assessment has been undertaken of any potentially significant adverse effects on the

environment deriving from the vulnerability of the development to risks of major accidents and/

or disasters.




assessment on Major Accidents and Disasters relevant to the project concerned. As these

matters are clearly important, whilst this ES will be determined in line with the 2011 Regulations,

the additional matters which would have been required under the 2017 Regulations have also

been assessed. The scope of this EIA is explained in more detail within Chapter 2.

17.3 To date, there is no specific guidance on how to consider Major Accidents and Disasters within

the context of EIA. However, the assessment takes account of emerging EIA good practice, which

refers to other relevant documentation, including the Cabinet Office’s National Risk Register of

Civil Emergencies.

17.4 A two-stage tiered scoping process has been adopted for the assessment. Firstly, and in

accordance with emerging EIA practice elsewhere, health and safety matters were excluded from

the assessment as they are covered elsewhere by detailed legislation. Secondly, the use of an

‘Initial Risk Screening List’ ruled out any potential accidents and disasters that are considered to

be highly unlikely to occur in the context of the project, such as earthquakes, wildfires or coastal

flooding. Those major accidents and disasters that could not be screened out formed a further

‘Refined List’ and were subject to more detailed consideration. The Refined List includes, for

example, surface water flooding; hurricanes, storms and gales; extreme temperatures and

pollution incidents.

17.5 Given a number of proposed design and operational measures, which are all considered and

reported in the assessment, it is not anticipated that the Revised Scheme is vulnerable to any

major accidents and/ or disasters which could result in significant effects on the environment.

Introduction

17.6 As major accidents and disasters can potentially result in significant adverse environmental

effects, it is prudent for them to be considered at the planning stage of a development. Through

identifying major accidents and disasters at an early stage, it is possible to prevent such events

from occurring, reduce the risk of this happening, or decrease the extent of their potential harm

in the local area and on local communities.

17.7 The structure of this chapter does not confirm to the typical chapter structure used elsewhere in

this Environmental Statement (ES) as it is recognised that existing legislation and health and

safety requirements already identify risks and help protect human beings and the

environment189. For this chapter to remain proportionate, it is not a full risk assessment in itself.

189 Examples include the Construction Design and Management (CDM) 2015 Regulations; Safety at Sports Grounds

Act 1975; The Fire Safety and Safety Places of Sports Act 1987; and the Guide to Safety at Sports Grounds (Green

Guide) 5th Edition.


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Rather this chapter identifies risks and explains whether or not they are relevant for the Revised

Scheme, and signposts other documentation where these risks have been addressed.


17.8 This ES is the output of the EIA process which has been undertaken in accordance with the Town

and Country Planning (Environmental Impact Assessment) Regulations 2011, as amended in 2015

(hereafter referred to as the ‘EIA Regulations’).




assessment on Major Accidents and Disasters relevant to the project concerned. As these

matters are clearly important, whilst this ES will be determined in line with the 2011 Regulations,

the additional matters which would have been required under the 2017 Regulations have also

been assessed. The scope of this EIA is explained in more detail within Chapter 2.

International

17.10 Paragraph 18 of Directive 2014/52/EU190 states:

“In order to ensure a high level of protection of the environment, precautionary actions need to

be taken for certain projects which, because of their vulnerability to major accidents, and/or

natural disasters (such as flooding, sea level rise, or earthquakes) are likely to have significant

adverse effects on the environment. For such projects, it is important to consider their

vulnerability (exposure and resilience) to major accidents and/or disasters, the risk of those

accidents and/or disasters occurring and the implications for the likelihood of significant adverse

effects on the environment.”

National

17.11 The above has been transposed into UK law under Schedule 4 (8) of the 2017 EIA Regulations191

which require:

“A description of the expected significant adverse effects of the development on the

environment deriving from the vulnerability of the development to risks of major accidents

and/or disasters which are relevant to the project concerned”.

17.12 It is worth noting that the UK approach has removed the word ‘natural’. An article written by a

registrant of the EIA Quality Mark Registrant Scheme of Institute of Environmental Management

and Assessment (IEMA) suggests that given the intention underlying this aspect of the 2017

Directive, both manmade and natural disasters should be considered192.

17.13 There is no specific guidance available at present on the assessment of major accidents and

disasters, and as this is a new topic within the realms of EIA, its approach will evolve over time.

190 EU Directive 2014/52EU amending Directive 2011/92/EU on the assessment of the effects of certain public and

private projects on the environment. 191 The Town and Country Planning (Environmental Impact Assessment) Regulations 2017. 192 IEMA (2016) EIA Quality Mark Article: Assessing Risks Of Major Accidents / Disasters In EIA. Available at:

https://www.iema.net/assets/uploads/EIA%20Articles/wsp_assessing_risks_of_major_accidents_disasters_in_eia_

revised.pdf


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However, taking account of emerging EIA practice, and advice from a recent EIA webinar advising

on Major Accidents and Disasters in EIA193, the following have been consulted:

• The Cabinet Office National Risk Register of Civil Emergencies (2017 Edition)194. This

document is the unclassified version of the National Risk Register and it identifies the main

types of civil emergencies that could affect the UK in the next five years. It is recognised,

however, that this document does not provide an all-encompassing list of all potential

accidents and disasters and its timescales are short term.

• The International Federation of Red Cross & Red Crescent Societies Early Warning, Early

Action (2008). This guidance looks to other countries including those in warmer climates,

thereby identifying risks that the UK may encounter in the future in light of climate change

and global warming.

• The International Disaster Database. This online source contains data covering over 22,000

mass disasters in the world since 1900 to the present day and aims to “rationalise decision

making for disaster preparedness, as well as provide an objective base for vulnerability

assessment and priority setting.”

17.14 Using these documents ensures that all potential major accidents and disasters are identified.


17.15 This chapter has been written by LUC, an environmental consultancy established over 50 years

ago. LUC’s EIA experience dates back to the 1970s when the concept was first introduced in the

UK and, since this time, the Company has prepared over 100 ESs, across a range of sectors and

undertaken over 100 independent ES reviews on behalf of local authorities. The Company has

also undertaken EIA research projects at the national and European level and has prepared EIA

good practice guidance. LUC has also secured the Institute of Environmental Management and

Assessment (IEMA)’s Quality Mark, which demonstrates the Consultancy’s commitment to best

EIA practice and preparation of ESs to a very high standard. As part of the requirements as EIA

Quality Mark registrants, LUC is required to submit all of their ESs to IEMA for independent

review. LUC is therefore well placed to address the new requirement to consider the potential

for significant adverse effects on the environment deriving from the vulnerability of the

development to relevant risks of major accidents and/or disasters.

17.16 This chapter was authored by Joanna Wright and Katie Norris of LUC. Joanna Wright MA MSc

MIEMA CEnv has an MSc in Environmental Impact Assessment, is a full Member of the Institute

of Environmental Management & Assessment and a Chartered Environmentalist. Joanna is a

Director of Environmental Planning at LUC and has over 24 years of professional EIA experience.

She has led on the integration of the new EIA regulations into LUC’s work, including incorporation

of the new requirement to consider the risk of major accidents and disasters, and spoke earlier

this year at the joint Scottish Government/IEMA conference on the implementation of the new

regulations. Katie Norris BA (Hons) MSc GradIEMA is a Senior Environmental Planner and since

joining LUC in 2015, has contributed to a wide range of EIAs, including mixed use schemes, a

193 IEMA (2017) EIA Quality Mark Webinar: Major Accidents and Natural Disasters in EIA. 13th July 2017. 194 Cabinet Office (2017) National Risk Register Of Civil Emergencies. Available at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644968/UK_National_Risk_Regis

ter_2017.pdf


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railway reinstatement project (a National Significant Infrastructure Project) and the nearby

reinstatement of the Cotswold Canals Phase 1B: Missing Mile.

Definitions

17.17 Although ‘accident’, ‘risk’ and ‘disaster’ are well known terms and are used in everyday language,

there is potential for their meaning to be interpreted differently. Currently, there are no standard

definitions adopted for EIA. The article written by a registrant of the EIA Quality Mark Registrant

Scheme in 2016 advised that the definition of accidents should be similar to the following:

“man-made and natural risks which are considered to be likely, and are anticipated to

result in substantial harm that the normal functioning of the project is unable to cope

with/ rectify i.e. a significant effect”.

17.18 However, a recent IEMA EIA webinar on Major Accidents and Disasters used definitions taken

from various sources that were already used in previous EIAs, and are, for the purposes of this

chapter, therefore deemed to be appropriate.

17.19 The Oxford English Dictionary defines ‘accident’ as:

“An unfortunate incident that happens unexpectedly and unintentionally, typically resulting in

damage or injury”.

17.20 The International Federation of Red Cross and Red Crescent Societies’ definition of ‘disaster’ is:

“A sudden, calamitous event that seriously disrupts the functioning of a community or society and

causes human, material, and economic or environmental losses that exceed the community’s or

society’s ability to cope using its own resources. Though often caused by nature, disasters can

have human origins”195.

17.21 Risk is defined in this chapter as:

“The product of the likelihood of an event occurring and the severity of the impact.196”

Significant effects

17.22 As the purpose of this chapter is to identify risks that result in ‘significant adverse effects’ this

definition is considered to mean:

“The loss of life or permanent injury, and/or permanent or long lasting damage to an

environmental receptor.197”

17.23 All effects are considered to be adverse. The duration of effects is highlighted in the definition of

‘significant adverse effects’ and is therefore considered within this chapter.

195 International Federation of Red Cross and Red Crescent Societies (no date) What is a disaster? Available at:

http://www.ifrc.org/en/what-we-do/disaster-management/about-disasters/what-is-a-disaster/ 196 Burrohappold Engineering (2016) Resilience Insight. Available at: https://www.burohappold.com/wp-

content/uploads/2016/06/2016-Royal-Charter-International-Research-Award-BuroHappold-Resilience-Insight-12-

Cities-Assessment-v2.pdf 197 IEMA (2017) EIA Quality Mark Webinar: Major Accidents and Natural Disasters in EIA. 13th July 2017.


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17.24 Two categories of effect are identified: ‘significant effects’ or ‘no significant effects’; there are no

degrees of significance identified.

Major Accidents and Disasters Scoped In

17.25 Significant adverse effects have been considered both within and outside the Redline Boundary

of the Revised Scheme.

17.26 In line with Part 1 4 (2) of the EIA Regulations, the chapter considers these receptors:

• Population and human health;

• Biodiversity, with particular attention to species and habitats protected under Directive

92/43/EEC(a) and Directive 2009/147/EC(b);

• Land, soil, water, air and climate;

• Material assets, cultural heritage and the landscape;

• The interaction between the factors of the above.

Major Accidents and Disasters Scoped Out

17.27 Low likelihood and low consequence events, such as minor spills, have been scoped out as these

events are unlikely to result in significant adverse effects as they do not fall into the category of

a major accident or disaster. Highly likely and low consequence events are also scoped out as

they will not lead to significant adverse effects. Furthermore, high likelihood and high

consequence events are also scoped out, as it is assumed that existing legislation and regulatory

controls would not permit the project to be progressed under these circumstances.

17.28 A two stage tiered scoping process has taken place:

• The first component is in accordance with emerging EIA practice elsewhere, whereby

health and safety is scoped out of this chapter as it is covered by detailed legislation. This

includes risks to employees which are covered by the Management of Health and Safety

at Work Regulations 1999, The Workplace (Health, Safety and Welfare) Regulations 1992

and The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995.

Ecotricity has committed to constructing and managing the Revised Scheme in accordance

with, inter alia:

o Health and safety management systems;

o Supplier management health and safety standards;

o Risk management systems;

o Construction and Environmental Management Systems (which are considered

under the planning conditions).

o Similarly, match day crowds are covered under licence.

• The Initial Risk List forms the second component of the scoping process by ruling out any

potential accidents and disasters that are considered to be highly unlikely to occur. This

screening process illustrates that due account has been taken of the full range of potential

accidents, risks and disasters and that the assessment process is fully transparent.

Initial Risk List


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17.29 Based on the sources identified in the Legislation, Policy and Guidance section above, and taking

specific account of the type of development in question (a sports stadium) and its location, Table

17.1 below provides an initial screening list of major accidents and disasters for consideration. It

is important to note that as this covers all risks and disasters on a global scale, some risks will not

be applicable to the Revised Scheme and the justification for a major accident or disaster to be

screened out is explained in the last column of the Initial Risk List. Those major accidents and

disasters that cannot be screened out, and therefore require further consideration in this

Chapter, are considered in the ‘Baseline Conditions’ section below the Initial Risk List and in Table

17.2: The Refined List.

17.30 For the Initial Risk List (Table 17.1), if the major accident or disaster type is not considered a

potential risk for the location of the Revised Scheme, a ‘x’ is indicated under the ‘location risk’

column. Similarly, if the major accident or disaster is not associated with the proposed use of

the development, either at the construction or operational phase, a ‘x’ is indicated. Where all

columns receive a ‘x’, for an identified major accident or disaster, this major accident or disaster

is screened out.

17.31 If the major accident or disaster is considered a potential risk owing to either the location of the

Revised Scheme or its use during construction or operation, a ‘’ is given. If a ‘’ is identified in

either column, or in both columns, the major accident or disaster is screened in and taken to the

next stage, the Refined List (Table 17.2). The Refined List considers whether or not the Revised

Scheme could make the major accident/ disaster worse (in the absence of any mitigation) and

whether or not the Revised Scheme could in turn be affected by the major accident or disaster.


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Table 17.1: The Initial Risk List

Disaster group Disaster sub group Accident/ Disaster type Location

risk

Proposed use risk Is further consideration required?

Construction

risk

Operational

risk

Natural

hazards

Geophysical Earthquakes x x x No – screened out:

Earthquakes do occur in Britain owing to the motion of the Earth’s tectonic plates causing

regional compression. In addition, uplift resulting from the melting of the ice sheets that

covered many parts of Britain thousands of years ago can also cause movement.

Earthquakes experienced in Britain can cause considerable damage to buildings, but the

British Geological Survey (BGS) notes that this is relatively small compared to the devastation

resulting from earthquakes occurring in other parts of the world. Between 1580 and 1940,

11 people have died as a result of earthquakes occurring in Britain (largely as a result of

falling stones, falls from upper floors or shock). However, no deaths related to earthquakes

in the UK have been recorded since 1940.

The BGS acknowledges that on average, a magnitude 4 earthquake happens in Britain

roughly every two years and a magnitude 5 earthquake occurs around every 10 to 20 years.

Their research found that the largest possible magnitude earthquake in the UK is around 6.5.

Smaller magnitude earthquakes can be felt by people and the BGS estimate that between 20

and 30 earthquakes each year occur with a few hundred smaller ones recorded by sensitive

instruments.

According to the BGS, the largest earthquake in Britain occurred in 1931 near the Dogger

Bank, around 60 miles offshore and 345km north east of the Revised Scheme. Due to this

remote location, the magnitude 6.1 earthquake only caused minor damage to buildings on

the east coast of England. The BGS record that one person died in Hull of shock, but this is

uncertain.

The BGS notes that the most damaging earthquake in Britain occurred in 1884 around

Colchester, approximately 225km east of the Revised Scheme, where structural damage such

as collapsed chimneys and cracked walls occurred to approximately 1,200 buildings. The

earthquake’s magnitude was 4.6 and records held by BGS suggest that there were two

fatalities.

In terms of geographic proximity, the closest epicenter of an earthquake to the Revised

Scheme occurred in Hereford in 1896 with a magnitude of 5.3 and is recorded as being the

largest onshore earthquake in England.

As such, the Cabinet Office National Risk Register of Civil Emergencies states that

“Earthquakes in the UK are moderately frequent but rarely result in large amounts of

damage. An earthquake of sufficient intensity (determined on the basis of the earthquake’s

local effect on people and the environment) to inflict severe damage is unlikely.”


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risk


Construction

risk

Operational

risk

As earthquakes have not caused any deaths in the UK since 1940, and buildings are damaged

(not devastated) this disaster is screened out.

Volcanic activity x x x No – screened out: Volcanic activity does not occur in the UK and is not linked to the Revised

Scheme.

It is noted that volcanic activity originating in other countries can disrupt air travel, but this is

unlikely to create any significant risk for the Revised Scheme.

Landslides x x x No – screened out: No historical landslides have been recorded within the Redline Boundary

of the Revised Scheme198.

Tsunamis x x x No – screened out: the Revised Scheme is located inland, outside a tsunami risk zone199.

Hydrological Coastal flooding x x x No – screened out: the Revised Scheme is located inland, outside a coastal area.

Fluvial flooding x x x No – screened out: The Development Footprint is not located within or adjacent Flood

Zones 2 or 3 (see RS Figure 9.1).

Surface water flooding x Yes

Avalanches x x x No - screened out: The Revised Scheme’s topography is relatively flat and therefore an

avalanche will not occur.

Climatological

and metrological

Cyclones/ hurricanes/

typhoons, storms and gales x x Yes

Note that hurricanes, typhoons and cyclones are the same weather phenomenon; different

names are used in different parts of the world. Hurricane is the correct term for locations in

the North Atlantic Ocean.

Wave surges x x x No – screened out: the Revised Scheme is located inland, and is therefore not subject to

wave surges.

Extreme temperatures:

• Heatwaves

• Low (sub-zero)

temperature and heavy

snow

x x Yes

Droughts x x Yes

Severe Space Weather: x x Yes

198 British Geological Survey (2017) Geo Index Onshore. Available at: http://mapapps2.bgs.ac.uk/geoindex/home.html 199 Prevention Web (2005) Europe: tsunami hazard map. Available at: http://www.preventionweb.net/english/professional/maps/v.php?id=3831


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risk


Construction

risk

Operational

risk

• Solar flares

• Solar energetic particles

• Coronal mass ejections

The exception is solar energetic particles which cause solar radiation storms, but only in

outer space, so this disaster sub-type can be screened out.

Fog x x Yes

Wildfires:

Forest Fire

Brush/bush

Pasture

x x x No – screened out: the Revised Scheme and the surrounding area does not contain

vegetation with a potential high fuel load such as gorse.

Poor Air Quality x x Yes – during the construction phase. No significant effects on local air quality are predicted

during the operational phase.

Biological Disease epidemics:

• Viral

• Bacterial

• Parasitic

• Fungal

• Prion

x x x No - screened out: The Revised Scheme is located in a developed country where the

population is in general good health. Furthermore, the use of the Revised Scheme, a football

stadium, is not going to give rise to any disease epidemics.

Public Health England, the executive agency of the Department of Health, is responsible for

protecting the nation from public health hazards preparing for and responding to public

health emergencies. One of Public Health England’s functions is to protect the public from

infectious disease outbreaks and the Agency has produced a document providing operational

guidance for the management of outbreaks of communicable disease, ‘Communicable

Disease Outbreak Management: Operational Guidance’.

Technological

or man-made

hazards

Complex emergencies:

• Extensive violence and

loss of life;

• Displacements of

populations;

• Widespread damage to

societies and economies;

• The need for large-scale,

multi-faceted

humanitarian assistance;

• The hindrance or

prevention of

humanitarian assistance

x x x No – screened out: The Revised Scheme is located in a developed country that has a steady,

yet small population growth. England is politically stable with no direct border with

countries experiencing conflicts. (However, see also bottom of table)


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risk


Construction

risk

Operational

risk

by political and military

constraints;

• Significant security risks

for humanitarian relief

workers in some areas

Famine x x x No – screened out: The Revised Scheme is located in a developed country that produces its

own crops and imports food. It is politically stable and not subject to hyperinflation and

therefore food is available, whether it produced within the UK or imported. Famine is also

not relevant to the use of the Revised Scheme.

Displaced populations x x x No – screened out: The Revised Scheme is located in a developed country that has a steady,

yet small population growth and is politically stable with no direct border with countries

experiencing conflicts. Furthermore, the UK does not lie on any tectonic plate boundary and

has a temperate climate. Displaced populations are also not relevant to the use of the

Revised Scheme.

Industrial accidents x x Yes

Transport accidents x Yes

Pollution accidents x x Yes

Electricity, gas, water supply

or sewage system failures Yes

Acts of Terrorism x x Yes

Urban fires x x x No – screened out: The Revised scheme is not located in an urban area.

Fire within the stadium x Yes

Crowd disasters x x Yes

Football related violence and

disorder x x Yes

Innovative Design of the

Stadium, poor design could

lead to:

• Crowd control issues

• Crowd crushing

incidents

x Yes


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Baseline Conditions

17.32 The Revised Scheme will be constructed on a greenfield site that is in agricultural use. The grass

is managed through grazing and mowing.

Surface Water Flooding

17.33 Historic flood records used in the Baseline Condition’s section of Chapter 9: Hydrology, Flood

Risk and Drainage chapter explain that two events have been recorded in the vicinity of the Site.

Two isolated records are located within the vicinity of both the Northern area (the Revised

Scheme or Development Footprint) and Southern Site area (south of the A419). An unknown

flood event occurred within the Development Footprint to the north of the A419, and a flood

event from artificial drainage occurred on the A419). By contrast, a total of 18 flood events are

mapped by SDC within the area of the Redline Boundary west of the M5, or at the neighbouring

Eastington Maintenance Compound (two surface water records, five artificial drainage records,

one fluvial record and 11 unknown records).

Hurricanes, storms and gales

17.34 Hurricanes cannot form in or around the United Kingdom as the sea temperatures are not warm

enough to sustain a wind of at 120km/h, which is one of the measurements used to classify a

hurricane. However, deep depressions that were originally hurricanes are experienced in the

United Kingdom.

17.35 The weather records from the past two decades taken from the closest available data source to

Stroud200 found that the greatest recorded wind speed was 93km/h201.

Extreme temperatures: Heatwaves, Low (sub-zero) temperature and heavy snow

17.36 According to the weather station at Ross on Wye (the nearest weather station that provides

historic weather data202, approximately 25km northwest to the Revised Scheme), the warmest

recorded temperature between the years of 1930 and 2016 was 26.8°C in 2006, and the coolest

temperature in the same time period was -6.7°C in 1963203. Closer to the Revised Scheme, the

highest daily maximum temperature of 37.1°C was recorded in Cheltenham on 3rd August

1990204. As no other weather stations near to the Revised Scheme have logged the daily

minimum temperature record in the District or country, there is no further comparable data.

200 Location unknown 201 My weather 2 (no date) Local Weather: Stroud Climate History. Available at: http://www.myweather2.com/City-

Town/United-Kingdom/Gloucestershire/Stroud/climate-profile.aspx?month=2 202 Chapter 13: Air Quality and Dust uses the Gloucestershire Airport meteorological monitoring station, however

this does not supply historic metrological data. 203 Met Office (2017) UK climate - Historic station data. Available at:

https://www.metoffice.gov.uk/public/weather/climate-historic/#?tab=climateHistoric 204 Met Office (2017) UK climate – Extremes. Available at: https://www.metoffice.gov.uk/public/weather/climate-

extremes/#?tab=climateExtremes


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17.37 The weather records from the past two decades taken from the closest available data source to

Stroud205 indicate that on average, February is the month with the greatest snowfall with two

days of snow206.

Droughts

17.38 Droughts are caused by insufficient rainfall and in the UK context, a drought is defined as at least

15 consecutive days where there is no more than 0.2mm of precipitation.

17.39 There is no historic record of droughts for the Revised Scheme, however the drought between

the winter of 2009/10 to March 2012 was one of the most substantial droughts of one to two

years duration in the last 100 years. Across southern England, the two-year period April 2010 to

March 2012 was the equal-driest such two year period in records from 1910, shared with April

1995 to March 1997.

17.40 Between April 2010 to March 2012, Stroud only received 65-75% of rainfall compared with the

1981 average207.

Severe Space Weather: Solar flares and Coronal mass ejections

17.41 There is no data for severe space weather specifically at the site of the Revised Scheme.

17.42 The Cabinet Office National Risk Register of Civil Emergencies (2017 Edition)208 notes that a

coronal mass ejection storm caused Global Positioning Systems to malfunction in the UK aviation

sector in 2003. Solar storms recorded between 1921 and 1960 resulted in widespread radio

disruption on railway signalling and switching systems in the UK.

Fog

17.43 According to the Met Office, the historical stations observations do not hold data for fog209.

Poor Air Quality (construction phase)

17.44 According to Chapter 13: Air Quality and Dust, the baseline air quality estimated at the Site does

not exceed the relevant air quality objectives for NOx, NO2, PM10 and PM2.5.

Industrial Accidents

17.45 There are no records of any industrial accidents or disasters located in close proximity to the

Revised Scheme.

Pollution Accidents

205 Location unknown 206 My weather 2 (no date) Local Weather: Stroud Climate History. Available at: http://www.myweather2.com/City-

Town/United-Kingdom/Gloucestershire/Stroud/climate-profile.aspx?month=2 207 Met Office (2013) England and Wales drought 2010 to 2012. Available at:

https://www.metoffice.gov.uk/climate/uk/interesting/2012-drought 208 Cabinet Office (2017) National Risk Register Of Civil Emergencies. Available at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644968/UK_National_Risk_Regis

ter_2017.pdf 209 Met Office (2016) Historical Station Observations. Available at:

https://www.metoffice.gov.uk/datapoint/product/historical-station-obs


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17.46 According to the central government database, a pollution accident occurred on 19th April 2016.

The location of the incident is not within the Development Footprint, but to the west of the

Redline Boundary.

Transport Accidents

17.47 The Revised Scheme is a greenfield and no traffic accidents have occurred.

Electricity, gas, water supply or sewage system failures

17.48 It is understood that potable water supply and foul drainage services are not currently present

on-site. The nearest foul water drainage and water supply are within close proximity to the Site

at properties directly to the east of the southern parcel of land at Chipmans Platt, and properties

located off Grove Lane adjacent to the Revised Scheme.

Acts of Terrorism

17.49 No acts of terrorism have been recorded at the site.

Fire within the stadium

17.50 There is no stadium currently at the location of the Revised Scheme.

Crowd disasters, football related violence and disorder

17.51 The site of the Revised Scheme does not hold large crowd events.

Innovative Design of the Stadium

17.52 There is no stadium currently at the location of the Revised Scheme.

Design Evolution

17.53 The design of the Revised Scheme continues to be informed by a suite of health and safety

regulations, design codes and other legislation. Adhering to these requirements minimises the

risk of major accidents and disasters from occurring.


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Table 17.1: The Refined List

Refined list Could the Revised

Scheme make the major

accident/ disaster

worse?

Could the use of the Revised Scheme be

affected by the major accident or disaster?

Additional comments, including mitigation Where the major accident/

disaster is addressed in the

ES or other planning

documentation

Residual risks

Surface water

flooding

Yes (in the absence of

embedded mitigation or

further mitigation). The

Revised Scheme is

located on greenfield

land and development

here is likely to increase

impermeable surfaces.

This will lead to increase

surface run off and

increase the risk of

surface water flooding.

Yes – potentially. RS Appendix 9.1: Flood Risk

Assessment uses the 60 year development

design lifetime and explains that the site is at

minimal risk of flooding from surface water at

the western boundary of the Development

Footprint due to the M5 and heavily silted

culvert drain under the A419.

Surface water flooding risk has been designed

into the surface water drainage plan and the

flood risk from surface water will reduce from a

medium to a low risk.

The Design Evolution section of Chapter 9:

Hydrology, Flood Risk and Drainage explains

that:

“The proposed surface water network on the Site

has been designed to ensure exceedance of the

network has been considered and that there is no

flooding of properties during a 1 in 100-year

rainfall event.

A SuDS system will be utilised on Site, and a new

attenuation pond designed as part of the

drainage strategy for the Site.

The development of the Site will be designed to

ensure that any excess surface water during

storm events is contained within the road

network and away from properties and released

to the sewer network as capacity dictates.”

In relation to climate change projections for

2080 using the medium emissions scenario (see

Chapter 16), central estimates are for heavy rain

days (rainfall greater than 25mm) over most of

the lowland UK to increase by a factor of

between 2 and 3.5 in winter, and 1 to 2 in

summer. However, the flood risk assessment

incorporates ‘climate change allowances’ in

accordance with standard practice.

Chapter 9 and associated

appendices: Flood Risk,

Hydrology and Drainage

The low risk

for surface

water

flooding is

not expected

to have

significant

adverse

effects on

receptors.

Hurricanes,

storms and gales

No Yes – Whilst climate change projections for 2080

and the medium emissions scenario do not

suggest an increase in the frequency or intensity

The Met Office and Environment Agency forecast

extreme adverse weather conditions and issue

weather warnings accordingly using the National

The Revised Scheme will be

designed to the best

information available in

Hurricanes,

storms and

gales are


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of storms across the UK, it is important to note

that there are still large uncertainties in the

future predictions of storms. Again, whilst there

are only small changes in projected wind speed,

there is considerable uncertainty with respect to

likely changes in wind speed (Chapter 16).

Severe Weather Warning Service and Flood

Information Service respectively. This

information can be used by the stadium

managers to cancel or postpone matches or any

other activities on site.

relation to hurricanes,

storms and gales whilst also

adhering to the current

design guidelines and

building standards that

have included specialist

input. These will feature in

the design, method and

sustainability statements

and detailed at the

Reserved Matters Stage in

the planning application

process.

Chapter 16: Climate

Change

expected to

have no

significant

adverse risks

on any

receptors.

Extreme

temperatures:

Heatwaves

Low (sub-zero)

temperature and

heavy snow

No Yes - Climate change projections for 2080 using

the medium emissions scenario suggest that

temperatures in the South-West will increase

both in summer and winter months. This is most

likely to be of concern in summer, with an

estimated increase of between 2.1ºC and 6.4ºC.

Conversely, with a projected temperature

increase in winter, heavy snow is likely to occur

less than at present.

These changes are unlikely to cause major

accidents or disasters in relation to the Revised

Scheme.

The Cold Weather Alerts and Heat Health Watch

Service provided by the Met Office and Public

Health England respectively can also be used to

inform stadium managers to cancel or postpone

matches in light of these warnings. These

warnings can also be used to advise fans to wear

appropriate clothing and drink plenty of water.

This is particularly important as the football

season occurs between August and May,

therefore occurring in the height of summer and

depths of winter where fans and players would

be exposed to high and freezing temperatures

respectively.

A significant adverse risk is not expected for

extreme temperatures on any receptors.

The ‘Design and Access

Statement notes that there

will be natural ventilation

entering the stadium

thereby helping to ensure

that crowds are not

exposed to extreme

temperatures.


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Residual risks

Droughts No Yes - Climate change projections for 2080 using

the medium emissions scenario, suggest that

summer rainfall is most likely to decrease.

Droughts already occur in England and parts of

the country are often subject to water

restrictions such as the hose pipe ban in the

summer months. Although this could potentially

disrupt the management of the grass within the

stadium and training pitches as well as

landscaping within the Revised Scheme, it will

not result in the loss of life or permanent injury,

and/or permanent or long lasting damage to a

receptor.

The Revised Scheme is likely to help mitigate the

impact of drought through the inclusion of

rainwater harvesting through the Sustainable

Drainage System (SuDS).

A significant

adverse risk is

not expected

for drought

on any

receptors.

Severe Space

Weather

• Solar flares

• Coronal mass

ejections

No Yes – Space weather can cause electricity

blackouts, loss and disruption of Global

Navigation Satellite Systems and can also disrupt

services including the energy and

communications networks.

The Government has produced a Space Weather

Preparedness Strategy (2015) that sets out three

elements in preparing for space weather;

designing mitigation into infrastructure where

possible; developing the ability to provide alerts

and warnings of space weather and its potential

impacts; and having in place plans to respond to

severe events.

Space weather could result in electrical and

communication blackouts, however these

disruptions are unlikely to give rise to the loss of

life or permanent injury, and/or permanent or

long lasting damage to an environmental

receptor.

The Revised Scheme will be

designed to the best

information available on

blackouts whilst also

adhering to the current

design guidelines and

building standards that

have included specialist

input. These will feature in

the design, method and

sustainability statements

and detailed at the

Reserved Matters Stage in

the planning application

process.

No significant

adverse

effects are

expected in

relation to

space

weather.

Fog No Yes - Fog reduces visibility and this increases risk

for fast moving vehicles such as those travelling

to/from football matches.

When fog is present precautionary approaches

such as warning drivers to slow down are

implemented on roads and announcements

asking drivers to take care after events can also

be adopted as mitigation.

N/A No significant

adverse

effects are

expected in

relation to

fog.


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If the fog was very severe, event organisers may

postpone the match or stop the match if play

had begun.

When taking into account these mitigation

measures, fog is unlikely to result in the loss of

life or permanent injury, and/or permanent or

long lasting damage to an environmental

receptor.

Taking the above into account, a significant

adverse risk is not expected on receptors.

Poor Air Quality

(construction

phase)

Yes –

Chapter 13 Air Quality and

Dust

The CEMP will be included

in the planning conditions.

The

implementati

on of the

mitigation

measures

outlined in

the CEMP will

result in no

significant

residual

effects during

the

construction

phase.

Industrial

accidents

No Yes – The Development footprint lies within

close proximity to:

• the Petroleum Garage (Shell) located

approximately 125m to the east.

• Oldends Lane Industrial Estate located

approximately 500m to the east. This

industrial Estate includes an

automotive supplier, a manufacturer in

precision measurement and probing

The industrial sites and businesses located within

close proximity to the Revised Scheme will have

established their own Health and Safety

measures and procedures to follow if incident

occurs.

Calling the 999 emergency services is a response

measure that will assist with all types of accident

and/or disaster.

N/A

The safety of nuclear power

stations is not the

responsibility of the

developer of the Revised

Scheme.

There are no records of any

industrial accidents or

disasters located in close

No significant

adverse

effects are

expected in

relation to

industrial

disasters.


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equipment, a manufacturer providing

technology for the oil and gas industry

and a research and development

company specialising in industrial

digitalisation.

• Stonehouse Paper and Bag Mill (near

Bridgend) is located approximately

2.4km to the south east.

In addition, the nuclear power stations at Hinkley

Point are located approximately 75km south

west of the Revised Scheme. The three power

stations are in various stages of use:

• Construction for Hinkley Point A

started in 1957 and it began operation

in 1965. In 2000, Hinkley Point A was

shut down and the site entered the

decommissioning phase;

• Construction for Hinkley Point B

started in 1967 and it began operation

in 1976. The decommissioning phase is

likely to start in 2023.

• Although it is not expected to begin

operation until 2023, construction

work began in 2017 for Hinkley Point C.

If there is an incident at one of the nuclear sites

at Hinkley Point, the Revised Scheme could be

affected by radioactive material.

The World Nuclear Association210 states that

“The risk of accidents in nuclear power plants is

low and declining…. the design and operation of

nuclear power plants aims to minimise the

likelihood of accidents, and avoid major human

consequences when they occur”.

proximity to the Revised

Scheme.

Pollution

accidents

Yes – during the

construction phase, a

large spillage of

No During the construction of the revised Scheme, a

Construction and Environmental Management

Plan (CEMP) will be produced and all

Chapter 8: Ecology and

Nature Conservation

A significant

adverse risk is

210 The World Nuclear Organisation (2016) Safety of Nuclear Power Reactors. Available at: http://www.world-nuclear.org/information-library/safety-and-security/safety-of-

plants/safety-of-nuclear-power-reactors.aspx


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materials, particularly

liquids, could result in

significant adverse effects

on environmental

receptors.


Nature Conservation

notes that there is a very

low potential risk for silt

runoff. It is considered

highly unlikely that any

fine silts, sediments or

chemical contamination

will enter Selbrook or the

River Frome courses or

reach the River Severn

SAC 3km downstream. It

is identified that there

will be no potential

negative effect on Sea

Lamprey, River Lamprey

and Twaite shad.

It is not anticipated that

activities associated with

the Revised Scheme

during the operational

phase would lead to

significant polluting

accidents.

Furthermore, other

polluting activities do not

occur within close

proximity of the site.

construction activities will need to adhere to this

document which will reduce the risk of a major

accident/ disaster occurring.

The CEMP will be included

in the planning conditions.

not expected

on receptors.

Transport

accidents

Yes – The construction

phase of the Revised

No The Transport Assessment concludes that effects

in relation to accidents and safety to road

Chapter 12: Transport and

Access

No significant

adverse


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Scheme will involve

materials and

construction workers

travelling to the site.

Events and facilities that

will be provided by the

Revised Scheme during

the operational phase will

increase the need to

travel which will increase

the risk of transport

accidents.

network users will be negligible during

construction, and minor to negligible during

operation.

effects are

expected on

receptors.

Electricity, gas,

water supply or

sewage system

failures

Yes – during construction

there is potential for an

accident interrupting the

gas/ water/ electrical

supplies.

Yes – A system failure could potentially lead to

significant adverse effects on human health

damage and/or built structures.

The natural environment within and beyond the

Development Footprint could be adversely

affected if chemicals enter watercourses or

contaminate land.

There are a number of response measures in

place (such as emergency contact numbers) that

can deal with any of these failures provided by

the utility provider. In addition, 999 is an

emergency service response that deals with all

accidents and disasters.

These responses reduce potential significant

adverse effects on human receptors and the built

environment.

However, a utility system failure such as a

sewage leak can have long term significant

adverse environmental effects.

Long term significant

adverse effects are on

environmental receptors

are considered in:


Nature Conservation

Chapter 9: Flood Risk,


The mitigation measures

explained in these chapters

will remove the significant

adverse environmental

effects.

No significant

adverse

effects are

expected on

receptors.

Acts of Terrorism Yes - The proposed

scheme will attract large

crowds to the site, into a

relatively confined space.

Yes - The proposed scheme will attract large

crowds to the site which could be vulnerable to

acts of terrorism.

Acts of terrorism are not accidental, they are

organised plots and are a result of human

actions, rather than natural occurrences.

The detailed design of the stadium and site

(during reserved matters) will be undertaken in

full compliance with The Construction (Design

and Management) Regulations 2015.

The Design and Access

Statement

A significant

adverse risk is

not expected

on receptors.


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Acts of terrorism have been screened out as no

significant adverse effects are expected on any

receptor.

Fire within the

stadium

No Yes - The Revised Scheme will attract large

crowds to the site who could become trapped in

the event of a fire if measures such as

extinguishers and sprinkler systems (active

measures) and passive measures such as fire

compartmentation and fire doors are not

implemented in suitable locations.

Under the Safety of Sports Grounds Act 1975,

the stadium is legally required to obtain a safety

certificate from Stroud District Council. This

certificate is unique to each sports ground and

details exits, entrances, means of access, crash

barriers and means of escape in case of fire. It is

an offence for sports grounds not to have a

safety certificate or to not obey the certificate’s

requirements.

The Fire Safety and Safety of Places of Sports Act

1987 and the Guide to Safety at Sports Grounds

(Fifth Edition, Stationery Office, 1997 - also

known as The Green Guide) also detail the safety

measures required at sports grounds. These

documents have been informed by incidents

such as the crowd disaster at the Ibrox Stadium

in 1971, the fire at Bradford football ground in

1985, and the Hillsborough disaster in 1989.

Zaha Hadid Architect’s Concept Design Proposal

for the Revised Scheme discusses the use of

engineered timber in ‘significant elements’ of the

stadium. This type of timber is recognised as

having a resistance to ignition and can be further

enhanced with fire retardant treatments. The

Structural Engineering Consultant statement

asserts that “the steel elements, such as bracing

rods, stabilizing pipes and joint connectors, must

be fire-protected by applying an intumescent

coating system.”

The stadium is considered to be a ‘normal fire

risk’ as it has been calculated that it can be

evacuated in six minutes. The design code states

The Design and Access

Statement

The long term significant

adverse effects on

environmental receptors

can be found in:


Nature Conservation

Chapter 9: Flood Risk,


As the River Frome is

relatively far from the

Development Footprint, the

risks of industrial pollution

or fire retardant chemicals

reaching the River directly

are highly unlikely,

particularly as chemicals

would be directed into the

drains along the A419.

Therefore, there will be no

potential negative effect on

Sea Lamprey,

River Lamprey and Twaite.

The pollution and major

accident pollution plan as

part of the planning

The pollution and major

accident pollution plan

No residual

significant

adverse

effects are

identified.


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that the structure and design of the stadium

were based on a number of design codes

including:

• BS EN 1995-1-2:2004 Eurocode 5: Design of

timber structures – Part 1-2: General –

Structural fire design; and,

• The UK National Annex to Eurocode 5: BS

EN 1995-1-2:2004: Design of timber

structures – Part 1-2: General – Structural

fire design.

Further consideration of fire risk has been

considered at the masterplan stage of the

stadium, with exits being located strategically,

limiting the distances occupants need to travel,

and where necessary, providing a choice of

exists. Dedicated refuge areas have also been

designated for disabled occupants on Level High

risk areas will be segregated from escape routes

and egress routes are designed to minimise

queuing in the concourse areas.

The structure of the building has been sub-

compartmentalised to ensure that fire and

smoke is inhibited from spreading beyond the

source of the fire and the building has a

structural fire resistance of 60 minutes.

The use of fire retardant chemicals when fighting

fire can have long term adverse environmental

effects.


(during reserved matters) will be undertaken in


and Management Regulations 2015.

proposed by planning

condition will ensure that if

any toxic substance were to

reach the ditches, it would

be prevented from reaching

the River Frome.


December 2017

Page | 407



accident/ disaster

worse?






documentation

Residual risks

No significant adverse effects from fire are

expected on human health or the built

environment. However, potentially significant

adverse effects on environmental receptors can

be identified using the source, pathway, receptor

process for fire retardant chemicals. These,

however, have been addressed in Chapter 8:

Ecology and Nature Conservation and Chapter

9: Flood Risk, Hydrology and Drainage. They will

be addressed further at Reserved Matters

Application(s).

Crowd disasters,

football related

violence and

disorder

No Yes – Crowd disasters, football related violence

and disorder are a potential risk within the

Revised Scheme, both within and beyond the

Development Footprint.

The Revised Scheme will attract large crowds (up

to 5,000 people) to the site. However, as

outlined above, the Safety of Sports Grounds Act

1975, The Fire Safety and Safety of Places of

Sports Act 1987 and the Guide to Safety at

Sports Grounds (Fifth Edition, Stationery Office,

1997) also known as The Green Guide, are all

adhered to in the design of this Revised Scheme.


(during Reserved Matters) will be undertaken in


and Management Regulations 2015.

There is still a risk of significant adverse effects

on human populations, however this is

addressed and mitigated in Chapter 12:

Transport ES Chapter/ Transport Assessment

(TA) and the Operational Management Plan

which will be drafted at Reserved Matters.

Chapter 12: Transport ES

Chapter/ Transport

Assessment (TA)

A significant

adverse risk is

not expected

on receptors.

Innovative

Design of the

Stadium

No Yes - The Revised Scheme includes a football

stadium that encompasses innovative design.

Previous major accidents and disasters in

stadiums include failures of stand structures,

resulting in crowd crushing.

The structure and design of the stadium adhere

to a number of design codes, thereby ensuring

that all materials and the structural design are

safe.

A significant

adverse risk is

not expected

on receptors.


December 2017

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accident/ disaster

worse?






documentation

Residual risks


(during Reserved Matters) will be undertaken in


and Management) Regulations 2015.


December 2017

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Cumulative Effects

17.54 As this chapter considers low likelihood events, it is unlikely that a major accident or disaster will

occur at one development and at another simultaneously. Furthermore, the developments

considered in the cumulative assessment, as with the Revised Scheme, are regulated by

environmental protection legislation, health and safety regulations and design standards, all of

which are focussed on preventing and/ or mitigating major accidents and disasters.

17.55 Table 17.3 below lists the developments that are identified within the scope of the assessment

of cumulative effects and explains the potential interactions of the Revised Scheme and these

developments.


December 2017

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Table 17.3: Cumulative Effects

Reference Address Development Status Co-ordinates Distance from site

(km)

Potential interactions Residual effect?

S.14/0810/OUT Land West of

Stonehouse, Nastend

Lane, Nastend,

Stonehouse,

Gloucestershire

A mixed use development comprising up to

1,350 dwellings and 9.3 hectares of

employment land for use classes B1, B2 and

B8; a mixed use local centre comprising use

classes A1, A2, A3, A4, A5, D1, D2 and B1;

primary school, open space and landscaping,

parking and supporting infrastructure and

utilities; and the creation of new vehicular

accesses from Grove Lane, Oldends Lane and

Brunel Way. Reserved Matters ow approved

under S.17/0095/REM.

Application

Permitted

379312, 206558

0.1 This housing development will

result in an increased number of

human receptors that could be

adversely affected by a major

accident or disaster occurring at

the Revised Scheme.

However, as no residual risks are

identified in this chapter, no

significant adverse effects are

likely.

No residual effect is

identified

S.12/0763/FUL Bonds Mill, Unit 27,

Bristol Road, Stonehouse

Demolition of part of an existing warehouse

including a hoist on the adjacent building,

renovation of the remainder as office space

and erection of a two storey extension.

Application

Permitted

379344, 205327 1.51 This development will remove

the risk of industrial and/ or

pollution accidents occurring at

Bonds Mill. However, the office

space could increase the number

of human receptors. However, it

is noted that the use of the

stadium is generally likely to

occur outside office hours.

As no residual risks are identified

in this chapter, no significant

adverse effects are likely.


identified

S.15/1088/FUL Westend Courtyard,

Grove Lane, Westend,

Stonehouse,

Gloucestershire

Proposed extension to Westend courtyard to

provide 10 additional offices (B1 use).

Application

Permitted

378312, 207018 0.1 The provision of increased office










identified

N/A Infilled canal to the south

of the Site

Canal restoration and realignment scheme

subject to successful bid funding from

Cotswold Canals Trust

No

planning

history,

however

Scoping

Opinion

soon to be

requested.

Directly to the

south of

Redline

Boundary.

Directly to the south

of Redline Boundary.

The reinstatement of the canal

will increase a number of both

human and environmental

receptors within close proximity

to the Revised Scheme.

However, users of the canal are

unlikely to increase the risk of a

major accident or disaster or

increase the risk of a major


identified


December 2017

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the Revised Scheme.




13/0001/INQUIR Land at Javelin Park Proposed Development of an Energy from

Waste (EfW) facility for the combustion of

non-hazardous waste and the generation of

energy

Appeal

Allowed

380040, 210430 3.92 The provision of this

development could increase the

risk of an industrial and/ or

pollution accident occurring in

relative close proximity to the

Revised Scheme. This EfW

development will however

contain its own pollution and

accident management plans so

any risks will be mitigated.





identified

S.15/2089/OUT Land Adjacent To

Eastington Trading Estate

Churchend, Eastington,

Gloucestershire.

Erection of three industrial employment

buildings with associated access, car parking

and service yards (Outline application - Access,

Layout and Scale included).

Application

Permitted

TBC 0.1 The provision of increased office










identified

S.17/0563/OUT Land Off School Lane,

Whitminster,

Gloucestershire

Residential development for up to 60

dwellings including infrastructure, ancillary

facilities, open space and landscaping.

Construction of a new vehicular access from

School Lane.

Application

Refused

377106, 208403 3.0 This housing development will





the Revised Scheme.




likely.


identified

S.17/1133/FUL Former Standish Hospital

and Former Westridge

Hospital Standish,

Stonehouse,

Gloucestershire

Conversion and refurbishment of the former

Standish Hospital complex, including Standish

House (Building A), Stable Block (Building B),

Ward Blocks (Buildings C & G), Standish Lodge

(Building L), Building I, and demolition and

works to associated out-buildings and

Pending

Considerati

on

381646, 206566 3.5 This housing development will





the Revised Scheme.


identified


December 2017

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gatehouse to form 50 dwellings; demolition of

Westridge Hospital and associated building.

Development of 98 new build homes within

the grounds; conversion; associated surface

vehicle and cycle car parking, pedestrian and

vehicular access and associated ancillary

development, landscaping, ancillary storage

and plant and ecological bat housing; and all

associated engineering works and operations

However as no residual risks are



likely.

S.16/0922/REM Land Adjoining Station

Road Bristol Road,

Stonehouse,

Gloucestershire, GL10

3RB

Approval of Reserved Matters Appearance

and Landscaping from appeal

APP/C1625/A/13/2195656 (S.12/2538/OUT) -

residential development for 49 units, new

access way and associated works.

Application

Permitted

This residential development will





the Revised Scheme.




likely.


identified

S.17/2331/OUT

Land Adjoining Oldbury

Lodge Pike Lock Lane

Eastington

Gloucestershire

Erection of new buildings for uses within use

class C1 (Hotel) up to 1,908 Sqm (56 Beds), and

use classes A3 / A4 Pub (Pub/Restaurant) up

to 711 Sqm (Including ancillary manager's

apartment) and associated access, servicing,

parking, drainage and landscaping (outline

application: all matters reserved except for

access and scale)

Awaiting

Decision

This housing development will





the Revised Scheme.


identified


December 2017

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Conclusions

17.56 This chapter has sought to identify all potential major accidents and disasters, and using a

screening process, has eliminated a number that are not relevant to the Revised Scheme. Those

major accidents and disasters that are considered as a potential risk have all been considered in

the ES or with other documents that are submitted for this application. It is not anticipated that

the Revised Scheme is vulnerable to major accidents and/or natural disasters which could result

in significant effects on the environment.


December 2017

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18 CUMULATIVE EFFECTS

Introduction

18.1 This chapter summarises the cumulative effects associated with the Revised Scheme. There is a

requirement to undertake an assessment of cumulative effects of the Revised Scheme through

Schedule 4 of the EIA Regulations 2011. At present, there is no widely accepted methodology or

best practice for the assessment of cumulative effects although there are a number of guidance

documents available. The following approach is based on previous experience, the types of

receptors being assessed, the nature of the Revised Scheme and the environmental information

available to inform the assessment.

18.2 Cumulative effects have been considered within each of the technical assessments. In

consultation with SDC, Table 2.5 lists the committed developments that have been identified as

part of this assessment, and RS Figure 18.1 illustrates the locations of these sites. In this list Land

West of Stonehouse (S.14/0810/OUT) now forms a strategic site allocation within the recently

adopted SDC Local Plan, and it has also recently been subject to a successful Reserved Matters

application allowing the development to commence. Each consultant has reviewed the

respective ES chapters of the planning submission to ensure any cumulative effect has been fully

assessed within the respective technical chapters.

18.3 For the assessment of transport effects, as detailed within Chapter 12 – Transport and Access, a

different approach has been adopted, in that Land West of Stonehouse has formed part of the

baseline rather than being treated as a cumulative effect. This is because all the traffic modelling

has included West of Stonehouse (and associated A419 junction improvements) as part of the

baseline traffic flows in order to assess worst case. Given the allocation of the site within SDC’s

Local Plan and near certain likelihood of development, together with the fact that access is not a

Reserved Matter at the Revised Scheme, this is considered the correct approach.

18.4 Traffic generated by the remaining developments (other than West of Stonehouse) identified in

Table 2.5 is taken into account through the application of traffic growth factors obtained from

the National Transport Model adjusted using the TEMPRO program, which also factors in changes

in car ownership, and local planning forecasts regarding housing and employment. Given Chapter

13 – Air Quality and Dust and Chapter 15 – Noise and Vibration utilise the data from the traffic

assessment, these chapters have also included Land West of Stonehouse, the A419 junction

improvements, and the committed developments as part of the baseline to their assessments.

18.5 The following Chapter provides a summary of the potential cumulative effects already described

in each Technical Chapter. It highlights where and how other committed development may alter

and influence the potential effects from the Revised Scheme, and indicates whether these effects

are considered to be significant or not, so that they may be taken fully into account by the

planning determination process.

Effects Interactions

18.6 The approach to the assessment of different environmental features considers the changes in

baseline conditions at key common sensitive receptors. The key common sensitive receptors

considered within this chapter are those which are assessed within two or more of the Technical

Chapters 7 – 17.


December 2017

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18.7 Common sensitive receptors identified throughout the ES are outlined within matrices alongside

their residual effects per technical discipline. The common receptors assessed are:

• Existing residential properties (including schools, care homes and William Morris College);

• Local Population (comprising existing and future users of the local road and footpath

network, third parties and local economic, housing and community receptors);

• Ecological receptors (including designated sites and protected species);

• Designated landscape and heritage assets.

18.8 An overall assessment of the cumulative effect on the common sensitive receptors identified

above has been made using professional judgement as well as through the utilisation of

recognised industry standards with regards to the technical assessments provided in Chapters 7

– 17.

18.9 Table 18.1 comprises a summary matrix showing the effect interactions between environmental

topics assessed following the implementation of the recommended mitigation measures set out

in Technical Chapters 7 – 17 of this ES. This enables a summary assessment of the interactions

of residual effects outlining the overall significance to the identified common sensitive receptors.

18.10 For the purposes of this assessment, residual effects that have been identified in the Technical

Chapters 7-17 which do not affect the common sensitive receptors identified above have not

been presented below as no effect interactions are anticipated. In addition, negligible residual

effects have not been considered during the assessment of interactions.

18.11 The effects listed in Table 18.1 are all based on worst-case assumptions, and cover both

construction and operation phases. Effects will vary depending on the particular activity, location

of works, duration of work and type of operation being undertaken. Similarly, the effects vary

from temporary in nature during construction and permanent in nature during operation. The

significant residual effects in the table are reliant on the mitigation measures being implemented

as discussed within the respective Technical Chapters 7 – 17.

Table 18.1: Matrix of Effects Interactions

Technical

Topic

Common Sensitive Receptors

Existing

residential

properties

Local Population

Ecological receptors

Designated heritage

assets

Archaeology

and Cultural

Heritage

N/A N/A N/A Lower end of less

than substantial harm

but no residual

significant effects.

Ecology and

Nature

Conservation

N/A N/A Negligible to high

negative effects but no

significant residual

effects.

N/A

Hydrology,

Flood Risk and

Drainage

N/A N/A Moderate positive

long-term significant

effects.

N/A


December 2017

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Technical

Topic


Existing

residential

properties

Local Population


Designated heritage

assets

Landscape

and Visual

Minor to major

negative long-

term effects some

of which are

significant

adverse residual

effects.

Minor to major

negative long-

term effects

some of which

are significant

adverse residual

effects.

N/A N/A

Socio-

Economics

N/A Minor beneficial

effects but no

significant

residential

effects.

N/A N/A

Transport and

Access

N/A Moderate

infrequent but

long-term

negative to

moderate long-

term positive

effects which are

significant

residual effects.

N/A N/A

Air Quality Low to medium

negative effects

but no significant

residual effects.

Low to medium

negative effects

but no significant

residual effects.

N/A N/A

Lighting Significant

infrequent but

long-term

adverse residual

effects.

Significant

infrequent but

long-term

adverse residual

effects.

Significant infrequent

but long-term adverse

residual effects.

Significant

infrequent but long-

term adverse

residual effects.

Noise

Minor negative

effects but no

residual

significant effects.

Minor negative

effects but no

residual

significant

effects.

N/A N/A

Climate

Change

No residual

significant effects

identified in

relation to climate

change mitigation

or climate change

adaption

No residual

significant

effects identified

in relation to

climate change

mitigation or

climate change

adaption

No residual significant

effects identified in

relation to climate

change mitigation or

climate change

adaption

No residual

significant effects

identified in relation

to climate change

mitigation or climate

change adaption


December 2017

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Technical

Topic


Existing

residential

properties

Local Population


Designated heritage

assets

Major

Accidents and

Disasters

No residual

significant effects

identified

No residual

significant

effects identified

No residual significant

effects identified

No residual

significant effects

identified

18.12 In summary, the effects associated with existing residential receptors vary from minor to major

negative. The latter arises from the assessment of landscape and visual effects, which constitute

a significant adverse long-term residual effect, for a small number of residential properties

located adjacent to the Site. Specifically, the visual amenity of Mole Cottage, Ivy Cottage and

Westend House are likely to experience significant adverse change in the long term due to

relatively unrestricted visibility of the Revised Scheme (or part of) at close range. Additionally,

the Revised Scheme will introduce an addition to the existing sky glow when the stadium lighting

is in operation (i.e. during evening matches). The increase in sky glow has been identified as a

major adverse effect and therefore significant in EIA terms, although this will be infrequent.

During the 2017-18 season, there are six weekday evening matches programmed when sky glow

effects would be most apparent.

18.13 The local population is anticipated to experience a range of effects ranging from major negative

to moderate positive, both of which would result in long-term residual significant effects. Again,

like residential receptors, major negative effects are anticipated in relation to landscape and

visual from short stretches of Eastington Footpath Nos 37 and 38 crossing the Development

Footprint due to relatively unrestricted visibility of the Revised Scheme (or part of) at close range.

Significant visual effects are also predicted to arise on short stretches of public highway adjacent

to the Site including the M5 motorway, the A419 and Grove Lane. With regards to transport

effects, on non-match days, pedestrians and cyclists could experience a moderate long-term

positive effect as a result of the introduction of the traffic signal controlled crossing of the A419

and improvements at Chipmans Platt roundabout. Like residential receptors, significant long-

term effects are anticipated in relation to sky glow, however, this effect would be infrequent.

18.14 In relation to ecological receptors, substantial negative and moderate positive effects are

anticipated. The substantial negative effects are however considered not to be significant when

mitigation is taken into account. Moderate long-term positive effects are anticipated in relation

to hydrology following the incorporation of the SuDS infiltration features into the surface water

drainage network, as these will provide beneficial ecological and conservation effects. The SuDS

features will introduce attractive planting features, and increased biodiversity whilst helping to

ensuring adaptation to climate change. These will be a significant positive residual effect. The

Revised Scheme will introduce an addition to the existing sky glow when the stadium lighting is

in operation (i.e. during evening matches). The increase in sky glow has been identified as a long-

term major adverse effect and therefore significant in EIA terms, although this will be infrequent.

18.15 With regards to designated assets, the lower end of less than substantial harm is anticipated.

These relate to the effect on the Grade II listed Westend Farmhouse and Mulgrove, both on


December 2017

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Grove Lane, but will not comprise a significant heritage effect in EIA terms. Sky glow will be a

long-term negative significant, this effect is infrequent.

Cumulative Effects from other Committed Developments

18.16 An assessment of the effects from other developments in proximity to the Revised Scheme has

been provided for each of the technical assessments within Chapter 7 – 17 of the ES. Table 18.2

provides a summary of the likely potential cumulative effects that may result from the

construction and operation of the Revised Scheme, in combination with the other committed

developments described in Table 5.2.

Table 18.2: Summary of Likely Potential Cumulative Effects from other Committed Developments

Environmental

Topics

Potential Cumulative Effects

Construction Phase Operational Phase

Archaeology

and Cultural

Heritage

No significant cumulative effects

are anticipated.

No significant cumulative effects are

anticipated.

Ecology and

Nature

Conservation


are anticipated.


anticipated.

Flood Risk,

Hydrology and

Water

Resource

Pre-mitigation, minor to moderate

negative significant effects are

anticipated if West of Stonehouse

and the Revised Scheme are

constructed at the same time,

therefore if left unmitigated it will

be considered significant in EIA

terms.




cumulative effects are expected and

therefore it will not be significant in

EIA terms.


anticipated as there is hydrological

separation.

Landscape and

Visual Significant additional, adverse cumulative landscape and visual effects

attributable to the Revised Scheme are predicted to arise during

construction up to Year 1 of operation within approximately 0.5km of the

Development Footprint in the general vicinity of Grove Lane from Westend

to Chipmans Platt. These short term, additional cumulative effects will result

from the combined and sequential visibility of the proposal in conjunction

with WOS and Pike Lock cumulative schemes.

The adverse cumulative effects will reduce over time as the proposed

landscape mitigation establishes and matures. Significant additional,

adverse residual cumulative landscape character effects are predicted to


December 2017

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Environmental

Topics



remain during operation with respect to a small area of the Escarpment

Footslopes (LCT5a) on and adjacent to the Development Footprint.

However, other cumulative landscape and visual effects predicted to be

significant during construction will be not significant during operation in the

medium to long term.

Adverse cumulative effects potentially arising across the wider Study Area in

conjunction with these and other cumulative schemes assessed and shown

in RS Figure 18.1 are predicted to be not significant.

Socio-

Economics

All of the proposed schemes will

create some temporary

construction employment, however

these effects have only been

quantified in two of the planning

applications for projects. These

were West of Stonehouse

(S.14/0810/OUT) which is

estimated to create 2,025 direct

person years of employment over a

ten-year construction period

(average of 202 jobs per annum),

and Land at Javelin Park

(13/0001/INQUIR) which is

estimated to create 300 jobs over a

three-year construction period. In

both cases, it is understood that

work has now commenced on these

sites. The other proposed

developments are smaller in scale

and therefore likely to create fewer

temporary jobs. They are also likely

to be built out over different time

periods, meaning any increase in

construction employment may

occur at different points in time and

thus not be cumulative. It is also

possible that a number of the

contracts are secured by firms

which are not based in Stroud

District, meaning some of the

economic benefits will be lost to the

area. With these caveats in mind,

the sensitivity of receptor and


anticipated.


December 2017

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Environmental

Topics



magnitude of effect are both

considered to be medium, meaning

the significance of effect is

moderate beneficial, which is

significant in EIA terms.

Transport and

Access

There is the potential for the

Revised Scheme, the land West of

Stonehouse and the A419 Corridor

Improvements to be under

construction simultaneously. In

such an eventuality, traffic

management will be dealt with via

the Construction Traffic

Management Plan and necessary

legal agreements for each of the

respective developments to ensure

no significant cumulative effects.

The traffic data applied to the model

takes account of all committed

developments as part of the baseline

assessment. Cumulative effects have

therefore already been incorporated

- and mitigated where necessary - as

part of the assessment. The access to

the Revised Scheme has been

designed to accommodate the future

modelled traffic flows allowing for

committed developments. There are

therefore no further cumulative

effects to be taken into account

during operation.

Air Quality Due to the separation distance

between the Revised Scheme site

and the other committed

developments nearby and also due

to different traffic routes, it is not

considered likely that cumulative

effects during the construction

phase are significant. Furthermore,

the potential effects of this

development during the

construction phase will be

temporary i.e. only during the

construction and demolition period.

The estimated number of car and

HGV movements from the Revised

Scheme are 260 and 100,

respectively. The cumulative effect

of construction traffic was not

assessed within the scope of this

report. However, construction

traffic is localised to the roads

nearby the Revised Scheme.

With regards to nearby residential

receptors, there is potential for a

The air quality assessment has taken

into consideration the cumulative

effects, as the traffic data applied to

the model takes account of all

committed developments. No

additional cumulative effects are

anticipated.


December 2017

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Environmental

Topics



significant effect as a result of dust

soiling during the construction

phase if the Revised Scheme

construction activities occur at the

same time as the Land West of

Stonehouse development. In such

an eventuality, traffic management

would be dealt with via the Dust



respective developments. This will

ensure no significant effect. The

same assessment will apply when

considering both the effect on

human health and ecology.

Lighting West of Stonehouse is located

approximately 23m from the

Redline Boundary of the Revised

Scheme. There is potential for

cumulative effects if both


simultaneously. In such an

eventuality, construction lighting

effect would be dealt with via the

Construction Environmental



respective developments. This

would ensure no significant effect.


anticipated.

Noise No significant cumulative effects

are anticipated.

The cumulative effects of the Revised

Scheme in terms of noise effects are

restricted to the long-term effects in

changing road traffic levels. The noise

assessment has taken into account

cumulative effects as the traffic

model considers all committed

developments. No significant

cumulative effects are anticipated.

Major

Accidents and

Disasters


are anticipated.


anticipated.


December 2017

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Environmental

Topics



Climate

Change

With respect to climate change mitigation, climate change is, in essence, a

cumulative effect and all greenhouse gas emissions from projects are

arguably significant. All the developments considered in this chapter will

involve the generation of direct, indirect and embodied greenhouse gas

emissions during construction and further emissions during operation, albeit

it is not possible to compare the level of these emissions against a ‘baseline’

of those associated with the previous use of the sites and/or any existing

developments which would be replaced by the committed developments. It

is, however, noted that application 13/0001/INQUIR relates to the

development of an Energy from Waste (EfW) facility, a low carbon

technology.

As all emissions are arguably significant, it is important that all

developments include climate change mitigation measures. Whilst not all

of these developments are subject to EIA, and the requirement to consider

climate in EIA is a recent one, all planning applications are subject to review

against Local Plan policy which states that “Sustainable design and

construction will be integral to new development in Stroud District” (Delivery

Policy ES1) and requires consideration of access on foot and bicycle and

public transport (Core Policy CP14). On this basis, it is considered

appropriate to assume that any applications that are consented include

‘reasonable’ measures to avoid, reduce and /or offset the generation of

greenhouse gas emissions.

With respect to climate change adaption, this is largely a project specific

consideration, namely the resilience of the project in question to climate

change, and the extent to which projected climate change could alter the

predicted impact judgements. More widely, in relation to potential

interactions with other developments, and following the same logic with

respect to required compliance with planning policy, it is noted that Core

Policy CP14: High Quality Sustainable Development requires all new

developments to achieve “no increased risk of flooding on or off the site, and

inclusion of measures to reduce the causes and impacts of flooding as a

consequence of that development” whilst Delivery Policy ES1: Sustainable

construction and design requires the “consideration of climate change

adaptation”. On this basis, again, it is considered appropriate to assume

that any applications that are consented include measures to ensure their

resilience to climate change.

18.17 In summary, based on Table 18.2, significant cumulative effects from different developments are

anticipated from:


December 2017

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• Landscape and Visual: Significant additional, adverse cumulative landscape and visual

effects attributable to the Revised Scheme are predicted to arise during construction up

to Year 1 of operation within approximately 0.5km of the Development Footprint in the

general vicinity of Grove Lane from Westend to Chipmans Platt. These short term,

additional cumulative effects will result from the combined and sequential visibility of the

proposal in conjunction with West of Stonehouse and Pike Lock cumulative schemes. The

adverse cumulative effects will reduce over time as the proposed landscape mitigation

establishes and matures.

• Landscape and Visual: Significant additional, adverse residual cumulative landscape

character effects are predicted to remain during operation with respect to a small area of

the Escarpment Footslopes (LCT5a) on and adjacent to the Development Footprint.

However, other cumulative landscape and visual effects predicted to be significant during

construction will be not significant during operation in the medium to long term.

• Socio-Economics: In relation to construction sector jobs, a significant, moderate, medium

term beneficial effect has been identified.

• Climate Change: With respect to climate change mitigation, climate change is, in essence,

a cumulative effect and all greenhouse gas emissions from projects are arguably

significant. However, it is considered appropriate to assume that any applications that are

consented include ‘reasonable’ measures to avoid, reduce and/or offset the generation of

greenhouse gas emissions.

Conclusion

18.18 This chapter has summarised the effect interactions and cumulative effects anticipated by the

Revised Scheme in relation to effects from different environmental features and effects from

different committed developments respectively.

18.19 With regards to cumulative effects from different environmental features, existing residential

properties and the local population of the common receptors included within Table 18.1 are

anticipated to be affected by more than one significant effect from different environmental

features from the technical assessments undertaken as part of this ES.

18.20 With regards to cumulative effects from different committed developments, negative significant

cumulative effects are anticipated in relation to landscape and visual receptors within 500m and

small areas of the Enscarpment Footslopes (LCT5a) from both the Revised Scheme, West of

Stonehouse and Pike Lock. However, positive significant cumulative effects are anticipated in

relation to socio-economics and the creation of construction jobs. With regards to climate

change, all greenhouse gas emissions are arguably significant, however, any application

considered should include ‘reasonable’ measures to avoid, reduce and/or offset the generations

of greenhouse gas emissions.


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19 SUMMARY AND STATEMENT OF SIGNIFICANCE

Introduction

19.1 This summary chapter brings together a summary of the significant effects for each of the

Technical Chapters of the ES. The respective Technical Chapters (other than Chapter 16 –

Climate Change and Chapter 17 – Major Accidents and Disasters) provide a Summary of Effects

and Mitigation table at the end of the chapter. These can be found in the following locations:

• Chapter 7 – Archaeology and Cultural Heritage (Table 7.7)

• Chapter 8 – Ecology and Nature Conservation (Table 8.10)

• Chapter 9 – Hydrology, Flood Risk and Drainage (Table 9.8 and 9.9)

• Chapter 10 – Landscape and Visual (Table 10.9)

• Chapter 11 – Socio-Economics (Table 11.7)

• Chapter 12 – Transport and Access (Table 12.13)

• Chapter 13 – Air Quality (Table 13.21)

• Chapter 14 – Lighting (Table 14.6)

• Chapter 15 – Noise (Table 15.20)

19.2 Table 19.1 (located at the end of this chapter) combines the residual significant effects of these

into a single table, detailing any mitigation measures. No residual significant effects (either

positive or negative), following the implementation of all identified mitigation, are anticipated in

relation Archaeology and Cultural Heritage (Chapter 7), Ecology and Nature Conservation

(Chapter 8), Socio-Economics (Chapter 11), Air Quality and Dust (Chapter 13), Noise and

Vibration (Chapter 15), Climate Change (Chapter 16) and Major Accidents and Disasters (Chapter

17). Therefore, these are not included within Table 19.1.

Statement of Significance

19.3 In terms of the assessments undertaken as part of the ES, significant effects are anticipated in

relation to the following technical assessments (full details are included in Table 19.1).

• Flood Risk, Hydrology and Drainage: Significant positive effects associated with

biodiversity and conservation.

• Landscape and Visual: Significant adverse effects are anticipated on a small area of

landscape and a limited number of visual receptors located on and/ or immediately

surrounding the Site within approximately 250m of the Development Footprint (500m for

cumulative effects).

• Transport and Access: During construction, the users of Footpaths Eastington 37 and 38

will experience a moderate, negative but medium term / temporary effects in terms of

severance, pedestrian delay, pedestrian amenity, fear and intimidation. During operation,

there could also be a moderate negative effect in terms of severance, amenity, delay and

fear and intimidation to users of PROW Footpaths Eastington 37 and 38, and National

Cycle Route 45 before and after a match. Although significant, this effect will be

infrequent. On non-match days, pedestrians and cyclists on these routes could experience

a moderate positive effect as a result of the introduction of the traffic signal controlled

crossing of the A419 and improvements at Chipmans Platt roundabout. The traffic


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modelling indicates that during operation on a moderate negative effect on journey times

is experienced by existing road users on the A419 corridor between the A38 and

Horsetrough roundabout during the match arrival and departure periods on a Saturday

and during the weekday evening match arrival period. On non-match days, drivers could

experience a moderate positive effect as a result of the dualling of the A419 between the

M5 Junction 13 and Chipmans Platt.

• Lighting: Significant adverse effects are anticipated from sky glow associated with when

the stadium lighting is in operation, albeit this effect will be infrequent.


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Table 19.1: Summary of Significant Effects211

211 Note: Cumulative effects are dealt within the preceding Chapter 18 and so are not re-stated in this chapter. In summary, negative significant cumulative effects are anticipated

in relation to landscape and visual receptors within 500m and small areas of the Enscarpment Footslopes (LCT5a) from both the Revised Scheme, West of Stonehouse and Pike Lock.

However, positive significant cumulative effects are anticipated in relation to socio-economics and the creation of construction jobs. With regards to climate change, all greenhouse

gas emissions are arguably significant, however, any permitted application should include ‘reasonable’ measures to avoid, reduce and/or offset the generations of greenhouse gas

emissions.

Environmental

Topic


Phase

Sensitivity /

importance

of receptor

Magnitude

Change

Level of Effect (and

Significance) prior to

mitigation

Mitigation /

Enhancement

Level of Effect (and

Significance) after mitigation /

enhancement

Nature of

effect

Chapter 9:

Flood Risk,

Hydrology and

Drainage

The Stadium

Location

Biodiversity

enhancements

Operation Medium N/A Minor positive SuDS drainage

network design

Moderate (significant) Positive, Long

Term

Chapter 10:

Landscape and

Visual

LCT SV6

Settled

Unwooded

Vale, LCA

SV6A Vale of

Berkeley

Effect on landscape

character / value


250m from

Development

Footprint

Medium / Low

beyond 250m

Major / Moderate

up to approximately 250m

from

Development Footprint

Moderate / Minor or less

beyond 250m

(Significant within 250m)

See RS Appendix

10.3 Moderate / Major up to

approximately250m from


Minor / Moderate or less

beyond 250m


Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct and

Indirect

Chapter 10:

Landscape and

Visual

Escarpment

Footslopes

(Stroud No

5A)

Effect on landscape

character / value

C & O Medium to

High

High up to

250m from

Development

Footprint

Medium / Low

beyond 250m

Major / Moderate to

Major


from


Moderate to Moderate /

Minor

or less beyond 250m


See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Moderate / Major up to 250m

from


Moderate / Minor or less

beyond

250m


Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct and

Indirect


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Chapter 10:

Landscape and

Visual

Lowland Plain

(Stroud No

5B)

Effect on landscape

character / value


250m from

Development

Footprint

Medium /

Low beyond

250m

Major / Moderate


from


Moderate / Minor

or less beyond 250m


See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.3

& 10.7.

Moderate to Moderate / Major

up

to 250m from


Minor / Moderate or less

beyond

250m


Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct and

Indirect

Chapter 10:

Landscape and

Visual

7. Viewpoint

Grove Lane

M5 over

bridge

Effect on views and

visual amenity

C & O Medium Medium to High Moderate / Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.


(Adverse and Beneficial)

(Significant)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 10:

Landscape and

Visual

16. Footpath

west of West

End Cross

(EEA 38)

Effect on views and

visual amenity

C & O High Medium to High Major / Moderate

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate / Major (Adverse &

Beneficial

(Significant)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 10:

Landscape and

Visual

Residential

Property

Westend

House

Effect on views and

visual amenity

C & O High Medium Moderate / Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

See also ES Figure

5.6.

Moderate

(Not Significant)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 10:

Landscape and

Visual

Residential

Properties (2

Properties)

Effect on views and

visual amenity

C & O High Medium Moderate / Major

(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7.

Moderate

(Not Significant)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct


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Ivy Cottage,

Mole Cottage

See also ES Figure

5.6.

Chapter 10:

Landscape and

Visual

PRoW

Eastington

Footpath

No.37

Effect on views and

visual amenity


(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Major/ Moderate

(Significant)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 10:

Landscape and

Visual

PRoW

Eastington

Footpath

No.38

Effect on views and

visual amenity


(Significant)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7

Major / Moderate

(Significant)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 10:

Landscape and

Visual

M5 Effect on views and

visual amenity

C & O Low High 250m

north of J13

Low

Overall

Moderate / Major for

250m north of J13

Minor

Overall

(Significant for 250m)

See RS Figures

5.3, 10.11c &

10.11d and RS

Appendices 10.4

& 10.7


for 250m

Minor Overall

(Significant for 250m)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 10:

Landscape and

Visual

A419 Effect on views and

visual amenity

C & O Low High between

Chipmans Platt

roundabout &

J13

Low Overall

Moderate / Major

between Chipmans Platt

roundabout & J13

Minor Overall

(Significant between

Chipmans Platt

roundabout & J13)

See Green

Infrastructure

Plan


between Chipmans Platt

round-about & J13

Minor / Negligible Overall

(Significant between Chipmans

Platt roundabout & J13)

Adverse and

Positive, Short

and Long Term,

Permanent and

Temporary,

Direct

Chapter 12:

Transport and

Access

People

walking on

PROW

Footpaths

Severance, pedestrian

delay, pedestrian

amenity, fear &

intimidation

Construction

(Weekdays,

and Saturday

morning)

Medium Substantial Moderate/ significant No construction

to take place on

Saturday PM,

Sunday or Bank

Holidays /

Construction

Traffic

Moderate / significant Negative,

Medium Term


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Easington 37

& 38

Management Plan

Chapter 12:

Transport and

Access

People

walking on

PROW

Footpath

Easington 37

as it crosses

A419


delay, pedestrian

amenity, fear &

intimidation

Operation

(Match)

Medium Substantial Moderate / significant Travel Plan to

encourage

sustainable travel

Moderate / significant Negative, Long

Term,

Infrequent

(during FGRFC

match)

Positive, Long

Term (No

FGRFC match)

Chapter 12:

Transport and

Access

People

walking on

PROW

Footpaths

Easington 37

& 38 within

Site


delay, pedestrian

amenity, fear &

intimidation

Operation

(Match)

Medium Medium Moderate / significant Travel Plan to

encourage

sustainable travel

Moderate/ significant Negative, Long

Term,

Infrequent

(during FGRFC

match)

Chapter 12:

Transport and

Access

People

walking or

cycling on

Spring Hill


delay, pedestrian

amenity, fear &

intimidation

Operation

(Match)


encourage

sustainable travel


Term,

Infrequent

(during FGRFC

match)

Positive, Long

Term (No

FGRFC match)

Chapter 12:

Transport and

Access

People

walking or

cycling on

Cycle Route

45 at

Chipmans

Platt


delay, pedestrian

amenity, fear &

intimidation

Operation

(Match)

Medium Medium to

Substantial

Moderate/ significant Travel Plan to

encourage

sustainable travel


Term,

Infrequent

(during FGRFC

match)

Positive, Long

Term (No

FGRFC match)

Chapter 12:

Transport and

Access

Key highway

junctions

operating

within

capacity:

A419 Corridor

Driver Delay

Operation

(Match)


encourage

sustainable travel


Term,

Infrequent

(during FGRFC

match)

Positive, Long

Term between


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M5 J13 and

Chipmans Platt

(No FGRFC

match)

Chapter 14:

Lighting

All receptors Sky glow Operation Significant Limiting hours of

operation Significant Permanent,

Adverse, Long

term,

Infrequent.


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20 GLOSSARY

Term Definition

Air Quality Standard Concentration of a pollutant, over a specified period, above which adverse

effects on health and/or the environment may occur and which should not be

exceeded

Ambient Of or relating to the immediate surroundings of something (e.g. ambient noise

level)

APS Annual Population Survey – a quarterly population survey conducted

throughout the UK, which gathers information on demographic and labour

market characteristics

ARCADY The roundabout module in Junctions 9

Assessment Process by which information about effects of a proposed plan, project or

intervention is collected, assessed and used to inform decision making

Automatic Traffic Count (ATC) Normally two rubber tubes laid across the carriageway linked to a road side

recorder box to measure speed, number and type of vehicle movements over a

24-hour period for a number of days

Background Sound Level Sound level measured in the absence of a specific sound source being studied. It

is common practice to measure the background sound level using statistical

analysis using the level of sound that is exceeded for 90% of the time: often

presented using the L90 descriptor

Barriers Other structures and buildings which are likely to impact on the propagation of

noise from construction works have also been included within the model. This

includes permanent surrounding residential and non-residential buildings and

any substantial barriers located in the surrounding area

Baseline Conditions Environment as it appears (or would appear) immediately prior to the

implementation of the project together with any known or foreseeable future

changes that will take place before completion of the project

Best Available Technique (BAT) The most effective and advanced engineering practices and methods of

operation, which are available and practicable, to prevent, and where this is not

practicable, reduce emissions and the impact on the environment as a whole

BRES Business Register and Employment Survey – an annual survey of employment

based on a sample of firms from the Interdepartmental Business Register

BS42020 British Standard Biodiversity. Code of Practice for Planning and Development

Catchment Drainage/basin area within which precipitation drains into a river system and

eventually into the sea

Climate Change Adaption The vulnerability of the Revised Scheme to climate change, with measures

included in the project to ensure resilience to climate change

Climate Change Mitigation The potential effects of the Revised Scheme on climate change, with measures

included in the project to reduce the emissions of greenhouse gases climate

change adaptation

CLG Department for Communities and Local Government – Government department

with responsibility for local government, communities, local enterprise

partnerships, the planning system and local fire and rescue authorities

Committed Development Development projects that are either under construction or have valid planning

permissions/consents

Conservation (for heritage policy) The process of maintaining and managing change to a heritage asset in a way

that sustains and, where appropriate, enhances its significance

Construction Phase Period during which the building or assembling of infrastructure is undertaken

Construction Traffic Management Plan (CTMP) Plan setting out proposals for the management of construction traffic including

vehicle routes and signing, construction traffic hours, site access and means of

protecting the public highway from detritus

Consultation Process by which those organisations or individuals with an interest in the area

associated with the proposed scheme are identified and engaged as part of the

EIA process

Culvert Pipe or box-type conduit through which water is carried under a structure


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Cumulative Effect Effects that result from incremental changes caused by other past, present or

reasonably foreseeable actions together with the project.

A cumulative effect may arise as the result of (a) the combined effect of a

number of different environmental topic-specific effects from a single

environmental impact assessment project on a single receptor/ resource or (b)

the combined effect of a number of different projects within the vicinity (in

combination with the environmental impact assessment project) on a single

receptor/resource

Curfew Refers to a time when the local planning authority has agreed that the lighting

installation should be switched off; this typically refers to 11pm - 7am

dBA (A-weighted Decibel) A single value in decibels used to represent the noise level from the entire

hearing frequency range

Decommissioning Period during which a development and its associated processes are removed

from active operation

Degree of Saturation (DOS) Measure of capacity of a traffic signal junction

Designated heritage assets a World Heritage Site, Scheduled Monument, Listed building, Protected Wreck

Site, Registered Park and Garden, Registered Battlefield or Conservation Area

Do-minimum Scenario Also known as the ‘do-nothing’ scenario: the conditions that would persist in

the absence of the implementation of a development

ECoW Ecological Clerk of the Works

Effect Term used to express the consequence of an impact (expressed as the

‘significance of effect’), which is determined by correlating the magnitude of the

impact with the importance (or sensitivity) of the receptor or resource in

accordance with defined significance criteria. For example, land clearing during

construction results in habitat loss, the effect of which is the significance of the

habitat loss on the ecological resource.

Embedded Mitigation Mitigation that has been embedded into the design of the Revised Scheme.

Emergency Noise For the purposes of this document, Emergency Noise is defined as acoustic

emission due to unplanned pressure valve release, emergency flaring, or

operation/procedures necessary to protect life or property. The duration of

emission is short and the frequency of operation is expected to be very low.

Longer duration but infrequent noise sources such as start-up/shutdown

venting and flaring and audible announcement/alarm systems sounding do not

meet the Emergency Noise definition

Enhancement Measure that is over and above what is required to mitigate the adverse effects

of a project

Environmental Impact Assessment (EIA) Statutory process by which certain planned projects must be assessed before a

formal decision to proceed can be made. Involves the collection and

consideration of environmental information, which fulfils the assessment

requirements of the EIA Directive, including the publication of an environmental

statement

Environmental Statement (ES) Document produced in accordance with the EIA Directive (as transposed into

UK law by the EIA Regulations) that reports the outcomes of the EIA process

Evaluation Determination of the significance of effects. Evaluation involves making

judgements as to the value of the receptor/resource that is being affected and

the consequences of the effect on the receptor/resource based on the

magnitude of the impact

Existing Environment See ‘baseline conditions’

Façade Corrections a 3 dB(A) correction has been applied to convert a free-field noise prediction to

a façade level

Forest Green Rovers (FGR) Football club based in Stroud District

Field of view The horizontal and / or vertical extent of the prospect in view as depicted in the

photographs, defined by the angle subtended between the extremities of view

frame

FTE Full Time Equivalent – a measurement of the number of jobs in an area which

takes account of full time and part time work, so that employment can be

compared on a consistent basis


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Glare The uncomfortable brightness of the light source against a dark background

which results in dazzling the observer, which may cause nuisance to residents

and a hazard to road users

Green Infrastructure Networks of Green Spaces and water courses and water bodies that connect

rural areas, villages, towns and cities

Ground Absorption Hard, acoustically reflective ground (0.5 coefficient) – roads, pavements and

hard standing areas

Acoustically soft (assumed 0.8 coefficient) – grass or vegetated areas

Heavy Goods Vehicle (HGV) goods vehicle over 3.5 tonnes gross weight

Heritage Asset A building, monument, site, place, area or landscape identified as having a

degree of significance meriting consideration in planning decisions, because of

its heritage interest

Hertz Unit of frequency defined as one cycle per second

Illuminance The luminous flux incident on unit area of a surface. The unit is the lux which is

one lumen per square metre

IMD Index of Multiple Deprivation – an index which assesses a wide range of

indicators to provide an assessment of deprivation in every local super output

area in England. This covers income, employment, crime, access to services,

health and living environment

Impact Sound The sound that results when two masses collide (typical peak sound level

duration of each impact would be between 25 microseconds and 1 second).

Typical examples are hammering and gunfire

Impulse Sound A sound created by the sudden impulse of pressure. Mathematically expressed

as the integral of a force over the time interval during which the force is

applied. Sometimes also referred to as impact sound

Intermittent For the purposes of this document, intermittent is defined as acoustic emissions

or operations that occur less than 5% of the time during a work shift and fewer

than six times per hour. Longer duration but infrequent noise sources such as

start-up/shutdown venting do not meet the intermittent definition

JSA Jobseekers Allowance – an out of work benefit for those people who are

actively seeking employment

Junctions 9 Industry standard package for modelling roundabouts and priority junctions.

Key Characteristics Those combinations of elements which are particularly important to the current

character of the landscape and help to give an area its particularly distinctive

sense of place

LA90, T A-weighted sound level which is exceeded for 90% of the duration of

measurement, often used to provide a value for the ‘background sound level’. T

is the period upon which the statistical level relates

LAeq, T A-weighted equivalent continuous sound pressure level, where A-weighted

refers to a frequency dependent correction that is applied to a measured or

calculated sound of moderate intensity to mimic the varying sensitivity of the

ear to sound for different frequencies. T is the period upon which the sound

pressure relates

Landscape An area, as perceived by people, whose character is the result of the action and

interaction of natural and/or human factors

Landscape and Visual Assessment (LVIA) A tool used to identify and assess the likely significance of the effects of change

resulting from development both on the landscape and as an environmental

resource in its own right and on people’s views and visual amenity

Landscape Capacity The degree to which a particular landscape character type or area is able to

accommodate change without unacceptable adverse effects on its character.

Capacity is likely to vary according to the type and nature of the change being

proposed

Landscape Character A distinct, recognisable and consistent pattern of elements in the landscape

that makes one landscape different from another, rather than better or worse

Landscape Character Areas (LCAs) These are single unique areas which are the discrete geographical areas of a

particular landscape type

Landscape Character Types (LCTs) These are distinct types of landscape that are relatively homogeneous in

character. They are generic in nature in that they may occur in different areas in


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different parts of the country, but wherever they occur they share broadly

similar combinations of geology, topography, drainage patterns, vegetation,

historical land use, and settlement pattern, and perceptual and aesthetic

attributes

Landscape Quality (or condition) A measure of the physical state of the landscape. It may include the extent to

which typical character is represented in individual areas, the intactness of the

landscape and the condition of individual elements

Landscape receptors Defined aspects of the landscape resource that have the potential to be

affected by a proposal

Landscape Susceptibility The ability of the landscape receptor…to accommodate the Revised Scheme

without undue consequences for maintenance of the baseline situation and/or

the achievement of landscape planning policies and strategies

Landscape Value The relative value that is attached to different landscapes by society. A

landscape may be valued by different stakeholders for a whole variety of

reasons

LEP Local Enterprise Partnership – business-led organisations tasked with delivering

economic development for their local area. There are 39 LEPs in the country,

with the boundaries determined by local economic geography

Light Spill The unwanted spillage of light onto adjacent areas and may affect sensitive

receptors, particularly residential properties and ecological sites

Light Trespass (into Windows) The spilling of light beyond the boundary of a property which may cause

nuisance to others

Lux: The SI unit of illuminance, equal to one lumen per square metre

LinSig Industry standard software for the assessment and design of traffic signal

junctions

LOAEL This is the level above which adverse effects on health and quality of life can be

detected. The term is defined within the Noise Policy Statement for England

LSOA Lower Super Output Area – geographical units used for data analysis at a local

level in England and Wales. There are nearly 33,000 LSOAs in England and

Wales, each with a minimum population of 1,000 people

MAGIC Multi-Agency Geographic Information for the countryside

Mitigation Measures that are necessary to avoid, minimize, or offset anticipated adverse

impacts and, where appropriate, to incorporate these into an environmental

management plan or system.

Monitoring Continuing assessment of the performance of the project, including mitigation

measures. This determines if effects occur as predicted or if operations remain

within acceptable limits, and if mitigation measures are as effective as

predicted.

MSOA Middle Super Output Area - geographical units used for data analysis at a local

level in England and Wales. Middle super output areas are made up of several

smaller lower super output areas and have a minimum population of 5,000

people

National Cycle Network (NCN) A series of safe, traffic free paths and quiet on-road cycling and walking routes

that connect to every major town and city

National Planning Policy Framework (NPPF) Sets out the Government's planning policies for England and how these are

expected to be applied

National Transport Model (NTM) Government model to forecast long term trends in road traffic

National Trip End Model (NTEM) Used with TEMPRO to estimate local growth for transport planning purposes

NOEL This is the level below which no effect can be detected. In simple terms, below

this level, there is no detectable effect on health and quality of life due to the

noise. The term is defined within the Noise Policy Statement for England

Noise/Sound Vibrations in air that are in the audible frequency range from 20Hz–20 kHz. The

word "sound" is used within this document in relation to emissions which are

independent of the effect on the receptor (e.g. a ‘sound power level’ is related

to the source and is not related to the receptor). The word "noise" is used

where a sound is related to its affect on a receptor and constitutes an unwanted

effect of sound (e.g. occupational noise exposure)


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Non-technical Summary Information for the non-specialist reader to enable them to understand the

main predicted environmental effects of the proposal without reference to the

main Environmental Statement.

NPPF National Planning Policy Framework – the main national planning policy

document which was published in March 2012, consolidating the previously

issued Planning Policy Statements and Planning Policy Guidance Notes for use in

England

Octave Bands Subdivision of sound spectrum based on set frequency ranges

OffPAT Office of Project Advice and Training - a membership network that operates a

value for money, shared services approach to programme and project best

practice. OffPAT closed in 2011

ONS Office for National Statistics - the UK’s largest independent producer of official

statistics and the recognised national statistical institute of the UK

Operation Functioning of a project on completion of construction

Passenger Car Unit (PCU) Method used in transport modelling to allow the different vehicle types within a

traffic flow group to nbe assessed in a consistent manner. Typical values are 1

for a car or light goods vehicle and 2 for a bus or heavy goods vehicle

PICADY The priority junction module in Junctions 9

Pollution Any increase of matter or energy to a level that is harmful to living organisms of

their environment (when it becomes a pollutant)

Programme Series of steps that have been identified by the applicant, or series of projects

that are linked by dependency

Project One (or more) aspect of a programme or plan that has been identified by the

applicant and usually involves a direct physical intervention

Pure Tone A narrow band component that is noticeable as a sound of distinguishable pitch

and that represents a dominant feature of the facility sound source.

Quantitatively, a measured 1/3 octave band sound level that is a minimum of 6

dB higher than both adjacent 1/3 octave band sound levels

RAMSAR Convention on Wetlands of International Importance, especially as Waterfowl

Habitat

Ratio of flow to capacity (RFC) Measure of traffic capacity of a junction

Receptor Defined individual environmental feature usually associated with population,

fauna and flora with the potential to be affected by a project

Receptor Height Ground Floor 1.5m above ground

First Floor 4.5m above ground

Residential Amenity Is understood to involve a combination of sensory factors which inform the

living conditions of a property including the visual, sound / noise and olfactory

(smell) environments

Resource Defined but generally collective environmental feature usually associated with

soil, water, air, climatic factors, landscape, material assets, including the

architectural and archaeological heritage that has potential to be affected by a

project

Run-off Precipitation that flows as surface water from a site, catchment or region to the

sea

Scoping Process of identifying the issues to be addressed by the environmental impact

assessment process. It is a method of ensuring that an assessment focuses on

the important issues and avoids those that are considered not significant.

Scoping Opinion Opinion provided by a competent authority that indicates the issues an

environmental impact assessment of a proposed development should consider

Screening Formal process undertaken to determine whether it is necessary to carry out a

statutory environmental impact assessment and publish an Environmental

Statement in accordance with the EIA Regulations

Section 106 Agreement A legally binding agreement between a Local Planning Authority and a land

developer, often to fund necessary improvments

Sediment Organic and inorganic material that has precipitated from water to accumulate

on the floor of a water body, watercourse or trap


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Sensitivity A term applied to specific receptor, combining judgements of the susceptibility

of the receptor to the specific type of change or development proposed and the

value to that receptor

SEP Strategic Economic Plan – strategy document produced by each of the local

enterprise partnerships in England which identifies the key economic priorities

and interventions for the area

Significance See ‘significance of effect’

Significance (for heritage policy) The value of a heritage asset to this and future generations because of its

heritage interest

Significance of Effect Measure of the importance or gravity of the environmental effect, defined by

either generic significance criteria or criteria specific to the environmental topic

Significant Effect Environmental effect considered material to the decision-making process

Sky Glow The upward spill of light into the sky which can cause a glowing effect and is

often seen above cities when viewed from a dark area

SOAEL This is the level above which significant adverse effects on health and quality of

life occur. The term is defined within the Noise Policy Statement for England

Sound (Pressure) Level In air, 20 times the log (base 10) of the given sound pressure to the reference

sound pressure of 20 micro-Pascal; the resultant unit is dB. Sound pressure is

the root-mean-square of the instantaneous pressure fluctuations caused by an

acoustic wave during a specified time interval in a stated frequency band; the

unit is Pascal

Sound Power Level 10 times the log (base 10) of the given sound power to the reference sound

power of 1 pico-Watt; the resultant unit is dB. The sound power (of a source) is

the rate per unit time at which sound energy is radiated in a given frequency

band in Watts. Sound power is typically calculated as a function of sound

pressure and surface area

Source Modelling External noise sources have been treated as omni-directional point sources;

Plant complement assumed to be operating on the closest boundary of the

construction site to each receptor;

Shortest distance from façade of noise sensitive receptor to site assumed;

Buildings and structures identified modelled as structures;

Average construction source emission height of 1.5m;

Construction Plant Data taken from BS5228:2009+A01:2014

Strategic Road Network (SRN) Network of motorways and all-purpose trunk roads in England managed by

Highways England

Study Area Spatial area within which environmental effects are assessed (i.e. extending a

distance from the project footprint in which significant environmental effects

are anticipated to occur). This may vary between the topic areas.

Sustainable Transport All forms of transport which minimise emissions of carbon dioxide and

pollutants. Can refer to public transport, car sharing, walking and cycling as well

as technology such as electric and hybrid cars and biodiesel.

Terrain OS terrain data has been included within the model

Threshold Specified level in grading effects (e.g. the order of significance)

Traffic Information Traffic data used within the assessment has been provided by PFA Consulting

Limited

Transport Assessment (TA) Comprehensive review of the potential transport impacts of a proposed

development, with proposals to mitigate any adverse consequences

Travel Plan Long term management strategy for encouraging sustainable travel, often

prepared in parallel to development proposals

TRICS A database of trip rates for estimating trip generation by development

Trip End Model Presentation Program (TEMPRO) Used with the NTEM forecasts to estimate local growth for transport planning

purposes

Visual amenity The overall pleasantness of the views people enjoy of their surroundings, which

provides an attractive visual setting or backdrop for the enjoyment of activities

for people, living, working, recreating, visiting or travelling through an area


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Visual Receptors Individuals and / or defined groups of people who have the potential to be

affected by a proposal

With Development Noise predictions taking into account the impact of road traffic flows with the

Revised Scheme

Without Development Noise predictions taking into account the impact of road traffic flows without

the Revised Scheme

Worst Case Principle applied where environmental effects may vary (e.g. owing to seasonal

variations) to ensure the most severe effect is assessed

Zone of Theoretical Visibility (ZTV) A map, usually digitally produced, showing areas of land within which a

development is theoretically visible