Our ref: Your ref: Energy Consents Unit Meridian Court 5 Cadogan Street Glasgow G2 6AT PCS/127265 If telephoning ask for: Nicola Abrams 15 July 2013 By email only to: EconsentsAdmin@scotland.gsi.gov.uk Dear Ms Gallacher The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000 Planning application: Proposed Rothienorman – Peterhead 400kV Reinforcement Project Thank you for your consultation letter which SEPA received on 12 June 2013. We ask that the planning condition in Section 3 be attached to the consent. If this will not be applied, then please consider this representation as an objection. Please also note the advice provided below. Advice for the Determining Authority 1. Impacts on Groundwater and Private Water Supplies 1.1 No significant hydrogeological issue have been identified and we therefore have no objections. 2. Engineering in the Water Environment 2.1 We note that a small number of watercourse crossing upgrades may be required to enable tower access, we have no objections to these proposals in a planning context but the applicant should be aware that such proposals will require to be regulated under the Water Environment Controlled Activities (Scotland) Regulations 2011 (CAR), we have not yet received an application for any such works but we would expect to be able to grant the required authorisations in due course. 3. Environmental Management and Pollution Prevention 3.1 We welcome the statement that a Construction Environmental Management Document will be prepared and welcome the mitigation identified in the Environmental Mitigation Register. We request that the provision of a CEMD for this project be ensured by condition. To assist, the following wording is suggested: That no development shall commence on site until site specific Construction Environmental Management Plan/Document have been submitted and approved in writing by the Planning Authority in consultation with [SEPA, SNH or other agencies as appropriate]. All works on site must be undertaken in accordance with the approved CEMP unless otherwise agreed in writing with the Planning Authority. The CEMP must address the following issues: Surface and ground water management Temporary track construction Tower removal Works in the water environment Pollution prevention Soils management Site waste management Informative: It is recommended that the CEMP is submitted at least 2 months prior to the commencement of any works on site; this is to allow the necessary agencies sufficient time to fully review the mitigation proposals to avoid any potential delays to the project moving forward. Reason: In order to minimise the impacts of necessary demolition/construction works on the environment Detailed advice for the applicant 4. Impacts on Groundwater and Private Water Supplies 4.1 Any dewatering during excavations should be in compliance with GBR 2 and GBR 15 of the Controlled Activities Scotland Regulations 2011. Abstraction of groundwater in quantities greater that 10m3/day will require a CAR permit depending on the scope and duration of the works. Details should be provided of how any dewatering will be managed, the amount of groundwater proposed to be abstracted and the anticipated timescales. 5. Environmental management 5.1 We welcome the inclusion of a mitigation register, given the number of watercourses which cross the route of the proposed, particular care should be taken to ensure that works do not result in pollution of the water environment and the CEMP will set out both general pollution prevention measures and site specific measures where there are particular sensitivities. 5.2 The CEMD should incorporate detailed pollution prevention and mitigation measures for all construction elements potentially capable of giving rise to pollution during all phases of construction, reinstatement after construction and final site decommissioning. 5.3 The CEMD should also include a site waste management plan which addresses all waste management elements of the proposals. Full details of what should be included in the CEMD can be found on our website. Regulatory advice for the applicant 6. Regulatory requirements 6.1 Details of regulatory requirements and good practice advice for the applicant can be found on our website at www.sepa.org.uk/planning.aspx. If you are unable to find the advice you need for a specific regulatory matter, please contact a member of the operations team in your local SEPA office at: Inverdee House, Baxter Street, Torry, AB11 9QA, Tel 01224 266600. If you have any queries relating to this letter, please contact me by telephone on 01224 266698 or e-mail at planning.aberdeen@sepa.org.uk. Yours sincerely Nicola Abrams Senior Planning Officer Planning Service Ecopy: peter.jennings@sse.com Disclaimer This advice is given without prejudice to any decision made on elements of the proposal regulated by us, as such a decision may take into account factors not considered at the planning stage. We prefer all the technical information required for any SEPA consents to be submitted at the same time as the planning application. However, we consider it to be at the applicant's commercial risk if any significant changes required during the regulatory stage necessitate a further planning application and/or neighbour notification or advertising. We have relied on the accuracy and completeness of the information supplied to us in providing the above advice and can take no responsibility for incorrect data or interpretation, or omissions, in such information. If we have not referred to a particular issue in our response, it should not be assumed that there is no impact associated with that issue. If you did not specifically request advice on flood risk, then advice will not have been provided on this issue. Further information on our consultation arrangements generally can be found in How and when to consult SEPA, and on flood risk specifically in the SEPA-Planning Authority Protocol.