___ Directorate for Energy and Climate Change Energy Division T: 0300 244 1238 F: 0300 244 1060 E: Mr Grant Young lesley.mcneil@scotland.gsi.gov.uk GVA Grimley Quayside House 127 Fountainbridge EDINBURGH EH3 9QG October 2011 Dear Mr Young APPLICATION FOR CONSENT UNDER SECTION 36 OF THE ELECTRICITY ACT 1989 AND DEEMED PLANNING PERMISSION UNDER SECTION 57(2) OF THE TOWN AND COUNTRY PLANNING (SCOTLAND) ACT 1997 TO CONSTRUCT AND OPERATE A GAS-FIRED CCGT GENERATING STATION AT COCKENZIE POWER STATION, EAST LOTHIAN Application 1. I refer to the application submitted on behalf of ScottishPower Generation Ltd (“the Company”), received on 21 December 2009 for(i) consent under section 36 of the Electricity Act 1989 ”the Electricity Act”) to construct and operate the 1000MW gas-fired combined cycle gas turbine (“CCGT”) generating station and associated works at Cockenzie Power Station, East Lothian as described in that letter and accompanying documents, and (ii) a direction under section 57(2) of the Town and Country Planning (Scotland) Act 1997 (“the Planning Act”) that planning permission be deemed to be granted in respect of the construction of that generating station and any ancillary development. 2. The development would consist of two high-efficiency CCGT units. The CCGT units combine a gas turbine and a steam generator connected to a steam turbine. Electricity is generated by both the gas turbine and the steam turbine with the exhaust gases from the gas turbine generating the steam to power the steam turbine. The development would be Carbon Capture Ready and the total electrical output would be 1000MW. Consultation 3. In accordance with statutory requirements, advertisements of the application had to be placed in the local press. Ministers note that these requirements have been met. Under Schedule 8 of the Electricity Act, the relevant planning authority is required to be notified of a section 36 consent application. East Lothian Council (ELC) was notified and initially objected to the scheme, subsequently withdrawing this objection after clarifying information was provided on a range of topics. Notification was also given to Scottish Natural Heritage (SNH) and the Scottish Environment Protection Agency (SEPA). A number of relevant organisations and departments were also consulted by the Scottish Ministers. A total of 37 representations were received of which 25 were objections and 12 were in support of the application. A summary of the responses received is at Annex 3. Inquiry 4. As ELC, the relevant planning authority, initially objected to the proposal, the Scottish Ministers were obliged to cause a public inquiry to be held in accordance with paragraph 2(2) of Schedule 8 to the Electricity Act. The Reporter considered evidence from written submissions, the environmental statement, supporting documents, a hearing session and site inspections. The report of the public inquiry was issued to the Scottish Ministers on 26 April 2011. Environmental matters 5. An environmental statement has been produced in accordance with the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000. Scottish Ministers have considered the environmental statement, as well as supplementary information provided to the inquiry. Ministers note and adopt the Reporter’s findings in fact and agree and adopt his conclusions and recommendations on environmental matters. Scottish Ministers’ Consideration 6. In December 2009 you applied to Scottish Ministers for consent to construct and operate a gas-fired CCGT generating station at the site of the existing coal-fired power station at Cockenzie. This proposal involved the demolition of the existing plant and the construction of a new plant consisting of two high-efficiency CCGT units. The CCGT units combine a gas turbine and a steam generator connected to a steam turbine. Electricity is generated by both the gas turbine and the steam turbine with the exhaust gases from the gas turbine generating the steam to power the steam turbine. The development will be Carbon Capture Ready and the total electrical output will be 1000MW. 7. The Scottish Ministers have considered fully and carefully the application and accompanying documents, the objections and representations received and the evidence considered in the course of the public inquiry. 8. Paragraph 3(1)(a) of Schedule 9 to the Electricity Act places a duty on the Company when formulating proposals to have regard to the desirability of preserving natural beauty, of conserving flora, fauna and geological and physiological features of special interest and of protecting sites, buildings and objects of architectural, historic or archaeological interest. It requires the Company to do what it reasonably can to mitigate the effects that the development would have on these features. Paragraph 3 also requires the Scottish Ministers to have regard to the desirability of the features and the extent to which the Company has complied with its duty. The Scottish Ministers are satisfied that in formulating its proposals the Company has had due regard to these features and has done what it reasonably can to mitigate their effect. Scottish Ministers Considerations - Scottish Government Policy 9. The Scottish Government’s Draft Electricity Generating Statement 2010 demonstrates that: Renewables alone cannot provide the security of electricity generation that would be required. That in the 2020’s and 2030’s without thermal electricity generation Scotland would be required to import electricity for between 50% and 60% of the time. It establishes that Scotland needs a minimum of 2.5GW of thermal generation by 2030 to back up renewable generation and that this can be met by new build plant, upgrades to existing plant, or a combination of both. 10. The Scottish Government policy in relation to Carbon Capture and Storage (CCS) on new gas-fired electricity generation is, that for any applications for new stations over 300MWe, applicants should be able to demonstrate carbon capture readiness. 11. Scottish Ministers are therefore satisfied that your proposals for Cockenzie are in alignment with Scottish Government thermal electricity generation policy. 12. The Scottish Government policy for reducing emissions from thermal generation is that CCS should be fitted to new or existing Scottish coal power stations by 2020, and should CCS be economically and technically proven by 2020, then progressively fitted to all coal and gas thermal plants thereafter by 2030. In line with this I have applied condition 4 to condition 6 of Part 1 of Annex 2 below. This requires that when CCS technology in the generation of electricity has been successfully demonstrated on a commercial scale you will be expected to submit the necessary applications to retrofit the station within CCS, and that the first of these applications must be submitted within 2 years. Scottish Ministers Considerations – Environmental Issues 13. CCGT is generally recognised as Best Available Technology for electricity generation from natural gas, due to their high efficiency of fuel use. A switch in fuel at the site from coal to CCGT reduces emissions of combustion gases such as nitrogen oxides. Compared to the current coal-fired plant you expect S02 emissions to be negligible, you expect N02 emissions to be less than 1/3 current levels and C02 emissions less than 1/2 current levels. 14. The Scottish Ministers have considered all the environmental information carefully. In addition to the environmental statement, they have considered the report of the public inquiry and the consultation responses from ELC and the statutory consultees, along with all other consultee responses. Ministers have also considered representations made by members of the public about the likely environmental effects of the proposed development and its compatibility with national policy. A summary of the consultation responses received has been attached at Annex 3 and a copy of the Public Inquiry Report has also been included and is available on the Scottish Government website. 15. The Scottish Ministers accept the Reporter’s findings, agree with his reasoning and conclusions and adopt them for the purposes of their own decision. They accept the recommendation that they should grant, subject to conditions, consent under section 36 of the Electricity Act and make a direction under section 57(2) of the Planning Act that planning permission is deemed to be granted. Scottish Ministers Considerations – Economic Benefits 16. This application has been considered in the context of the benefit of the development to the national and local economy. It was considered that the development accords with Scottish Government policy to grow the Scottish economy and with Scottish planning policy. The environmental statement and supporting information estimates that at the peak of the demolition and construction phase, the on-site workforce will be around 1000 and that employment during the operational phase is expected to be around 50 full time positions supported by additional ancillary, part-time and contractor positions The Scottish Ministers’ Determination 17. The Scottish Ministers: (i) grant consent under section 36 of the Electricity Act 1989, for the construction and operation of an electricity generating station as described in Annex 1, subject to the conditions set out in Part 1 of Annex 2; and (ii) direct that in accordance with section 57(2) of the Town and Country Planning (Scotland) Act 1997 planning permission is deemed to be granted in respect of the development described in Annex 1, subject to the conditions set out in Part 2 of Annex 2, 18. The Scottish Ministers direct that section 58(1) of the Town and Country Planning (Scotland) Act 1997 is not to apply with regard to that planning permission because of the constraints of constructing a generating station with a capacity of over 50MW within 3 years, and that planning permission is to lapse on the expiry of a period of 5 years from the date of this direction if the development has not commenced within that period. 19. In accordance with the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000, the Company must publicise this determination for two successive weeks in the Edinburgh Gazette and one or more newspapers circulating in the locality in which the land to which the application relates is situated. 20. Copies of this letter have been sent to East Lothian Council, as the planning authority, and to the statutory consultees who made representations about this proposal. This letter has also been published on the Scottish Government website. 21. The Scottish Ministers’ decision is final, subject to the right of any aggrieved person to apply to the Court of Session for judicial review. Judicial review is the mechanism by which the Court of Session supervises the exercise of administrative functions, including how the Scottish Ministers exercise their statutory function to determine applications for consent. The rules relating to the judicial review process can be found on the website of the Scottish Courts: http://www.scotcourts.gov.uk/session/rules/print/rules/CHAP58.pdf. Local Citizens’ Advice Bureaus or a solicitor will be able to advise about the applicable procedures. Yours sincerely Simon Coote Head of Energy Consents and Deployment Unit A Member of Staff of the Scottish Ministers ANNEX 1 Description of the Development Pursuant to section 36 of the Electricity Act 1989, the Scottish Ministers hereby grant consent to the construction by ScottishPower Generation Limited (“the Company”), on the area of land delineated by a solid red line on Drawing Number 8740 (PL)001 Revision P - annexed hereto and duly endorsed on behalf of the Scottish Ministers of a Combined Cycle Gas Turbine (CCGT) generating station at Prestonpans, East Lothian (“the Development”), and to the operation of that generating station. Subject to condition (1) in paragraph 3 below, the Development shall be about1 1000 MWe capacity at ISO conditions and comprise: s; (a) up to two high efficiency combined cycle gas turbine units; (b) two new stacks (nominally 83 metres in height) located exterior to the existing generating station; (c) ancillary plant and equipment, and where required associated additional stacks for the auxiliary boiler plant at a maximum of 5 metres above the building roof height; (d) the alteration and conversion of the main and associated buildings to house the new CCGT plant; (e) the necessary buildings, civil engineering works and new car park; (f) a design which has the capability for extracting steam from the electricity generating cycle; (g) new pressure reduction station (PRS) for the CCGT gas supply; and (h) refurbishment of the existing seaward structures for continued operation, including the existing jetty, seawall and cooling water infrastructure. nes; 1 A tolerance of up to 5% is permitted ANNEX 2 CONDITIONS PART 1 This consent is granted subject to the following conditions: Conditions applying only to section 36 consent 1. The Development must be constructed and operated in accordance with the details contained in the description of the Development above and the application dated 9 December 2009, subject to such changes as may be approved by the Planning Authority pursuant to the requirements of the deemed planning permission. 2. The commencement of the Development must begin not later than Five years from the date of this consent. 3. The Company must not assign, alienate or transfer this consent without the prior written authorisation of the Scottish Ministers. Carbon Capture Readiness: Compliance with EU Law Requirements 4. Until such time as the Development is decommissioned, the Company must not, without the written consent of the Scottish Ministers: (a) dispose of any interest in land which includes the designated site; (b) do any other thing, or allow any other thing to be done or to occur, which may reasonably be expected to diminish the Company’s ability, within two years of such act or occurrence, to install and operate the capture equipment on the designated site. Carbon Capture Readiness: Review of compliance 5. The Company must make a report to the Scottish Ministers: (a) on or before the date on which three months have passed from the completion of the commissioning of the Development; and (b) within one month of the second anniversary, and each subsequent even-numbered anniversary, of that date. or (2) The report must provide evidence that the Company has complied with condition 4 : (a) in the case of the first report, since this consent was granted; (b) in the case of any subsequent report, since the making of the previous report, and explain how it expects to continue to comply with condition 2 over the next two years. (3) If the Company considers that some or all of the technology referred to in the current CCS proposals will not work, this conclusion, and the reasons for it, must be stated in the report. (4) The report must identify any other impediment of which the Company is aware, as a result of which it considers that any aspect of what is proposed in the current CCS proposals is unlikely to be technically feasible. (5) A report which identifies an impediment must state, with reasons, if the Company considers it technically feasible to overcome the impediment using revised CCS proposals, and, if so, include such proposals. (6) The report must state, with reasons, whether the Company has decided to seek any additional regulatory clearances, or to modify any existing regulatory clearances, in respect of its current CCS proposals in the period referred to in condition 5(2)(a) or (b) as appropriate. (7) This condition ceases to have effect if the capture equipment is installed or the Development is decommissioned or if the Scottish Ministers so agree in writing. Carbon Capture Readiness: Compliance with Scottish Government Policy 6. Following the publication of a report made under section 5(2)(a) of the Energy Act 2010 which concludes that the CCS technology relevant to a CCGT Plant has been successfully demonstrated on a commercial scale, the Company must submit applications for the consents required to retrofit carbon capture and storage technology on all of the station’s generating capacity ("necessary applications") . The first application must be submitted within 2 years of Scottish Ministers notifying the Company of the publication of the report, or within any other timescale as may be agreed by Scottish Ministers. The electricity generating station must cease to operate if the first application is not submitted within this 2 year period, or within any other timescale agreed by Scottish Ministers. Interpretation The following definitions apply for the purposes of Part 1 of this Annex. “capture equipment” means the plant and equipment required to capture the target carbon dioxide and identified as such in the current CCS proposal; “CCS proposal” means a proposal for the capture, transport and storage of the target carbon dioxide, which identifies the proposed capture technology, transport route and storage location; “current CCS proposal” means: (i) the CCS proposal set out in the feasibility study and assessed as technically feasible by Scottish Ministers; (ii) if a revised CCS proposal has been identified under condition 3(5), the proposal which has been most recently so identified; “Company” means ScottishPower Generation Limited. “designated site” means the internal and external areas outlined in red and green respectively on Figure 4a of the feasibility study as the areas where the Company proposes to locate the capture equipment; “feasibility study” means the document entitled Cockenzie Combined Cycle Gas Turbine Power Station Carbon Capture Ready (CCR) Feasibility Study Issue No 3 and dated 30 November 2009 and the letter from URS to SEPA dated 3 November 2010; “Planning Authority” means East Lothian Council as a planning authority in exercise of its powers under the Town and Country Planning (Scotland) Act 1997 and its successors. “target carbon dioxide” means as much of the carbon dioxide emitted by the development when it is operating at full capacity as it is reasonably practicable to capture for the purposes of permanent storage, having regard to the state of the art in carbon capture and storage technology. PART 2 Conditions applying only to the Deemed Planning Permission The Site 1. The construction of the Development must only take place within the boundary of the site. Reason: to ensure that no construction takes place beyond the boundary of the area which is the subject of this planning permission. Time Limits 2. The commencement of the development must begin before the expiration of five years from the grant of consent. Reason: to comply with the requirements of section 58 of the Town and Country Planning (Scotland) Act 1997 and ‘Thermal Power Stations in Scotland: Guidance and Information on Section 36 of the Electricity Act 1989 under which Scottish Ministers determine consents relating to thermal power stations’ (March 2010). Environmental Statement 3. Other than as varied by the following conditions or as otherwise agreed in writing with the Planning Authority, the development must be constructed, and operated in accordance with the environmental statement and the mitigation measures therein. Reason: to ensure that the reported likely environmental impacts of the development are not exceeded and the mitigation measures are put in place. Environmental Manager 4. (1) Prior to the commencement of the development, the Company must appoint an appropriately experienced and qualified Environmental Manager (“EM”) in consultation with the planning authority and Scottish Natural Heritage (“SNH”). The EM must be in post at least throughout the demolition and construction phase. The scope of work of the EM must include: (i) monitoring compliance with the mitigation measures within the environmental statement and the conditions of this consent, in particular the Construction Environmental Management Plan; and (ii) advising the Company on adequate protection of nature conservation interests on the site. Reason: to minimise environmental impacts during the demolition and construction phase. Protected Species 5. (1) There must be no commencement of the development until an ecologist has carried out a further protected species survey and based on the findings of this survey, the Company must submit a Protected Species Management Plan for the approval of the Planning Authority in consultation with SNH. This management plan must include further mitigation measures designed to safeguard any protected mammals within the operational areas of the site. During the demolition and construction phase of the development, regular monitoring of the mammal mitigation measures in the management plan must be carried out by the EM, or their representative to ensure the mitigation is carried out to the written satisfaction of the Planning Authority. (2) Should such survey or ongoing monitoring work identify impacts from any part of the works proposed for this development on European Protected Species (“EPS”), Scottish Ministers and SNH are to be informed. No work which could cause disturbance to EPS may go ahead unless a licence is obtained from the Scottish Ministers. (3) Subject to the discovery of any EPS, if the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the survey (or if required the management plan) or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the details have been approved. The development shall be implemented in accordance with the approved details. Reason: to minimise disturbance to protected species during the demolition and construction phase. Layout and Design 6. (1) Except for the permitted preliminary works, the commencement of the main development must not take place until the following details, including proposed timescales, have been submitted to and approved in writing by the Planning Authority, after consultation with SNH: (i) A schedule of materials and finishes and samples of such finishes for the new build components of the development shall be retained following the final commissioning of the development, including ground surfaces and boundary enclosures. Notwithstanding the foregoing, the two proposed new stacks, once constructed, must have a matt finish; (ii) The siting, design, external appearance and dimensions of all buildings and structures to be erected and retained following the final commissioning of the development; (iii) The proposed levels of any earthworks, the design of permanent fencing, planting plans, written specifications (including cultivations and other operations associated with vegetation re-establishment), schedules of plants (noting species, plant sizes and proposed numbers/densities) along with implementation timetables. (2) If the Planning Authority has not confirmed to The Company in writing within 28 days of the initial receipt of details referenced in paragraphs (i), (ii), (iii), or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, then the Company shall be entitled to assume that no further details are required. (3) The development must be completed in accordance with the approved details and approved timescales unless any variation is approved in writing by the Planning Authority. Reason: to enable the Planning Authority to exercise reasonable and proper control over the design and appearance of the new build elements of the development. 7. (1) Except for the permitted preliminary works, the commencement of the development must not take place until the following details, including proposed timescales, have been submitted to and approved in writing by the Planning Authority, after consultation with SNH: (i) The siting, design, external appearance and dimensions of all buildings and structures to be erected and used during the demolition and construction phase of the development (other than buildings and structures forming part of the permitted preliminary works); and (ii) Details of vehicle circulation roads, junctions, parking, hardstanding and turning facilities required only during the demolition and construction phase of the development. If the Planning Authority has not confirmed to the Company in writing within 28 days of initial receipt of details referenced in paragraphs (i) and (ii), or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and, if so, the nature of that information, then the Company shall be entitled to assume that no further details are required. (2) (3) The development must be completed in accordance with the approved details and approved timescales unless any variation is approved in writing by the Planning Authority. Reason: to enable the Planning Authority to exercise reasonable and proper control over the design and appearance of the new build elements of the development. Construction Environmental Management Plan 8. (1) Except for the permitted preliminary works, the commencement of the development must not take place until a Construction Environmental Management Plan (“CEMP”) has been submitted to and approved in writing by the Planning Authority, after consultation with SEPA and SNH. The CEMP must include the following: (i) An Air Quality and Dust Management Plan for minimising the emission of dust during the demolition and construction phase of the development. The dust management plan must specify the means by which dust shall be monitored and suppressed; (ii) A Construction Noise Management Plan, covering the demolition and construction phase of the development, prepared in accordance with BS5228 Parts 1 and 2:2009 and Part 4:1992; Noise and Vibration Control on Open Sites. The Construction Noise Management Plan must include (1) the means to ensure that noise generated by the construction complies with the guidance set out in the relevant British Standard, (2) the exact locations from which noise and vibration must be monitored; (3) the method of noise and vibration measurement; (4) details of any mitigation measures to be implemented; (5) the procedures for dealing with any complaints regarding noise and vibration, which must reflect the terms of condition 13 below; (iii) Details of arrangements for non-vehicular access management during the demolition and construction phase of the development, including the temporary diversion of the John Muir Way; (iv) A Peregrine Management Plan which must include the relocation of the nest box to a site outwith the construction/demolition areas, a timetable for relocation and the carrying out of a demolition/construction breeding survey by an ornithologist; and (v) A groundwater and surface water monitoring plan, setting out the steps that must be taken to monitor the levels and quality of groundwater and surface water during the demolition and construction phase of the development. The monitoring plan must include the locations, frequency and details for the reporting of monitoring information. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the CEMP or such other period as may be agreed to writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the details have been approved. The development shall be implemented in accordance with the approved details unless otherwise agreed with the Planning Authority in writing. Reason: to monitor the water environment, to minimise the impact of noise, dust and construction vehicle movements, and to protect peregrine falcons, during the demolition and construction phase of the development. 9. The works associated with the demolition and construction phase of the development must be implemented in such a way that PM10 emissions arising from the development do not exceed the Scottish Government’s Air Quality Objectives for the PM10 annual mean of 18µg/m3 or the PM10 24hour mean of 50µg/m3 (not to be exceeded more than 7 times a year). Reason: to ensure that concentrations of PM10s are controlled such that the Scottish Government’s Air Quality Objective PM10 annual mean of 18µg/m3 will not be exceeded. Site Waste Management Plan 10. (1) Except for the permitted preliminary works, the commencement of the development must not take place until a Site Waste Management Plan (“SWMP”) has been submitted to and approved in writing by the Planning Authority, after consultation with SEPA. The SWMP must include the following: (i) The types and quantities of waste expected to arise during the demolition and construction phase of the development; (ii) Details of the waste management measures to be implemented, during the demolition and construction phase, including the steps to be taken to maximise the quantity of waste to be reduced, re-used and recycled; (iii) is The identification of the contractors to be used to ensure the waste correctly recycled or disposed of responsibly and legally; (iv) Information on how the quantity of waste will be measured; and (v) Identification of responsible personnel. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the SWMP or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the SWMP have been approved. The Development shall be carried out in accordance with the approved SWMP unless otherwise agreed with the Planning Authority in writing. Reason: in order to minimise waste during demolition and construction and to ensure that it is properly managed. Construction Noise and Vibration 11. Notwithstanding the terms of condition 8 above, the Company must in all activities associated with the demolition and construction phase of the development, use the best practical means to minimise noise, with reference to guidance detailed in BS5228 2009: ‘Noise and Vibration Control on Construction Sites’ (Part 1). 12. During the demolition and construction phase of the development, noise levels at the facades of noise sensitive properties, to be agreed with the Planning Authority, which are associated with the demolition and construction activities, should be measured according to the agreed monitoring scheme referred to in condition 8. This must not exceed 65dB LAeq, between 0700 and 1900 hours from Monday to Friday and between 0700 and 1300 hours on Saturday, and 55dB L Aeq during the period 1900 to 2200 hours from Monday to Friday, with no working associated with demolition and construction activities audible at the site boundary outwith these hours unless otherwise agreed by the planning authority in writing or in an emergency. Subject to prior written approval by the planning authority, a higher daytime noise limit of 70dBLAeq will be permitted for short duration works such as soil stripping or bund formation. For the purposes of this condition, “noise sensitive properties” means the façade of those residential dwellings which exist at the date of this consent and which are occupied or utilised during the hours referred to above. Reason: to minimise the impact of noise during the demolition and construction phase of the development. 13. In the event of the Company receiving a complaint concerning noise emission from the site during the demolition and construction phase of the development, the Company must immediately notify the Planning Authority in accordance with the specific procedures to be approved in terms of the Construction Noise Management Plan referred to in condition 8. In such cases, and in cases where the complaint is received directly by the Planning Authority and brought to the attention of the Company, the Company must immediately undertake an investigation in consultation with the Planning Authority and initiate any necessary mitigating measures within the site as agreed in writing with the Planning Authority. The specific site activity giving rise to the cause of the complaint must thereafter be carried out in accordance with the agreed mitigation measures. Reason: to ensure that noise complaints are investigated and any mitigation measures implemented. 14. There must be no sheet or driven piling for any seaward development from 1 October to 31 March inclusive unless otherwise approved in writing by the Planning Authority, after consultation with SNH. Reason: to protect the marine environment within the Firth of Forth Special Protection Area and Ramsar Site. Wheel Cleansing 15. (1) The permitted preliminary works must not take place until there has been submitted to, and approved in writing by, the Planning Authority, a scheme for the provision of wheel cleansing facilities for construction traffic. The scheme must include a timescale for implementation. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the scheme or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and, if so, the nature of that information, the Company shall be entitled to assume that the details have been approved. The development shall be implemented in accordance with the approved details unless otherwise agreed with the Planning Authority in writing. (3) The approved wheel cleansing facilities must be installed and maintained throughout the demolition and construction phase of the development, unless any variation has been approved in writing by the Planning Authority. 16. All construction traffic leaving the site must, prior to leaving, pass through the wheel cleansing facilities to be provided pursuant to condition 15, unless otherwise approved in writing by the Planning Authority. Reason: to ensure that satisfactory measures are in force to minimise the impact of mud on the public road. Sheeting of HGVs 17. All open bodied HGVs carrying dry loose aggregate, cement or soil into and out of the site must be sheeted. Reason: to ensure that satisfactory measures are in force to minimise the impact of dust on the local environment and public roads. Green Travel Plans 18. (1) Prior to the commencement of the development, a Green Travel Plan in respect of the demolition and construction phase of the development must be submitted to, and approved in writing by. the planning authority. The Green Travel plan must include the following measures: (i) measures to minimise dependency on the private car for travel to and from the site; and (ii) measures to ensure that the morning and evening construction traffic peaks associated with the development do not coincide with the morning and evening network peaks, unless otherwise approved in writing by the Planning Authority. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the Green Travel Plan, or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the Green Travel Plan has been approved. (3) The development must be carried out in accordance with the approved Green Travel Plan unless otherwise approved by the Planning Authority in writing. Reason: to minimise the environmental impact of travel and transport as a result of the demolition and construction of the development. 19. (1) Prior to the final commissioning of the development, a Green Travel Plan in respect of the operational phase of the development ("Operational Green Travel Plan") must be submitted to, and approved in writing by, the Planning Authority. The plan must include measures to minimise dependency on the private car for travel to and from the CCGT power station within the site. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the Operational Green Travel Plan, or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the details have been approved. (3) The Company must implement the Operational Green Travel Plan as approved unless otherwise agreed by the Planning Authority in writing. Reason: to minimise the environmental impact of travel and transport as a result of the operation of the development. Traffic Management Plan 20. (1) Prior to the commencement of the development, a Traffic Management Plan (“TMP") must be submitted to the Planning Authority for approval in consultation with Transport Scotland. (2) The TMP must include the following: (i) Method Statements detailing access routes to and from the site for large components and day-to-day deliveries associated with the construction phase of the development. The Method Statement must include a swept path assessment of large component delivery routes, as well as frequencies and times of deliveries and arrangements for the removal of materials/plant from the site. The Method Statement must also include details of any off-site mitigation works; (ii) Details of proposed accesses onto the B1348 for HGV traffic, including consideration of traffic signals; (iii) Details of the temporary construction car park. Access to the car park from the public road must be detailed and controlled through the TMP; (iv) Details of the design and specification of required amendments to the Alder Road Roundabout to facilitate the new construction access road to the B1348. The junction linking the new construction access road and the Alder Road Roundabout must be designed in accordance with the Design Manual for Roads and Bridges; and (v) Arrangements for accessing the temporary construction car park. (3) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the TMP or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information the Company shall be entitled to assume that the TMP has been approved. (4) The development must be carried out in accordance with the approved TMP, unless otherwise approved by the Planning Authority in writing. Reason: to minimise the impact of construction traffic on the local road network and local road users. 21. Prior to the commencement of the development, proposals for new and altered road junctions must be submitted to the Planning Authority for approval. The development must be carried out in accordance with the approved details unless otherwise approved by the Planning Authority in writing. Reason: to retain effective control over the new and altered junctions. 22. (1) There must be no commencement of the development until the Company has entered into an agreement with the Planning Authority under section 96 of the Roads (Scotland) Act 1984 regarding any extraordinary expenses which will be incurred by the roads authority in maintaining the Road by reason of damage caused to it by excessively heavy, or other extraordinary, vehicles or traffic engaged in the works to be carried out during the demolition and construction phase of the development. (2) The agreement must provide for: (i) the undertaking of a joint initial inspection of the Road, in both directions and the preparation by the Company of a written and photographic record of its condition; (ii) the issuing of a notice of the repair amount by the Planning Authority to the Company at the end of each relevant repair period; (iii) a mechanism to allow for challenge of the repair amount; (iv) the payment of the repair amount by the Company; and (v) the undertaking of further inspections of the Road and the preparation of written and photographic records of its condition at the end of each relevant repair period. Reason: in the interests of road safety and to ensure the satisfactory reinstatement of the public road network. Combined Heat and Power (CHP) 23. (1) Prior to the final commissioning of the development, an updated Combined Heat and Power (CHP) Feasibility Review assessing potential commercial opportunities for the use of waste heat from the Development shall be submitted to and approved in writing by the Planning Authority in consultation with SEPA. (2) This Review shall provide for the ongoing monitoring and full exploration of potential commercial opportunities to use heat from the Development as part of a good Quality CHP scheme (as defined in the CHPQA Standard issue 3) (as may be amended or replaced from time to time but subject to compliance with any amended or replacement standard remaining technically feasible). The Review shall generally follow the approach within the Combined Heat and Power (CHP) Feasibility Study prepared by URS dated 26 November 2009. Where commercially viable opportunities for the use of heat in such a scheme are identified by the Company, a scheme for the provision of the necessary plant and pipework to the boundary of the Site, including a timetable for installation, must be submitted to and approved in writing by the Planning Authority. (3) The timetable for installation shall take account of the demand for the heat. Any plant and pipe-work installed to the boundary of the Site must be undertaken in accordance with the approved scheme. (4) If no commercially viable opportunities for the use of waste heat are identified prior to the final commissioning of the Development, the Combined Heat and Power (CHP) Feasibility Review must be undertaken at 2 yearly intervals thereafter until such time as the Planning Authority is satisfied that there are no feasible options for a good Quality CHP scheme within the vicinity of the Site. (5) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the Review, or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the Review has been approved. Reason: to ensure waste heat is available for use to the benefit of local domestic, commercial and industrial users if a demand exists and supply is technically feasible and economically viable. 24. (1) The development must be designed to ensure that it does not preclude the installation and operation of a Good Quality CHP scheme. Prior to the commencement of the development, the Company must demonstrate to the satisfaction of the Planning Authority that nothing in the proposed development’s design, construction and operation will preclude the installation and operation of a Good Quality CHP scheme deriving its heat source from the development. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the submission, or such other period as may be agreed to in writing with the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the submission has been approved. Reason: to ensure that the development is designed to facilitate the use of waste heat in the event that a demand exists and supply is technically feasible and economically viable. Archaeology 25. There must be no commencement of the development until the Company has, through the employment of an archaeologist or archaeological organisation, secured the implementation of a Programme of Archaeological Works (Evaluation and Metal Detecting Survey) on any areas of ground disturbance associated with the development, including temporary compounds and haul roads, in accordance with a written scheme of investigation which the Company must submit to and have approved in advance by the Planning Authority. Reason: to facilitate an acceptable archaeological investigation of the site. Removal of Coal Conveyor 26. (1) Prior to the final commissioning of the development, a programme of works for the dismantling and removal of the coal conveyor system and all supporting infrastructure within the site must be submitted to and approved in writing by the Planning Authority. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the programme of works or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the details have been approved. The development shall be implemented in accordance with the approved details. The dismantling and removal works shall be carried out in accordance with the approved programme unless otherwise agreed with the Planning Authority in writing. Reason: to ensure that the redundant coal moving apparatus is removed from the site after the cessation of coal-fired electricity generation. Reinstatement following Construction 27. Unless otherwise agreed in writing with the Planning Authority, the land used temporarily for construction purposes (including temporary access and car parking, contractors’ cabins, and the lay down and storage of construction materials and plant) must be reinstated to its former condition within 36 months of the final commissioning of the development. For the purposes of this condition, “former condition” means its condition immediately preceding the commencement of development. Reason: to ensure that the temporary buildings are removed and the land reinstated when no longer required for construction purposes. Cessation of Generation and Restoration of the Site 28. (1) Within 12 months of the site ceasing to be used permanently for the purposes of electricity generation, the Company must submit to the Planning Authority, for approval in writing, a scheme for the demolition and removal of the development from the site ("Demolition and Restoration Scheme"). (2) The Demolition and Restoration Scheme must provide for: (i) details of all structures and buildings which are to be demolished; (ii) details of the means of removal of materials resulting from the demolition; (iii) the phasing of the demolition and removal; (iv) details of the restoration works; and (v) the phasing of the restoration works. (3) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the Demolition and Restoration Scheme, or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the details have been approved. (4) The demolition and removal of the development and subsequent restoration of the site must thereafter be implemented in accordance with the Demolition and Restoration Scheme as approved unless any variation has been approved in writing by the Planning Authority. Reason: to ensure that the site is restored after the cessation of electricity generation. Removal of Chimney Stacks 29. (1) Prior to the final commissioning of the development, the Company must submit to the Planning Authority for approval in writing, a timetable for the demolition and removal of the two existing 149 metre high chimney stacks. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the timetable or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information, the Company shall be entitled to assume that the timetable has been approved. (3) The demolition and removal of the chimneys must thereafter be implemented in accordance with the timetable as approved unless any variation has been agreed in writing by the Planning Authority. Reason: to ensure that the chimney stacks are removed after they are no longer required in association with coal-fired electricity generation. Flood Prevention Measures 30. (1) Except for the permitted preliminary works, the commencement of the main development must not take place until measures to protect the low lying areas to the north-east of the site and south-west of the existing defences from inundation from the Forth Estuary have been submitted to and approved in writing by the Planning Authority in consultation with SEPA. The measures must include the following: (i) details of the areas in which any mitigation is to be undertaken together with the nature of the measures themselves; (ii) and details of the materials to be used and their colours and finishes; (iii) details of the implementation timetable for the works. (2) If the Planning Authority has not confirmed to the Company in writing within 28 days of the initial receipt of the last of the details required in terms of (i)-(iii) above or such other period as may be agreed to in writing by the Company, whether any further information is reasonably required and if so, the nature of that information the Company shall be entitled to assume that the details have been approved. The Development shall thereafter be completed in accordance with the approved details and approved timescales unless any variation has been approved in writing by the Planning Authority. Reason: to ensure that the mitigation measures are in place to manage the risk of the overtopping of flood defences in extreme events. Interpretation of Part 2 Unless the context otherwise requires, the following definitions apply for the purposes of Part 2 of this Annex— "application" means the application for section 36 consent and deemed planning permission in respect of the development made to Scottish Ministers by the Company and dated 9 December 2009; "commencement of the development" means the date on which the development must be taken to have been initiated in accordance with section 27 of the Town and Country Planning (Scotland) Act 1997; "Company" means ScottishPower Generation Limited; "construction traffic" means traffic engaged in the transportation of material, plant and machinery associated with the works being undertaken during the demolition and construction phase s of the development (excluding private cars and other vehicles used to carry workers to and from the site); "development" means the development described in Annex 1 of this consent; "due proportion" means the proportion of the costs of the repair of the road representing extraordinary expenditure (having regard to the average expense of repairing other similar roads in the administrative area of the Planning Authority ("adjoining highway") incurred by the Planning Authority by reason of damage to the road caused by excessively heavy or extraordinary vehicles engaged in the demolition and construction works associated with of the development. In assessing and determining such proportion regard is to be had to: (i) the use, if any, of the road caused by excessively heavy or other extraordinary vehicles which have no connection with the development; (ii) the amount by which the costs of repair per kilometre of Road during the relevant repair period exceed the costs of repair per kilometre incurred in respect of the adjoining roadway; and (iii) any period during a relevant repair period during which demolition and construction works associated with of the development were not taking place; "emergency" means circumstances in which there is reasonable cause for apprehending imminent injury to persons, serious damage to property or serious danger of pollution to the environment; "environmental statement" means the environmental statement produced in accordance with the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000 which accompanied the application; "final commissioning of the development" means the date on which the development first supplies electricity on a commercial basis, except such electricity generated during the commissioning phase; "the main development" means the construction work which begins with the installation of the new enclosure to house the CCGT units; "permitted preliminary works" means: (i) survey and geotechnical surveys; (ii) the erection of temporary fencing on the site; (iii) service diversions; (iv) the provision of wheel cleansing facilities pursuant to condition 15; and (v) the provision of temporary contractors’ facilities and relocation of existing site offices and welfare facilities. "Planning Authority" means East Lothian Council as planning authority in exercise of its powers under the Town and Country Planning (Scotland) Act 1997 and its successors; "relevant repair period" means each period of 12 months beginning with the commencement of development or such other period of time as may be agreed in writing with the Planning Authority; "repair amount" means the due proportion in respect of each relevant repair period; "Road" means the A198/B1361 roundabout junction to the Site, the B6371 north to East Lorimer Place (including the Alder Road roundabout junction) and the B1348 from the B6371 East Lorimer Place junction west over the site frontage; as shown delineated in red on the plan annexed hereto or such roads as may be specified in terms of the Traffic Management Plan; "site" means the area of land described in Annex 1 to this consent. ANNEX 2 Summary of Consultation Responses East Lothian Council (ELC), the relevant planning authority, took the application to a specially convened public meeting/planning committee on 20 April 2010 with a recommendation from the Environmental/Planning Officer that members should submit a holding objection to the proposal conditional on the submission of further information. The Environmental/Planning Officer notes in this report that should the information submitted be to the satisfaction of ELC, and subject to the application of a range of conditions, the proposal would then be satisfactory to ELC. Elected members, however, voted at this committee (at a vote of 12 to 6) to reject the recommendation of the Environmental/Planning Officer and to object to the principal of converting Cockenzie from a coal-fired station to a gas-fired station. This formal objection was received by officials in June 2010 and detailed the ELC objection to the proposal on the following grounds: There is a lack of clear evidence in the ES as to the nature, scale and cumulative impact of the potential environmental effects of the proposed development during its demolition and construction phases. The baseline daytime noise levels for the receptors at Whin Park and Cedar Road, Cockenzie appear unreasonably high It has not been demonstrated that the demolition and construction activities can be controlled such that the Scottish Government’s Air Quality Objective PM10 annual mean objective of 18ug/m3 will not be exceeded The Transport Assessment has not undertaken an assessment of the Bankton Junction (A1) and the A198/B1361 roundabout junction or taken account of traffic related to the committed Blindwells new settlement The Transport Assessment has no undertaken junction capacity assessments The cumulative adverse impacts on communities have not been adequately addressed There is no commitment to providing a Combined Heat and Power system, although experts regard this as essential from new gas-fired power stations. In accordance with paragraph 2(2) of Schedule 8 to the Electricity Act 1989, a public inquiry was called due to the objection from the ELC. However, as the process to hear this Inquiry was underway the Company continued its dialogue with ELC, providing clarifying information. In December 2010 ELC voted to withdraw all 7 objections to the proposed plant and this information was passed to the Reporter to be considered alongside other evidence at the public inquiry. Scottish Natural Heritage (“SNH”) provided detailed comments on the potential impacts on the Firth of Forth SPA and Ramsar site, the Isle of May SAC and the Firth of Forth SSSI as well as comments on Ash Lagoon Management, European protected species, coastal processes, air quality and landscape and visual impacts. Firth of Forth SPA and Ramsar Site SNH noted that the proposal was likely to have a significant impact on the qualifying interests of the Firth of Forth Special Protection Area (“SPA”). SNH assessed this potential impact based on the information provided and concluded that if the proposal was undertaken strictly in accordance with conditions provided then the proposal would not adversely affect the integrity of the sites. SNH carried out this assessment on wintering populations of bird species identified under Annex 1 of the Habitats Regulations as well as internationally migratory bird species. Scottish Ministers accept the findings of SNH in this regard. Ash Lagoon Management SNH noted that a consequence of the change in operating process from coalbased fuel to gas will be the cessation of ash as a by-product. Part of the Musselburgh Ash Lagoons, and in particular Lagoon 8, is within the Firth of Forth SPA. The lagoons provide an important roosting and feeding location for a number of SPA qualifying species. SNH noted that the creation and management of the Musselburgh Ash Lagoons was overseen by the Scottish Environmental Protection Agency (“SEPA”) through a Pollution Prevention and Control permit but requested that a meeting be held between Scottish Ministers, SEPA Scottish Power and SNH to discuss a future management strategy for the Ash Lagoons, outwith the section 36 process. Such a meeting will take place during PPC considerations. Isle of May SAC SNH noted that the proposal was likely to have a significant effect on the qualifying interests of the Isle of May Special Area of Conservation and that an appropriate assessment into the conservation objectives of the site was necessary. SNH further advised that they had considered the impacts of the proposals on the grey seal population and reef habitats, based on the information provided, and had concluded that the proposal would not adversely affect the integrity of the site. Scottish Ministers accept the findings of SNH in this regard. Firth of Forth SSSI SNH advised that the proposal would not have an adverse impact on the Firth of Forth Site of Special Scientific Interest subject to the application of conditions recommended for the Firth of Forth SPA. European Protected Species SNH noted that there would be no adverse effects on the favourable conservation status to any cetaceans during the works but recommended the mitigation proposed in the Marine Noise Impact Assessment Report is set out as a condition to any consent. This has been applied at Annex 2. SNH also noted that they welcomed the Peregrine Management Plan to avoid disturbance to peregrine falcons as they have been recorded on the proposed development site and it is an offence to intentionally or recklessly disturb the birds. Coastal Processes SNH noted they were content with the methodology applied by the Company in the environmental statement and concurred with the conclusions of shortterm minor adverse impacts for the construction phase of the development and long term minor adverse impacts for the operational phase. Air Quality SNH noted that they were content with the methodology followed to assess air quality impacts and welcomed the substantial reduction in nitrogen deposition and the reduction in sulphur emission. Landscape and Visual Impacts SNH noted that the proposed development would have temporary local adverse impacts on local landscape characters and visual amenity. Upon consideration of all the above SNH concluded that the proposal could proceed without adversely affecting the integrity of any Natura sites, provided that conditions requested by SNH be attached to any consent. These conditions are reflected in Annex 2. The hydrological impacts of the development have been assessed by SEPA who provided detailed comments in their consultation response. SEPA noted that they had no objection to the principle of the development but noted that the conditions they suggested should be attached to any consent as they were essential to the acceptability of the development and complementary to their regulatory control. SEPA also made specific comments on carbon capture readiness, combined heat and power, air quality, noise, flood risk, the protection of groundwater, the protection of the marine environment, surface water drainage, contaminated land and construction-phase environmental management including detailed advice to the developer on each point. SEPA assessed the carbon capture readiness feasibility study (assessed against the Department of Energy and Climate Change guidance note in advance of the publication of the Scottish Thermal Guidance) and advised Scottish Ministers to request clarifying information from the developer in this regard. This information related to: Wastewater treatment The ability of the plant to use alternative capture solvents A more detailed justification for the use of a standalone re-boiler system Space available for instrument air compressors Scottish Ministers advised the Company of SEPA’s request for more information and the Company continued to work with SEPA to provide the information necessary for SEPA to assess the proposal against the current guidance. In December 2010 SEPA confirmed that the information supplied was sufficient and that they were now fully satisfied on all aspects of the application. The Royal Society for the Protection of Birds (“RSPB Scotland”) provided consultation comments and officially objected to the proposal. This objection was on the grounds of serious concerns about the indirect contribution the plant would have to environmental degradation from an extended period of unabated greenhouse gas emissions arising from gas-fired generation. RSPB Scotland contended that the current proposal was contrary to Scottish Government policy which acknowledges that the electricity sector must be virtually decarbonised by 2030. RSPB Scotland noted that they would be prepared to review their position should an appropriate mechanism be secured that would required carbon dioxide emissions from Cockenzie to be less than 300g/kWh and this objection has been maintained. Civil Aviation Authority Airspace Policy (“CAA”) noted that the various proposed structures would not formally constitute an aviation en-route obstruction but noted the relative close proximity of BAA Edinburgh and that the planning authority’s responsibility to check any safeguarding maps lodged with them to identify any aerodrome specific safeguarding issues. CAA also noted that: Should the power station plan to vent or flare gas, either routinely or as an emergency procedure, further discussion with CAA would be required The position of the Ministry of Defence on the proposal should be sought Any structure of 300 feet or more in height must be charted on aviation maps and the details of the development should be provided to the Defence Geographic Centre Historic Scotland noted that there would not be a significant adverse impact on the setting of the scheduled monuments and category A listed buildings in the vicinity of the development. They specifically noted that although the power station is prominent in some views from Cockenzie House Garden and Designated Landscape and would be visible from some areas of Seton House Palace Garden and Designated Landscape, that they were content that the level of changes proposed was not sufficient to cause a significant adverse impact on the settings of these assets. Marine Scotland noted that they would like to ensure that the Salmon (Fish Passes and Screens) (Scotland) Amendment Regulations 2003 were adhered to whereby fish screens are maintained at all times. Marine Scotland also noted that they would welcome construction work avoiding fish migratory periods but had no objection to the proposal. The Health and Safety Executive commented that given a hazardous substances consent (“HSC”) was not required for any future CCS plant at Cockenzie they had no specific advice on HSC but noted that the Company should consider whether the possible storage of oils and fuels onsite would require an HSC. This advice was passed to the Company but as this relates to a consent outwith the section 36 regime, no further action was taken. Defence Estates had no safeguarding objections to the development but commented that the height of the development would necessitate the amendment of aeronautical charts and mapping records and the developer must supply details of the development to Defence Geographic & Imagery Agency prior to its commencement. The Coal Authority commented that the site had been subject to past coalmining activities and as such there may be instability, gas, drainage and safety issues. The Coal Authority noted that wherever possible removing any remnant shallow coal should be considered. The Coal Authority advised that they had no objection to the proposal but that the Company should be reminded that any intrusive activities which intersect, disturb or enter any coal seams, coal mine workings or coal mine entries (shafts and adits) require written prior permission of the Coal Authority. This information was passed to the Company. WWF Scotland objected to the proposal on the grounds that it is not consistent with the Scottish Government aim to largely decarbonise the power sector by 2030, that the plant does not demonstrate carbon capture and storage and that the proposals do not make use of waste heat. These issues have been considered by Ministers and conditions in relation to both issues have been attached to the consent. Cockenzie and Port Seton Community Council submitted a detailed report objecting to the proposed development. This objection was on the grounds of emissions, socio-economics, health and safety and traffic. The content of this report was forwarded to both the Company and ELC for their consideration. Prestonpans Community Council supported the application but requested the application of a condition stating that Prestonpans Community Council and ELC are involved in discussions on future of the land currently used by the community which is owned by the Company. As these concerns do not relate to the proposal under consideration, they have been fed back to East Lothian Council for their consideration and any action they considered appropriate at their Planning Committee. The following bodies had no objection and no comments to make on the proposal: Crown Estate, Scottish Government SEPA Sponsorship Team, Scottish Government Ports and Harbours Branch, Scottish Government Directorate for the Built Environment, Scottish Government Air, Noise and Nuisance Team (with responsibility for Large Combustion Plants), CAA Aerodrome Standards, the Mountaineering Council of Scotland, NERL Safeguarding and the Forestry Commission Scotland.