Review of the Scoping Report indicates three major factors that must inform any consideration of this application.  These are as follows:

  1. Section 1.4 of the Report describes the general policy supporting the development of more energy from waste (EFW) capacity, but fails to justify any overriding need for a plant of this capacity in this area.  What is the demand for additional capacity in the vicinity of the proposed site, would a smaller (and less intrusive) plant not make a sufficient contribution to meet the requirement in the area, and what guarantee is there that sufficient fuel will be available throughout the planned life of the plant?  It also appears counter-intuitive that the burning of man-made waste that produces CO2 can be classified as ‘renewable’ energy. The IPC must judge “whether any adverse impact on the landscape would be so damaging that it is not offset by the benefits (including need) of the project” (NPS).
  2. VISUAL IMPACT. It is clear from initial comments that the visual impact of an isolated 55 metre high structure with two 90-100 metre high chimneys on rising ground in what is effectively open countryside is one of the key concerns associated with this application and makes the choice of location a very sensitive one.  The recycling site next to the proposed development is well screened, of low rise construction, relatively small in scale and unobtrusive, so this cannot be characterised as a pre-existing major industrial site, unlike those chosen for similar developments.  All potential impacts on the visual amenity of this essentially rural area and the effect on views from surrounding settlements and vantage points, both nearby and further away, must be considered in detail, and any assessment must be made when the impact is likely to be greatest; i.e. in winter when there is no leaf cover on the trees.
  3. LOCAL INPUT. The preliminary assessment in the Scoping Report has been carried out by external consultants, and it is apparent from the omissions and errors in the Report highlighted in the detailed comments that the failure to seek information from those living locally has led to a lack of understanding of a range of issues associated with this proposal.  Any detailed assessment must therefore engage positively with nearby communities and take full advantage of local knowledge and experience in order to provide a comprehensive overview of all the implications of the proposal.

Detailed comments from Longparish Parish Council are given in the table below and linked with the relevant paragraphs in the Scoping Report: 

Document section

Para Ref


1 Introduction

1.1 Background


What is the minimum guaranteed output of the proposed facility?


The sources of waste should be clearly identified, as these will have a material impact on the scope of the EIA and the level of analysis required. Alignment with national, regional and local waste policies should be demonstrated.

The positive contribution towards the Government’s commitment to carbon emission reductions needs to be demonstrated and balanced against the increase in emissions associated with anticipated transport of waste to the facility, and IBAA out of the facility.

1.2 Consenting and Regulatory Regime


The EIA should clearly demonstrate that the minimum guaranteed gross output is greater than 50MW and that security of feedstock exists for the duration of the proposed operational life of the facility to maintain this output.

1.3 The Purpose of Scoping in the Environmental Impact Assessment Process


The Report has been prepared on behalf the Applicant and is therefore subjective. Care must be taken to ensure that the final version makes a fair assessment of impacts and takes account of the limited time respondents have had to consider potential impacts.

1.4 The Need for the Proposed Development

This Section deals with the general need for new energy infrastructure rather than the overriding need for this proposed development – a case to justify this specific proposal is therefore required. The EN provisions that address the adverse impacts, such as EN1 1.1.2, 4.1.4,  4.2.5etc. should also be incorporated.

2 Description of the Existing Environment

2.1 Site Description

There is insufficient detail in the description of the site.  What is referred to as The Street is known locally as Southside Road.

2.2 Site History

2.3 Potential Environmental Receptors



The environmental receptors appear to be very narrowly defined and the list does not cover a lot of receptors who should be in scope. Specifically, but not exclusively, the following should be included:

Human receptors:

·         Local residents of Wherwell, Whitchurch, Tufton, Bullington, Sutton Scotney and Andover

·         Local farms – there is no Southside farm and the nearest farms are Vale, Owl’s Lodge and Middleton Estate

·         All local schools including Longparish, Barton Stacey, Wherwell, Whitchurch secondary and primary schools

·         Longparish playgroup

·         Users of Village Halls such as local clubs

·         Pedestrians, cyclists, riders and drivers of horse-drawn vehicles 

·         Users of local playgrounds and sports facilities such as Whitchurch football club (users of Longparish football field)

·         Military personnel on the adjacent MOD training area

·         Users of local businesses and their staff (including fishing and shooting)

Traffic and Transport

·         The A303 and A34 will both be affected by a potentially significant increase in HGVs and this impact should be considered in the EIA, in particular the extent of the traffic studies should cover, as a minimum, A34 between Bullington Cross Junction and Winchester, and A303 between Andover and the junction with the M3.

·         Cycle routes are not mentioned - the Street is regularly used by cyclists and less frequently by riders and horse-drawn vehicles

Other infrastructure and social considerations

·         Local tourism and recreation businesses

·         Fly fishing on nearby rivers and lakes, and game shooting on neighbouring estates

·         RAF, Army Air Corps and Popham Airfield



The site has been subject to flooding from groundwater a number of times, including as recently as February 2014. Therefore the statement regarding the low risk of flooding should be reviewed and revised. Proper flood risk assessment should be carried out and details of mitigation and emergency management plans for the proposed development in the event of a flood provided.


3 Proposed Development Description

3.1 The Proposed Development Description


The proposed use for the heat output should be clearly demonstrated by clearly identifying; the market demand for heat offtake in the vicinity of the facility, the means of transferring the heat offtake to future customers, and the impacts that these provisions would have on all identified receptors.


The details of the methodology for storage of the waste to ensure uninterrupted operation of the facility should be provided, as well as the operational plans showing how the contamination risks, especially water contamination risks, will be managed in normal operational conditions and in the event of an emergency (fire, flood etc.).

The Scoping Report states that the facility would be “CHP ready” - see comment on 3.1.1 above. Information on the operational efficiency of the plant and the reduction in environmental benefits in the event that heat offtake is not secured should be provided, together with analysis of the associated effects on the environment and identified receptors.


Details of the proposed site reuse, through life maintenance, including major re-fits, and facility disposal strategy should be included, together with information on the future potential impact on the surrounding countryside, soil and ground pollution management strategy and anticipated carbon footprint impact of the facility over its anticipated life.

The operational life of most EfW plants is closer to 25 years.

3.2 Preparation of the Site


The visual and environmental impact of the proposed levelling of the existing bund should be demonstrated and mitigation measures proposed. The bund is in place to mitigate impacts of the existing Raymond Brown operation on the local community.

Details of how a workforce of 1,000 personnel will arrive at site should be given: the environmental impact of the additional land take (albeit temporary) and arrangement for car parking, accommodation arrangements etc.

3.3 Plant Description

3.4 Grid and Utilities Connection

Details of the proposals for managing heat offtake should be presented, together with assessment of impacts on all receptors. Proposals for future connections to the users of heat output should form part of the assessment.


Details of the proposed grid connections should be presented together with analysis of associated impacts and mitigation measures. In particular, information on what form the connection will take, the route of the connection, interface between the connection and other local infrastructure, the level of interference that will be caused by the installation of the connection and potential visual or other impact on identified receptors should be provided.  This should be considered in conjunction with the proposed development.

3.5 Fuel Description


Analysis of the following should be provided:

·         Guaranteed sources of waste

·         Potential sources of waste

·         Typical composition of the waste

·         Sufficiency of guaranteed and potential sources of waste to ensure the gross output of 50MW over the operational life of 50 years

·         Market analysis of the competing demands for the sources of waste from other facilities in Hampshire and the South of England (the proposed waste catchment area)

·         Analysis of the effects of Government policies on waste reduction and increased recycling on current and future sources of waste

·         Detailed information on the location of the sources of waste and the logistics of its delivery to the facility

·         Analysis of the plans for operational continuity of the facility (minimum and maximum amount of waste to be stored, associated handling and environmental safety measures and plans)

3.6 Operations and Access


Detailed analysis of impact on road safety at the E and W-bound junctions with the A303 should be provided, taking into consideration the mixing of HGVs, light commercial vehicles, private vehicles, construction plant, cyclists, pedestrians and others.

Analysis of accidents in the area that covers, as a minimum, A34 from Newbury to Winchester, with particular focus on Bullington Cross Interchange, and A303 from the M3 junction to Andover should be provided as part of the road safety impact analysis.


Plans for traffic management during construction and operation in the event of accident/congestion on A303 and A34 should be prepared, clearly demonstrating alternative routes of access to the facility and associated impact on the receptors.

Plan for management of risks of increased litter/waste dislodges from the vehicles transporting it along the road network should be provided.  There is already a problem with litter on the access roads.


Details of proposals for management of construction workers’ accommodation, transport, recreation and associated facilities should be provided, as well as analysis of associated impacts.

3.7 Process Description

Analysis of emergency response plans should be provided to cover, as a minimum, fire, flood and major breach/pollution incidents.


Details of the potential recipients of IBA and their locations should be provided, as well as analysis of their capacity to accept the volumes of IBA to be generated, their location and the plan for logistics and traffic impacts. Details of the landfill sites should be provided, together with analysis of their location and capacity.  Consideration should be given to the stockpiling of IBA and transmission of leachate into the ground water in close proximity to a SPZ.


Details of the potential recipients of hazardous waste and their locations should be provided, as well as analysis of their capacity to accept the volumes of hazardous waste to be generated, their location and the plan for safe storage, logistics and traffic impacts. Details of the specialist landfill sites should be provided, together with analysis of their location and capacity.  The carbon emissions resulting from this aspect of the plant lifecycle should not be ignored.

3.8 Indicative Programme

3.9 Construction Environmental Management Plan

4 Consideration of Alternatives



A comprehensive analysis of alternative sites should be presented, with particular focus on the number and location of industrial sites with proximity to power and heat offtake locations that have been considered and reasons for their unsuitability. A detailed justification for selection of a development site in the countryside away from sources of waste and market for heat offtake should be presented. It should be demonstrated how analysis of the existing IBA and hazardous waste processing capacity on the adjacent site and the current and future levels of congestions of the A303/A34 network have been taken into consideration when selecting the current site.

5 Planning Policy Context

5.1 Introduction

5.2 National Policy Statements


Guidance on the Electricity Works (Environmental Impact Assessment) Regulations 2000 is also relevant in determining the need for EIA to cover any overhead lines included in development of a power station .


Para 4.2.1 EN1 directs that the EIA must cover “ the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects at all stages of the project”. In particular, a detailed analysis of the cumulative effects of the proposed development should be included.

5.3 National Planning Policy Framework (NPPF)

5.4 National Waste Policy

TVBC and HCC waste policies should also be considered.

5.5 The Development Plan

It is noted that this and other sections are selective in their choice of quotes. It is expected that the EIA will pay proper regard to ALL relevant sections of national and local policy. For example:



Policy 10 should be quoted. It states that “Minerals and waste development should not cause adverse public health and safety impacts, and unacceptable adverse amenity impact” and goes on to list objections to such development.

Policy 13 notes that “Minerals and waste development should not cause an unacceptable adverse visual impact and should maintain and enhance the distinctive character of the landscape”



Policy 25 appears to be quoted in part only. Policy 25 in full states “The co-location of activities with existing operations will be supported, where appropriate, if commensurate with the operational life of the site, and where it would not result in intensification of uses that would cause unacceptable harm to the environment or communities in a local area (including access routes), or prolong any unacceptable impacts associated with the existing development.

6 Proposed EIA Methodology

6.1 Introduction

6.2 EIA Methodology

6.3 Environmental Design and Management Measures

6.4 Approach to Assessment Scenarios

6.5 Approach to Significance Criteria

6.6 Approach to Effect Interactions and Cumulative Effects Assessment

The Zone of Influence for other developments should be extended in the case of transport considerations to developments affecting a wider area. For example, potential changes to the A303 at Stonehenge fall within the timescale of this development and will have a major impact on traffic flow along the A303.

7 Potentially Significant Environmental Effects

7.1 Introduction

7.2 Traffic and Transport

The Traffic and Transport impacts should be considered within the context of the identified sources of waste and uses/disposal sites of the IBA and hazardous waste. The impact on the road network, as a minimum on sections of A34 and A303 set out in the comments on 3.6.2, should be demonstrated. Consideration should be given to other major planned activities nearby along the route of the A303 (Solstice park, A303 Stonehenge tunnel) and the effects of combined HGV increase and associated pressure on the surrounding countryside and local residents. Detailed plans for alternative access routes and operating procedures in the event of an accident/blockage/congestion on the A303 and/or A34 and associated impact assessment should be provided.

It should be noted that the Street is, in part, a single track road with limited unofficial passing places unsuitable for large vehicles.


Although the Street is not designated as a footpath it serves as the only pedestrian link, via the bridge, between the communities of Longparish and Barton Stacey, and is frequently used as such. In particular, it serves patrons of local businesses, such as the Swan Inn and the Cricketers Inn PHs. The Street is also regularly used by cyclists and is a major route for local cycling clubs.  Impact on all of these user groups should be demonstrated.  The bus to Peter Symonds College stops on the bridge, so minors may be waiting there for some time at peak hours..

An important PRoW is likely to be reinstated adjacent to the site under DMMO Barton Stacey 602, This PRoW will greatly improve the connectedness of the minor road and footpath/byway network close to the site by allowing walkers, cyclists and horse riders to move between the routes to the east of Longparish including Longparish 50, 49, and the routes around Barton Stacey such as Barton Stacey 19, via the Barton Stacey A 303 road bridge. Actual usage of this PRoW once approved is difficult to assess but likely to be significant.

Several landowners have a right of access over the main track past the Raymond Brown/Fortis Plant, as well as the shooting school. This track also has a history of being a public right of way.


Traffic counts on A303 E and W-bound and on the junction with the regionally important A34 at Bullington Cross should be carried out as a minimum, to demonstrate potential impact on the adjacent road infrastructure. This should be presented in the context of the established sources of waste and locations for future IBA disposal.


Traffic impact during the operational period is also expected to be significant and should be demonstrated, together with proposals for mitigation of traffic safety and environmental impacts.


Given the scale of the development and potentially significant dispersal of sources of waste and IBA disposal sites across the South of England, a traffic model demonstrating the impact and sensitivity of the associated HGV traffic increase is provided. The model should include assumptions of the combined effect of the traffic increase associated with other confirmed planned developments on the affected routes, in particular on the A303 and A34 and the regionally important Bullington Cross interchange. The methodology for determining the extent of the traffic study should engage with local knowledge of traffic conditions in order to avoid any unconscious bias in favour of the developer introduced by subjective professional judgement.


Assessment should take into consideration other planned developments on route (Solstice park, Stonehenge tunnel and others), given the dispersal of the sources of waste sites and the locations for IBA disposal


Specific analysis of the impact of the potential increase in congestion on the A303 on the access to local schools should be provided.

Impact on cyclist and pedestrian safety in particular should be analysed.

7.2.18 table 7.3

Pedestrian delay should be included in the scope, as the Street serves as the only pedestrian link between the communities of Longparish and Barton Stacey, and is frequently used as such. It also serves as the only means of pedestrian access for the residents of the mobile home park, who use it in order to get to and from their workplace in the village.

On the same basis, Pedestrian Amenity and Community Severance should be included in the scope.

It is noted that the impact on Cyclists is not mentioned at all in the scoping document. This must be included, and proper assessment of the amenity effects, access, tourism, disruption of use and safety impacts should be provided.

Fear and Intimidation should be included in the scope, given the regular and continued use of the Street by pedestrians and cyclists and other vulnerable road users.

7.3 Air Quality


Air quality should be examined, particularly at key pinch points such as Bullington Cross, where, at peak times, there can be significant queues of vehicles trying to get onto the southbound A34.

It should be noted that air pollution/odour from the settlement activity of bottom ash at the existing Fortis operation has been reported to the Environment Agency since June 2016 over two years ago and is one area that requires further study, as a matter of urgency.


Baseline air quality should be based on locally recorded data.


Given existing concerns about odour from the current IBAA processing plant, the potential significant impact of odour on nearby human receptors must be reviewed and odour management plans specified.  Robustness of the management process should be demonstrated, together with fail-safe mitigation plans.  Odour should be included in the scope of the Environmental Impact Assessment.


Plume dispersion, effect of temperature inversions etc. is a complex subject especially in a shallow valley area such as the proposed site that runs perpendicular to the prevailing wind direction. One of the big issues with valleys concerns anticyclonic conditions which can produce temperature inversions that trap pollutant in the valley. Research shows that anticyclones are becoming more prevalent over Western Europe as global warming takes hold. Longparish and Barton Stacey etc could become more frequently shrouded in the pollution for extended periods over the coming decades as the result of the proposed development. It is clear that historic data may be no reliable indicator of future plume dispersion. Impact assessments should therefore be based on worst case.

7.4 Human Health Assessment

Air quality assessment should include effects of the increase in HGV traffic on the A303/A34 and potential increase in congestion and associated vehicle emissions.

7.5 Noise and Vibration


It is anticipated that the proposed development will affect traffic levels on both the local and the national roads adjacent to the site, therefore impact of the change of traffic noise levels should be evaluated on the local roads as well as the A303 and A34.

7.6 Ecology

The EIA must carry out all the requirements set out in wildlife legislation, not exclusively, but especially, the Wildlife and Countryside Act 1981 and the Countryside and Right of Way Act


The EIA should consider how the proposed development will comply with relevant good practice of achieving no overall loss of biodiversity. 

The adjacent field has a rich diversity of plants, nesting birds including a Schedule 1 species, reptiles, amphibians and especially insects, one butterfly is a priority species and one a candidate priority species on the UK Biodiversity Action Plan status and indicator plants including two species of orchid. Undoubtedly some of these species will occur on the development site.

The adjacent field to the North is regularly used as an education resource because of its natural history interest. Two schools and the Longparish Countryside Club have been continuous users for the past five years.



There is very little spare space available within the footprint of the site, so it is unclear how any effective landscaping plan could be created.

7.7 Water Resources

The Environment agency has already stated that there is over-abstraction in the Test and Itchen

River catchments. With the Picket Twenty development this will reach a tipping point and an internationally important habitat system could be destroyed.


The statement regarding absence of surface water connectivity should be reviewed. The site is a known source of a winterbourne which crosses the A303 via a culvert.  During periods of high water table a permanent stream is evident, and there are reports of historic flooding of A303 in the adjacent area.  Adequate consideration must be given to groundwater connectivity and impact upon this given the comments contained in section 7.8.4 regarding the “main and most sensitive receptor” being groundwater.


The potential effects resulting from the two storage reservoirs becoming contaminated should be considered, or the absence of hydraulic connectivity with ground water should be demonstrated.


Will pilings have any effect on the aquifer?

The management of ground water during construction and potential plan to meet the “dewatering” requirements should be demonstrated. In particular, management of the water which may need to be extracted in order to build (what is expected to be, considerable) foundations should be described in detail. In particular, if the water is to be pumped back into the river system, the impact of introducing high levels of silt on the aquatic habitats should be evaluated in detail.


Plans for emergency management should be provided, covering flood/fire/pollution events as a minimum.


Confirmation and evidence is needed to show that there is no potential adverse effect on the Rivers Test and Dever.


The effectiveness and safety of the proposed soakaway drainage must be demonstrated, given that the proposed site is located over a designated aquifer and is close to protected water sources.

A comprehensive water and drainage management plan must be provided clearly demonstrating potential risks and impacts arising from the proposed construction and operation (routine and emergency).

7.8 Ground Conditions

7.9 Archaeology and Cultural Heritage



It is unclear why the scoping assessment study area has been restricted to a radius of 1 km, as there are approximately 55 listed buildings within 3 kms of the proposed site, including a Grade 1 listed Church in Longparish.  Further study at a greater radius, should be undertaken.   The impact on such built heritage should clearly be considered, demonstrating which settings will be compromised by the proposed development, in view of its height and mass.  Any review of archaeological data should also include Hampshire County Council’s HER.


Built heritage should be scoped in and considered within a study area of at least 5 kms. Given the fact that the majority of the vegetation within the vicinity is deciduous, it cannot be taken into account unless it completely screens the development throughout the year and can be reasonably expected to do so for the duration of the lifecycle of the facility.

7.10 Landscape and Visual Impact Assessment

The visual impact of the proposed development would be considerable and would clearly result in a significant loss of amenity for surrounding communities over a wide area.  Even the preliminary analysis in Appendix B demonstrates that the harmful effects would be felt as far out as Beacon Hill between Whitchurch and Newbury.  This aspect of the study therefore requires to be carried out in great detail. 

South Downs National Park is located 11.5 kms south-south east of the site, and parts of the New Forest National Park are located within 30 kms south of the site. Both of these areas should be included in the list of visual impact receptors.



The link between the height of the proposed building and chimneys and guidance on the Zone of Theoretical Visibility (ZTV) for wind farms is understood, but takes no account of the significantly increased visual impact of a solid structure.



The initial search area of 30 kms took account of visible plume. Reduced intended study area takes no account of this. It should also take account of aircraft warning lights on the stacks to the extent these are visible from the ground.



The Report seeks to reduce the radius of study to 15 kms, but it is clear from the map at Figure B.3 that the chimneys would be visible out to a radius of 30 kms, particularly if there is a column of steam on cold days.  Figure B.1 clearly identifies that there will be significant areas (particularly to the west) where the main building envelope will be visible at 20kms.  Visual Representation of Wind Farms’ (Scottish Natural Heritage (SNH), 2017 (Para 48) guidance for visual impact for structures with a height 51-70 mtrs recommends a ZTV of radius 20 kms, and for a height of 86-100 mtrs recommends a ZTV of radius 30 kms.  The scope of the study should therefore be broadened to 30 kms. 



Representative viewpoints should not be taken as exclusive. It is also noted that the attached photographs are taken with heavy foliage present.



March is considered to be too late to properly assess winter conditions, as spring regrowth has already started - January/February would be more appropriate. The illustrative photographs in Figures B.5 to B.24 were all taken with the trees in full leaf so do not show how much more visible the site would be in winter.  Any such representations included in the final assessment must have the scale of the proposed structures superimposed and show their full impact when there are no leaves on the trees.

7.11 Climate Change

7.11.7 table 7.14

Impacts from vehicle movements from site should also be considered, given the need for IBA and toxic waste disposal.


Emissions from maintenance and estimate of fault time (looking at emissions from similar plants when not working optimally) should be scoped in so that realistic cumulative impact is modelled.

7.12 Socio-economics and Land use


The Report is in error by seeking to scope out tourism.  While there are no large tourist attractions in the area, Test Valley generates some £150m through visitors to the area ( They mainly engage in outdoor activities such as walking, cycling, shooting and fishing on chalk streams such as the Test, Itchen and Dever.  The potential knock-on impact on pubs, restaurants, cafes, and tourist accommodation must be assessed.  Furthermore, the site is next to the A303 and would be clearly visible from what is the main tourist route to the South West.

The potential impact on house prices in the area should also be assessed.



Consideration should also be given to the impact on local fishing tourism. This should include the world renowned chalk bed fishing streams as well as fishing ponds in the very local area. There is also a Kart Racing track adjacent to the site that should be considered in the review



Consideration should be given to the odours created by the site both in the construction and operational phases



An assessment should be made as to the risk of industrial waste being passed to the aquifer during the construction and operational phases. This is important not only to the quality of water for domestic and commercial use but also the risk of pollution of the water in the surrounding rives that are world famous for the quality of chalk bed trout fishing



The impact of 50 workers in the operational phase will have a direct effect on local amenities and so should be included within the scope of the report



The site is very close to world class chalk bed trout fishing streams and draws fishermen from around the world. The impact of this site should be assessed both in terms of the environmental effect but also the potential effects on local business who support this tourism both directly and indirectly



The Street is a popular cycle route and is regularly used by cyclists. An assessment on the impact both during construction and in the operational phase should be undertaken

8 Environmental Topics to be Scoped out of the EIA

8.1 Introduction

8.2 Aviation


Aviation must be included in the scope of the EIA, because the site is located on a low-flying route for military helicopters and the adjacent MOD training area is used for military helicopter training.

8.3 Major Accidents and Disasters

Specific assessment of major fire and flood events should be included, and it is not sufficient to suggest that adequate precautionary measures would be in place to mitigate the risk – witness the fire at an EFW facility in Kent on 13 March.  Chaos was caused in Andover and the surrounding villages recently by a major fire at an Ocado warehouse equipped with the latest technology, including fire detection and sprinkler systems.

8.4 Electronic Interference

8.5 Daylight, Sunlight and Overshadowing

Potential overshadowing of the existing renewable energy plant on the adjacent site is considered to be an important issue and must be included in any assessment.  Compensation is not an adequate response to the potential loss of generating capacity.

9 Proposed Structure of the Environmental Statement

9.2 Structure of Technical Chapters

10 Summary and Conclusions

10.1 Conclusion

10.2 Summary of Environmental Topics