Pollution prevention and environmental management

The risk of adverse environmental impacts can be significant during construction. For large scale developments, we would expect all potential pollution risks and all aspects of site work, which may impact on the environment, to be systematically identified, as well as preventative measures and mitigation. For small scale developements, please refer to our Standing advice for small scale local development (47k).

Any information supporting a planning application should include a dedicated pollution prevention section, as well as any additional information that may be necessary. This information should incorporate the principles of all proposed pollution prevention and mitigation measures for all construction elements potentially capable of giving rise to pollution during all phases of construction, reinstatement after construction and final site decommissioning. This approach provides a useful link between the principles of development that will need to be outlined at the early stages of the project and the method statements which are usually produced following award of contract (just before development commences).

The pollution prevention section should set out the principles of all proposed pollution prevention and mitigation measures on the following issues, where relevant, to the proposed site:

Monitoring proposals, contingency measures and emergency plans, including an environmental checklist to monitor and plan the timing of works to avoid construction of roads, dewatering of pits and other potentially polluting activities during periods of high rainfall. This should cover:

daily visual inspections and the recording of required environmental actions (eg in relation to silt management);
proposals for planning activities in relation to heavy rain (up to 3 day forecast);
identification of all construction elements and their location in relation to sensitive receptors, including any waterbodies, water supplies, and water-dependent species;

Details of how the works will be programmed to avoid any adverse impact on sensitive receptors. A timetable of works that takes into account all environmental sensitivities, such as fish spawning, which have been raised by SEPA, SNH or other stakeholders should be included.
Protection of development in relation to unstable land including peat landslides or landslip is not an area within our expertise or remit. This is a matter for the planning and building standards authorities and civil engineers who will determine if a peat stability assessment is required. Where an assessment is required, our main interest relates to the consequences of a peat-slide or bog burst which can result in severe environmental damage including the pollution of the surrounding area. The risk of this occurring should form part of any peat stability report and any associated pollution prevention measures should be included in planning submissions.
Surface water management plan - The site specific principles of how drainage will be controlled should be detailed in the planning submission.
Particulate or chemical contamination of waterbodies due to, for example, track or cable crossings or dewatering of excavations. Any proposed discharges should be set out and dilution data provided. Any destabilisation works, excavations, ground disturbance or stripping of vegetation and/or topsoil should be carried out so as to avoid pollution of the water environment.
Sediment – resulting from operations including stockpile storage, storage of weather sensitive materials at lay-down areas, haul routes, access roads, earthworks, drainage channels, vehicle access over watercourses, construction of watercourse crossings and digging of excavations. Permanent and temporary drainage arrangements for access tracks, turbines and substation should be based on sustainable drainage principles.
Dust Management - proposals for dust management including dust sprays. Excavation works, particularly through drilling and blasting, may cause nuisance to adjacent land users due to the generation of dust and noise. Comments from local authority Environmental Health Officers should be sought on the potential nuisance to adjacent land users during the construction and decommissioning phases of the project.
Concrete production/use – Environmental impacts resulting from concrete batching plant operations, use of blinding cement on roadways, wash-out during construction, poor integrity of shuttering. Discharge to waterbodies and pH impact on peatland (where relevant) should be avoided.
Mineral oils, fuel transport and storage – Environmental impacts resulting from spillages, refuelling and burst cables. Contingency plans for large oil spills that cannot be dealt with at a local level, details of designated bunded fuel stores and mobile bunded stores. Our preferred option is for a site compound to avoid fuel and other chemicals being stored at numerous locations around the site. Maintenance of vehicles and plant should be carried out only on impermeable areas where any oil spillages can be contained. Additional information pertaining to the storage of oil can be found below.
Road and crane hardstanding - Environmental impacts resulting from construction, use, and decommissioning of such infrastructure. Guidance on minimising impact from construction of access roads can be found in “Forests and Water Guidelines” Fourth Edition (2003) which can be obtained from the Forestry Commission. Where tracks or hardstanding will be located on peat and will carry heavy loads, evidence will be necessary of additional consideration of specific measures required to deliver best practice should be included.
Pollution risks and impacts on other environmental sensitivities as a result of the timing of operations. For example, construction of roads, dewatering of pits and other potentially polluting activities should be avoided during periods of high rainfall periods of high rainfall, or at particular times of the year e.g. fish spawning. The ES should demonstrate which periods of the year would be best practice for construction at the site to avoid pollution risks and other environmental sensitivities.
Welfare arrangements - Details of waste water drainage from temporary and permanent facilities for workers on site should be provided. Our preference would be for waste water and solid waste to be transported away from the site and disposed of using standard waste handling facilities during the construction period.
Site restoration - It is good practice for large scale developments to be subject to conditions requiring the submission of a restoration and aftercare scheme. The restoration principles should be set out within the submission. It should also outline the proposals for phased working and progressive restoration. Consideration should be given to the effect that any restoration will have on the water environment including groundwater quality and quantity and should include an assessment of the effect that any backfilling below the water table will have on groundwater flow.
Environmental accident management procedures - This should include toolbox talks relating to pollution prevention.
Site environmental management - arrangements for the appointment of an appropriately qualified and experienced environmental manager to supervise operations on site during the whole construction period, and with the authority to stop work and implement remedial work with immediate effect.
Site Waste Management Plan (SWMP) which identifies all waste streams and proposals for their management, including peat, soils and other materials excavated on site and the importation of any waste materials to the site. Additional information on SWPSs can be found on the Sustainable Waste Management section of our website. Our Regulatory Position Statement – Developments on Peat (8.56mb) and Guidance on the Assessment of Peat Volumes, Reuse of Excavated Peat and Minimisation of Waste (2.6MB) may also be of help. This includes reference to guidance Developments on Peatland: Site Surveys and Best Practice (96k).

SEPA policy and guidance

SEPA produces a series of Pollution Prevention Guidelines (PPGs) and the principles of any relevant PPGs should be incorporated into proposals. Particular attention should be paid to the Construction PPGs .

Construction PPGs :

SEPA have also worked jointly with Highland Council to produce a guidance note on Construction Environmental Management Process for Large Scale Projects . SEPA, SNH, Scottish Renewables and FCS have also produced Good practice during windfarm construction (2228k) which provides useful pollution prevention advice applicable to many types of projects. We also have useful guidance on the sustainable reuse of greenfield soils in construction (2.52mb).

Regulatory and best practice advice

Standing advice for small scale local development (47k)

The storage of any oil on site must be undertaken in accordance with The Water Environment (Oil Storage) (Scotland) Regulations 2006. For best practice advice please refer to PPG 7 Refuelling facilities , PPG 8 Safe storage and disposal of used oils and PPG 27 Installation, decommissioning and removal of underground storage tanks .

Further information on the types of storage tanks to be used and additional publications can be found within the Pollution Control section of the website.