For "the following documents for the Aberdeen Western Periphery Route:
- The Interpretive Reports provided by the Company for the environmental monitoring of Hydrological and Hydrogeological Sensitive Environment Sites (groundwater, surface waters, private and pubic water supplies) during construction and post construction phase
- The post construction report that assesses / compares: the predicted residual impacts on the water environment for construction phase (that were made in the Environmental Statement); against the observed / monitored impacts that were recorded during construction. This should demonstrate compliance with the findings of the environmental statement.
On 18 June you clarified that "The request can be limited to the Norther Leg of the AWPR Chapter 9 (Water Environment) of the Environmental Statement concluded that the residual construction phase impacts of, for example, the Northern Leg, were:
Kepplehill Burn: negligible significance.'
Gough Burn: Moderate significance
Parkhead Burn: Negligible significance
Craibstone Burn: Moderate significance
Green burn: Negligible significance
River Don: Slight/Negligible significance."
"Please can information be provided to assess/demonstrate if the predicted environmental residual impact significances were achieved in reality? Or put another way, can Transport Scotland validate the ES findings for the construction phase in relation to impacts on the water environment?"
So it's anticipated that my second question is addressed in the STRIPE Reports. The STRIPE reports for the AWPR are not available on the TS website, so I'd be grateful for them."
As the information you have requested is 'environmental information' for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.
This exemption is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.
1. Some of the information you have requested is available from The Water Environment (Controlled Activities) (Scotland) Regulations 2011 (legislation.gov.uk). Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.
For the watercourses you listed, except the Parkhead Burn, all were covered by the above regulations.
This meant that the design and construction method statement had to be agreed with SEPA prior to works starting. SEPA also inspected the construction works as they progressed. Furthermore, as part of the CAR licence a geomorphological monitoring plan had to be designed and implemented to monitor the watercourses 5 years post completion. This was to ensure that the watercourse crossings and realignments were responding appropriately and there were no long-term unacceptable impacts on the watercourse. Of the watercourses you enquired, the long-term monitoring was identified for Kepplehill Burn, Gough Burn, Craibstone Burn and Green Burn.
Parkhill burn was classified as a field ditch and therefore did not come under the CAR regulations and was not subject to any additional monitoring. It was incorporated into the permeant road drainage. The River Don was not subject to the geomorphological impact reviews as the design ensured that no piers were placed within the River and therefore there were no potential impacts on the hydrogeomorphology of the River which needed monitoring.
A summary of the monitoring and outcome for the watercourses you are interested in is provided as table 1 below. The final year 5 survey is due to be completed in 2023.
Table 1: Geomorphological Monitoring surveys
|Watercourse||2019 (year 1)||2021 (year 3)|
|Kepplehill Burn||No works needed||No works needed|
|Gough Burn||Reform step pools required||Two minor step repairs needed|
|Craibstone Burn||No works needed||No works needed|
|Green Burn||Concrete reinforcement in bed to be removed||No works needed|
As well as looking at the morphological impacts, during construction regular water quality testing was completed on the project to ensure that the project did not have a negative impact on the overall water quality of the watercourses. This monitoring involved taking water samples from each of the watercourses and sending them off to the lab for analysis against key chemical components as well as general water quality indicators such as pH.
These results were compared to the baseline monitoring that was completed before construction works began. Monitoring was undertaken in all the watercourses you enquired about with the exception of Parkhill Burn for the reasons explained previously and Gough Burn, as this was adjacent to Craibstone Burn and also flows into Green Burn which was also sampled. Craibstone Burn was only sampled for the first year as this also flows into the Green Burn however due to scale of works in this watercourse, it was monitored initially. Table 2 shows the number of samples and date range that samples were taken.
Table 2: Chemical sampling history
|Watercourse mentioned in
|Water quality sample dates||Actions required|
|Kepplehill Burn||31 samples between Jun 15 to Sept 18||none|
|Craibstone Burn||10 samples between Jul 15 to Aug 16||Incident investigation due to sediment entering
watercourse. No permanent impacts/degradation of watercourse.
|Green Burn||35 samples between Jun 15 to Sept 18||none|
|River Don||35 samples between Jun 15 to Sept 18||None|
Throughout these monitoring regimes, no adverse impacts were identified that changed the overall impact to the watercourses you have identified, as per their ratings in the Environmental Statement. Additional measures were required as a result of the geomorphological monitoring survey 1 year post completion. The most significant for the watercourses you are interested in, was at Gough Burn where some of the steps as a result of the realignment had to be reworked to ensure that no hydraulic drops were present. This work was completed and verified by SEPA and the next inspection confirmed that the realignment was naturalising well. There are still further monitoring rounds programmed under this monitoring regime.
The AWPR is subject to a programme of evaluation in line with Scottish Trunk Road Infrastructure Project Evaluation (STRIPE) Guidance) against both its objectives and wider evaluation criteria, which includes areas such as the environment, accessibility & social inclusion, safety etc. The evaluation is carried out to assess the impact of a scheme by comparing conditions one year after (1YA) and three years after (3YA) opening with forecasts made during scheme design and development. As a large road infrastructure project, an evaluation will also be undertaken five years after opening. While our aim is to provide information whenever possible, in this instance Transport Scotland does not have some of the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. This is because evaluation work was paused in 2020/21 in response to the COVID emergency, as resources were pivoted to deal with the pandemic and this has affected the timescale for the 1YA evaluation.
While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because an exception under regulation 10(4)(d), material in the course of completion, of the EIRs applies to that information.
This is because we are currently reviewing an initial evaluation of the project and this is scheduled to be published in 2022, although the exact timescale for publication depends on the review outcomes and approval process, both of which are undertaken routinely by Transport Scotland prior to publishing technical reports. This initial evaluation was, however, limited in scope to focus on giving an early indication of how the AWPR is performing against a few selected operational indicators, such as journey times, and did not cover other aspects of evaluation set out in the STRIPE Guidance including evaluation related to Environment criteria.
The evaluation process of any road project related to Environment criteria is set out in STRIPE Guidance and does not involve “validating” the Environmental Statement (ES) findings. For example, on page 2 of Appendix A to the STRIPE Guidance, the minimum evaluation requirement under the “Water Quality, Drainage and Flood Defence” sub objective include: “site visit to confirm mitigation measures, including contaminated land mitigation measures, identified in ES have been implemented and are performing as expected and to identify any additional issues/mitigation requirements”. It is also stated that: “no further evaluation required if there are no issues identified”.
This methodology aligns with the overarching approach to evaluation within the STRIPE Guidance aimed at: findings giving an early indication of project performance so that any potential issues are identified and addressed; and adopting an appropriate and proportionate evaluation against scheme objectives and other evaluation criteria.
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.
Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000
The Scottish Government
St Andrews House
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