The proposed development is for the re-development and expansion of the Shotton Paper Mill which was bought by Eren Group in September 2021. The proposed development, which the ES supports, is the subject of three separate planning applications as follows:

• Main Site & Expansion Land – the Main Site comprises the redevelopment of the existing site operations for card and containerboard production and covers an area of approximately 61 hectares (ha). The Expansion Land covers to 22ha. It lies to the north of the Main Site and is currently vacant, having previously formed part of Shotton steelworks which was demolished in the 1980s. It would be developed for tissue paper and products.

• Combined Heat & Power (CHP) Facility – the CHP Facility falls within the Main Site, but is the subject of a separate planning application to be determined by Welsh Government due to it falling under the definition of a ‘Development of National Significance’ (DNS). The CHP Facility would provide approximately 60Megawatts of power (MWe) to the Site, which in combination with existing onsite energy generation would make the Site self-sufficient in energy.

• Piling – advance accommodation works (piling) are required in the central area of the Site.

The total area that these three applications cover is 83 ha in size. The proposed development is described further within the Project Description section of this document.

The Site

The proposed development is located within the Deeside Industrial Park at Weighbridge Road, Deeside, Flintshire CH5 2LL at National Grid Reference (NGR) SJ30407159 (the Site). The immediately surrounding area is predominantly industrial with Tata Steel adjacent to the Site’s southern boundary and the remainder of Deeside Industrial Park lying immediately to the east. The figure below shows the proposed development within its geographical setting.

The Main Site comprises both buildings that will be demolished to make room for the new card and containerboard production processes, and a number of existing industrial and manufacturing units which will be retained as an integral part of the proposed development. The figure below focuses on the Main Site and shows buildings to be retained in pink, and new buildings in blue.

Within the southern area of the Site is a series of lagoons, used for the treatment of process water. The final lagoons can be seen in the photograph below.

The northern area of the Site, the Expansion Land, is a revegetated area which is bordered by the existing A548 Weighbridge Road to the north and local estate road to the south.

A view of the Site looking north east from the final lagoons can be seen in the photograph below.

Site

Lying to the north and north west of the Site is the Dee Estuary which is subject to a number of ecological designations.

North of the Site

Looking north from the Site, the surrounding area is dominated by the Dee Estuary with a series of mudflats and grassland areas. The Dee Estuary is designated as a Ramsar Site, Special Areas of Conservation (SPA) and Special Protection Area (SPA).

There are a number of small villages to the north and east of the Site, in the Wirral (England). These include Burton which is 2.5km north of the Site and Puddington 3km north east of the Site.

South of the Site

The Tata Steel lies to the south of the proposed development. The lagoons within the Tata Steel land ownership have become an important site for nesting common tern (Sterna hirundo) and are separately designated as Shotton Lagoons and Reedbeds SSSI.

The UK is currently a net importer of both containerboard products and tissue products, while at the same time being a net exporter of recycled (waste) paper. The proposed development is intended to close both these gaps by switching from the former production of newsprint (a declining market) to make card, containerboard, tissue paper and tissue products. Increased levels of production when compared with the former newsprint production will allow the use of more recycled paper, card and other fibres, with the proposed new cardboard paper production facility using 100% recycled materials.

The Applicant has been looking for a suitable Site in the UK for some time to expand its paper and packaging division. Having acquired the established paper production site at Shotton Mill, significant capital investment is required to change the type of paper produced and bring the building and plant up to modern sustainable standards.

The proposed development has a number of functions. The Main Site will involve the redevelopment of the existing operational site. Within this area some of the existing buildings

will be retained such as the reception area, recycled paper storage buildings, the Materials Recovery facility, and the Biomass Plant and wood preparation plant.

There will also be a need to construct new buildings, which would house the Cardboard Paper Machine and the Corrugating Machine, Warehouse Building, Dispatch Area, Effluent Treatment facility, and ancillary buildings including Starch Process and Storage Building, Raw Materials Storage Area and power services area.

The Expansion Land would house the new Tissue Paper Mills and associated Buildings including Reel Storage, Converting Building and Finished Goods Building. The figure below shows the expansion site as well as the main Site and the new combined heat and power (CHP) plant which is discussed further below.

The CHP Facility will provide an additional 60MWe power to Shotton Mill. The proposed CHP facility would have an efficiency of around 80% due to the utilisation of the heat that is a by-product of the electricity generation process. It is therefore considered a low carbon source of energy.

SCOPING AND EIA METHODOLOGY

The requirement for an assessment of the potential environmental effects on the existing environment is a result of the Environmental Impact Assessment Regulations (2017). The regulations require that a scheme which falls under ‘Schedule 1’ will require an Environmental Impact Assessment (EIA). The proposed development falls under this schedule and therefore has been the subject of EIA.

As part of the EIA process a Scoping Request was submitted to each of the determining authorities (Flintshire County Council and PEDW (Planning and Environment Decisions Wales).

SLR prepared a Scoping Report that described the proposed development and outlined the likely significant effects on the existing environment with regard to: landscape and visual receptors, ecology, water environment, noise, land quality, air quality, traffic and transport, socio economics, and cultural heritage. For these technical areas, a methodology for assessing the ability of the existing environment to accommodate the proposed development. In addition to this, consideration was also given to waste, major accidents and disasters.

Following consultation with regulatory bodies a Scoping opinion / Direction was issued by Flintshire County Council and PEDW that provided commentary on the Scoping Report and a direction for the assessment.

The ES has taken into account the feedback received on the Scoping Report. The ES draws together the findings of the EIA using the agreed methodology and is a comprehensive assessment which looks to inform the reader of the potential effect of the proposed development on the environment. It comprises technical assessments which are supported by surveys; appendices and drawings and provides a detailed, systematic and objective assessment. The ES has been produced by experts within their technical field.

The next section of this NTS summarises the findings of the technical assessments which have been undertaken for the proposed development.

LANDSCAPE AND VISUAL IMPACTS

The landscape and visual impacts assessment (LVIA) looks at the potential effects that the proposed development could have on the existing landscape and visual receptors within a specific area. The assessment has been undertaken following the relevant best practice and guidance, which for landscape is the Guidelines for Landscape and Visual Impact Assessment (GLVIA3).

The LVIA has a number of objectives which include looking at the landscape character of the Site and its immediate surroundings to see if there are any notable individual landscape elements which the assessor needs to be aware of. A view on how sensitive the landscape and identification of potential receptors is also established. A further objective is to identify and describe the changes to the landscape and visual amenity that could occur as a result of the proposed development.

Site visits were undertaken by an experienced landscape architect in December 2021 and January 2022. The purpose of the site visits was to understand the study area that would be assessed, to examine the landscape character and to look at the view of the proposed development from a specific area (or viewpoint) to better understand how the proposed development would fit within the landscape.

The LVIA found that the landscape in the area is dominated by large scale industrial building and infrastructure which supports these buildings which have developed along the River Dee. There are a number of buildings and structures which play an important part of defining the local landscape character, the largest being Parc Adfer EfW, Deeside Power Station, Tata Steel Works, Shotton Paper Mill, Flintshire Bridge and Connah’s Quay Power Station, along with numerous overhead power lines and their pylons. The proposed development would not have a significant impact upon the landscape that these industrial building sit within.

There are a number of viewpoints which would have a view of the proposed development during operation. However, due to the existing industrial setting the proposed development sits within this industrial setting well and so views to the proposed development would not result in a significant and negative effect on visual amenity. However, one viewpoint (K) which is located on Weighbridge Road, and approximately 100m from the nearest proposed building would have a large change in its view as a result of how close this viewpoint is to the proposed development.

NOISE & VIBRATION

The noise and vibration assessment for the proposed development has looked at what effects the proposed development could have on the surrounding environment during construction and operation. The assessment has been undertaken in accordance with the relevant guidance and standards applicable to noise and vibration.

Sensitive receptors were identified, and these included ecological receptors such as Burton Marsh Farm and residential receptors such as Kenneth Cross Way and Rock Cottages. Noise surveys were undertaken in September 2021 when the existing Shotton Paper Mill was operating in normal conditions and a further noise survey undertaken in October 2021 when the existing Shotton Paper Mill had ceased operation.

The construction operations will require a variety of machinery to be used onsite at varying times. The machinery has different noise levels, and the assessment identifies the type of machinery and construction methods that will likely be required to build the proposed development.

The assessment also looks at the traffic which will be accessing the Site including Heavy Goods Vehicles and cars. All of these elements were then put into a noise model which predicts the noise level changes on sensitive receptors before any mitigation has been designed. Mitigation during construction and mitigation during operation, such as noise fences can be designed into the proposed development if required.

The assessment has shown that specific noise mitigation measures will not be required because during construction there would not be an increase in the noise levels high enough on the sensitive receptors to require mitigation. However, a Construction Environment Management Plan (CEMP) has been produced which is a document used by the construction team which provides information on the Best Practicable Means to reduce noise levels during construction.

When the proposed development is operational the levels of noise including noise generated by site traffic will be small and therefore operational mitigation is not required.

WASTE & RESOURCES

This chapter considers the use of materials within the construction of the proposed development. It also considers the raw material feedstock used in the operation of the new plant. With regard to card production the process would solely utilise recovered paper, card and other materials that are collected for recycling by local authorities and businesses across the UK as its raw material feedstock. The tissue manufacturing process would use a proportion of office (white) paper and wood pulp. The existing Biomass Plant would contribute to the paper mill’s energy requirements through the use of recycled wood and wood products.

The chapter also considers use of water resources, as water is an important element of the paper making process. Paper mills require vast amounts of process water for paper production. Shotton Mill benefits from its own private water supply, which is drawn from a location on the River Dee above Chester and transported by underground pipeline to the Site. There is no limit on abstraction volumes.

Of the total water usage of 1,386 m3/hour, approximately 45% would be recycled, resulting in a significant reduction in water demand. This is substantially higher than the recycling rate of 10% achieved for the newsprint plant. The balance of approximately 55% would be discharged via the existing consented Discharge Point to the River Dee, thereby returning into the same river from which it was extracted.

The proposed development has been designed to optimise the use of recycled materials and minimise waste generated on-site, thereby making a substantial contribution to national and local objectives in moving the management of waste up the ‘waste hierarchy’.

Construction waste management would be undertaken in accordance with the waste hierarchy, and the Site Waste Management Plan in accordance with Welsh legislation.

It is considered that the embedded good practice design principles and mitigation are unlikely to result in significant adverse effects and have the potential to be significantly beneficial.

The socio-economic chapter assesses the potential beneficial and adverse effects on the local area, through the impacts on recreational assets, such as long-distance routes, land use and the potential impacts on the local labour market and economy through the proposed developments construction and operational phases.

Desktop research forms the baseline study for the assessment, which comprises two separate parts; the Wider Study Area (WSA) and the Local Area of Impact (LAI). The WSA considers the ‘home’ local authority of the proposed development, Flintshire County Council, and the neighbouring local authority, Cheshire West and Chester Council, where there is an expected to be a considerable draw from the labour market due to the closeness of the proposed development to these areas. The LAI comprises a 2km radius of the proposed development’s boundary, where the impacts on recreational assets are most likely to occur.

The socio-economic assessment is split into two parts; the impact of the proposed development during the construction phase, and impact during the operational phase.

During the construction of the proposed development, the assessment found that the proposed development would generate approximately 400 jobs. This does not include additional jobs which could be created due to the demands put on supply chains and deliveries.

It is estimated that approximately 20% of these jobs may be taken by people from the respective local authorities of WSA and there will be additional employees commuting to the Site and a number of specialised roles. The creation of the new jobs both directly for the Site construction and through the increased demands on the supply change will have a beneficial effect.

There are a number of recreational facilities of national or regional importance, and there of high to medium sensitivity. These include RSPB Burton Mere Wetlands and long-distance walking and cycling routes, including the Wales Coastal Path, the Dee Way and National Cycle Network (NCN) routes. NCN 568 passes the Site boundary but with the implementation of a Construction Environmental Management Plan (CEMP), the NCN route would remain open and safe for users, resulting in a low impact. Overall, with mitigation in place it is unlikely that there will be an adverse residual impact on recreational facilities.

For the operational phase, the proposed development is expected to retain the current 190 roles at the existing paper mill and create an additional 660 new roles, which would result in 850 total roles. As with the construction phase, during operation the proposed development would likely result in additional indirect roles, through supply chain services such as logistics and waste management amongst many others. In addition to this, training and skills development would be offered to new and existing employees to ensure they have the necessary skills and expertise to work effectively with the new technologies and output.

For recreational facilities it is unlikely that there will be an impact upon these during the operation of the proposed development. NCN 568 may experience increased levels of use through the potential for the increased numbers of employees using the route.

Overall, the socio-economic impact of the proposed development is expected to be beneficial.

The Land Quality chapter of the Environmental Statement considers the possible impacts that the construction and operation of the proposed development might have at both the Site and the surrounding area. The assessment looks at potential contamination risks onsite and the current ground conditions within the Site area and it looks at the existing ground conditions which could have an effect on sensitive receptors at and near to the Site (such as groundwater and surface water) current and future Site users and Site Construction Workers.

A desk study assessment has been completed that has looked at the environmental setting of the Site, its historical development and ground condition information available from previous reports completed at the Site. This has helped to build up an understanding of contamination that may be present and how this could move and impact on the identified receptors during the Site’s construction and operation.

The desk study review has found that the Site was originally open tidal flats, before the land was raised with natural dredged sands and gravels in the 1950s. A steelworks was subsequently developed on the raised land in the 1960s before being demolished and making way for the current paper mill during the 1980s.

There have been a number of ground investigations on the Site over the years, and therefore much is known about the ground and groundwater, including areas of contamination. The Site has also been operated under an NRW permit which ensures that contamination is identified and dealt with as part of site activities.

Ground investigations have identified pockets of contamination across the Site, some of which relate to the former steelworks and some of which relates to the paper mill. There is widespread presence of made ground up to 6m in thickness and legacy contaminants associated with the former steelworks operations, particularly in the area of the former by-products plant, former waste effluent pond and former cooling ponds/current effluent lagoons. Potential sources from the paper mill include demolition of structures, storage of chemicals and fuels and the site drainage system. Those contaminants identified from historical use include slag waste, mixture of hydrocarbons (oils, greases, fuels, coolant fluids), clinker and ash, solvents, metals, ammonium, sulphate and asbestos. A ground gas risk assessment has also been undertaken. Recent investigations have confirmed these to be at relatively low levels.

As part of the assessment, receptors have been identified as human health which includes workers on the Site (construction, office and maintenance), off-site workers in the surrounding area as well as residential areas of development. Controlled waters have been identified to include groundwater (within

the Tidal Flats and deeper bedrock aquifers) as well as surrounding surface waters (Greenwood Burn, Broken Bank Drain, White Sands Gutter) and the ecologically sensitive Dee Estuary. Impacts to buildings, utilities and infrastructure have also been assessed.

The assessment has found that during construction of the proposed development there would not be an impact to the identified receptors when control measures and best practice are put in place. Further detailed ground investigation work will be undertaken, prior to construction, to confirm the contamination status of the soil and groundwater beneath each area across the Site. A Remediation Strategy will be developed which will identify the remediation or protection required in order to remove/reduce the levels of contaminants to acceptable standards.

In addition to this, during construction a Construction Environmental Management Plan (CEMP) based on industry best practice will be implemented to control construction activities and agreed with the planning and regulatory authorities. Monitoring of impacts to health, waters and the environment will take place during the construction phase and a watching brief for contaminated ground during construction will be implemented.

For the operation phase of the proposed development the assessment has found that there will not be a significant effect from on the receptors identified. The proposed development will remove existing areas of contamination and improve existing ground conditions through reduction and/or remediation and the new infrastructure will reduce the risk of potential contamination reaching receptors through providing protection and control of potential releases in accordance with good practice, legislation and technical guidance. A Verification Report will also be prepared once the Site remediation has been completed during the construction phase to demonstrate remediation has been undertaken to the necessary standards and which will be submitted to NRW for approval. In addition to this, the Site will operate into the future under a regulatory permit obtained from NRW which will continue to monitor for potential contamination impacts to the ground and water environment, its subsequent identification and required remediation/restoration.

As such, with the implementation of the mitigation measures outlined above, no significant residual effects from contamination on ground conditions, the water environment or to property and infrastructure are considered likely