screening for appropriate assessment and article 12

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SCREENING FOR APPROPRIATE ASSESSMENT AND ARTICLE 12 SCREENING ASSESSMENT TECHNICAL REVIEW FS007050 Greenlink Interconnector Foreshore Licence Application

MGE0778RP0006

Screening for Appropriate

Assessment and Article 12

Screening Assessment

Technical Review

F01

23/07/2021

REPORT

MGE0778RP0006 | Screening for Appropriate Assessment and Article 12 Screening Assessment Technical Review | F01 | 23/07/2021

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Document status

Version Purpose of document Authored by Reviewed by Approved by Review date

A01 Draft for Client Review 11/06/2021

F01 Final 23/07/2021

Approval for issue

23 July 2021

© Copyright RPS Group Limited. All rights reserved.

The report has been prepared for the exclusive use of our client and unless otherwise agreed in writing by RPS Group

Limited no other party may use, make use of or rely on the contents of this report.

The report has been compiled using the resources agreed with the client and in accordance with the scope of work

agreed with the client. No liability is accepted by RPS Group Limited for any use of this report, other than the purpose for

which it was prepared.

RPS Group Limited accepts no responsibility for any documents or information supplied to RPS Group Limited by others and no legal liability arising from the use by others of opinions or data contained in this report. It is expressly stated that

no independent verification of any documents or information supplied by others has been made.

RPS Group Limited has used reasonable skill, care and diligence in compiling this report and no warranty is provided as

to the report’s accuracy.

No part of this report may be copied or reproduced, by any means, without the written permission of RPS Group Limited.

Prepared by: Prepared for:

RPS Department of Housing, Local Government and Heritage

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Contents

1 INTRODUCTION ...................................................................................................................................... 1

1.1 Greenlink Interconnector Project.................................................................................................... 1

1.2 Application Documents .................................................................................................................. 1

1.3 Relevant Legislation ....................................................................................................................... 2

2 TECHNICAL REVIEW.............................................................................................................................. 3

2.1 Methodology ................................................................................................................................... 3

2.2 Consultation Responses ................................................................................................................ 3

2.2.1 Inland Fisheries Ireland .................................................................................................... 3

2.3 Further Information Request .......................................................................................................... 4

3 SCREENING FOR APPROPROATE ASSESSMENT ............................................................................. 5

3.1 Management of the European Site ................................................................................................ 6

3.2 Description of the Project ............................................................................................................... 6

3.3 Characteristics of the European Sites ............................................................................................ 6

3.3.1 Conservation Objectives ................................................................................................... 6

3.4 Impact Prediction .........................................................................................................................14

3.5 Screening for Appropriate Assessment Matrix .............................................................................16

4 CONCLUSION .......................................................................................................................................21

4.1 Article 6(3) Appropriate Assessment Screening Conclusion .......................................................21

5 ARTICLE 12 ASSESSMENT .................................................................................................................22

5.1 Annex IV Species .........................................................................................................................22

5.1.1 Cetacean baseline assessment ......................................................................................22

5.1.2 Marine turtles baseline assessment ...............................................................................23

5.2 Discussion ....................................................................................................................................23

5.2.1 Potential effects on cetaceans ........................................................................................23

5.2.2 Potential effects on Turtles .............................................................................................25

5.3 Article 12 Conclusion ...................................................................................................................25

6 REFERENCES .......................................................................................................................................26

Tables

Table 3.1: Information Checklist for the Appropriate Assessment ..................................................................... 5

Table 3.2: Potential sources of impact to European Sites from the Proposed Development ............................ 8

Table 3.3: Information Checklist for the Impact Assessment ...........................................................................14

Table 3.4: Screening for Appropriate Assessment ...........................................................................................16

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1 INTRODUCTION

1.1 Greenlink Interconnector Project

Greenlink Interconnector Limited (GIL) is proposing to develop an electricity interconnector cable (Greenlink) linking the existing electricity grids in Ireland and Great Britain. The interconnector will have a nominal capacity of 500 MW. There will be one converter station near the existing National Grid substation at Pembroke in Pembrokeshire (Wales) and one converter station near the existing EirGrid substation at Great Island in County Wexford (Ireland). These will be connected by underground cables (onshore) and subsea cables (offshore). Greenlink is designated as a European Union Project of Common Interest (PCI), project number 1.9.1, under the provisions of European Union Regulation No. 347/2013 on guidelines for Trans-European Network for Energy (TEN-E Regulations) and has successfully applied for funding under the Connecting Europe Facility.

The landfall points for the submarine cables are Baginbun Beach, County Wexford and Freshwater West, Pembrokeshire. The overall length of the interconnector is approximately 159km of submarine cabling and approximately 7km and 23km of onshore cable in Wales and Ireland respectively. The proposed development for the purposes of this Foreshore Licence Application covers the Irish marine components of Greenlink from mean high-water springs (MHWS) at the Irish landfall at Baginbun Beach, Co. Wexford to the 12nm limit. The Foreshore Licence Application also includes works at the Campile Estuary component of Greenlink (where the onshore cable route crosses the foreshore at the River Campile).

The proposed development comprises the following:

• Two high voltage direct current (HVDC) electricity power cables;

• A smaller fibre-optic cable for control and communication purposes;

• All associated works required to install, test, commission and complete the aforementioned cables; and

• All associated works required to operate, maintain, repair and decommission the aforementioned cables, including five repair events over the 40 year lifetime of Greenlink.

1.2 Application Documents

GIL submitted the following documents as part of the application:

• Greenlink Marine Environmental Impact Assessment Report (EIAR)

• Volume 1 – Non Technical Summary

• Volume 2 – EIAR

• Volume 3 – Appendices

• Appendix A – Stakeholder Meetings

• Appendix B – Competent Experts Table

• Appendix C – Underwater Noise Assessment

• Appendix D – Herring and Sandeel Assessment

• Appendix E – Commercial Fisheries Assessment

• Appendix F – Marine Archaeology

• Appendix G – Cable Route Survey

• Appendix H – Environmental Survey Report

• Appendix I – Intertidal Habitat Survey Report

• Appendix J – UXO Risk Assessment

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• Appendix K – Magnetic Fields and the Induced Voltages caused by the Greenlink HVDC Circuit

• Appendix L – Landfall Selection;

• Greenlink Marine Natura Impact Statement (NIS);

• Greenlink Foreshore Licence Application Form;

• Greenlink Marine Foreshore Licence Map;

• Foreshore Licence Application FS007050 Greenlink Response to Consultation Comments;

• Consolidated Prescribed Bodies Observations FS007050 Greenlink Interconnector Limited;

• Campile Estuary Foreshore Licence Map; and

• Greenlink Summary of Onshore and Offshore Environmental Effects to Accompany Welsh Marine Licence Application.

Following requests for further information (RFI), the following documents were provided to DHLGH by GIL:

• Greenlink Response to Request for Further Information (December 2020).

• Greenlink Information to Inform 2nd Public Consultation (March 2021).

The above reports and documents were considered as part of this technical review.

1.3 Relevant Legislation

Under Article 6(3) of the EU Habitats Directive (92/43/EEC) and the Birds and Natural Habitats Regulations 2011 (S.I. 477 of 2011) as amended, project proponents are required to provide sufficient information to enable a designated public authority to undertake a Screening for Appropriate Assessment (AA) to determine whether or not the proposed project (either alone or in-combination with other projects) is likely to have significant effects on the conservation objectives of designated Natura 2000 (or European) sites1. Where significant effects of the project cannot be screened out, the public authority can request the project proponent to submit a Natura Impact Statement (NIS) to inform the AA for the project.

In addition to the requirement to consider potential effects of a plan or project on Natura 2000 sites under Article 6(3) of the Habitats Directive, the Directive requires consideration of the potential effects on species listed under Annex IV of the Directive (termed Annex IV species). Under Article 12, Annex IV species are afforded strict protection throughout their range, both inside and outside of designated protected areas.

This technical review and assessment of the AA Screening Report has been undertaken with regard to the appropriate legislation, guidance and departmental circulars.

1 In Ireland, designated European sites include Special Areas of Conservation (SACs), designated due to their significant ecological importance for species and habitats protected under Annexes I and II respectively of the Habitats Directive, and Special Protected Areas (SPAs), designated for the protection of bird species protected under Annex I of the EU Birds Directive (Council Directive 2009/409/EEC).

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2 TECHNICAL REVIEW

2.1 Methodology

This technical review report presents the findings of the RPS review and assessment of GIL’s Foreshore Application for the Greenlink Interconnector. The NIS, and other relevant documents will be scrutinised to assess whether it includes the following:

• Robust scientific information and analysis including the reasoning and justifications for the conclusion.

• Compliance with the tests and standards of AA as presented in European and national guidance.

• The assessment is carried out on the entirety of information submitted as part of consent application.

• A robust scientific assessment and conclusions are reached relative to:

– Conservation objectives of the site(s); and

– Integrity of the site(s).

• Complete, precise and definitive findings and conclusions, capable of removing all reasonable scientific doubt as to the effects on the European sites.

The European Communities (Birds and Natural Habitats) Regulations 2011 (as amended) outlines the requirements for Screening for AA under Regulation 42(1) and 42(2), as follows:

42. (1) A screening for Appropriate Assessment of a plan or project for which an application for consent is received, or which a public authority wishes to undertake or adopt, and which is not directly connected with or necessary to the management of the site as a European Site, shall be carried out by the public authority to assess, in view of best scientific knowledge and in view of the conservation objectives of the site, if that plan or project, individually or in combination with other plans or projects is likely to have a significant effect on the European site.

(2) A public authority shall carry out a screening for Appropriate Assessment under paragraph (1) before consent for a plan or project is given, or a decision to undertake or adopt a plan or project is taken.

2.2 Consultation Responses

Consultation responses are described in detail in Section 2.3 of the accompanying EIAR Technical Review, carried out by RPS on behalf of DHLGH. Observations received from the prescribed bodies and the applicant’s responses to these are available to view on the DHLGH website. Of relevance for European sites and therefore this Screening for AA report are the observations from Inland Fisheries Ireland (IFI), which are summarised below.

2.2.1 Inland Fisheries Ireland

Inland Fisheries Ireland (IFI) raised two main observations on 5th March 2020.

IFI raised concerns regarding additional geophysical survey work 3-6 months ahead of installation, due to the potential for impacts to fish species due to impacts from underwater noise. IFI initially requested that further geophysical surveying not be undertaken, and that route clearance as indicated by the applicant (pre-lay grapnel) be used to ensure no issues impeding the cable route. The applicant responded to IFI outlining that the pre-construction geophysical route survey will be limited in extent, centring on the cable centreline and that the survey is required for additional reasons, including identifying any unexploded ordnance, confirming the seabed level and to inform micro-routing of the cable around mobile bedforms and sensitive habitats. Due to the time period between the previous geophysical survey and cable laying (3 years) there is the potential for sensitive habitat areas to have increased or appeared. For these reasons the applicant strongly requested that IFI’s request does not become a condition of the foreshore licence. IFI confirmed that they were satisfied that additional surveys are required and requested that all mitigation measures outlined by the applicant in their response be implemented.

https://www.gov.ie/en/foreshore-notice/a6150-greenlink-interconnector-wexford/?referrer=http://www.gov.ie/en/publication/9ed2f-greenlink-interconnector-wexford/#prescribed-bodies-consultation

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In their initial observations, IFI highlighted the importance of the area of the proposed development for twaite shad, which is an Annex II species under the Habitats Directive and protected by Special Areas of Conservation nearby. IFI recommended that the timing of the works should take into consideration the relevant life cycle elements of the species, i.e. that directional drilling under the River Campile and all marine works of route clearing, rock armour placement and cable laying be undertaken outside the period April- May inclusive, in order to reduce any adverse impacts on the twaite shad.

The applicant responded, outlining why underwater sound pressures from horizontal directional drilling (HDD) under the Campile Estuary are unlikely to result in any disturbance to fish. The applicant recognised that UXO detonation has the potential to injure twaite shad and agree that as a precaution, UXO detonation between April and May (inclusive) should be avoided. The applicant proposed that the following Project Specific Mitigation be added to the Schedule of Mitigation of the EIAR:

PS19 – UXO detonation will not be undertaken between April and May (inclusive) between KP145 and KP159.27.

IFI agreed to the proposed mitigation measure.

In their response to the second public consultation, IFI reiterated their position regarding UXO detonation, acknowledging the mitigation measures to be implemented if a detonation is necessary. IFI further requested that the local Environment Officer is notified once the cable laying method is agreed and in the event that UXO detonation is required. In their response, the applicant agreed to these requests and reiterated the mitigation measures proposed.

2.3 Further Information Request

The initial RPS review of the ‘Stage 1 – Appropriate Assessment Screening’ (provided in the NIS, Chapter 4) and associated documents determined that insufficient information had been provided to assess, in view of best scientific knowledge and in view of the conservation objectives of the European sites, whether the proposed interconnector cable activities, individually or in combination with other plans or projects, is likely to have a significant effects on a European site, and further information was required to information the Screening for AA determination, and subsequently the AA.

A Request for Further Information (RFI), in accordance with Regulation 42(3) of the European Communities (Birds and Habitats) Regulations 2011, as amended, was issued by the DHLGH to the applicant. The following further information was requested:

• Inclusion of the Keeragh Islands SPA and Saltee Islands SPA in the assessment for likely significant effects.

• An assessment of likely significant effect related to the identified pressure ‘hydrological changes (inshore/local)’ as a result of placement of external cable protection.

• Provision of additional information to support the conclusion that there would be no likely significant effects to migratory fish species viability, populations, or stocks, as a result of UXO detonation, specifically how aggregations of migratory fish would be avoided. It was also noted that the applicant, in their response to IFI, provided additional project specific mitigation not included in the NIS.

• Clarification regarding the exclusion of transboundary effects, i.e. likely significant effects to marine mammals from UK SACs.

After receiving a further information response from the applicant, RPS completed a Stage 1 Screening for AA on behalf of DHLGH. This assessment found that likely significant effects on European sites could not be ruled out and therefore a Stage 2 Appropriate Assessment should be undertaken. An initial evaluation by RPS of the NIS and associated documents indicated that an adverse effect on site integrity of Hook Head SAC could not be avoided due to the installation of external cable protection at the HDD exit point within the SAC. Following a meeting between RPS, DHLGH and the applicant, this element of the project was redesigned, removing the potential for requiring external cable protection within Hook Head SAC. As a result, this Screening for AA has been amended to account for this redesign and reflects the final project design. Removal of the requirement for external cable protection within Hook Head SAC removes the likelihood of hydrological changes (inshore/local) and therefore this potential effect has been screened out.

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3 SCREENING FOR APPROPROATE ASSESSMENT

As per the EU Guidelines (2002) the checklist below outlines the information necessary to complete the Screening for AA for the Greenlink Interconnector.

Table 3.1: Information Checklist for the Appropriate Assessment

Are these known or available? Yes/No

Size, scale area, land-take, etc. Yes: Detailed information regarding size and scale of the project can be found in Section 2 of the Greenlink Marine Natura Impact Statement (NIS).

Project Sector Yes: This project is in the Telecommunications Sector.

Physical Changes that will flow from the Project (from excavation, piling, dredging etc.)

Yes: Potential sources of effects to European sites are outlined in Table 4-1 of the NIS. The primary physical change that will occur is excavation of the seabed for cable installation and HDD exit pit and HDD under Baginbun Beach and the Campile Estuary.

Resource Requirements Yes: The main natural resources and raw materials required by the Greenlink Interconnector include the use of fuel for the vessels and rock or concrete materials for external cable protection, where required.

Emissions and Waste Yes: Information regarding emissions is given in section 4.11 of the EIAR. Emissions as a result of the proposed project include:

• Electromagnetic fields (EMF)

• Heat

• Noise

Potential pressures from emissions to air and climate are scoped out of the EIAR as no deterioration in local air quality or significant contribution to global emissions is expected (Table 5-2 of the EIAR) The overall significance of the impact of atmospheric emissions from the project is considered to be low and will not cause a significant impact on European sites.

Waste associated with installation: Project vessels will be equipped with waste disposal/storage facilities as embedded mitigation (Table 17-1 of EIAR).

Waste associated with decommissioning will be subject to a waste management protocol at the time (Section 4.13.4 of EIAR).

Transportation Requirements Yes: Sections 4.7 and 4.8 of the EIAR outline vessels required for cable and landfall transportation and installation.

Cable-laying vessel to transport and install cable.

Rock-placement vessels to transport rock for cable protection.

Duration of Construction, Operation, Decommissioning etc.

Yes: Duration of cable and landfall installation (construction) is outlined in the indicative programme (Section 2.6 of the NIS) and estimated to be 36 months in total.

Cable operation is outlined in Section 4.10 of the EIAR. The operational lifetime of the cable is expected to be 40 years.

The duration of decommissioning is not explicitly stated but is estimated to be similar to that of installation (EIAR, Section 4.13).

Project Implementation Period Yes: An indicative project schedule of the marine installation works is shown in the Table 2-4, Section 2.6 of the NIS. Seasonality is discussed in Section 2.6.

Distance from European Site Yes: The project Zone of Influence (ZoI) is described in Section 4.3.1.2 and Table 4-1 of the NIS, along with appropriate search distances for mobile species from European sites further afield. Distances from the closest element of the Greenlink. Interconnector to European sites are provided in Table 4-3 of the NIS.

Cumulative Impacts with Other Projects or Plans Yes: Consideration of the potential cumulative/in-combination effects is provided in Section 4.5 of the NIS.

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Are these known or available? Yes/No

Other, as appropriate Yes: A Screening Statement and Conclusion are provided in Section 4.6 the NIS. Assessment of likely effects to relevant Annex IV species (cetaceans, turtles and otter) is provided in Section 10 of the EIAR.

3.1 Management of the European Site

The Greenlink Interconnector Project is not directly connected with or necessary to the management of any European site.

3.2 Description of the Project

The proposed development is approximately 36km long and generally 500m wide, between Baginbun Beach, County Wexford and the 12nm limit. A small part of this width will be required for installation (of the order of 10-20m) once the final cable route within this corridor is agreed. It is proposed to finalise the precise position of the submarine cables within the corridor after permits are granted but before installation has commenced. This will allow for optimisation of the final laid submarine cables to minimise engineering and environmental challenges. Cables will be bundled together with no separation between the cables.

The programme is expected to take approximately 36 months from start to finish.

The project description includes the deposit and burial of the cables in the seabed; a horizontal direction drill (HDD) underneath the beach at Baginbun Beach and the contingency for one unexploded ordnance detonation. The project description includes up to five discrete repairs of the submarine cables, including as a worst-case deposition of external cable protection, should it be required. The project also includes a horizontal direction drill under the Campile Estuary associated with the Greenlink onshore cables.

As discussed in Section 2.3, a contingency for the deposit of two areas of external cable protection (each 20m x 5.2m by 0.7m high) at the HDD exit points was included in the initial project design, however, following discussions with DHLGH, this contingency has now been removed from the project design and no cable protection will be used at the HDD exit point.

A detailed project description of the proposed development and Campile River is provided in Chapter 4 of the EIAR.

3.3 Characteristics of the European Sites

The zone of influence (ZOI) has been used to establish a search area within which European sites are screened for the relevant qualifying interests (QI). Since mobile species from European sites further field may travel into the ZOI, the ZOI cannot be used alone as a distance to screen in relevant conservation sites. Therefore, search areas (distances from the proposed development) for each receptor group were applied by the applicant, taking into consideration other information such as marine mammal management units and expert judgement for the initial screening of sites. Justification for the spatial extent of each search area is provided in Table 4-1 of the NIS. Receptor groups are habitats, birds, fish, cetaceans and otter, and pinnipeds (seals), and their corresponding search areas are provided in Table 4-1 of the NIS. All SACs and SPAs within the search areas were screened in for relevant QIs. QIs were identified as relevant if there was potential for a pressure-receptor pathway (Table 4-3 in the NIS). QIs with no potential pathway were screened out from further assessment.

A total of 16 SACs and SPAs were identified within the search areas defined. These sites are presented in Table 4.3 and Figures 4.1 and 4.2 of the NIS.

3.3.1 Conservation Objectives

The qualifying interests of SACs and SPAs within the search areas and the closest distance to the Greenlink activities are outlined in Table 4-3 of the NIS. An assessment of the potential for likely significant effects from the works in light of the conservation objectives of the relevant qualifying interests is provided in Section 4.4 of the NIS.

The European sites identified for further assessment are due to potential interaction with Greenlink activities and the sensitivities of the qualifying interests of the sites. The potential sources of impact from the Greenlink

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activities to European sites within the receptor-specific search areas and a screening determination are provided in Table 3.2.

The applicant’s initial AA Screening did not screen in the Saltee Islands SPA and Keeragh Islands SPA for Stage 1 assessment. Following our technical review, RPS considered that there is a potential pressure-receptor pathway between the Greenlink activities and Saltee Islands SPA. This is because several seabird species protected by this site are known to forage out to sea at distances >10 km, which was the ZoI identified by the applicant for this receptor. Sea birds with known foraging-at-sea distances of greater than 10 km have the potential to be feeding within or transiting through the proposed development area, and therefore there is a potential pressure-receptor pathway. Similarly, Keeragh Island SPA is 4.5 km from the proposed development area and designated for breeding cormorant, which are known to have a mean foraging range of 7.1 km, up to a maximum mean of 25.6km (Woodward, 2019), providing a potential overlap with the ZoI of the project.

The applicant subsequently provided information for the inclusion of the Saltee Islands SPA and Keeragh Islands SPA in the Stage 1 assessment of likely significant effect.


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Table 3.2: Potential sources of impact to European Sites from the Proposed Development

European Site

(code)

Site Specific Conservation Objectives

Yes / No

Distance from Proposed Development (km)

List of Qualifying Interest / Special Conservation Interest

Potential Impacts

Screened in for Stage

1?

Hook Head SAC

(IE000764)

Yes Within Large shallow inlets and bays • Penetration and/or disturbance including abrasion

• Siltation rate changes

The following potential impacts from cable protection at the HDD exit point were initially identified, however, due to the re-design of the project, these are now screened out:

• Physical change (to another seabed type)

• Hydrological changes (inshore/local)

Yes

Reefs

Vegetated sea cliffs of the Atlantic and Baltic coasts

None. No interaction with this QI. No

River Barrow & River Nore SAC

(IE002162)

Yes Within Desmoulin's whorl snail Vertigo moulinsiana None. No potential for interaction with these freshwater and

terrestrial QIs due to marine nature of the project. No

Freshwater pearl mussel Margaritifera margaritifera

White‐clawed crayfish Austropotamobius pallipes

Sea lamprey Petromyzon marinus Underwater noise changes.

Note: Sea and river lamprey were not screened in for Stage 1 by GIL, however, on the basis of the precautionary principle, these species are taken forward in this screening assessment.

Yes

River lamprey Lampetra fluviatilis

Twaite shad Alosa fallax

Atlantic salmon Salmo salar

Brook lamprey Lampetra planeri None. QI does not migrate to sea and therefore will not be present within proposed development.

No

Estuaries None. Campile Estuary crossing will be by HDD and will not interact with these QIs.

No

Mudflats and sandflats not covered by seawater at low tide


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European Site

(code)


Yes / No



Potential Impacts

Screened in for Stage 1?

Salicornia and other annuals colonizing mud and sand

Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)

Mediterranean salt meadows (Juncetalia maritimi)

Otter Lutra lutra Visual and noise disturbance. Yes

Killarney fern Trichomanes speciosum None. No potential for interaction with these terrestrial QIs due to marine nature of the project.

No

Nore freshwater pearl mussel Margaritifera durrovensis

Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho‐Batrachion vegetation

European dry heaths

Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels

Petrifying springs with tufa formation (Cratoneurion)

Old sessile oak woods with Ilex and Blechnum in the British Isles

Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno‐Padion, Alnion incanae, Salicion albae)

Bannow Bay SPA

(IE0004033)

Yes 1.6 Overwintering birds – 13 species and wetland

and waterbirds SCI Visual and noise disturbance Yes

Keeragh Islands SPA Yes 4.5 Cormorant Phalacrocorax carbo Visual and noise disturbance Yes


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European Site

(code)


Yes / No



Potential Impacts


(IE004118)

Saltee Islands SAC

(IE000707)

Yes 6.1 Mudflats and sandflats not covered by seawater at low tide

No potential for interaction with these QI due to distance from and nature of the proposed development.

No

Large shallow inlets and bays

Reefs

Vegetated sea cliffs of the Atlantic and Baltic coasts

Submerged or partially submerged sea caves

Grey seal Halichoerus grypus Underwater noise changes. Yes

Ballyteige Burrow SPA

(IE004020)

Yes 8.1 Overwintering birds – 7 species and wetland and waterbirds SCI

No pathway identified. Qualifying Interests all intertidal foragers and not within ZoI for visual and noise disturbance.

No

Saltee Islands SPA

(IE000707)

Yes 10 Breeding birds – 10 species Visual and noise disturbance Yes

Lower River Suir SAC

(IE002137)

Yes 18 Freshwater pearl mussel Margaritifera margaritifera

None. No potential for interaction with these freshwater QIs due to marine nature of the project.

No

White‐clawed crayfish Austropotamobius pallipes

Sea lamprey Petromyzon marinus Underwater noise changes.

Note: Sea and river lamprey were not screened in for Stage 1 by GIL, however, on the basis of the precautionary principle, these species are taken forward in this assessment.

Yes



Atlantic salmon Salmo salar



European Site

(code)


Yes / No



Potential Impacts


Brook lamprey Lampetra planeri None. QI does not migrate to sea and therefore will not be present within proposed development.

No

Otter Lutra lutra None. No potential for interaction with these terrestrial and coastal QI as there is no spatial overlap with the site or foraging habitats.

No

Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)

Mediterranean salt meadows (Juncetalia maritimi)


Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels



Taxus baccata woods of the British Isles

Slaney River Valley SAC

(IE000781)

Yes 29.7 Freshwater pearl mussel Margaritifera margaritifera

None. No potential for interaction with this freshwater QI due to marine nature of the project.

No

Brook lamprey Lampetra planeri QI does not migrate to sea and therefore will not be present within proposed development.

Sea lamprey Petromyzon marinus Underwater noise changes. Yes





European Site

(code)


Yes / No



Potential Impacts


Atlantic salmon Salmo salar Note: Sea and river lamprey were not screened in for Stage 1 by GIL, however, on the basis of the precautionary principle, these species are taken forward in this assessment

Estuaries None. No potential for interaction with these QI as there is no spatial overlap with the site.

No

Mudflats and sandflats not covered by seawater at low tide

Otter Lutra lutra None. No potential for interaction as there is no spatial overlap with otter habitat.

No

Harbour seal Phoca vitulina Underwater noise changes. Yes


None. No potential for interaction with these terrestrial and freshwater QIs as there is no spatial overlap with the site.

No



The following transboundary SACs are considered for their marine mammal QIs only, based on the highly mobile nature of cetaceans and known foraging ranges of pinnipeds. It is considered that distances to these SACs exclude the possibility of likely significant effects for all other QIs.

Pembrokeshire Marine / Sir Benfro Forol SAC

(UK0013116)

Yes 24.3 Grey seal Halichoerus grypus Underwater noise changes. Yes

West Wales Marine / Gorllewin Cymru Forol SAC

(UK0030397)

Yes 35 Harbour porpoise Phocoena phocoena Underwater noise changes. Yes



European Site

(code)


Yes / No



Potential Impacts


Pen Llyn a`r Sarnau / Lleyn Peninsula and the Sarnau SAC

(UK0013117)

Yes 150.5 Bottlenose dolphin Tursiops truncates Underwater noise changes.

Note: Grey seal at this SAC was not screened in for Stage 1 by GIL, however, as grey seal has been recorded foraging up to 522 km from haul out sites (Cronin et al., 2011) on the basis of the precautionary principle, these species are taken forward in this assessment.

Yes

Grey seal Halichoerus grypus

Cardigan Bay / Bae Ceredigion SAC

(UK0012712)

Yes 96.3 Bottlenose dolphin Tursiops truncates Underwater noise changes.

Note: Grey seal at this SAC was not screened in for Stage 1 by GIL, however, as grey seal has been recorded foraging up to 522 km from haul out sites (Cronin et al., 2011) on the basis of the precautionary principle, these species are taken forward in this assessment.

Yes

Grey seal Halichoerus grypus

Bristol Channel Approaches / Dynesfeydd Môr Hafren SAC

(UK0030396)

Yes 73.3 Harbour porpoise Phocoena phocoena Underwater noise changes. Yes

North Anglesey Marine / Gogledd Môn Forol SAC

(UK0030398)


North Channel SAC

(UK0030399)




3.4 Impact Prediction

Table 3.3: Information Checklist for the Impact Assessment

Have these sources been consulted? Assessment

The Natura 2000 standard data form for the site

A summary of the qualifying habitats and species of SACs and the special conservation interests of SPA are provided in Table 4-3 of the NIS and in the RFI Response. The conservation objectives for each of the qualifying habitats and species considered to have potential pressure-receptor pathways are listed in Section 4.4 of the NIS and in the RFI Response.

Reference is made throughout Section 4.4 to Natura 2000 data forms for the relevant sites.

Existing and historical maps Figures 4.1 and 4.2 of the NIS display the SACs and SPAs within the various receptor-specific search areas of the project.

Land-use and other relevant existing plans

Baseline activities and approved plans in the vicinity of the Proposed Development include:

• Commercial shipping

• Fisheries

• Active and disused cables (telecom)

• Abandoned wellheads

• Kilmore Quay Disposal Site

• Aquaculture (oyster beds)

In addition to those existing/approved projects/activities, the following proposed offshore projects were identified which are yet to be formally approved:

• Eir fibre optic cable

• Celtic Sea Array survey

• Aquaculture (seaweed harvesting)

Section 4.5 of the NIS provides additional information on the assessment of cumulative effects with proposed plans or projects. No significant cumulative effects are predicted.

Existing site survey material Marine (geophysical and environmental) and intertidal habitat surveys were commissioned by the applicant to inform the baseline description of the environment. The findings of these reports are available in the EIAR Appendices G, H and I. An ecological assessment of estuarine habitats at Campile Estuary was also commissioned, however, this report does not appear to have been supplied with the foreshore application documentation. Information from the above surveys has been focused in Section 3 of the NIS to provide a baseline for the receptors associated with screened-in European sites. Published information and consultation with relevant bodies also informs the baseline.

Conservation objectives, site synopses and supporting documents for each of the screened-in European sites were referenced in the NIS.

https://www.npws.ie/protected-sites/conservation-management-planning/conservation-objectives

Site specific conservation objectives can be found at the above website have been prepared by the NPWS and are available for a number of the European sites listed in Table 3.2 of this report.

Existing data on hydrogeology Not relevant for this project.

Existing data on key species Birds

Winter bird surveys were carried out for one season (2018/19) at Baginbun Beach and Campile Estuary. Site synopses for the SPAs within





Have these sources been consulted? Assessment

the search areas were consulted. These are available on the NPWS website.

Seals

Published seal usage maps and conservation objectives for relevant sites were consulted for information on seal abundance and distribution.

Cetaceans

For cetacean species protected by SACs (harbour porpoise and bottlenose dolphin), published data relating to population densities were provided, in addition to observations from the Marine Institute’s Marine Atlas and the ObSERVE Project.

For cetacean species protected under Annex IV of the Habitats Directive, the Marine Atlas and IWDG’s sightings browser were consulted to provide information on the species composition of the marine mammal fauna in the project area, in addition to other data sources listed in Section 10.1 of the EIAR.

Otter

An otter survey was carried out in 2018/19 at Baginbun Beach and Campile Estuary and existing records from the National Biodiversity Data Centre records were reviewed.

Environmental statements for similar projects or plans elsewhere

The following reports for offshore projects/plans were referenced in the NIS:

• BEIS (2018). Offshore Oil & Gas Licensing 30th Seaward Round. Habitat Regulations Assessment. Draft Appropriate Assessment: Southern North Sea.

• Delft (2000). Attachment E.1 (vii) Extracts from Environmental Impact of Dredging and Spoil Dumping, Delft H3544 Report, September 2000. In: Port of Waterford Company Foreshore Licence application for Maintenance Dredging FS005701.

State of the environment reports The application does not appear to have taken state of the environment reports (e.g. Article 17 reporting for Ireland, NPWS, 2019) into account.

Site management plans The specific CO for each of the relevant sites have been consulted, including supporting documents, where available (refer to NPWS website for full details of CO of each particular site - https://www.npws.ie/protectedsites/conservationmanagement-planning/conservation-objectives).

Geographical information systems Sources for digital spatial data for the European site boundaries include NPWS, Department of Communication, Climate Action and Environment (DCCAE), UKHO, CDA, GEBCO, EMODNET.

Site history files The application does not appear to include information on history of the site; however, this is not deemed relevant as primarily offshore.

Other, as appropriate A specific Annex IV species assessment has not been carried out, however, impacts from the project to marine mammals, turtles and otter have been assessed in Chapter 10 in the EIAR.

For cetacean species protected under Annex IV of the Habitats Directive, the Marine Atlas and IWDG’s sightings browser were consulted to provide information on the species composition of the marine mammal fauna in the project area, in addition to other data sources listed in Section 10.1 of the EIAR.

https://www.npws.ie/protectedsites/conservationmanagement-planning/conservation-objectives

https://www.npws.ie/protectedsites/conservationmanagement-planning/conservation-objectives



3.5 Screening for Appropriate Assessment Matrix

Table 3.4: Screening for Appropriate Assessment

Appropriate Assessment Screening Criteria

Response

Describe the individual elements of the project (either alone or in combination with other plans or projects) likely to give rise to impacts on the European Sites

The individual elements of the proposed project likely to give rise to impacts on European sites are identified in Table 4-1 in the NIS. In summary these are:

• Seabed preparation

• Cable burial

• HDD exit point installation

• Cable removal

• Anchor placement

• External cable protection*

• Presence of project vessels

• Presence of onshore works (HDD compounds)

• Continuous sound from geophysical survey

• Continuous sound from cable installation, cable removal and vessels

• Impulsive sound from unexploded ordnance detonation

• Electromagnetic changes from cable operation

* Following the RFI response and redesign of the project, no external cable protection will be placed within a European site. Cable protection will be used in the offshore area at third-party asset crossings, however, as this is outside the scope of this Screening for AA, this element/impact will not be investigated further.

Unplanned events (accidental oil or chemical spills) were excluded from the assessment as it was not considered that such events were likely to give rise to impacts on European sites (Table 4-2 in the NIS).

Describe any likely direct, indirect or secondary impacts of the project on the European Sites by virtue of:

• Size and Scale

• Land Take

• Distance from European sites or key features of the site

• Resource Requirements

• Emissions

• Excavation Requirements

• Transport Requirements

• Duration of construction, operation and decommissioning

• Other.

The likely direct, indirect or secondary impacts of the project on the European Sites are assessed in the NIS, Section 4.4. Relevant receptors are subtidal habitats, marine mammals, migratory fish, otter and wintering birds. Potential sources of effects are outlined in Table 4-1 and discussed in the following sections in the context of potential receptors (qualifying interests of SPAs and SACs) for which interactions could not be discounted.

Size, Scale and Land take: The Greenlink Interconnector project is approximately 36 km long within the Irish foreshore (out to 12 nm) and while the proposed development is 500 m wide, installation of the final cable route will only use 10-20 m of this width.

Impacts are not expected in relation to the size and scale of the proposed works, however, potential impacts to habitats are expected as a result of land take for the cable.

Distance from European sites or key features of the site: The distances of European sites within the ZoI of the different elements of the proposed activities are provided in Table 4-3 of the NIS. The relative locations of the European sites within the ZoI are presented in Figures 4-1 and 4-2 of the NIS.

Of the 12 SACs and four SPAs identified within the Project ZoI, potential impacts from proposed activities were identified for all 12 SACs and three SPAs (see Table 3.2). The potential impacts screened-in were:

• Penetration and/or disturbance of the substrate below the surface of the seabed including abrasion

• Siltation rate changes, including smothering (depth of vertical sediment overburden)

• Disturbance (visual and noise)

• Underwater noise changes

The remaining SPA was excluded from further assessment because it was deemed unlikely that there would be any interaction with the proposed works.

Resource Requirements: The installation of the cable will involve use of fuel for the vessels.




Response

Emissions: Emissions expected from the proposed activities include discharges to sea, light and noise emissions. Unplanned events (accidental oil or chemical spills) were excluded from the assessment as it was not considered that such events were likely to give rise to impacts on European sites (Table 4-2 in the NIS).

Excavation Requirements: Cable will be buried in sediment, requiring ploughing or jetting of soft sediments and cutting of hard sediments. An area of seabed in the nearshore (past the 10m depth contour) will be excavated to install the HDD ducts. No excavation within the foreshore is required for the Campile Estuary HDD crossing.

Transport Requirements: Cable will be transported to site on a cable-laying vessel, and rock placement vessels will transport rock for cable protection in the offshore area and may transit through the foreshore.

Duration: An indicative project programme is given in Section 3.2 of the NIS. See also Table 3.1 of this report for details of duration.

Describe any likely changes to the site arising as a result of:

• Reduction of Habitat

• Disturbance to Key Species

• Habitat or Species Fragmentation

• Reduction in Species Diversity

• Changes in Key Indicators of Conservation Value

• Climate Change

Taking account of the above information, this assessment considers the following effects:

Reduction of Habitat: Potential impacts from cable and HDD exit point installation were identified for the reef and large shallow inlets and bays QIs of Hook Head SAC. There is a potential for penetration and/or disturbance including abrasion to benthic habitats from seabed preparation, cable burial, cable removal and anchor placement.

Disturbance to Key Species: There is potential for underwater injury or disturbance to marine mammals and fish from underwater noise from geophysical survey, cable installation, cable removal, vessels and unexploded ordnance (UXO) detonation. There is potential for visual and noise disturbance to otter and breeding and wintering birds. These effects are considered by receptor group below.

Migratory fish It is considered that disturbance to migratory fish from underwater noise associated with cable installation and vessel presence will be localised, temporary and transient, and therefore significant effects in view of the COs are considered unlikely. The applicant’s AA Screening concluded that there were no likely significant effects from underwater noise associated with the geophysical survey. The current assessment considers that the frequencies of the proposed surveys will be outside of the audible range of lamprey and Atlantic salmon, however, for hearing specialist species such as twaite shad, the Noise Assessment found zone of influences for recoverable injury and temporary injury of 630m and 2.2km, respectively. Therefore, on a precautionary basis, likely significant effects to twaite shad from underwater noise cannot be ruled out. Lamprey species belong to a group of fish with no swim bladder or other gas chamber and are known to have limited physiological hearing ranges. UXO produces a pressure waveform with rapid oscillations from positive pressure to negative pressure which results in rapid volume changes in gas-containing organs and as a result, species without swim bladders are likely to be more resistant to UXO noise. Therefore, it is considered that there will be no likely significant effects on sea lamprey and river lamprey. Salmon and twaite shad are considered sensitive to disturbance in the form of mortality from UXO detonation. The Stage 1 assessment provided by GIL concluded that effects to these migratory fish from UXO detonation were not significant as they are unlikely to affect the viability or population of the species. This conclusion was queried by RPS in the RFI and GIL subsequently provided additional information to support appropriate assessment of effects from UXO detonation to salmon and twaite shade. It is RPS’ view that likely significant effects from UXO detonation cannot be ruled out without mitigation, and as such, an appropriate assessment is required. Otter There is potential for disturbance to otter within the River Barrow and River Nore SAC from the works at Campile Estuary, however, as the work compounds at this




Response

location (and at Baginbun Beach) are on agricultural land and will not cause habitat loss or degradation, disturbances to otter will be temporary, localised and minor in nature and are not considered to be significant. Therefore, likely significant effects are considered unlikely.

Wintering birds There is potential for visual and noise disturbance effects to wintering birds at Bannow Bay SPA from presence and movement of project vessels. Due to the planned summer timings of the installation works which will avoid the over-wintering period and given that wintering birds from the SPA are unlikely to feed/roost offshore, it is unlikely that there will be significant effects on the species of the SPA.

Breeding birds

There is potential for visual and noise disturbance effects to the breeding species from the Saltee Islands SPA (fulmar, gannet, cormorant, shag, lesser black-backed gull, herring gull, kittiwake, guillemot, razorbill and puffin) and Keeragh Islands SPA (cormorant). Information on the extent and potential consequences of seabird displacement from offshore wind farm developments is published by the UK Joint Statutory Nature Conservation Bodies (JNCC, 2017). This guidance covers offshore developments but also associated vessel traffic and can be considered a useful proxy in this case. The guidance states that for most bird species a standard displacement buffer of 2 km is recommended and for divers and sea ducks that this is increased to 4 km. As the proposed development occurs 4.5 km from Keeragh Islands SPA and 10 km from the Saltee Islands SPA, it is considered that the only pathway for disturbance is during foraging and transit close to the proposed project. JNCC (2017) also provide disturbance susceptibility and habitat specialisation scores for breeding seabird species With the exception of cormorant, all species at the two SPAs are associated with low to moderate disturbance and habitat specialisation scores, suggesting that they are not confined to specific areas and will forage elsewhere. Cormorant has a high disturbance and moderate habitat specialisation score, meaning that although cormorant is susceptible to disturbance, they can forage elsewhere. Given that the works will be temporary and transient, involving one vessel in an area of existing shipping traffic, it is unlikely that disturbance to foraging cormorant will be significant.

Marine mammals It is considered that underwater noise associated with cable installation and vessel presence will not exceed thresholds for permanent or temporary injury or cause significant disturbance to Annex II marine mammals; therefore, significant effects are considered unlikely.

Marine mammals are vulnerable to injury and disturbance from continuous and impulsive sound from geophysical survey. The applicant’s AA Screening concluded that there were no likely significant effects from underwater noise associated with the geophysical survey. The Noise Assessment carried out by the applicant concluded that, as a worst-case scenario, harbour porpoise are at risk of permanent injury within 110m, temporary injury within 180m and disturbance within 2.6km of the sound source. Zones of influence for bottlenose dolphin and seals were lower, but still likely. Therefore, on a precautionary basis, in the absence of mitigation, likely significant effects to marine mammals from underwater noise cannot be ruled out.

Marine mammals are considered vulnerable to permanent and temporary injury and disturbance as a result of impulsive noise from UXO detonation and as a result the likelihood of significant effects cannot be excluded. The AA Screening provided by GIL excluded likely significant effects for marine mammals from transboundary SACs. This decision was queried by RPS in the RFI and GIL provided a rationale, which was that significant numbers of animals from these SACs would not be present within the ZoI for UXO detonation in Irish waters, should it be required. RPS considers that this rationale does not exclude the possibility of injury and disturbance to marine mammals from transboundary sites transiting through or foraging within the ZoI of UXO detonation. In view of the precautionary principle, likely significant effects cannot be excluded for all marine mammal species from all SACs screened in for Stage 1.

Habitat or Species Fragmentation: The physical presence of the vessels may influence the distribution and movements of sensitive species in the water column,




Response

namely protected migratory fish and marine mammals, and may potentially cause displacement and/or other behavioural responses in birds, however, it is unlikely that the proposed project will result in habitat or species fragmentation.

Reduction in Species Diversity: There is likely to be a reduction in species diversity in benthic habitats of Hook Head SAC during seabed preparation and cable installation work.

Changes in Key Indicators of Conservation Value: Seabed preparation, cable burial and cable removal (if required at decommissioning) will cause a short-term, localised increase in suspended sediment in the water column with subsequent re-deposition of sediment on surrounding habitats. Sessile and less mobile epifauna and infauna in surface sediments are most likely to be affected. However, as increased siltation rates are expected to be brief and localised and background levels of suspended sediment are considered to be relatively high, there is unlikely to be a significant effect on the Annex I habitats at Hook Head SAC.

Climate Change: Activities associated with the interconnector installation will lead to emissions of gases which contribute both to localised and short-term increases in atmospheric pollutants, and to atmospheric GHG concentrations. However, the overall significance of the impact of atmospheric emissions from the project is considered to be low, temporary and will not cause a significant impact on European sites.

Describe any likely impacts on the European Sites as a whole in terms of:

• Interference with key relationships that define the structure of the site

• Interference with key relationships that define the function of the site

Penetration/disturbance of Annex I benthic habitats and injury/disturbance to marine mammals and migratory fish are identified as the likely impacts to the structure and function of European sites.

Indicators of significance as a result of the identification of effects set out above in terms of:

• Loss

• Fragmentation

• Disruption

• Disturbance

• Change to Key Elements of the Site.

See detailed discussion on indicators of significance for each receptor group above.

Describe from the above those elements of the project or plan, or combination of elements, where the above impacts are likely to be significant or where the scale or magnitude of impacts is not known.

Significant effects are likely to arise from the following impacts:

• Penetration and/or disturbance of the substrate below the surface of the seabed including abrasion

• Underwater noise changes – geophysical survey and UXO detonation

Other – in-combination effects A screening exercise was undertaken to determine if there were common-pressure receptor pathways, and spatial and temporal overlaps between the proposed development and other plans or projects. Fourteen projects were identified within 10 km of the proposed development with the potential for cumulative effects. Twelve




Response

projects were screened out, while two projects (Kilmore Quay Disposal Site and Celtic Sea Array surveys) were found to have a common pressure receptor pathways and spatial overlap. Although the Kilmore Quay disposal was due to complete in 2020, it has not yet been consented therefore could overlap temporally with Greenlink. These pathways are discussed below:

Penetration and/or disturbance including abrasion

Kilmore Quay Disposal site will not overlap temporally as the activities will be completed prior to the start of the proposed development, therefore there is no potential for cumulative effects.

Disturbance

There is potential that vessels for the two projects could be in the same area for a short period of time (temporal and spatial overlap). One of the proposed export cable corridors to be surveyed for the Celtic Sea Array project passes close to the Keeragh Islands SPA. There is the potential that if works along the proposed development and Celtic Sea Array occur near to the Keeragh Islands SPA at the same time there may be a temporary elevation in visual disturbance to breeding cormorant in the Keeragh Islands SPA. As discussed above, cormorant has a high disturbance and moderate habitat specialisation score. However, both projects are transient, temporary and localised with vessels that are slow moving and disturbance is unlikely to be felt beyond existing disturbance levels in the area. It is therefore unlikely that any potential cumulative effect will be significant.

Underwater noise changes

It is possible that noise generated from the Celtic Sea Array geophysical survey will occur at the same time as the proposed project. Given that there is a likely significant effect alone for this pressure for the proposed development, the potential for cumulative effects will be assessed in the appropriate assessment.



4 CONCLUSION

4.1 Article 6(3) Appropriate Assessment Screening Conclusion

Based on the information available on the project, it cannot be excluded, on the basis of objective scientific information, following screening under the European Communities (Birds and Natural Habitats) Regulations 2011 as amended, that the proposed project, individually or in combination with other plans or projects will have a significant effect on the following European sites:

• Hook Head SAC (reefs)

• River Barrow and River Nore SAC (twaite shad, Atlantic salmon)

• Lower River Suir SAC (twaite shad, Atlantic salmon)

• Slaney River SAC (twaite shad, Atlantic salmon, harbour seal)

• Saltee Islands SAC (grey seal)

• Pembrokeshire Marine/Sir Benfro Forol SAC (grey seal)

• West Wales Marine/Gorllewin Cymru Forol SAC (harbour porpoise)

• Bristol Channel Approaches/Dynesfeydd Môr Hafren SAC (harbour porpoise)

• North Anglesey Marine/Gogledd Môn Forol SAC (harbour porpoise)

• North Channel SAC(harbour porpoise)

• Lleyn Peninsula and the Sarnau/Pen Llyn a’r Sarnau SAC (bottlenose dolphin, grey seal)

• Cardigan Bay/Bae Ceredigion SAC (bottlenose dolphin, grey seal)

It can therefore be determined that an Appropriate Assessment (AA) of the project is required. A Natura Impact Statement has been provided by the Applicant to inform the AA and is reviewed by RPS in the Appropriate Assessment report, submitted with this Screening for AA Technical Review.



5 ARTICLE 12 ASSESSMENT

5.1 Annex IV Species

Under Article 12 of the Habitats Directive, Annex IV species are afforded strict protection throughout their range, both inside and outside of designated protected areas. It is an offence to deliberately kill, injure or disturb animals listed in the Annex. Annex IV species identified as relevant to the proposed development include all cetaceans and turtles.

Chapter 10 in the EIAR provides an assessment on the impact of the proposed survey on marine mammals and reptiles, including the relevant Annex IV species. A baseline description of the species present in the vicinity of the proposed project is provided in Section 10.3 of the EIAR. Annex IV species that could potentially occur within the proposed development are listed in Table 10-2, along with their abundances and densities. A summary of seasonal distributions of marine mammal and reptiles within and near the proposed development is provided in Table 10-3.

Annex IV mammals and turtles whose distribution includes the Proposed Development are:

• Harbour porpoise (Phocoena phocoena)

• Short-beaked common dolphin (Delphinus delphis)

• Bottlenose dolphin (Tursiops truncatus)

• Striped dolphin (Stenella coeruleoalba)

• Risso’s dolphin (Grampus griseus)

• White-beaked dolphin (Lagenorhynchus albirostris)

• Long-finned pilot whale (Globicephala melas)

• Killer whale (Orcinus orca)

• Minke whale (Balaenoptera acutorostrata)

• Humpback whale (Megaptera novaeangliae)

• Fin whale (Balaenoptera physalus)

• Leatherback turtle (Dermochelys coriacea)

• Loggerhead turtle (Caretta caretta)

• Hawksbill turtle (Eretmochelys imbricate)

• Kemp’s Ridley turtle (Lepidochelys kempii)

• Green turtle (Chelonia mydas)

The EIAR assesses impacts to harbour and grey seals, however, as these species are not listed on Annex IV they not considered here. While otter is listed on Annex IV, it is not considered that there is any pathway to impact from the proposed development to this species and as a result, otter is not considered here.

5.1.1 Cetacean baseline assessment

The baseline assessment on cetaceans is provided in Section 10.3.2 of the EIAR. Of the 24 cetacean species found in Irish waters, 11 (listed above) are considered to have the potential to be present within the proposed development. Generally, the greatest numbers of cetacean species are present in coastal waters within the summer months (April to September) The Irish Whale and Dolphin Group (IWDG) website (http://www.iwdg.ie/) has 67 records of cetacean sightings near the Proposed Development for the period February 2018 to February 2019.

Harbour porpoise and short beaked common dolphin are the most abundant and commonly sighted species in the area, with most sightings taking place between spring and autumn. Other toothed whales (e.g. white beaked dolphin and long finned pilot whale) are sighted in low numbers, most frequently between spring and



autumn. Baleen whales (e.g. minke, humpback and fin whale) may also be sighted. The most frequently sighted baleen whale is the minke, with peak sightings taking place from May to September. The seasonal occurrence of regularly occurring cetaceans within and near the proposed development is provided in Table 10-3 of the EIAR.

Additional baseline information is provided for harbour porpoise and common dolphin, being the most abundant species in the area. The proposed development is within the Celtic and Irish Sea Management Unit (MU) for harbour porpoise, which includes four UK SACs designated for the protection of the species. Harbour porpoise are observed close to Hook Head all year round, with the greatest number of sightings occurring in the summer months. Although the proposed development is located over 50 km from the UK SACs, it is acknowledged that harbour porpoise from these sites may visit the area.

Short-beaked common dolphin is widely distributed throughout the proposed development and the continental shelf slope in summer, while strong seasonal shifts have been observed, leading to winter inshore movements onto the Celtic Shelf and into the western English Channel.

5.1.2 Marine turtles baseline assessment

A brief baseline assessment of marine turtles is given in Section 10.3.4 of the EIAR. Five species of turtle have been recorded in Irish water, the vast majority of which are leatherback turtle, and are generally sighted between June and October. Approximately 33 individuals are sighted per year in all UK and Irish waters. The Irish Sea is considered a through route for leatherbacks.

5.2 Discussion

5.2.1 Potential effects on cetaceans

The potential effects on marine mammals (including Annex IV cetacean species) from underwater noise and electromagnetic changes are considered in Section 10.6.2 and 10.6.3 (respectively) of the EIAR and are summarised in Table 10-7 in the EIAR.

5.2.1.1 Electromagnetic changes

Cetaceans are potentially sensitive to minor changes in magnetic fields and local variations caused by power cable electromagnetic fields (EMFs) during operation, affecting their ability to navigate within the immediate vicinity of the cables. Submarine power cables generate magnetic fields owing to the electric current flowing along the cables. The magnitude of the magnetic field (B field) produced is directly dependent on the level of flow. In addition, localised static electric fields may be induced as seawater (tidal flow) or other conductors such as marine organisms pass through the DC cable’s magnetic field. These induced electric fields (iE fields) will attenuate with distance from the cable conductor. Burial depth can reduce the effect range of EMFs but to a lesser extent than cable bundling, due to mutual cancellation of the positive and negative poles and currents travelling in opposite directions.

The assessment calculated that the Greenlink cables will generate B fields of 21μT directly over the cables reducing to natural background levels within 2m. The iE fields are estimated to be between 48.79 and 69.7 μV/m at 1 m from the cables. No detectable change above background geomagnetic fields will be noticeable at 2 m from the cables. For a short section of the cable route after the cables exit the HDD point (approximately between 9 m and 15 m) they will not be bundled, and as a result the iE fields will be higher; up to 128.7 µV/m at the seabed, reducing to 63.7 µV/m at 10 m from the cable and returning to natural background levels within 12 m.

The assessment concluded that due to the localised nature of the higher electromagnetic changes and the fact that cetaceans are predominantly pelagic, it is unlikely that cetaceans will be sensitive to these changes and the effect is classified as imperceptible. This current assessment agrees with this conclusion.

5.2.1.2 Underwater noise changes

Auditory injury in marine mammals, including cetaceans, can be defined as a permanent threshold shift (PTS) leading to non-reversible auditory injury, or as a temporary threshold shift (TTS) in hearing sensitivity, which can have negative effects on the ability to use natural sounds (e.g. to communicate, navigate, locate prey) for a period of minutes, hours or days. Potential effects to cetaceans from underwater noise changes



are injury (PTS/TTS) and/or disturbance from continuous (geophysical survey and vessel activity) and impulsive (UXO detonation) sources.

A range of best practice measures are built into the project design, also referred to as ‘embedded mitigation’ and those relevant to marine mammals are outlined in Table 10-6 of the EIAR. These measures include vessel speeds not exceeding 14 knots within the proposed development, a decision-making process to be followed which seeks to avoid in-situ UXO detonation if possible, and a requirement for contractors to comply with DAHG (2014) ‘Guidance to Manage the Risk to Marine Mammals from Man-made sound source in Irish Water’.

An assessment was carried out to calculate the zones of influence for injury and disturbance to marine mammals, combining literature review with underwater sound modelling. The assessment refers to thresholds for PTS and TTS published in Southall et al. (2007) and those presented in NMFS (2018). The thresholds in Southall et al. (2007) have been updated those published in Southall et al. (2019), however, it is noted that this application was submitted in 2019 and therefore it is likely that the updated thresholds were not available at this time. The marine mammal injury criteria published in Southall et al. (2019) utilise the same hearing weighting curves and thresholds as presented in NMFS (2018), therefore it is considered that the assessment provided makes use of best available evidence. Note that the naming of different hearing groups differs between NMFS (2018) and Southall et al. (2019). A comparison between the two naming conventions is shown in Table 5.1 below. It is noted that the estimated zones of influence are highly conservative due to the methods used.

Table 5.1 Comparison of hearing group names between NMFS (2018) and Southall et al. (2019)

NMFS (2018) hearing group name Southall et al. (2019) hearing group name

Low frequency cetaceans Low-frequency cetaceans

Mid frequency cetaceans High-frequency cetaceans

High frequency cetaceans Very high-frequency cetaceans

Otariid Pinnipeds in water Other marine carnivores in water

Phocid pinnipeds in water Phocid carnivores in water

The underwater noise assessment concluded that for cable installation activities generating continuous noise (vessel using dynamic positioning (DP), rock placement and trenching) no cetaceans are at risk of PTS and TTS. The zone of influence for disturbance for all cetaceans is 130m.

For near-continuous noise (geophysical survey), the ‘worst-case’ zones of influence for PTS and TTS are 110 m and 189 m for high frequency cetaceans (reclassified as very high frequency cetaceans by Southall et al. (2019) – i.e. harbour porpoise), with smaller zones of influence for other cetacean groups. The ‘worst-case’ zone of influence for disturbance is 2.6 km for all cetaceans.

For activities generating impulsive sound (i.e. UXO detonation), the ‘worst-case’ modelled scenario found that high frequency cetaceans (i.e. harbour porpoise) are at risk of PTS and TTS within 23 km and 27 km of the source, respectively, with smaller zones of influence for other cetacean groups. All cetaceans are at risk of disturbance within 54 km of the source.

With the designed-in measures described above in place, the potential for impacts to cetaceans from geophysical survey and vessel activity noise was assessed as slight for injury effects and imperceptible for disturbance effects. Even with these measures in place, effects to cetaceans from UXO detonation remained significant for injury and moderate for disturbance. As a result, a number of project specific mitigation measures were proposed in the EIAR, with additional measures proposed in the information provided following the RFI. An up-to-date list of mitigation measures is provided in Table 9-2 in ‘Greenlink Information to Inform 2nd Public Consultation’. In summary, the following measures are proposed to mitigate for effects on cetaceans from UXO detonation:

• Avoid need for detonation, as described in the ‘embedded mitigation’.

• Use of deflagration for all UXO charge sizes to reduce the zone of influence.

• Use of visual and acoustic monitoring prior to detonation.

• Use of noise abatement (e.g. big bubble curtain) and acoustic deterrent devices.

• Soft start procedure in line with DAFM (2014) guidelines.



5.2.2 Potential effects on turtles

The impacts of underwater noise on turtle species is poorly understood, and there is no existing data on the effects of continuous sound on turtles. Effects of impulsive sound from UXO detonations on sea turtles was been considered in Technical Appendix C of the EIAR. Mortality and potential mortal injury were considered likely to occur within 6.2 km and 4.2 km, respectively of the sound source. Other sources of underwater noise are not considered with regards to effects on turtles. Potential impact from UXO detonation on sea turtles was assessed as slight. Sea turtles are unlikely to be found in high numbers in the area, as they are rare visitors and effects were therefore assessed as slight and not significant.

5.3 Article 12 Conclusion

With the implementation of measures embedded into the project design (i.e. implementation of DAHG (2014) guidelines) it is not expected that underwater noise from continuous sources (geophysical survey and cable installation vessel activity) will not give rise to significant impacts to cetacean species listed under Annex IV of the Habitats Directive.

Given the rarity of occurrence of turtles in Irish waters, the perceived limited sensitivity of the receptor and the moderate intensity of nature of the continuous noise sources, it is concluded that geophysical survey and cable installation activity will not give rise to significant impacts to turtles.

Implementation of both embedded and project-specific measures will mitigate impacts from UXO detonation in line with industry best-practice, and it is recommended that the applicant develops a UXO clearance mitigation plan which clearly outlines the procedures to be followed in the unlikely event of the requirement to detonate UXO. Such a plan should be developed in line with DAHG (2014) guidance and engagement with the Irish Naval Service, NPWS and the EPA is recommended. DHLGH may wish to condition a UXO mitigation plan as part of the Foreshore Licence.

It is noted that formal determination of whether further assessment of Annex IV species is required will be made by the Minister for the DHLGH. The Minister’s determination will not be prejudiced by this review.



6 REFERENCES

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NMFS (National Marine Fisheries Service). 2018. “2018 Revision to: Technical Guidance for Assessing the

Effects of Anthropogenic Sound on Marine Mammal Hearing (Version 2.0).” NOAA Technical Memorandum

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