Greenlink · Rev0 14/12/16 Draft RJ AF AF Rev 1 ... ing name of Metoc Ltd, a member of the Intertek...

P1975_R3994_Rev1 | 19/12/2016

GREENLINK

GREENLINK INTERCONNECTOR

ENVIRONMENTAL SCOPING REPORT - UK MARINE ROUTE


I

0. DOCUMENT RELEASE FORM

Greenlink

P1975F_BN4107_Rev1

Greenlink Interconnector

ENVIRONMENTAL SCOPING REPORT - UK MARINE ROUTE

Project Manager Authoriser

Anna Farley Anna Farley

RevNo Date Reason Author Checker Authoriser

Rev0 14/12/16 Draft RJ AF AF

Rev 1 19/12/16 Final RJ AF AF

Intertek Energy & Water Consultancy Services is the trading name of Metoc Ltd, a member of the Intertek

group of companies.


II

Contents

1. Introduction .................................................................................................................................................... 1

1.1 Project overview .................................................................................................................................... 1

1.2 The developer ........................................................................................................................................ 2

1.3 Project need .......................................................................................................................................... 2

1.4 EIA screening and scoping ..................................................................................................................... 4

2. Project Description .......................................................................................................................................... 7

2.1 Overview ................................................................................................................................................ 7

2.2 Selected landfall .................................................................................................................................... 8

2.3 Marine route development and alternatives considered ..................................................................... 9

2.4 Cable specification ............................................................................................................................... 12

2.5 Pre-construction route survey ............................................................................................................. 12

2.6 Pre-installation .................................................................................................................................... 14

2.7 Installation operations ......................................................................................................................... 15

2.8 Cable operation ................................................................................................................................... 17

2.9 Unplanned events................................................................................................................................ 17

2.10 Decommissioning ................................................................................................................................ 18

2.11 Timescales ........................................................................................................................................... 18

3. Legislative Framework .................................................................................................................................. 19

4. Physical Environment .................................................................................................................................... 25

4.1 Metocean conditions ........................................................................................................................... 25

4.2 Geology, geomorphology and sedimentary processes ....................................................................... 27

4.3 Water and seabed quality ................................................................................................................... 31

5. Biological Environment ................................................................................................................................. 35

5.1 Intertidal and benthic communities .................................................................................................... 35

5.2 Fish and shellfish ................................................................................................................................. 40

5.3 Birds ..................................................................................................................................................... 45

5.4 Marine mammals and reptiles ............................................................................................................. 47

5.5 Protected sites ..................................................................................................................................... 51

6. Human Environment ..................................................................................................................................... 57

6.1 Commercial fisheries ........................................................................................................................... 57

6.2 Shipping and navigation ...................................................................................................................... 59

6.3 Infrastructure and other users ............................................................................................................ 62

6.4 Marine archaeology ............................................................................................................................. 66

7. Impact Assessment Methodology ................................................................................................................. 68

7.1 Introduction ......................................................................................................................................... 68

7.2 Basis of the assessment ....................................................................................................................... 68

7.3 Environmental assessment approach .................................................................................................. 68

7.4 Structure of the Environmental Report ............................................................................................... 76

8. Summary of Assessment ............................................................................................................................... 78

9. Scoping Questions ......................................................................................................................................... 80

10. References ............................................................................................................................................... 81

Appendix A – Consultee List .................................................................................................................................. 84

Appendix B – Screening Opinions ......................................................................................................................... 85


III

0. GLOSSARY

AA

Appropriate assessment

BTO

British Trust for Ornithology

BWD

Bathing Waters Directive

CA

Crossing agreement

CADW

Welsh Government's historic environment service

CEFAS

Centre for Environment, Fisheries and Aquaculture Science

CFP

Common Fisheries Policy

dB

Decibels

DP

Dynamic positioning

EA

Environment Agency

EC

European Commission

EEZ

Exclusive Economic Zone

EIA

Environmental impact assessment

EQS

Environmental quality standards

EMF

Electromagnetic field

EPS

European Protected Species

EU

European Union

HDD

Horizontal directional drilling

ICES

International Council for the Exploration of the Sea

IFCA

Inshore Fisheries Conservation Authority

IMO

International Maritime Organisation

IUCN

International Union for the Conservation of Nature

JNCC

Joint Nature Conservation Committee

KISCA

Kingfisher Information Services- Cable Awareness

km

Kilometre

km2

Square kilometre

m

Metre

m2

Square metre

MAC

Maximum allowable concentrations

MARPOL

International Convention for the Prevention of Pollution from Ships

MCA

Maritime and Coastguard Agency

MCAA

Marine and Coastal Access Act

MCZ

Marine Conservation Zone

MHWS

Mean high water spring

MMO

Marine Management Organisation

MOD

Ministry of Defence

MU

Management unit

MW

Mega watt


IV

NFFO

The National Federation of Fishermen’s Organisations

NEAFC

North East Atlantic Fisheries Commission

nm

Nautical mile

NRA

Navigation Risk Assessment

OSPAR

Oslo Paris Convention

PAD

Protocol for Archaeological Discovery

PAH

Polycyclic aromatic hydrocarbons

PCB

Polychlorinated biphenyls

pSAC

Possible Special Area of Conservation

PTS

Permanent threshold shift

PWA

Protection of Wrecks Act

RBMP

River Basin Management Plans

RYA

Royal Yachting Association

SAC

Special Area of Conservation

SEA

Strategic Environmental Area

SFWD

Shellfish Waters Directive

SPA

Special Protection Area

SPM

Suspended particulate matter

SSS

Side scan sonar

TBT

Tributyltin

TCE

The Crown Estate

TEN-E

Trans-European Networks for Energy Regulation

TJB

Transition joint bay

TSS

Traffic separation scheme

TTS

Temporary threshold shift

UK

United Kingdom

UK BAP

UK Biodiversity Action Plan

UKDMAP

United Kingdom Digital Marine Atlas

UKHO

United Kingdom Hydrographic Office

UXO

Unexploded ordnance

WFD

Water Framework Directive

WNMP

Welsh National Marine Plan


19 December 2016 1

1. INTRODUCTION

This Scoping Report has been prepared by Intertek Energy & Water Consultancy Services (Intertek)

on behalf of Greenlink. The purpose of the Report is to consult with statutory consultees and other

interested parties on the approach to, and scope of, a non-statutory Environmental Appraisal of the

proposed installation, operation and maintenance of the Greenlink Interconnector.

This report covers the UK marine component of the proposed route from mean high water springs

(MHWS) at Freshwater West to the UK/Ireland median line. A separate report has been prepared

(P1975F_R4102_Rev0) which covers the remainder of the route from the median line to landfall on

the Hook Head Peninsula, County Wexford, Ireland. High level description of the entire route has

been provided in the following sections where necessary to facilitate scoping opinion.

Generally the potential environmental effects of the onshore and offshore parts of the project are

relatively discrete and not interrelated; however, there is some overlap in the intertidal area at the

cable landfalls. A separate onshore scoping report will be produced as part of the onshore planning

application process which will cover the onshore area down to mean low water springs (MLWS).

The installation of the cables is not considered to constitute ‘EIA Development’ as defined under the

Marine Works (Environmental Impact Assessment) Amendment Regulations 2011 – see Section 1.4.

1.1 PROJECT OVERVIEW

Greenwire Transmission Pembroke Ltd, trading as ‘Greenlink,’ is proposing to develop an electricity

interconnector linking the existing electricity grids in the UK and Ireland. The ‘Greenlink’ project will

consist of two converter stations, one close to the existing substation at Great Island in County

Wexford (Ireland) and one close to the existing substation at Pembroke in Pembrokeshire (Wales)

(Figure 1-1). The converter stations will be connected by underground cables (onshore) and subsea

cables (offshore).

Greenlink will have key strategic importance providing significant additional interconnection

between Ireland, the UK and onwards to mainland Europe. It will provide additional transmission

network capacities, reinforcing the existing electricity grids in south-east Ireland and south Wales

and contributing to each country’s strategic interconnection objectives. The development and

construction of Greenlink will deliver increased security of supply, fuel diversity, greater competition

and ultimately provide significant benefits to consumers in Ireland, Wales and Great Britain as a

whole.

Greenlink was awarded an Interconnector Licence in Great Britain, by Ofgem, on 10th February 2015

and was also awarded Initial Project Assessment (IPA) Status under Ofgem’s Cap and Floor Regime,

on 30th September 2015.

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 (CEF).


19 December 2016 2

Figure 1-1 Greenlink overview (shortlisted routes)

1.2 THE DEVELOPER

Element Power, the global renewable energy developer behind the Greenlink Interconnector

project, develops, acquires, builds, owns and operates a portfolio of wind and solar power

generation facilities worldwide. Element Power is owned by Hudson Clean Energy Partners, a global

private equity firm dedicated solely to investing in renewable power, alternative fuels, energy

efficiency and storage.

Greenwire Transmission Pembroke Ltd is the project company incorporated by Element Power to

develop the Greenlink interconnector project. In Wales, a connection agreement has been signed

with National Grid for a grid connection at the Pembroke substation.

1.3 PROJECT NEED

The UK is currently connected to Ireland by two “two-way” electricity interconnectors; the East West

Interconnector (EWIC), County Dublin to North Wales; and Moyle, County Antrim, Northern Ireland

to Ayrshire, Scotland, which provides a means of transferring electricity between the two countries.


19 December 2016 3

However, the challenges faced by the British, Irish and wider European energy system drives the

need for additional interconnectors. There is strong support within Europe for additional

interconnection.

The “Energy Union” launched by the European Commission on 25th February 2015 is driving a

fundamental transition towards more innovative ways to produce, transport and consume energy,

and to address different approaches to the design and implementation of energy policy. Facilitating

the Union requires a range of actions, chief amongst them being an increase in the physical

interconnectedness of the EU and surrounding country energy grids (both gas and electricity) to

meet a 10% interconnectedness target by 2020 and to reach 15% by 2030.

An interconnected European energy grid is vital for Europe's energy security, for more competition

in the internal market resulting in more competitive prices as well as for better achieving the

decarbonisation and climate policy targets which the European Union has committed to. An

interconnected grid will help deliver the ultimate goal of the Energy Union, i.e. to ensure affordable,

secure and sustainable energy, and also growth and jobs across the EU.

Greenlink will have key strategic importance as it will provide significant additional interconnection

between Ireland, the UK and continental Europe. It will also provide additional transmission network

capacities, reinforcing the existing electricity grids in south-east Ireland and south Wales. The

development and construction of Greenlink will deliver increased security of supply, fuel diversity

and greater competition in Ireland, Wales, Great Britain as a whole and continental Europe. The link

is expected to provide significant benefits to consumers in Ireland and Great Britain and contribute

to each country’s strategic interconnection objectives.

Greenlink is strategically placed to reinforce the power grids in the south of Ireland and in South

Wales by connecting to the existing radial transmission network, creating an increasingly meshed

network and so improving security of supply.

Greenlink’s location in respect of the existing Moyle and EWIC interconnectors also enables EirGrid

and National Grid to increase the use of these connections to manage power flows on their networks

reducing network constraints and hence reducing costs of operating their transmission systems.

The main benefits from the Greenlink interconnector are expected to be:

▪ Strategically placed to reinforce the south of Ireland by connection to Wales, creating synergy

with existing interconnectors EWIC and Moyle connecting the centre and north of Ireland to GB;

▪ Provides reinforcement to transmission boundaries in South Wales;

▪ Provides additional import and export capacity for the Island of Ireland;

▪ Greater market integration;

▪ Greater sharing of reserve, generation capacity and ancillary services between GB and the Island

of Ireland; and

▪ Reduce CO2 emissions.


19 December 2016 4

1.4 EIA SCREENING AND SCOPING

1.4.1 NEED FOR ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

Greenlink requested screening opinions from the marine consenting authorities – Natural Resources

Wales (Welsh territorial waters) and the Marine Management Organisation (MMO; UK offshore

waters) – to confirm the view that a statutory Environmental Impact Assessment (EIA) is not

required for the installation of the marine cables in Welsh territorial and UK offshore waters. NRW

has confirmed that as marine cables are not listed under Annex I or II of the Marine Works

(Environmental Impact Assessment) Amendment Regulations 2011, the proposed interconnector

does not constitute an “EIA development”. Therefore, a statutory environmental impact assessment

(EIA) is not required to support the Marine Licence application.

The MMO has confirmed that the installation of the interconnector cable in UK waters i.e. beyond

12nm limit, is exempt from marine licence requirement under Section 81(1) of the Marine and

Coastal Access Act 2009 (MCAA). However, the deposition of protection material e.g. grout

mattresses or rock dumping, would be a licensable activity and would require a Marine Licence. The

Marine Licence would not need to be supported by a statutory EIA.

The screening opinions obtained from NRW and the MMO are provided as Appendix B.

Under Schedule 9 of the UK Electricity Act, 1989, Greenlink as an interconnector licence holder, will

have a “duty to preserve amenity”. In anticipation of its duty Greenlink is committed to completing

appropriate marine surveys and assessments. The scale of the project and its location require that a

number of issues in respect of potential environmental effects should be addressed and Greenlink

consider it best practice to meet its obligations by undertaking a series of non-statutory

Environmental Appraisals (EA).

Whilst not a statutory EIA; the EAs will be undertaken in accordance with all relevant industry best

practice. An Environmental Report (ER) will be prepared and will accompany the Marine Licence

applications to NRW and MMO. This will report on the environmental appraisal process, its findings

and conclusions for the marine components of the project. It will set out proposed mitigation

measures to avoid or reduce the level of impact to an acceptable level.

Under the requirements of the TEN-E Regulations, Greenlink will be required to agree with the

Welsh Government a ‘Schedule of Permit Granting Process’. The Schedule is an in principle timeline

that outlines the dates, decisions and opinions necessary for the project to proceed. Under this

Schedule and Article 10(4) (c) of the TEN-E Regulation, Greenlink will be required to submit a Draft

Application File to NRW. NRW are required to review the draft application and identify whether they

consider any information to be missing. The Environmental Report will form part of the Draft

Application File.

1.4.2 PURPOSE OF SCOPING REPORT

This Scoping Report forms a written request, on behalf of Greenlink, for an opinion as to the

information to be considered within the non-statutory EA of the marine interconnector route as well

as the approach to the appraisal.


19 December 2016 5

The aim of the scoping process is to assist a developer in identifying the key environmental issues

surrounding their proposal. It also provides statutory and non-statutory consultees with an

opportunity to comment on the proposed development, the scope of the EA and raise any issues

which they consider may be important to the EA process. This in turn can help provide direction on

the topics the EA should focus on.

The specific aims of the scoping report are to:

▪ Describe the proposed project;

▪ Undertake a preliminary review of the existing environmental baseline within and surrounding

the project area;

▪ Identify key sensitivities / receptors likely to be affected by the project;

▪ Identify the potential environmental issues which are to be assessed as part of the EA;

▪ Identify those issues which can be scoped out of the EA;

▪ Set out the approach of the EA and the proposed structure and content of the Environmental

Report (which reports the findings of the EA);

▪ Agree the general approach to the assessment and the specific methodologies for each technical

discipline;

▪ Provide details / plan for technical studies, methodologies and resources to be used;

▪ Address any comments received as feedback from the screening stage; and

▪ Provide a framework for consultation with statutory and non – statutory consultees (listed in

Appendix A).

1.4.3 STRUCTURE OF SCOPING REPORT

The remainder of this scoping report is set out in the following sections (Table 1-1):

Table 1-1 Structure of Scoping Report

Section Title

2 Project Description

3 Legislative Framework

4 Physical Environment

5 Biological Environment

6 Human Environment

7 Impact Assessment Methodology

8 Summary of Assessment

9 Scoping Questions


19 December 2016 6

Within Sections 4 to 6 each receptor topic is divided into the following sub-sections:

▪ Existing environment: Baseline description based on current knowledge.

▪ Identification of key sensitivities and potential impacts: Identified key sensitivities based on

baseline description and a summary of the potential impacts of the project on each receptor.

Environmental Appraisal approach: A table for each receptor topic presents the approach to be

taken within the EA in terms of sources of information to be used and the scope of assessment for

each aspect of the receptor topic. The table also summarises any specialist studies / surveys which

will be undertaken by Greenlink in support of the EA.

1.4.4 SCOPING OPINION

It is requested that any correspondence relating to this Scoping Report be directed to:

Anna Farley Intertek Exchange House, Station Road, Liphook, Hampshire, GU30 7DW D: 01428 728 537 E: [email protected]

The closing date for comments to be returned by is 28 February 2017.

1.4.5 CONSULTATION

The following meetings/discussions have been held with primary advisors and consultees:

Table 1-2 Consultation undertaken to date

Meeting Date Objective

UK

NRW 25 Aug 2016

15 Dec 2016

EIA screening request submitted

EIA Screening decision received

MMO 06 Sep 2016

07 Nov 2016

EIA Screening request submitted

EIA Screening decision received

The Crown Estate 08 Jan 2016 Greenlink provided project update and requested conflict check.

09 May 2016 TCE provided conflict check

NRW 11 Feb 2016 Joint meeting to discuss onshore and offshore aspects of project. Presented potential routes, discussed baseline studies, requested initial scoping advice.

Pembrokeshire County Council

Pembrokeshire Coast National Park

Port of Milford Haven Harbour Authority

11 Feb 2016 Provided project update including discussion of potential marine route. Received feedback on permitting expectations.

Rural Steering Group (Castlemartin Firing Range, Pembray Sands Air Weapons Range, Manorbier Firing Range, NRW, Pembrokeshire Coast National Park)

11 Feb 2016 Provided update on the Greenlink project. Group has previously been briefed on the Greenwire project.


19 December 2016 7

Meeting Date Objective

Ireland

National Parks & Wildlife Service (NPWS)

09 Dec 2015 Discussed onshore and offshore aspects of project, focusing on choice of landfall sites. Requested advice regarding Hook Head SAC.

04 July 2016 Provided habitat data for Hook Head SAC

Department of Housing, Planning, Community and Local Government (DHPCLG) – Foreshore Unit

18 Dec 2015

(via email)

Submitted pre-application for Foreshore Licence to cover marine survey campaign (geophysical, geotechnical and environmental).

Department of Arts, Heritage and the Gaeltacht (DAHG) – Underwater Archaeology Unit (UAU)

15 Feb 2016 Discussed archaeological requirements that may be a condition of the foreshore licence for geotechnical aspects of marine survey programme.

Port of Waterford Harbour Authority 09 Mar 2016 Provided project information and discussed feasibility of landfalls with Waterford estuary.

Jul – Aug 2016 Discussions regarding feasibility and potential route to Boyce’s Bay.

Department of Communications, Climate Action & Environment - Petroleum Affairs Division

10 Aug 2016 Confirmed that consent under the Continental Shelf Act is not required for the installation of the cable within Irish EEZ or for associated cable protection material

Environmental Protection Agency 11 Aug 2016 Confirmed that Dumping at Sea permit will not be required for the project.

This Scoping Report has been circulated to the list of consultees presented in Appendix A

2. PROJECT DESCRIPTION

2.1 OVERVIEW

Greenlink proposes to develop an electricity interconnector, which will allow transfer of power

between the high voltage grid systems of the UK and the Republic of Ireland. The power would be

able to flow in either direction at different times, depending on the supply and demand in each

country. The proposed marine cable route would run from Freshwater West, Pembrokeshire to the

Hook Head Peninsula in County Wexford.

Greenlink will use high voltage direct current voltage source converter (HVDC VSC) technology to link

the two power systems. HVDC is preferred to an alternating current (AC) connection, because it can

be much more easily controlled according to trading and market requirements, and has much lower

losses at the distances being considered. The VSC technology requires less reinforcement to the AC

grid at the connection points (compared to older current source converters), as well as allowing very

rapid change of flow direction and reactive power, which is valuable to system operators when

managing grid stability.

As both national electrical systems use high voltage alternating current (HVAC) supply, convertor

stations will be located near each substation to convert the HVAC electrical supply to HVDC. A

converter station consists of various components, including: a converter hall; converter

transformers; AC switchgear and busbars; harmonics filters; lightning towers; ancillary plant; and a

control building. Typically the tallest components are the lightning towers at circa 26m high and the

converter hall, which could be up to 21m high at its apex. The layout of the converter station and


19 December 2016 8

final dimensions will depend on the local terrain, physical constraints, the results of environmental

surveys, consultation and the supplier’s technical requirements.

Onshore routes from the Pembroke converter substation to the landfall will be the subject of a

separate scoping exercise. The following section describes: the selected marine cable route; the

proposed landfall; the marine survey programme; the proposed method of cable installation;

operation, maintenance and decommissioning; and the project timescales.

2.2 SELECTED LANDFALL

In 2012 extensive option feasibility studies were carried out to identify suitable landfall options. As

part of this work four options to the south of Milford Haven and seven options to the north of

Milford Haven were considered.

Freshwater West was identified as the preferred landfall on the Welsh coast as it offers close

onshore connection to the Pembroke substation. In addition it would not require a technically

challenging crossing of Milford Haven. Facing south westerly it is a wide sandy beach backed by an

extensive system of sand dunes. These dunes form part of the Angle Peninsula Coast Site of Special

Scientific Interest (SSSI). At the southern end of the beach is an area of rocky reef.

The exact location of the landfall and onshore construction compound are still to be decided. Given

the ecologically sensitive nature of the site a number of locations have been considered. The

preferred option is a site located at the north end of the beach.

The southern end of the beach is part of the Castlemartin Firing Range, which extends out into

nearshore waters. The beach contains two areas of archaeological interest: an upside down wooden

wreck and a fossil forest (see Section 6.4 below). It is also popular for surfing, canoeing, windsurfing,

walking and sea fishing.


19 December 2016 9

Figure 2-1 Aerial view of Freshwater West

Figure 2-2 Freshwater West (facing north)

Figure 2-3 View from site of preferred onshore compound

2.3 MARINE ROUTE DEVELOPMENT AND ALTERNATIVES CONSIDERED

Element Power Ireland commissioned Intertek Energy & Water Consultancy Services to provide a

marine route selection report for the Greenlink interconnector. The report identifies possible

marine cable routes between Freshwater West, Wales and the Hook Head Peninsula, Ireland. The

most suitable route will be the shortest and least constrained route. However, there is a balance to

be achieved between the length and environmental, technical and economic constraints.

Each constraint was identified and categorised according to the likely impact on installation of the

interconnector cable. Constraints were categorised as ‘major’, ‘moderate’ or ‘minor’ with remaining

space classified as ‘no constraint’. The aforementioned constraint categories were mapped and

routes were drawn to fit around them, where possible and if necessary.


19 December 2016 10

The outcome was the development of one route through UK waters (Figure 2-4), which branches

into different options in Irish waters, depending on the shortlisted Irish landfall.

Within UK waters the route avoids offshore shipping lanes, dumping grounds around the Port of

Milford Haven and as far as possible the Ministry of Defence firing range at Castlemartin. It has

endeavoured to avoid marine protected sites where possible, although given the high concentration

in Welsh waters this has been difficult. It is the intention that data acquired during the proposed

2018 marine survey campaign will allow identification of sensitive habitats and subsequent micro-

routing and/or development of appropriate mitigation.

. Figure 2-4 Shortlisted Marine Route

Created ByReviewed By

Jennifer ArthurEmma Langley

Monday, December 19, 2016 09:03:12WGS_1984_UTM_Zone_29N

D_WGS_1984DECC, UKDEAL, UKHOJ:\P1975\Mxd\Scoping Report\Report Figures\UK_Overview_SMR.mxd

WGS_1984

DateProjection

DatumData Source

File Reference

Spheroid

NOTE: Not to be used for Navigation

Contains Ordnance Survey Ireland data © OSi 2012. © Crown Copyright, 2015. Charts from MarineFIND.co.uk © Crown Copyright, 2015. All rights reserved. Licence No: EK001-1001-WEB105. Not to be used for Navigation.

Approved By Anna Farley

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Pembroke

Freshwater West

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5700

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5700

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5720

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5720

000

5740

000

5740

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5760

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Legend!( Landfall") Substation

Shortlisted Marine Route

12nm limitMedian Line

0 2 4 6 8 10km

.

Drawing No.Scale 1:300,000

DN_P1795_LA_002_Rev_0

© Metoc Ltd, 2016.All rights reserved.

Greenlink InterconnectorEnvironmental Scoping Report -

UK Marine Route


19 December 2016 12

2.4 CABLE SPECIFICATION

Greenlink will be a bipole submarine cable system. Bipole systems transmit power via a closed

circuit of two HVDC submarine cables laid alongside each other. Cables can either be installed

individually in the seabed with varying widths apart according to water depth, or more commonly

bundled together as a pair with no separation between the cables (Figure 2-5). A fibre optic cable

may also be laid for control and communication purposes.

There are currently two types of DC submarine cable available (Figure 2-6): mass impregnated (MI)

paper; and cross linked polyethylene (XLPE). The basic design of both cables is similar, with the key

difference being the materials used for insulation. MI insulation is formed of numerous layers of

tapes made from natural wood pulp based paper, impregnated with mineral grease. This type of

cable has been in use for HVDC submarine cables since the 1950’s and has proven to be extremely

reliable. XLPE is an extruded polyethylene material that is thermoset after extrusion through a

controlled heating process. XLPE cables have been in use for AC applications since the 1980’s and for

HVDC applications since around 2000 and have also proven to be reliable.

Both cable types have a lead sheath to ensure no moisture can penetrate the insulation and heavy

steel wire armour to protect the cables from external damage during installation and

burial/protection. The armouring is made from round or flat steel wire wound in a helical form.

Over the armour wires a polyethylene sheath is applied to make the cable easier to handle and

ensure the armour wires remain in place during bending.

Figure 2-5 Typical cable bundle arrangement

Figure 2-6 Typical MI submarine cable

2.5 PRE-CONSTRUCTION ROUTE SURVEY

A pre-construction marine survey campaign is proposed for a suitable period between summer 2017

and summer 2018. The objective of the campaign is to acquire all appropriate data for the

confirmation of a preferred offshore route. This includes: detailed mapping of nearshore shallow

geological and seabed character; reconnaissance level mapping of seabed relief and features along

offshore sections; and baseline environmental mapping along the entire route corridor. The likely

scope of the Greenlink survey campaign is detailed in Table 2-1.


19 December 2016 13

Table 2-1 Marine survey scope of work

Objective Method Specifications

Offshore route corridor (>15m water depth)

Bathymorphology

Wide area bathymetry and seabed features mapping for cable route engineering evaluation and environmental characterisation.

Swath bathymetry, sidescan sonar, sub bottom profiler

Nominal 1km wide corridor

<1m target detection

Target & crossings investigation

Unidentified seabed anomaly characterisation and archaeological assessment

Confirmation of alignment and character of existing cables / pipelines

Sidescan sonar, magnetometer, ROV

Target list graded by significance

Seabed sampling

Environmental sampling for confirmation of biotope and seabed characterisation for environmental baseline mapping

Environmental grab Sampling locations selected from preliminary interpretation of sidescan sonar data, nominally 5km interval

Seabed imagery

Visual confirmation of biotope and seabed characterisation

Drop-down video camera

<1km traverse locations coincident with each environmental sampling location

Nearshore route corridor (nominal 3 to 15m water depth)

Geophysical & hydrographic

Detailed bathymetry, seabed features and shallow geology mapping for cable landfall approach, engineering evaluation and environmental characterisation.

Swath bathymetry, sidescan sonar, subbottom profiler and magnetometer

Nominal 1km wide corridor

<1m target detection

Target investigation

Unidentified seabed anomaly characterisation and archaeological assessment

Magnetometer Target list graded by significance

Seabed sampling

Environmental sampling for confirmation of biotope and seabed characterization for environmental baseline mapping

Environmental grab Sampling locations selected from preliminary interpretation of sidescan sonar data, nominally 1km interval

Seabed imagery

Visual confirmation of biotope and seabed characterisation

Drop-down video camera

Locations coincident with each environmental sampling location

Landfall site (nominal 3 to 15m water depth)

Geotechnical borehole

Confirmation of geology to ground truth geophysical and shallow geology for purposes of determining HDD feasibility

25m deep borehole 4 geotechnical boreholes up to 25m deep at 250m spacing from beach


19 December 2016 14

In addition to the marine campaign the following surveys may also be commissioned, following

results of consultation:

▪ Intertidal survey focusing on identifying any EC Habitats Directive Annex I habitats present;

▪ Over-wintering bird survey;

▪ Archaeological desk-based study; and

▪ Archaeological review of marine and intertidal survey data.

It is anticipated that the marine survey campaign will be conducted between May and October 2018.

2.6 PRE-INSTALLATION

2.6.1 SURVEY REQUIREMENTS

Although the marine survey campaign discussed in Section 2.5 above, will have been completed for

the marine cable route, further surveys will be completed by the cable installation contractor prior

to commencement of cable installation. This typically takes place 3-6 months ahead of installation.

The primary objective of these surveys is to confirm that no new obstructions have appeared on the

seabed since the detailed engineering surveys, and to complete unexploded ordnance (UXO)

clearance survey. The survey will involve a range of standard geophysical survey techniques such as

multi-beam echosounder, side scan sonar (SSS), sub-bottom profiler and magnetometer.

2.6.2 SEABED PREPARATION

In general little or no preparation of the seabed is required prior to laying cables. However, the

marine survey may indicate short sections where some preparation is required. Typical techniques

that may be used include:

▪ Mass flow excavation: used in in areas of mobile sediments such as sand waves. The technique

removes a portion of the sandwave (referred to as pre-sweeping), depositing it on either side of

the trench. This removes the excessive inclines on the sandwave, creating a flatter profile, or

‘working profile’, for the burial machine.

▪ Boulder removal: used in areas of boulder fields. A plough is towed across the seabed which

pushes the boulders to one side clearing a swathe for the burial machine.

2.6.3 ROUTE CLEARANCE AND PRE-LAY GRAPNEL RUN

Immediately prior to the installation a heavy grapnel with a series of specially designed hooks, or

grapnels, approximately 1m width and 0.5m – 1m penetration depth will be towed along the

centreline of the cable route by either a work boat or the cable lay vessel. The purpose of the pre-

lay grapnel run is to clear any debris from the cable route, such as lost fishing gear, that could impact

on the cable burial operations. Debris retained by the grapnel will be collected on board and

disposed of appropriately through licensed onshore facilities.


19 December 2016 15

2.7 INSTALLATION OPERATIONS

2.7.1 VESSELS

The cable lay operation will be performed on a 24-hour basis to ensure minimal navigational impact

on other users and to maximise efficient use of suitable weather conditions and vessel and

equipment time. A ‘rolling box’ technique will be employed for installation so that only the area

required by the installation vessel, its attendant tugs and support vessels will be restricted to other

marine traffic. The remainder of the route will remain open to normal marine activities.

Notifications will be issued in accordance with statutory procedures to ensure navigational and

operational safety. In addition to the installation vessel(s), additional vessels (i.e. guard vessels) will

be involved with the operation. Although exact details may change, it is likely that the vessels to be

used will consist of:

▪ Cable lay vessel: a specialist ship, equipped with dynamic positioning (DP) systems, designed to

carry and handle long lengths of heavy power cables.

▪ Cable lay barge: typically used in shallower water to lay the cables, using anchors to maintain

position.

▪ Guard vessel: if necessary, will accompany cable lay vessel to maintain surveillance around the

worksite ensuring other vessels are kept clear, reducing the risk of collision and to protect the

cable prior to burial.

▪ Rock placement vessel: feature a large hopper to transport rock and a mechanism for

deployment of rock on site for the purposes of cable protection. The usual mechanisms for rock

deployment are side dumping, split hopper or flexible fall pipe.

2.7.2 LAYING

Cable lay vessels can carry cable lengths in bundled configuration up to or even over 100km. It is

likely that at least one cable joint will be required for the Greenlink route. Greenlink will ensure that

if joints are required, as far as possible, they are not located in sensitive areas, e.g. shipping

channels, anchoring grounds, where the prolonged location of the installation spread is not

desirable.

The proposed route crosses disused and live cables. There are no pipelines along the proposed

route. Disused cables are usually severed with the permission of the owner. For live cable crossings

Greenlink will enter into formal agreements with the asset owner. The physical design of the

crossing will vary according to, among other things, the size, type, location and burial state of the

crossed infrastructure. Generally the marine cables will cross over infrastructure on a ‘bridge’

comprised of either aggregate or concrete mattresses. This section will subsequently be covered

over with a protective layer of either aggregate or mattresses.


19 December 2016 16

2.7.3 CABLE BURIAL AND PROTECTION

The cables will normally be buried as a safety measure to avoid damage and entanglement (with, for

example, trawling gear and anchors) and also to minimise the risk of “free span” cable over gaps,

causing cable fatigue.

A range of cable installation techniques can be deployed depending upon the seabed conditions.

These are set out in Table 2-2 below.

Depending on the method of burial the sediment over the cable can be reinstated mechanically or

naturally by normal sedimentary processes. Where possible the cable will be buried in the seabed.

Where the seabed composition is not suitable for burial, external mechanical protection will be

provided through either rock-placement, application of concrete mattresses and/or installation of

cast iron shells.

The recommended target burial depths along the cable route will be determined by a detailed cable

burial study. Typically target depth for burial is 1m to 3m below mean seabed level, although this

may vary depending on the nature of the substrate. For example, in areas where there is evidence

of trawling activity or areas of mobile seabed this may be increased.

Table 2-2 Cable burial methods

Burial method Description

Ploughing Ploughing is suitable for most types of seabed material, with the exception of rock and some glacial material. The cable is fed from the vessel, through the plough share into the seabed.

The forward blades of the plough cuts a narrow trench into the seabed and holds it open long enough to depress the cable into the bottom of the trench. The seabed then closes behind the plough.

Jetting Jetting is most effective in sandy sediment, and may not be capable of burying cable in more cohesive sediment. Two methods of jetting are typically available: ▪ Fluidising the seabed: the cable is laid on the seabed, where a jetting sledge flushes

water below it, fluidising the sand. The cable sinks by its own weight to the depth set

by the operator. This will result in increased suspended sediment compared to

ploughing or forward jetting.

▪ Forward jetting a trench: Water jets are used to jet a trench ahead of the cable lay. The

cable can typically be laid into the trench behind the jetting tool.

Jetting and ploughing may be used in combination.

Rock cutting / trenching

A trench is excavated, displacing the sediment to alongside the trench. The cable is subsequently laid in the trench and the sediment is either returned to the trench or left behind.

This can provide an option for burial in harder substrates where the plough and jet burial may not be effective. However, the progress of these machines can be slow and expensive.

2.7.4 CABLE LANDFALL

The land cables will be connected with the marine cables in a transition joint bay (TJB) buried in the

ground above the high water mark. In all areas the cables will be buried below surface, i.e. into the

beach. TJBs are typically 25m long x 5m wide and 3m deep below ground level.

Horizontal directional drilling (HDD) is the preferred method of installation at the landfall. HDD is a

technique whereby a hole is drilled from shore under any sea defences, cliffs, dune systems or


19 December 2016 17

sensitive features, to a point a suitable distance offshore, usually several hundred metres. A pipe is

inserted into the drilled hole which is then used as a duct into which the cables are installed.

If, HDD is not technically possible, a trench will be excavated across the beach using conventional

excavators (either on the shore or mounted on a shallow barge). Trenching would affect a maximum

10m wide strip of the intertidal area. Once the trench has been formed the cable will be installed

from the cable lay vessel by a combination of floating and pulling the cable ashore using a winch

anchored behind the beach. On completion of works, the beach / intertidal area will be restored to

pre-impact conditions.

2.8 CABLE OPERATION

During operation of the cables, emissions to the environment consist of electrically-induced and

magnetic fields, and heat. The HVDC current in the cable will produce a static electric field, but this

is shielded by the lead sheath and other metallic components of the cable and will not be emitted to

the marine environment. The cable will also produce a static magnetic field with a low-level time-

varying magnetic field superimposed onto it.

The movement of the sea through the magnetic field will result in a small localised electric field

being produced. The magnitude of the electric field induced will be dependent upon magnetic field

strength, seawater chemistry, viscosity and its flow velocity and direction relative to the lines of

magnetic flux. However should the cables be laid close together or bundled together, this will have a

cancelling out effect on the magnetic field and associated induced electric field, minimising the

electromagnetic field (EMF) impact on the marine environment. There are no other significant

emissions, apart from a small temperature effect, associated with the cables in the marine

environment.

2.8.1 MAINTENANCE AND REPAIR

It is likely that routine surveys using standard geophysical survey equipment and/or remotely

operated vehicles to monitor buried depth and integrity of rock berms will be undertaken;

particularly in the initial years of operation, and should the local environmental conditions change or

be suspected as having changed. Cable intervention activities will have a similar impact to the

installation activities, however they will be on a smaller extremely localized scale, and as such are

not expected to have any significant impacts. Any impacts will be less than those identified for

installation operations.

Once installed, marine cables are not expected to require routine maintenance. If a cable fault is

detected, usually as a consequence of damage cause by external interaction e.g. trawlers and

commercial ship anchors, the relevant section of the cable will be located and retrieved to surface

for inspection and replacement. Typical repair scenarios will be presented in the EA together with an

assessment of the environmental impact.

2.9 UNPLANNED EVENTS

Unplanned events are incidents or non-routine events that have the potential to trigger impacts that

would otherwise not be anticipated during the normal course of installation or operation. The

severity of impact from unplanned events can be greater than those from planned installation and


19 December 2016 18

maintenance operations, however the probability of an unplanned event occurring is typically much

lower.

Unplanned events which will be considered by the assessment include: hydrocarbon or chemical

spill; damage to an external asset e.g. cable, through anchor dragging; and ship to marine mammal

collision.

2.10 DECOMMISSIONING

Greenlink recognises the importance of considering the decommissioning process at an early stage.

The least environmentally damaging option and the usual approach for submarine cables is to leave

the cable in-situ and this is the expected approach for Greenlink.

2.11 TIMESCALES

The indicative timescales for the key stages of the project are outlined below in Table 2-3.

Table 2-3 Indicative project schedule

Stage of development Time period

Screening Request August/September 2016

Scoping Report December 2016

Consultation on Scoping Report January - February 2017

Marine survey works May – October 2018

Non-Statutory Environmental Assessment May – December 2018

Submission of Licence applications with Environmental Report

December 2018

Regulator Consultation on Licence applications January – June 2019

Cable installation 2020 - 2023

Operation 2022 - 2023


19 December 2016 19

3. LEGISLATIVE FRAMEWORK

The installation of marine cables is not a form of development which falls under the remit of

European Commission Council Directive 85/337/EEC on the assessment of the effects of certain

public and private projects on the environment (EIA Directive) and subsequent amendments.

Therefore, for this type of development a statutory EIA is not required. However, there are a

number of other policies and laws under which the competent authority is required to consider the

environmental impact of a project. In addition, the project will require a number of consents and

licences, of which the main ones are summarised in Figure 3-1.

Figure 3-1 Marine consents

3.1.2 TEN-E REGULATION

European Commission (EC) Regulation No 347/2013 on Guidelines for Trans-European Networks for

Energy (TEN-E Regulation) lays down rules for the timely development and interoperability of energy

networks in European Union Member States and the European Economic Area (EEA). The Regulation

sets out guidelines for streamlining the permitting processes for major energy infrastructure projects

that contribute to European energy networks. These are referred to as Projects of Common Interest

(PCIs). PCIs are required to be given ‘priority status’ at a national level and should be considered by

competent authorities as being in the public interest. Greenlink has achieved PCI status under the

TEN-E Regulation.

3.1.3 WELSH NATIONAL MARINE PLAN

The Welsh National Marine Plan (WNMP) is currently being prepared by the Welsh Government in

accordance with the Marine and Coastal Access Act 2009 (MCAA) with an initial draft created

November 2015 for consultation. The purpose of the WNMP is to enable the Welsh Government to

plan for, and guide, the management of Welsh seas; integrating economic, social and environmental

considerations and engaging with communities to help shape the future of the plan area and thereby

contribute to the wellbeing of current and future generations.


19 December 2016 20

The draft plan contains four policy statements in relation to marine cables. Of these CAB-01 and

CAB-02 are pertinent to the project.

▪ CAB-01: Decision making authorities should ensure that proposals demonstrate that they will, in

order of preference: a) avoid adverse impacts on existing (and planned) subsea cables (and their

landfall sites); b) minimise and mitigate impacts where they cannot be avoided; c) mitigate

impacts where they cannot be minimised; and d) present the case for proceeding where (a-c) are

not possible.

▪ CAB-02: Decision making authorities should ensure that subsea cable laying, operation,

maintenance and decommissioning complies with recognised good practices to minimise the

impact on the environment and other users.

Care will be taken in the design of Greenlink to ensure that it is aligned with these policies and that

sufficient information is provided to the competent authorities to demonstrate that significant

environmental impacts have been identified, minimised and mitigated as appropriate.

3.1.4 MARINE LICENCE

The MCAA provides the framework for the UK marine licensing system. Under the Act it is a

licensable activity to install and maintain marine cables within territorial waters (i.e. between MHWS

and the 12nm limit) and to deposit material on the seabed for the purposes of cable protection

within territorial waters and UK offshore waters (i.e. within the EEZ). NRW are responsible for

regulating activities within Welsh territorial waters, whilst the MMO is responsible for UK offshore

waters. Both regulators do so by issuing Marine Licences.

As part of the assessment of the marine licence application the regulator may seek advice from their

primary advisors and consultees before making a decision on whether to issue the licence. The

regulator may consult any person or body it deems fit, in cases involving any matter in which that

person or body has particular interest or expertise.

Review of current marine licencing policy indicates:

▪ Laying and burial of the inshore section of the cable (within 12nm) requires a marine licence from

NRW under Part 4 of the MCAA.

▪ Within the offshore marine plan area (outside of 12nm) installation of an international electricity

cable is exempt from requiring a marine licence under Section 81(2) of the MCAA. However, the

deposition of protection material e.g. grout mattresses or rock, seabed preparation and disposal

of dredged material would be licensable activities.

▪ Any form of cable protection works, is a licensable activity, whether the need for such protection

works is identified before or after the laying of the cable. Cable protection can be included in the

installation Marine Licence application to the NRW (for works within territorial waters), but a

separate Marine Licence from the MMO will be required for cable protection material in UK

offshore waters.

▪ Conditions to the marine licence for the installation and maintenance of the offshore section of

the cable may be attached to take account of other marine users and conservation designations.


19 December 2016 21

3.1.5 HABITATS REGULATION ASSESSMENT (HRA)

The Conservation of Habitats and Species Regulations 2012 (as amended) (the Habitats Regulations)

transpose into UK law Article 6(3) of EC Council Directive 92/43/EC on the conservation of natural

habitats and of wild fauna and flora (Habitats Directive). This requires project-related activities

within Natura 2000 sites to be assessed with regard to their implications for the site conservation

objectives.

Under regulation 61 of the Habitats Regulations, a Habitats Regulations Assessment (HRA) is

required for any plan or project which has the potential to affect a Natura 2000 site, no matter how

far away from that site, in order to determine whether an Appropriate Assessment (AA) is required.

The three tests set out under regulation 61 to determine if a proposal will affect a Natura 2000 site

are:

▪ Is the proposal directly connected with or necessary for site management for nature

conservation?

▪ Is the proposal likely to have a significant effect on the site? (this is the Screening Stage)

▪ Can it be ascertained that the proposal will not adversely affect the integrity of the site? (this is

the appropriate assessment stage)

The tests are known as the HRA process.

3.1.5.1 NATURA 2000

EC Council Directive 92/43/EC on the conservation of natural habitats and of wild fauna and flora

(Habitats Directive) and EC Council Directive 2009/147/EC on the conservation of wild birds (Birds

Directive) enable European Union member states to work together within the same legislative

framework to protect Europe’s most valuable species and habitats, irrespective of political or

administrative boundaries. At the heart of these Directives is the creation of a network of Europe’s

most valuable species and habitat sites known as Natura 2000.

The aim of the Natura 2000 network is to ensure the long-term survival of European threatened

species and habitats. The network comprises Special Areas of Conservation (SACs) designated under

the Habitats Directive, and Special Protection Areas (SPAs) designated under the Birds Directive.

SPAs and SACs are designated by the individual member states.

In addition, sites designated under the Convention on Wetlands (Ramsar, Iran 1971) known as the

"Ramsar Convention" are also included under the definition Natura 2000. The Ramsar Convention is

an intergovernmental treaty that embodies the commitments of its member countries to maintain

the ecological character of their Wetlands of International Importance and to plan for the "wise

use", or sustainable use, of all of the wetlands in their territories” (RAMSAR, 2011). The vast

majority of Ramsar sites are also classified as SPAs. As a matter of policy, Ramsar sites in the UK are

protected as European sites - as set out in:

▪ The Conservation (Natural Habitats, &c.) Regulations (1994) (as amended); and

▪ The Conservation of Habitats and Species Regulations 2012 (as amended).


19 December 2016 22

SPAs, SACs and Ramsar sites are collectively referred to as European sites.

3.1.6 PROTECTED SPECIES

Certain species are protected by international, European and national wildlife legislation throughout

the UK. This includes protection from intentional or reckless disturbance, taking, harming and killing,

and in some cases possession or sale of the species.

There is no intention to take, trade or sell protected species during the proposed project; therefore,

this section focuses on the legislation for which it is an offence to recklessly disturb, harm or kill a

protected species. The legislation that applies is:

▪ The Offshore Marine Conservation (Natural Habitats, &c.) Regulations 2007 (as amended);

▪ The Conservation of Habitats and Species Regulations 2010; and

▪ The Wildlife and Countryside Act 1981 (as amended)

Table 2-1 below provides details of the marine species which are currently protected in Wales under

this legislation. The schedules to the legislation are regularly reviewed and updated in light of

scientific evidence.

Table 3-1 Protection measures for marine species

Offshore Marine Conservation (Natural

Habitats, &c.) Regulations 2007

Conservation of Habitats and Species Regulations 2010

Wildlife & Countryside Act

Schedule 1 (European Protected Species)

Schedule 2 (European Protected Species)

Schedule 5

Whales, Dolphins and Porpoises (all species)

Loggerhead turtle

Green turtle

Kemp’s Ridley turtle

Hawksbill turtle

Leatherback turtle

Common Sturgeon

Otter


Loggerhead turtle

Green turtle

Kemp’s Ridley turtle

Hawksbill turtle

Leatherback turtle

Common Sturgeon

Otter


Basking and Angel Shark

Allis shad and Twaite shad

Common Sturgeon

Short Snouted Seahorse and Spiny Seahorse

Fan Mussel and Freshwater Pearl Mussel

Starlet sea anemone

Otter

In Wales, a licence under regulation 49 of the Offshore Marine Conservation (Natural Habitats)

Regulations 2007, referred to as a ‘Wildlife Licence’, can be issued to authorise what would

otherwise be an offence under the nature conservation legislation. A licence may only be issued

where the activity meets certain purposes and where there is no satisfactory alternative. Licences

are granted subject to conditions and licence holders are responsible for ensuring compliance with

conditions. Failure to comply with conditions is an offence.


19 December 2016 23

It is not anticipated that activities undertaken in the construction, operation and maintenance of

Greenlink will recklessly disturb, harm or kill any protected species. Where there is the potential for

accidental harm that could injure a protected species e.g. vessel collision, the significance of the

impact will be assessed.

It is not considered likely that any Wildlife licences will be required for this project.

3.1.7 MARINE ARCHAEOLOGY

As part of the UK marine licencing consultation, the statutory stakeholder Cadw (Welsh

Government’s historic environment service) requires that the following legislation is considered

during the assessment of impact:

▪ Protection of Wrecks Act 1973

▪ Ancient Monuments and Archaeological Areas Act 1979

▪ Protection of Military Remains Act 1986

On consideration of this legislation and prior to work being conducted, a project specific Written

Scheme of Investigation (WSI) for Archaeological Remains and a Protocol for Archaeological

Discovery (PAD) are required to minimise disturbance and destruction of archaeological features and

set out a methodology for investigation.

A draft WSI will be provided with the draft Marine Licence applications for review.

3.1.8 OTHER EUROPEAN DIRECTIVES

Water and sediment quality are monitored and regulated in the UK under a number of EC Directives.

The most relevant to the project are:

▪ Directive 2008/56/EC establishing a framework for community action in the field of marine

environmental policy (Marine Strategy Framework Directive, MSFD);

▪ Directive 2000/60/EC establishing a framework for Community action in the field of water policy

(Water Framework Directive, WFD);

▪ Directive 2006/7/EC concerning the management of bathing water quality (Bathing Waters

Directive, BWD); and

▪ Directive 2006/113/EC on the quality required of shellfish waters (Shellfish Waters Directive,

SFWD).

The WFD established a framework to protect and improve the ecological health of European waters,

including inland surface waters (rivers and lakes), transitional waters, coastal waters and

groundwater. Protection of coastal waters under the WFD extends from the mean low water mark

up to one nm from shore and requires that licensed projects or activities do not ‘cause deterioration

in a water body’. The MSFD considers water beyond 1nm.

The BWD and the SFWD are only applicable at designated bathing waters and shellfisheries,

respectively.


19 December 2016 24

As part of the marine licence applications, Greenlink will consider the effects of the project in

accordance with the above Directives as appropriate.

3.1.9 CROWN ESTATE LICENCES

The Crown Estate own and manage the majority of the seabed out to the 12nm territorial limit.

Permission is needed for rights to lay, maintain and operate cables on areas of seabed for which they

are the landlord. The Crown Estate also request that they are informed of cables that transit the UK

continental shelf (within the 200nm limit), as other activities may be impacted. A Crown Estate

Licence will be required for the right to install and operate Greenlink.

Seabed Survey Licences are the formal permissions granted by The Crown Estate for temporary

activities that take up to a maximum term of six months and physically affects the foreshore and/or

seabed that we manage. A Seabed Survey Licence will be required for pre-construction marine

survey grab sampling.

3.1.10 CROSSING AND PROXIMITY AGREEMENTS

At the early stages of the project, The Crown Estate provided details of third party infrastructure

present which may be crossed or in close proximity to Greenlink within UK waters (see Section 6.3).

The crossing of third party infrastructure is made with prior agreement of the owners following a

negotiated formal Crossing Agreement (CA). The CA describes the rights and responsibilities of the

parties and also the detailed physical design of the crossing. The design addresses the need to

protect both the cables and the third-party infrastructure and other aspects such as crossing angle

and vertical separation. In some cases the crossing location, relative to sensitive structures, e.g.

subsea valves or cable repeaters, is specified. A proximity agreement similarly protects the third

party asset and is negotiated if cable routing is unable to avoid infrastructure completely. Greenlink

has the responsibility to ensure the third party asset integrity is not affected.

The exact physical design of the crossing will depend on both the negotiated CA and the resources of

the installation contractor and may vary from location to location.

3.1.11 PORT OF MILFORD HAVEN PERMITS

The marine survey (in particular geotechnical) and cable installation will require a Marine Works

Licence from the Harbour Authority. They will request opinion from NRW in relation to potential

impacts on protected sites and will need sufficient information with the application to undertake an

Appropriate Assessment.


19 December 2016 25

4. PHYSICAL ENVIRONMENT

4.1 METOCEAN CONDITIONS

4.1.1 EXISTING BASELINE

4.1.1.1 WIND

The region has a temperate maritime climate whose wind regime is driven by high and low pressure

systems. Frontal depressions generally approach from the Atlantic moving east or northeast, while

areas of high pressure (anticyclones) tend to reduce wind speeds and, if they become stationary over

the region, can fend off the arrival of depressions.

The prevailing wind direction is generally south-westerly over much of the northeast Atlantic and

this is the case over the proposed marine cable route.

Generally, the strongest winds are reported during the autumn and winter, with winds of Force 6

and over being reported in December on around 35% of occasions off the west coast of Wales. This

frequency falls to about 9% by July (DTI 2005a).

4.1.1.2 WATER LEVELS AND CURRENTS

Water levels and currents in the region are driven by astronomical tides and occasional storm surges.

The tides are semi-diurnal (two high and two low waters each day) and their range varies through

the lunar cycle reaching a maximum (spring tide) every 2 weeks. The mean spring range is around

3m to 3.5m near the UK/Irish median line, increasing to 7m at the Freshwater West landfall. Spring

tides reach peak speeds of 1.0 to 1.5 m/s generally in a northwest-southeast direction past the

Pembrokeshire coast; they are nearly rectilinear, i.e. they have very little movement perpendicular

to their main direction of flow. Peaks during neap tides are 0.75 m/s (Barne et al 2005).

Storm surges occur when deep depressions move through the area and may temporarily increase

the water level by up to 1.3m in extreme cases. They are weaker than tides in this area, having

estimated speed of around 0.4m/s in an extreme (50-year return period) event.

There is thought to be a slow residual surface current drift of the order of 2km per day. Its direction

is said to be generally northward.

4.1.1.3 WAVES

The wave regime is a product of the winds described above. Exposure to largest waves is more

pronounced on coasts and submarine shoals facing the longest fetch from the south-west and in

environments where the wave energy has been least dissipated by the interaction of waves with

shoaling seabed. Wave motions follow a roughly circular trajectory, forward on a wave crest and

backward on the following trough. These motions can extend to great depth below the surface

(several tens of metres) so that they can mobilise seabed sediment, or exert force on seafloor cables

and other structures (DTI 2005a).


19 December 2016 26

The average wave height for the proposed marine cable route ranges from 1.75m to 2m at the

UK/Irish median line increasing to between 2.5m to 4m at the Freshwater West landfall (Barne et al

2005).

4.1.1.4 TEMPERATURE AND SALINITY

The surface temperature of seawater varies with the seasons, being coldest in February/March at

between 6°C to 8.5°C, and warmest in August/September, when it varies between 14°C and 16°C.

The magnitude of this variation is greater in coastal waters. The surface water may be up to 5°C

warmer than the bottom layer. Water salinity is fairly constant throughout the year and at all depths

along the proposed marine cable route. A salinity of 35 is typical (DTI 2007a).

4.1.2 IDENTIFICATION OF KEY SENSITIVITIES AND POTENTIAL IMPACTS

4.1.2.1 KEY SENSITIVITIES

None envisaged.

4.1.2.2 POTENTIAL IMPACTS

Modifications of metocean regime: It is not anticipated that cable installation, operation or

maintenance will have any significant impacts on the metocean regime. Marine cables will be

buried, where possible, and any changes to the seabed profile associated with cable protection

material will be localised. At most, cable protection may cause very local changes to tidal or wave-

induced current flows but is unlikely to cause measureable or long-term changes to metocean

conditions. Any impacts would most likely be observed in the shallower coastal waters near the

landfall, but these environments tend to be fairly dynamic (for example, due to wave activity) and

the affected corridor will be relatively small.

Impacts on the wider metocean environment will be negligible, and certainly considerably lower

than the natural variability in metocean conditions. It is proposed that this impact is scoped out of

the EA at this stage.

Changes to seabed temperature: When cables are in operation, localised heating of the environment

may occur surrounding the cables (i.e. sediments including interstitial water, where cables are

buried, rock berms/concrete mattresses when cable protection employed). Seawater temperatures

within the Celtic Sea vary seasonally and therefore are likely to accommodate minor localised

variations in temperature associated with thermal losses.

Impacts on seabed temperature will be negligible and it is proposed that this impact is scoped out of

the EA at this stage.

4.1.3 ENVIRONMENTAL APPRAISAL APPROACH

No significant impacts on the metocean conditions of the project area are anticipated and therefore

it is considered that no further assessment is required within the EA. However, a detailed baseline

description will be included as the metocean conditions have a significant influence on other impacts

being assessed within the EA.


19 December 2016 27

Metocean conditions will be characterised using publicly available data such as:

▪ UKHO Admiralty charts and pilots;

▪ OSPAR Region III Status Report - Celtic Seas. OSPAR Commission, London;

▪ Strategic Environmental Assessment (SEA) 8 (OESEA) Western English Channel and Celtic Sea and

Offshore Energy SEAs;

▪ Charting Progress 2;

▪ JNCC Coastal Directories, Barne et al Region 12 (1995); and

▪ NERC UK Digital Marine Atlas Project (1998).

4.2 GEOLOGY, GEOMORPHOLOGY AND SEDIMENTARY PROCESSES


4.2.1.1 BATHYMETRY

The dominant bathymetric feature off the west coast of Wales is a wide trough, having a maximum

depth in excess of 100m which runs the length of St Georges Channel between Wales and Ireland

(Figure 4-1). Along the proposed marine cable route, the water depths range from 91-120m at the

UK/Ireland median line to 0-30m close to the Pembrokeshire coast.


19 December 2016 28

Figure 4-1 Bathymetry

4.2.1.2 SEABED SEDIMENTS

Seabed sediments off the west coast of Wales predominantly consist of sandy gravel with nearshore

areas of sand (DTI 2005a). The inshore seabed around the south Pembrokeshire coast is

characterised by rocky reef, shoals and sandbanks creating areas of varied depth and water patterns.

The seabed is generally described as gravelly sand with a depth of 30m to 60m turning to a more

sandy composition in shallower waters (<30m); however, Skomer to Strumble Head is described as

rock based. Seabed distribution within the Pembrokeshire Marine SAC and surrounding areas is

shown in Figure 4-2. Very fine muds are present in sheltered areas of the Milford Haven waterway,

through sands and gravels, to consolidated and unconsolidated pebbles and cobbles in deep subtidal

areas subject to strong currents and storm surges. Sediment structures vary from uniform to very

heterogeneous (CCW 2009). Further offshore towards the UK/Ireland median line, sediments are

more uniform consisting of sand with some areas of gravel.


19 December 2016 29

Figure 4-2 Seabed sediments

4.2.1.3 GEOLOGY

The underlying geology is reported to consist of Palaeozoic rock (541 – 252.17 million years ago)

overlain by Permian (252.17 – 298.9 million years ago), Mesozoic (252.17 – 66 million years ago) and

Tertiary strata (66 – 2.58 million years ago), of which overlying Quaternary sediments locally exceed

300m in depth (Tappin et al. 1994).

Coastal

The Pembrokeshire Marine SAC area has a rich and complex geology. The southern part, which the

proposed marine cable route passes through, is dominated by old red sandstone and carboniferous

rocks, notably the limestone block of the Castlemartin coast, and the silurian volcanics of the

Marloes Peninsula, Skomer and offshore rocks and islands. There has been a spectacular degree of

rock faulting and folding. The coastal cliffs of highly faulted Cambrian (northern St Brides Bay

shoreline) and old red sandstone (southern St Brides Bay, West Dale, Freshwater West) shorelines

have extensive sublittoral extension. Softer more recent rocks form cliffs behind and underlying

sediment on the lower shores on eastern shorelines (CCW 2009).


19 December 2016 30

Offshore

The central Celtic Sea comprises Upper Cretaceous (100.5 – 66 million years ago) and Paleogene

sedimentary rock (66 – 23.03 million years ago), with Devonian to Carboniferous rock extending

along the coast of southern Ireland (Tappin et al. 1994).

4.2.1.4 SEDIMENT TRANSPORT PATHWAYS

The hydrodynamic conditions present in the Irish Sea are heavily influenced by tidal stream strength.

Tidal streams increase in strength from north to south, from approximately 0.2m/s to 1.2m/s

respectively. The differing hydrodynamic conditions in this area are reflected in the spatial variation

in sediment particle size and bedform distribution. A sand parting zone is present across the Irish

Sea from Dublin Bay to the Lleyn Peninsula from which sands migrate north and south parallel to the

UK/Irish Coast. Soft glacial coastal sediments have little resistance to the hydrodynamic conditions

and therefore impacts from erosion are significant; this is lessened slightly by the supply of

sediments from the offshore banks (DTI 2005a). Detailed sediment processes in St George’s Channel

are poorly known but are dominated by tidal currents. Around the Pembrokeshire coast, strong tidal

currents are present which suspend high levels of seabed particles in the water column.



None envisaged.


Changes to seabed bathymetry and seabed features: The physical disturbance caused by cable

installation, e.g. excavation of sediment and underlying bedrock, has the potential to affect

sedimentary structures and bedforms, solid geology or geomorphologic features. In areas of seabed

where the marine cables are buried, any changes in seabed morphology will be localised and

temporary. Where burial cannot be achieved and cable protection measures are necessary it is

unlikely to significantly alter the physical condition of area.

A large area of mobile sandwaves is known to be present in Irish offshore waters and it is possible

that this may extend across in UK offshore waters. The proposed marine route has been designed to

avoid this area as it poses technical challenges, however, if the marine survey identifies the sand

waves are more extensive than originally thought small amounts of localised pre-sweeping may be

required. Pre-sweeping has the potential to have a significant effect on seabed features and this

potential impact will be considered in more detail in the EA once the marine survey is complete.

Changes to sediment regime and coastal processes: This refers to the wide-scale transport of

suspended sediment or bedload, with knock-on effects on (for example) local sediment budgets and

beach stability. Changes could in theory be caused by a change in the current flow regime

associated with tidal or wave action, and/or a change in the seabed morphology or seabed surface

sediment composition. Changes to seabed morphology and sediment composition may result from

the cable installation process or, potentially, scour around cable protection measures. It is

considered likely that, at most, any such changes will affect only a small area in the short-term.


19 December 2016 31

Following installation, the seabed sedimentary environment will quickly return to its pre-installation

state. Any scour around cable protection will reach a dynamic equilibrium and will not impact the

wider environment in the longer term. It is therefore considered unlikely that the project will cause

any significant impacts on sediment transport paths and associated processes. It is therefore

proposed that this impact is scoped out of the EA at this stage.


Table 4-1 Geology, geomorphology and sedimentary processes EA approach

Data Requirement Method Data Sources

Desk based review A desk based review of publicly available data will be used to describe the physical environment.

Strategic Environmental Assessment 8 (OESEA);

BGS UK Offshore Regional Reports: The geology of the Irish Sea 1995;

BGS Seabed Sediments Digital data;

JNCC Coastal Directories, Barne et al Region 12 (1995);

Countryside Council for Wales (CCW). Pembrokeshire Marine European Site. Advice

Marine survey Geophysical and geotechnical surveys of the cable route will provide an understanding of the baseline bathymetry, seabed sediments, shallow geology and seabed features along the proposed marine cable route.

Seabed survey of the marine cable corridor

Consultation Consultation with the regulatory authorities and their Statutory Nature Conservation Agencies (SNCA).

JNCC, NRW, MMO, BGS

4.3 WATER AND SEABED QUALITY


Water and sediment quality at any particular location on the UK continental shelf is the result of a

combination of source, transport and removal mechanisms for the individual chemical species under

consideration. There are many routes by which substances with the potential to affect water quality

enter the Celtic Sea, both through natural processes and as a result of anthropogenic activity, with a

general downward trend in anthropogenic inputs over the past few decades (UKMMAS 2010).

4.3.1.1 WATER QUALITY

The EU Marine Strategy Framework Directive adopted in 2008 requires that the UK takes “the

necessary measures to achieve or maintain Good Environmental Status in the marine environment

by the year 2020 at the latest” (UKMMAS 2010). The report on the current state of the UK seas

(UKMMAS 2010) concludes that good progress has been made towards this end with significant

contamination restricted to industrial estuaries and coastal areas.

The requirement for monitoring of UK rivers and near-shore waters has increased as a result of the

implementation of the EU Water Framework Directive (WFD), with more stringent criteria for water

quality in rivers applied. River Basin Management Plans (RBMP) are being developed as a


19 December 2016 32

requirement of the WFD and report on the ‘ecological status’ of surface and ground water in coastal

waters (out to 1nm from the baseline) and ‘chemical status’ of surface and ground waters in

territorial waters (out to 12nm from the baseline). The proposed marine cable route is located within

the Western Wales River Basin District.

Water quality, defined in terms of bacterial concentration, is monitored within Bathing Waters

designated under the revised Bathing Water Directive (2007/7/EC). These are classified as Excellent,

Good, Sufficient and Poor. The beaches within close proximity to the Freshwater West landfall have

been assessed as having excellent water quality for the last four years (Pembrokeshire County

Council 2016). Water quality is also monitored for shellfish waters designated under the Shellfish

Waters Directive 79/923/EEC and requires specification of protected areas for protection of

economically significant species. Currently the nearest shellfish water to the Freshwater West

landfall is the Milford Haven Cleddau approximately 13km to the north-east.

4.3.1.2 SEDIMENT QUALITY

Sediment contamination may result from natural and anthropogenic inputs that are harmful to

biota. Dissolved contaminants in the Celtic Sea and off the Pembrokeshire coast are low or below

the level of detection for current analytical tools. Coastal waters contain the highest concentrations

of contaminants as they are within close proximity to run off from industry. However, contamination

along the south Pembrokeshire coast does not exceed environmental quality standards (EQSs) for

metals and maximum allowable concentrations (MACs) for alkylphenolic chemicals.

Hydrocarbons such as polycyclic aromatic hydrocarbons (PAH) can occur naturally in the marine

environment as well as from anthropogenic inputs; and concentrations can vary widely. However,

concentrations of contaminates into the Celtic Sea from coastal industries in offshore samples and

the south coast of Pembrokeshire do not exceed their MACs.

Persistent organic compounds include polychlorinated biphenyls (PCBs) and Tributyltin (TBT). PCBs

concentrations are decreasing across the Celtic and Irish Sea but are highest in industrialised regions

such as harbours. TBT is a widespread contaminant of coastal waters and sediments due to its use

an antifoulant on marine structures and shipping. OSPAR (2010) reports suggest that levels of TBT

are acceptable across the Celtic Sea but there are still areas of high concentrations such as harbours

and shipping lanes.



▪ Freshwater West and surrounding areas bathing water


Disturbance of natural seabed sediments: Sediments will be disturbed during cable installation and

to a lesser extent during cable maintenance and repairs. The coarser fraction of the sediment

disturbed is likely to be initially re-deposited on the seabed close to the works, but will remain

mobile. Any fine material released in a high energy area will disperse widely with eventual


19 December 2016 33

deposition over a large area i.e. in a sediment plume. Where seabed operations impact low energy

areas, fine sediments may be disturbed and large quantities of fine material could be released.

Placement of cable protection material on the seabed also has the potential to change the nature of

the seabed through the introduction of material of different geological origin.

Construction activity in the intertidal area has the potential to compact natural sediments, as

vehicles move up and down the beach. This compaction can have an indirect impact on marine

ecology.

The significance of the disturbance will be assessed in more detail in the EA.

Disturbance of contaminated sediments: The potential adverse effects of disturbing historically

contaminated sediments during cable installation depend on the nature (e.g. domestic or industrial

waste, munitions) of the potential contamination source and local receptors. The proposed marine

cable route has been routed to avoid existing and historic disposal sites where possible. However, as

discussed in Section 6.4 below, it passes within close proximity of a historic site within Welsh

territorial waters. There is therefore the potential for contaminated sediments to be disturbed and

distributed throughout the area where the sediment plume is present.

Change in water / sediment quality: There are two pathways through which the proposed project

could potentially affect water and/or sediment quality:

▪ By increasing suspended sediment concentrations; and

▪ Through intentional or unplanned discharges e.g. sewage, ballast water or unplanned releases of

hydrocarbons or chemicals including HDD drilling fluids.

An increase in suspended sediment loads is often of particular concern if shellfish waters or

aquaculture sites are located close by. As described above the coarser fractions of sediment will

settle out of suspension within close proximity of the cable trench, whilst finer particles will disperse

widely over a large area. However, there are no aquaculture sites nor shellfish waters within close

proximity of the proposed marine cable route. The other concern is that a change in water quality

would have an indirect effect on benthic communities, fish species and certain diving bird species.

The potential significance of these impacts will be considered in the respective topic chapters.

Project vessels will comply with the International Marine Organisation (IMO) International

Convention for the Prevention of Pollution from Ships (MARPOL) standards. No discharges of waste

or sewage are permitted within 12nm of the coast, therefore no impacts to bathing waters are

anticipated. Impacts of discharges offshore will be temporary and localised and are unlikely to have

a significant effect on water quality.

Ballast water is pumped in to a vessel to maintain safe operating conditions throughout a voyage.

The multitude of marine species carried in ships’ ballast water may pose ecological problems as

transferred species may survive a voyage and be discharged at a destination. Here they may

establish a reproductive population in the host environment, becoming invasive and out-competing

native species. The potential for a significant impact will depend on the vessels used and their

provenance, although discharges are managed under International Convention for the Control and

Management of Ships’ Ballast Water and Sediments.


19 December 2016 34

The presence of project vessels will marginally increase the risk of a pollution incident. The running

aground of a vessel or a collision could lead to a fuel spill and cleaning fluids, oils and hydraulic fluids

used onboard cable lay vessels and during ROV operation could be spilled overboard or accidentally

discharged. The significance of the impact will depend on the nature of the spill and the sensitivity

of the receiving environment within the footprint of the spill. The potential significance of an impact

will be considered in more detail by the EA.


Table 4-2 Water and sediment quality EA approach


Desk based review A desk based review of publicly available data will be used to describe the water quality and sediment contamination in the project area.

Any risks to water quality and sediment contamination as a result of the project will be identified and assessed within the EA.

SEA 8 (OESEA)

Marine survey - -

Consultation Consultation with NRW will identify any requirements for analysis of existing sediment contamination.

NRW


19 December 2016 35

5. BIOLOGICAL ENVIRONMENT

5.1 INTERTIDAL AND BENTHIC COMMUNITIES


Intertidal and benthic ecology comprises the habitats and species (flora and fauna) present in, on or

closely associated with the seabed. A high level assessment of the key sensitive habitats and species

along the proposed marine cable route has been made by reviewing the following data sources:

▪ European Nature Information System (EUNIS) Habitats 2012 – Compiled by JNCC on behalf of

MESH using existing studies and survey data

▪ Marine European Seabed Habitat (MESH) Predicted EUNIS Habitats 2008 GIS Data – Modelled

predicted habitats based on physical hydrographic information within different habitats areas

and water depths.

The MESH project has collated studies and survey data to map EUNIS habitats present on the seabed

of north-west Europe. Within the study area this data is predictive rather than definitive however it

does provide some indication to the types of benthic habitats that may be found. These EUNIS

habitats are presented in Table 5-1 with specific benthic habitats shown in Figure 5-1.

The waters around Freshwater West are characterised by its sedimentary shore which supports rich

invertebrate fauna including various species of polychaetes, molluscs and algae (Davies 1998).

In contrast to this, the varied seabed sediments around Skokholm and Skomer gives rise to a range

of benthic fauna particularly around Skomer Island which is recognised as a site of significant

biological and conservation importance and a designated MCZ. This is partly due to the strong tides

and water currents which bring new supplies of food and nutrients and well as its varied seabed

habitats. Invertebrates living in or on the seabed include the broad sea fan Eunicella verrucosa and

the scarlet-and-gold star coral Balanophyllia regia which are at the limit of their geographical range

and also species which are more localised such as the colonial anemone Parazoanthus axinellae. The

areas of coarse, current exposed shelly gravel in this region support a low variety of physically

resilient species (CCW 2005).

Within the wider Pembrokeshire Marine SAC, the area supports habitat features of varying

individuals scale, distribution, significance, quality and sensitivity. High biological diversity is present

and as stated above, this area is positioned at a biogeographically boundary between northern and

southern species. The mixed sediments support long-lived macrofauna buried within and living on

the sediment surface and rare infauna including molluscs (Ensis and Arctica); anthozoans

(Mesacmea, Peachia, Aureliania); tube living polychaetes and echinoderms. Sediment epifauna

includes a relatively isolated population of great scallop (Pecten maximus) and a wide variety of

species characteristic of reefs living on and in stony material, molluscan shell debris and in

association with species consolidating mobile substrates, e.g. Ross coral (Pentapora folicea) (CCW

2005).

Further offshore at the UK/Ireland median line, richly abundant and diverse polychaete dominant

communities are present within the soft sedimentary seabed although patches of muddy, sandy

gravel are still present (DTI 2005b).


19 December 2016 36

Table 5-1 EUNIS habitats present along the proposed marine cable route

EUNIS Code EUNIS Name JNCC Biotope Annex I Habitat Type UK BAP Habitat / Priority Marine Feature

Typical Fauna

A4.2 Atlantic and Mediterranean moderate energy circalittoral rock

CR.MCR Reefs Tidal rapids This habitat type contains a broad range of biological subtypes, from echinoderms and crustose communties (A4.21) to Sabellaria reefs (A4.22) and circalittoral mussel beds (A4.24).

A5.13 Infralittoral coarse sediment

SS.SCS.ICS Sandbanks which are slightly covered by seawater all the time

Subtidal sands and gravels Characterised by robust fauna including infaunal polychaetes such as Chaetozone setosa and Lanice conchilega, Cumacean crustacea such as Iphinoe trispinosa and Diastylis bradyi, and venerid bivalves.

A5.14 Circalittoral coarse sediment

SS.SCS.CCS Sandbanks which are slightly covered by seawater all the time

Subtidal sands and gravels Characterised by robust infaunal polychaetes, mobile crustacea and bivalves. Certain species of sea cucumber (e.g. Neopentadactyla) may also be prevalent in these areas along with the lancelet Branchiostoma lanceolatum.

A5.15 Deep circalittoral coarse sediment

SS.SCS.OCS - Subtidal sands and gravels Characterised by robust infaunal polychaete and bivalve species including Modiolus modiolus.

A5.25 Circalittoral fine sand SS.SSa.CFiSa Sandbanks which are slightly covered by seawater all the time -

Subtidal sands The habitat may also extend offshore and is characterised by a wide range of echinoderms (in some areas including the pea urchin (Echinocyamus pusillus), polychaetes and bivalves. This habitat supports a more diverse community.

A5.26 Circalittoral muddy sand

SS.SSa.CMuSa Sandbanks which are slightly covered by seawater all the time

Subtidal sands Characterised by a wide variety of polychaetes, bivalves such as Abra alba and Nucula nitidosa, and echinoderms such as Amphiura spp and Ophiura spp., and Astropecten irregularis.

.

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Figure 5-1 Be nthic habitats

EUNIS Clas s ificationAlgal turfBrittlestarsCircalittoral muddy sand (AbrNucCor)Exposed littoral rock with Mytilus edulis and barnacles (BPat.Fvesl; FvesB; Fser.R; Ala.Ldig)Faunal & Algal CrustsFaunal TurfGravelGravel & cobblesInfralittoral gravel/ sand with maerl beds (Phy)Infralittoral mixed sediment (FaMx; VsenMtru; LsacX)Infralittoral muddy sand with Abra alba and Nucula nitida (FaMS)Infralittoral rock with Laminaria digitata and Laminaria hyperborea (Lhyp.Ft; Lhyp.Pk)Infralittoral sand (Mob; ScupHyd; Lcon)Infralittoral sand and gravel (FaG; Sell)Kelp

Littoral bedrock and mixed substrata with fucoids (Fser.Fser.Bo; FvesX; FserX; Fves; Fspi; Pel)Littoral mixed sediment (LMX)Littoral mixed substrata with fucoids (FvesX; AscX; FserX; FserX.T)Littoral muddy sand (MacAre)Littoral rock with dense fucoids (BPat; Pel; Fspi; Fves; Asc.Asc; Fserr; Fserr.T)Littoral sand and gravel (Lan)Lower shore or infralittoral sediment with Zostera marina beds (Zmar)Moderately exposed infralittoral rock (MIR)Moderately exposed littoral rock (MLR)

MudMuddy sandSaltmarshSaltmarsh (Sm) and littoral soft mudSand

Moderately exposed littoral rock with barnacles, fucoids and red algal turfs

Gre e nlink Inte rconne ctorEnvironme ntal Scoping Re port –

UK Marine Route


19 December 2016 38



▪ Designated habitats and species of protected sites.

▪ EC Habitats Directive Annex I habitats (designated or potential) e.g. reefs (stony or biogenic),

sandbanks which are slightly covered by seawater all the time.

▪ Estuaries

▪ Large shallow inlets and bays;


Temporary habitat loss – intertidal species: If for any reason HDD is not a feasible installation

technique at the landfall, open cut–trenching may be considered across the intertidal zone.

Intertidal species in the vicinity of the cable trench may be displaced or suffer direct mortality during

trenching operations, and will be temporarily unavailable as prey items for bird species. The

temporary habitat loss as a result of cable trenching would be minimal and restricted to a narrow

strip (approximately 10m wide). Construction activity (e.g. the movement of vehicles) also has the

potential to compact natural sediments and indirectly impact intertidal species. The area affected is

likely to represent only a small percentage of the available habitat. Following installation, the beach

profile would be restored to pre-impact conditions. More detailed assessment will be provided in

the EA.

Temporary habitat loss – subtidal species: Benthic communities in the zone of influence of the

marine cables will be impacted through substratum loss and direct displacement during cable laying

and maintenance operations. The significance of the impact varies according to the technique of

cable burial employed (e.g. jet or plough trenching) and the sensitivity of the habitat. It is likely that

in most cases any impacts to species and habitats will be localised and short term and once installed

the substratum will be reinstated over the cable.

The EA will provide more detailed assessment of the significance of this impact.

Smothering of species: Species will be smothered by two activities: the suspension and subsequent

deposition of sediments as a result of ploughing and trenching operations; and the placement of

cable protection material (if required) on the seabed. When suspended sediments resettle back on

to the seabed, sessile organisms can be smothered. Any significant impacts from smothering are

likely to be restricted to a very narrow extent beyond the cable trench (depending on current flow),

where the maximum thickness of sediment will be deposited. The significance of impact will depend

on sensitivity and recoverability of any species present within this impact footprint and will be

assessed in detail in the EA.

Cable protection (if necessary) through the placement of rock and or concrete mattresses on the

seabed will result in a direct, permanent but localised, change of habitat and potentially species. The

significance of the impact will vary according to the sensitivity of the habitat affected and will be

assessed in detail in the EA.


19 December 2016 39

Disturbance of contaminated sediments: Re-suspension of contaminants is possible during cable

installation, should contaminated sediments be disturbed. This may have potential effects on

nearby species which are exposed to remobilised contaminants. The proposed marine cable route

avoids known areas of contamination and therefore the impact is unlikely to be significant.

However, it will be considered in the EA.

Introduction of new substrate: Where cable burial is not possible, rock protection or concrete

mattressing will be used to protect the exposed cable. This will be used in areas of hard substrate,

stony reef or bedrock and therefore will not represent a significant change to the existing baseline.

The impact is unlikely to be significant but will be considered in the EA.

Emission of EMF: The impact of electric and magnetic fields generated during cable operation on

benthic species is largely unknown. As benthic communities are typified by sessile or low-mobility

species, which are unlikely to navigate using magnetic fields and anomalies, these species, are less

likely to be impacted than more mobile species such as teleost fish, elasmobranchs and cetaceans.

The effects of EMF on intertidal and benthic communities will be assessed within the EIA.

Toxic effects from the unplanned release of hydrocarbons or chemicals: Depending on the location

and size of a hydrocarbon spill there is the potential that intertidal benthic communities could be

affected. Therefore, consideration will be given to the potential impact in the EA.


Table 5-2 Intertidal and benthic communities EA approach


Desk based review Desk based information on the benthic ecology of the project area and designated sites and species will be used to support the review of the specialist benthic survey data.

EMODnet (EUSeaMap) Predicted EUNIS Habitats data digital data 2012;

OSPAR habitats digital data 2014;

Davies, J. (1998). Bristol Channel and approaches;

DTI Strategic Environmental Assessment 8 (OESEA) Synthesis of Information on Benthos 2007;

DTI Strategic Environmental Assessment 6 Synthesis of Information on Benthos 2005.

Marine survey Survey data will be reviewed to establish the main habitats/biotopes occurring along the length of the marine cable route, and identify any areas of particular sensitivity which may be susceptible to impacts during construction, maintenance and operation activities.

Benthic survey data.

Consultation Request any information on known areas of conservation interest for benthic ecology such as Annex I Habitat.

Consult on necessity of intertidal survey if confirmed approach is HDD.

NRW, JNCC


19 December 2016 40

5.2 FISH AND SHELLFISH


The Strategic Environmental Assessment (SEA) 6 provides information on fish assemblages in the

Irish and Celtic Sea. The variable seabed conditions across the south-western coasts of England and

Wales supports a wide variety of fish species with distinct assemblages associated with particular

seabed conditions. Sandy inshore areas support large number of juvenile flatfish and sandeels, with

seasonal populations of sprat and herring. Rockier strata are characterised by small species such as

wrasse, gobies and blennies as well as juvenile Pollock (Pollachius). A number of demersal fish

spawn and have nursery grounds in the area whilst pelagic fish such as mackerel and herring range

widely within the region, migrating between summer feeding grounds and overwintering grounds

(Cefas 2005).

The Centre for Environment, Fisheries and Aquaculture Science (Cefas) provides information on

spawning ground for fish stock in the UK waters in the form of fisheries sensitivity maps (Coull et al.

1998 and Ellis et al. 2012). This data, presented in Figure 5-3, provides an indication of the species

that spawn and nurse within or close to the proposed marine cable route. These species include:

tope (Galeorhinus galeus); thornback ray (Raja clavata); herring (Clupea harengus); Atlantic cod

(Gadus morhua); whiting (Merlangius merlangus); blue whiting (Micromesistius poutassou); ling

(Molva molva); hake (Merluccius merluccius); anglerfish (Lophius piscatorius); sandeels

(Ammodytidae); horse mackerel (Trachurus trachurus); mackerel (Scomber scombrus); plaice

(Pleuronectes platessa); sole (Solea solea); lemon sole (Microstomus kitt); and sprat (Sprattus

sprattus).

With the exception of hake all species have a low to medium probability of 0 group fish (i.e. fish

within their first year of life) within the vicinity of the work site (The Scottish Government 2014).

The probability of 0 group hake increases to medium to high towards the UK/Irish median line. In

addition to fish noted to spawn and nurse in the area, horse mackerel (Trachurus trachurus) has

been identified as having a probability of 0 group varying between low to medium and medium to

high along the marine cable corridor. The likelihood of presence has been defined with reference to

the Random Forest probability of presence scale, low probability is defined as 0 ranging to high

probability at around 0.99 (maximum score is dependent on species type and ranges from 0.525 for

herring to 0.99 for haddock).

Important fish species

On the International Union for Conservation of Nature (IUCN) (the World Conservation Union) Red

List of Threatened Species; Atlantic cod and spurdog (Squalus acanthias) are listed as vulnerable and

sandeel (species Ammodytes tobianus) and sole are listed as deficient. In addition, sandeel, herring,

cod, whiting, European hake, blue whiting, spurdog, ling, plaice, mackerel and sole have been listed

on the UK Biodiversity Action Plan (UK BAP) as priority fish species (JNCC 2016a).

Commercially, the Atlantic herring (Clupea harengus) fishery within Milford Haven has considerable

local and commercial importance with its season running between December and February.

Spawning of herring usually takes place in late summer at depths of between 15-40m with herring

depositing their sticky eggs on coarse sand and gravel. The dependency of herring on these specific

substrates makes the species potentially susceptible to disturbance.


19 December 2016 41

Sandeels are also susceptible to disturbance as they lay their eggs on the sediment and live within

close contact with the sediments. This species is important for the breeding success of some

seabirds which can be reduced dramatically when sandeel abundance decreases (Furness and Tasker

2000).

Elasmobranchs

Elasmobranchs (sharks, skates and rays) are among the most vulnerable marine fish due to their

slow growth rates, late maturity, low fecundity and productivity which limits their capacity to

recover from population declines. All sharks and rays are on the OSPAR list of threatened and

declining species.

The basking shark (Cetorhinus maximus) is the largest fish in the North Atlantic and the second

largest in the world. The shark is commonly seen at the surface in the summer months, particularly

around the western coasts of the UK, but it is less clear where they spend the winter. This species is

listed on the UK BAP as a priority marine species. The lesser and greater spotted dogfish

(Scyliorhinus canicula and Scyliorhinus stellaris) are also very abundant around western UK waters.

Diadromous species

Diadromous species are those which migrate between marine and freshwater as part of their

lifecycle. The sea lamprey (Petromyzon marinus) is listed on Annex II on the EC Habitats Directive

and is a qualifying feature for the Pembrokeshire Marine SAC. This species spawns within freshwater

but completes its lifecycle in the sea. The twaite shad (Alosa fallax) and Allis shad (Alosa alosa) are

both members of the herring family and also qualify as features for the designation of the

Pembrokeshire Marine SAC and are listed as Annex II species on the EC Habitats Directive (DTI

2009a). In addition, these two species are also listed as UK BAP priority fish species.




D_WGS_1984DECC, GEBCO, CEFAS, UKHOJ:\P1975\Mxd\Scoping Report\Report Figures\Fish_UK.mxd

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DatePro jec tio n

DatumData So ur c e

File Referenc e

Sp hero id

Ap p r o ved By Anna Farley

0 10 20 30 40 50km © Meto c Ltd, 2014.

All rights reserved.

LegendMedian Line12nm limit

Sp awning areasCod spawning areaLemon Sole spawning areaNephrops spawning areaPlaice spawning areaSprat spawning areaHerring spawning areaSole spawning areaLing spawning areaMackerel spawning areaWhiting spawning areaHorse Mackerel spawning areaSandeel spawning areaHake spawning area

Nursery areasNephrops nursery areaCod nursery areaMackerel nursery areaLemon Sole nursery areaWhiting nursery areaAnglerfish nursery areaBlue whiting nursery areaEuropean hake nursery areaLing nursery areaSandeel nursery areaHerring Nursery AreaSole Nursery AreaThornback Ray Nursery AreaTope Shark Nursery AreaPlaice Nursery Area

Co d Mac kerel Lemo n So le Nep hro p s

Whiting Plaic e & Hake Sp rat Herring & Ho rse Mac kerel

Anglerfish Blue Whiting

Euro p eanHake

Sandeel

Ling

Figure 5-2 Fish sp awning and nursing areas

So le

Tho rnbac k Ray

To p e Shark

Proposed Cable Route

Greenlink Inter c o nnec to rEnvir o nmental Sc o p ing Rep o rt –

UK Marine Ro ute


19 December 2016 43



▪ Demersal spawners: herring, sandeel and thornback ray;

▪ EC Habitats Directive Annex II species: sea lamprey, twaite shad and Allis shad;

▪ IUCN Red listed species e.g. Atlantic cod, spurdog and sandeel;

▪ OSPAR threatened and declining species: all sharks and rays; and

▪ UKBAP priority marine species e.g. sandeel, herring, cod, whiting, European hake, blue whiting,

ling, plaice, shad, mackerel, sole, spurdog and basking shark.


Habitat disturbance: Activities that physically disturb the seabed e.g. cable trenching, have the

potential to disturb species with demersal life stages (i.e. those that lay their eggs on specific seabed

types) such as herring, larval or juvenile ages, or species that live in contact with the seabed like

sandeel. Although disturbed, the composition of sediments are unlikely to significantly change and

the habitat should be suitable for demersal spawning again once activities have ceased. However, as

cable installation and maintenance activities are likely to take place during spring and summer due

to potentially better weather at this time, there is potential that a years’ recruitment could be

affected. The EA will consider the significance of this impact in further detail.

Substratum loss: The placement of cable protection in the form of rock or concrete mattresses (if

required) will result in the localised permanent habitat loss in the direct footprint of the cable

protection. The significance of this impact would depend on the extent of the cable protection

required, the reliance of a species of fish or shellfish upon the particular habitat and the extent of

habitat in the wider area. The presence of the rock protection (if used) could also represent a

change in habitat type, although this may represent a positive effect for some fish species, indirectly

increasing prey availability. As the quantity and position of cable protection is not currently known,

the EA will consider the significance of this impact in further detail.

Physical disturbance of mobile species: Could occur during cable installation, as a result of the

presence of the installation vessels and equipment (and associated noise) within the vicinity of

operations. This could result in the displacement of fish within the water column. The disturbance

from installation operations will be short term, localised and not considered to be significant given

existing background levels of noise and shipping in the St Georges Channel. This impact has been

scoped out of the EA.

Smothering of species: There are three pathways for species to be smothered as a result of project

activities: by displaced sediments during trenching; by the re-deposition of suspended sediment; and

by cable protection material being placed on the seabed. The impact from displaced sediment will

be very localised, only effecting species in the immediate vicinity of cable trenches. Suspended

sediment settlement levels are expected to be minimal with any material deposited likely to be

quickly re-suspended and distributed by natural hydrodynamic processes. The significance of the


19 December 2016 44

impact of depositing cable protection will depend on the extent of the deposit and the nature of the

habitat. This impact will be considered in further detail in the EA.

Reduced feeding success of visual species: The suspension of sediments within the water column

from cable installation may cause small, localised and temporary turbidity before being re-deposited

on the seabed. A temporary reduction in the feeding capability of species relying on sight to locate

their prey may occur. Most species are likely to be tolerant to any changes in turbidity levels (likely

to be equivalent to those experienced during storm events) and the significance of the impact is

likely to be negligible. It is therefore proposed that the impact is scoped out of the EA at this stage.

Toxic effects from disturbance of contaminated sediments: Re-suspension of contaminants is

possible during cable installation, should contaminated sediments be disturbed. This may have

potential effects on nearby species which are exposed to remobilised contaminants. The proposed

marine cable route avoids known areas of contamination and therefore the impact is unlikely to be

significant. However, it will be considered in the EA.

Disturbance from electromagnetic fields (EMF): Electric and magnetic fields generated during cable

operation will be detectable by pelagic fish species such as salmon and certain electrosensitive fish

such as elasmobranchs. The effects of EMF on fish and shellfish species will be assessed in the EA.

Disturbance or injury from underwater noise: Noise will be generated from project vessels including

from dynamic positioning (DP) systems and during installation and maintenance from cable

trenching, ploughing and rock placement operations. The effects of noise on fish and shellfish will be

assessed in the EA.

Heating effects: Operation of the cables will produce heat as a consequence of the internal

resistance of the conductors. The degree of heating will depend on cable specification, however, it is

expected that cable heat will be rapidly dissipated and any heating of the seabed immediately

surrounding the cables will therefore be only marginally elevated above background levels.

Demersal fish species and shellfish in close contact with the seabed are not expected to be impacted.

It is therefore proposed that this impact is scoped out of the EA at this stage.

Collision of project vessels with basking sharks: Basking sharks have occasionally been sighted

within the Pembrokeshire Marine SAC and are considered particularly susceptible to collisions with

vessels due to their presence at the surface for feeding and apparent unawareness of vessels. The

EA will consider the potential impact of the project on this species.

Toxic effects of unplanned hydrocarbon or chemical release: Any unplanned release of surface

pollutants, such as diesel, mineral oils and chemicals from project vessels has the potential to have

toxic consequences for fish species. In fish life cycles the egg and juveniles stages are the most

vulnerable to toxicity in the water column, as adult fish are highly mobile and generally able to avoid

polluted areas. The EA will consider the potential impact of a hydrocarbon or chemical release on

fish and shellfish.


19 December 2016 45


Table 5-3 Fish and shellfish EA approach


Desk based review The fish and shellfish section will identify the distribution of fish and shellfish in the project area (including spawning & nursery grounds), and their sensitivities to cable installation and operation impacts. Particular focus will be given to sandeels and herring which are recognised as sensitive to seabed disturbance. Species of conservation importance including any specific areas designated for their protection will be identified and assessed.

Information on fish spawning and nursery grounds from Cefas (Coull et al 1998 and Ellis et al 2012);

Strategic Environmental Assessment Provision of Fishing Activity Data;

UKBAP priority fish species.

Consultation Consultation with named consultees. MMO, Cefas, JNCC, NRW

5.3 BIRDS


There are three SPAs whose boundaries are in close proximity to the proposed marine cable route:

Grassholm; Skokholm and Skomer; and Castlemartin Coast. Two of these areas regularly support at

least 20,000 seabirds and thus qualify as seabird assemblages of international importance under the

EC Birds Directive (79/409/EEC).

The Irish and Celtic Sea’s diverse habitats provide a suitable environment for a wide range of

seabirds and marine ducks. Around the Pembrokeshire coast species such as herring gulls (Larus

argentatus) and lesser black-backed gulls (Larus fuscus) are found throughout the year with

guillemots (Uria aalge), razorbills (Alca torda) and kittiwakes (Rissa tridactyla) found between July

and September. The latter part of this period is also important for fulmars (Fulmarus glacialis) and

manx shearwaters (Puffinus puffinus) and to a lesser extent puffins and terns (Stone et al. 1995).

Seabird distribution is influenced by various factors, the most important of which is the availability of

food (Stone et al. 1995). Fishing activity influences the distribution of species; most species of

seabirds feed on fish, either directly or as discards from fishing vessels. Most pelagic (and some

coastal) species (e.g. Manx shearwater, gannet, shag, terns, guillemot, razorbill, puffin) are active

fishers, feeding on sandeels, clupeid (herring, sprat) and gadoids (cod, whiting, haddock, saithe, blue

whiting). The distribution and abundance of all seabird species varies throughout the year. Due to

the highly mobile nature of seabirds and their food sources, any areas of high density are likely to

change between seasons and years (Forewind 2013).

The Pembrokeshire islands hold large numbers of manx shearwater, storm-petrel (Hydrobates

pelagicus), guillemot and razorbill, and include Grassholm with its 39,000 gannet (Morus bassanus),

making it the third largest colony on the planet. The coastal habitats of the Skokholm and Skomer

SPA support an important resident population of chough (Pyrrhocorax pyrrhocorax) as well as

breeding seabirds such as petrels, gulls and auks. The Castlemartin Coast is also an important area

for breeding chough with its extensive cliffs and diverse mix of habitats (JNCC 2016b). Table 5-8

provides further information regarding the SPAs within close proximity to the proposed marine cable

route.


19 December 2016 46



▪ Species listed as designated features of SPAs within close proximity to the proposed marine cable

corridor e.g. chough, gannet, manx shearwater, storm-petrel, guillemot, razorbill, puffin, lesser-

black backed gull.


Physical disturbance: During cable installation, repair and maintenance activities, the presence of

project vessels/equipment could result in a temporary disturbance to birds in the immediate vicinity

of the works. Noise is the primary cause of disturbance although the physical presence of

vessels/equipment can also cause a disturbance effect due to physical and visual intrusion.

Disturbance may result in displacement of birds from an area of use (for feeding, breeding, resting,

passage etc.). Given the localised and temporary nature of disturbance, this impact is unlikely to be

significant for disturbance of feeding and foraging birds as they are likely to be able to find

alternative feeding grounds. This impact would be of most concern where disturbance could have

implications for breeding success for example disturbance of nesting birds during the breeding

season. Given the proximity of a number of SPAs, this will be assessed in further detail in the EA.

Temporary loss of food resources and habitat: An option to install the marine cables across the

intertidal zone using open-cut trenching is being considered. A narrow strip of intertidal zone will be

temporarily disturbed with the direct loss of intertidal species within the installation footprint. This

temporary depletion of invertebrate food resource will be restricted and any displaced birds are

likely to find alternative feeding sites. This will be assessed in further detail in the EA.

Toxic effects from unplanned hydrocarbon or chemical release: The presence of installation vessels

may increase the risk of a pollution incident. The significance of the impact will depend on the

nature of the spill (volume and fluid characteristics) and the sensitivity of the receiving environment

within the footprint of the spill. Marine birds are highly sensitive to hydrocarbon or chemical spills,

particularly diving and pelagic species. Control measures and oil pollution emergency plans will be in

pace and adhered to under MARPOL requirements for all project vessels. The significance of this

impact will be assessed in detail in the EA.


19 December 2016 47


Table 5-4 Birds EA approach


Desk based review A desk based review of publicly available information will be used to characterise the sensitivity of coastal and marine birds in and around the project area.

SPA site synopsis

JNCC and NRW area data.

Consultation Request information from the named consultees which will inform the assessment of sensitivity of birds in the project area, particularly any bird surveys.

JNCC, NRW, MMO, Royal Society for the Protection of Birds (RSPB), British Trust for Ornithology (BTO).

5.4 MARINE MAMMALS AND REPTILES


Marine mammals present in the study area include cetaceans (whales, dolphins and porpoises),

pinnipeds (seals) and potentially otter. Chelonians (marine turtles) are the only type of reptile that

may potentially be encountered (Hammond et al. 2008).

Most cetaceans are wide-ranging and individuals encountered within the UKCS form part of a much

larger biological population whose range extends beyond UK waters. As a result management units

(MUs) have been have been outlined for seven of the common regularly occurring species following

advice from the Sea Mammals Research Unit (DECC 2016) and the International Council for the

Exploration of the Seas (ICES). Theses provide an indication of the spatial scales at which impacts of

anthropogenic activities should be taken into consideration. Guidance on the application of the MUs

is currently pending. Species, for which MUs have been defined and the relevant MUs are shown in

Table 5-5.

All cetaceans and marine turtles are European Protected Species (EPS) protected under Annex IV of

EC Directive 92/43/EEC (the Habitats Directive), which lists species of Community Interest in need of

strict protection. It is an offence to deliberately capture, kill, injure or disturb animals classed as EPS.

Harbour porpoise (Phocoena phocoena), bottlenose dolphin (Tursiops truncates), grey seal

(Halichoerus grypus), common/harbour seal (Phoca vitulina) and otter (Lutra lutra) are listed under

Annex II of the Habitats Directive, which lists species whose conservation requires designation of

SACs.

5.4.1.1 CETACEANS

More than 28 cetacean species have been recorded in UK waters of which 11 occur regularly. Within

the Irish and Celtic Sea, approximately 15 species have been recorded and therefore may be

encountered along the marine cable route, at least on a seasonal basis.

Table 5-5 lists species which may be present in the study area and provides an appraisal of the

frequency of sightings.


19 December 2016 48

Table 5-5 Cetacean species recorded within proximity of the proposed marine cable route

Species Frequency of sightings Applicable MU

Toothed whales (odontocetes)

Harbour porpoise (Phocoena phocoena)

Common from June through the autumn/winter. Peak period in August

Celtic and Irish Seas

Bottlenose dolphin (Tursiops truncatus)

Common year round but most frequent in summer.

The Channel, Celtic Sea & SW England

Short beaked common dolphin (Delphinus delphis)

Common off the western coasts of the UK, notable the Celtic Sea and Western approaches to the Channel.

Peak period is spring and summer with a winter peak on the south coast associated with prey items.

Celtic & Greater North Seas

Striped dolphin (Stenella coeruleoalba)

Occasional sightings, most frequent in summer and early autumn months.

N/A

Risso’s dolphin (Grampus griseus)

Peak period in April to September. Celtic & Greater North Seas

Atlantic white-sided dolphin (Lagenorhynchus acutus)

Summer months.

White-beaked dolphin (Lagenorhynchus albirostris)

More regular in late summer – autumn.

Long-finned pilot whale (Globicephala melas)

Most frequent between April and September.

N/A

Killer whale (Orcinus orca)

Occasional sightings off the south coast of Ireland and northern and Western Scotland, but rare in the Irish Sea and south-western UK waters.

N/A

Baleen whales (mysticetes)

Minke whale (Balaenoptera acutorostrata)

Peak period May to September. Celtic & Greater North Seas

Humpback whale (Megaptera novaengliae)

Occasional sightings. N/A

Fin whale (Balaenoptera physalus)

Occasional sightings between June and Decembers

N/A

Sources: Marine Institute (2015), Reid et al. 2003, DECC 2016

The proposed marine cable route passes through the West Wales Marine possible SAC (pSAC). The

objectives of this pSAC are to protect and maintain a favourable status of harbour porpoise

populations in the area. It covers both inshore and offshore waters and is part of a larger network of

a further four pSACs around UK waters.


19 December 2016 49

5.4.1.2 PINNIPEDS

There are three periods in the seal’s life cycle which are of particular importance: breeding, moulting

and pupping. At these times seals tend to be restricted to haul out sites e.g. males defending

territory and females, females feeding pups which can’t swim, animals undergoing the moult, and

are unlikely to be found offshore. These seasons vary between species and sometimes regions.

Two species of seal are resident within UK waters - grey seals (Halichoerus grypus) and harbour (or

common) seals (Phoca vitulina).

Grey seals utilising the area of the Pembrokeshire Marine SAC comprise the major proportion of an

isolated breeding population, in which their breeding ecology differs from that of grey seals

elsewhere. The population size estimates are approximately 5,000 individuals. Pupping time occurs

primarily from August through to December. After three weeks the pups moult with adults

congregating in large numbers on beaches between December and February to moult. Grey seals

can be found within the site all year and favour rocks to haul out such as those present at Stack Fort

in Milford Haven, Skomer and Skokholm. This species is a primary feature for the designation of the

Pembrokeshire Marine SAC (Pembrokeshire Marine Special Area of Conservation 2016).

The harbour seal is widespread around the shores of the UK, but population density varies greatly

from place to place with low numbers recorded at many sites. Sightings of the harbour seal within

the Pembrokeshire SAC are infrequent.

5.4.1.3 REPTILES

Five species of turtle have been recorded in UK waters; the vast majority of these are of Leatherback

turtle (Dermochelys coriacea). Loggerhead (Caretta caretta) and kemp ridley (Lepidochelys kempii)

turtle have also been observed infrequently whilst records of green (Chelonia mydas) and hawksbill

turtles (Eretmochelys imbricate) are extremely rare. Most sightings are on the West and South

coasts of Ireland, southwest England, south and northwest Wales, the west coast of Scotland,

Orkney and Shetland. The Irish Sea is considered a through route for leatherbacks passing from

South Ireland and South West England through to Northern Ireland and the west coast of Scotland.

Leatherback turtles are most commonly observed around the UK and Ireland between June and

October, with peak abundances in August. All marine turtles are endangered and are listed as

critically endangered on the IUCN Red List 2002. As discussed above, they are an EPS listed on Annex

IV of the EC Habitats Directive and are also listed as a UK priority species on the UKBAP (DTI 2009b).

5.4.1.4 OTTER

The otter (Lutra lutra) is a semi-aquatic animal and occurs in both inland freshwater and coastal

areas. Populations in coastal areas utilise shallow, inshore marine areas for feeding. Within the

Pembrokeshire Coast SAC, this Annex II species is present as a qualifying feature for the selection of

the site. Otters are frequent throughout the SAC both on open coast and in the Milford Haven

waterway especially in areas where there is good access to the sea, sufficient tree and scrub cover

and near streams where salt water can be washed off.


19 December 2016 50



▪ EPS species – all cetaceans and turtles

▪ Annex II species listed as designating features of SACs e.g. grey seal and otter.


Disturbance or injury from underwater noise: Both cetaceans and pinnipeds are sensitive to

increased levels of underwater noise, which can induce a range of effects on animals. These range

from behavioural changes, to non-injurious type effects such as masking communication signals, to

temporary or permanent auditory injuries. Project vessels, cable burial machinery, cable protection

placement and marine surveys will all generate underwater noise. A marine mammal risk

assessment, using injury criteria proposed by NMFS (2016), will be conducted as part of the EA to

assess the potential for noise to harm or disturb species.

Collision risk: There is the risk that animals could collide with machinery and vessels present during

cable installation, repair and maintenance activities. Shipping collision is a recognised cause of

marine mammal mortality worldwide, the key factor influencing the injury or mortality caused by

collisions being ship size and speed. Ships travelling at 14 knots or faster are most likely to cause

lethal or serious injuries.

Vessels involved in cable installation or cable repair and maintenance are likely to be either

stationary or travelling considerably slower than this and therefore the collision risk is likely to be

lower than that posed by commercial shipping activity. The significance of the impact will be

considered in the EA.

Physical disturbance: Seals hauled out on land could react to the presence of project vessels. In

general, ships more than 1,500m away from hauled out grey or common seals are unlikely to evoke

any reactions, between 900 and 1,500m seals could be expected to detect the presence of vessels

and at closer than 900m a flight reaction could be expected (Brasseur & Reijnders,1994). This impact

would be most significant for breeding and moulting seals, hauled out on the coast and on intertidal

banks. This will be further explored in the EA.

Magnetic fields interfering with cetacean navigation: Magnetic fields generated during cable

operation have the potential to affect cetaceans. Cetacean species appear sensitive to variations in

the Earth’s magnetic field. There is no apparent evidence that existing interconnector cables have

influenced migration of cetaceans. The effects of magnetic fields on marine mammals will be

assessed within the EA.

Toxic effects from unplanned release of hydrocarbons or chemicals: Any unplanned release of

surface pollutants such as mineral oils and chemicals from project vessels has the potential to affect

marine mammals which encounter the surface pollutant. This will be considered in further detail in

the EA.


19 December 2016 51


Table 5-6 Marine mammals and reptiles EA approach


Desk based review Publicly available data will be used to describe the baseline in terms of importance of the project area for marine mammals and key sensitivities such as seal haul out sites and designated sites for marine mammals. A desk based assessment of the sensitivity of marine mammals to underwater noise will be undertaken.

Cetacean Atlas Reid et al 2003;

Previous survey data e.g. Sea Mammal Research Unit (SMRU);

Small Cetacean Abundance in the North Sea and Adjacent waters (SCANS);

JNCC designated site information; and

SEA8 (OESEA) Hammond et al. 2008.

Consultation Request information on marine mammals including migration routes from named consultees.

JNCC, NRW, MMO.

5.5 PROTECTED SITES


Offshore and coastal protected sites have been established in UK in order to fulfil the requirements

of European Council Directives and national legislation. Table 5-7 describes the different

designations of protected sites.

Table 5-7 Protected site designations

Full designation

Description/notes

Area of Outstanding Natural Beauty (AONB)

Established under the Countryside and Rights of Way Act 2000.

This is a UK designation established for the conservation and enhancement of the natural beauty of the area. They are areas of countryside, which include towns and villages. The duty for the protection of AONBs falls to the local authorities, however, it is most commonly managed by AONB Partnerships, who prepare and review the required Management Plans.

Special Area of Conservation (SAC)

Established under the EC Habitats Directive:

Sites that have been adopted by the European Commission and formally designated by the government of each country in whose territory the site lies. Strictly protected by the Government in which territory it lies.

Note: sites progressing through the designation scheme e.g. candidate (cSAC) and possible (pSAC) sites, are also included.

Site of Community Importance (SCI)

Established under the EC Habitats Directive:

Site which has been adopted by the European Commission but not formally designated as a full SAC by the Government in which territory it lies.

Special Protection Area (SPA)

Established under the EC Birds Directive:

Site which has been adopted by the EC and the Government in which territory it lies for the protection of rare and vulnerable birds and for regularly occurring migratory species.

Site of Special Scientific Interest (SSSI)

Established under the Wildlife and Countryside Act 1981:

Site which has been considered by NRW to best represent natural heritage – diversity of plants, animals and habitats, rocks and landforms, or a combination of such natural features.


19 December 2016 52

Full designation

Description/notes

Marine Conservation Zone (MCZ)

UK designation, established under the Marine and Coastal Access Act (2009):

Designated to protect a range of nationally important marine wildlife, habitats, geology and geomorphology.

Note: recommended (rMCZ) sites, being considered for designation are also included.

National Park Established by Environment Act 1995.

This is a UK designation established for the protection of beautiful areas for the nation. They are areas of countryside, which include towns and villages. National park authorities are responsible for protecting the landscape.

Ramsar Established under the Ramsar Convention.

Wetlands of international importance

As a starting point, protected sites within 10km of the proposed marine cable route have been

identified using a geographical information system (GIS). Based on experience of similar

interconnector projects, 10km is considered to be a suitable distance for assessment purposes. The

project has the potential to interact with conservation features within this footprint and therefore

adversely affect them. Additionally selected sites have been included up to 100km from the

proposed marine cable route because they are important for mobile species. These include sites

important for marine birds and marine mammals which may travel into of through the project area

e.g. for foraging or migration. Sites greater than 100km have not been considered because whilst it

is acknowledged that seabirds may forage and marine mammals may forage / migrate distances

greater than 100km, it is recognised that species from protected sites further away are less likely to

travel to the proposed marine cable route in high enough numbers for the population of qualifying

species to be significantly impacted.

Sites to be included for assessment in the EA are listed in Table 5-8 and are presented in Figure 5-3.

In addition to these designated sites there are also areas of potential Annex I habitat (PAIH). These

are areas identified by JNCC as having the potential to contain habitats listed on Annex I of the EC

Habitats Directive. Annex I habitats that occur in UK waters include: reefs (biogenic and stony);

sandbanks which are slightly covered by seawater all the time; and submarine structures made by

leaking gases.

.

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Env ironmental Sensitiv itiesSPASAC

E E EE E ESSSI

SandbanksProposed MCZpSACpSPAMarine Nature reserve

0 2 4 6 8 10km

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© Metoc Ltd, 2016.All rig hts reserv ed.

Fig ure 5.3: Protected Sites

Jennifer ArthurEmma LangleyAnna Farley

Greenlink InterconnectorEnv ironmental Scoping Report –

UK Marine Route


19 December 2016 54

Table 5-8 Details of protected sites within close proximity to the proposed cable route

Site Name Designation Feature of Conservation Interest Distance to proposed marine cable route (km)

Reason for inclusion

North of Celtic Deep MCZ

(Recommended, but currently on hold)

Covers an area of approximately 656km2. Conservation features include: ▪ Deep water sediments in this zone support richly diverse and abundant population of marine

invertebrates. Worms, clams and crustaceans are present in large numbers and provide food for populations of fish.

▪ Priority features: Sub-tidal coarse sediment, sub-tidal sand and moderate energy circalittoral rock; Habitat of Conservation Importance; Sub-tidal sands and gravels; Geological features, range of habitats (intertidal rock, sand and gravel habitats)

▪ Range of foraging seabird communities including: Chough (Pyrrhocorax pyrrhocorax); Gannet (Morus bassanus); Manx shearwater (Puffinus puffinus); Fulmar (Fulmarus glacialis); Guillemot (Uria aalge)

27.7 Mobile species (seabirds)

Pembrokeshire Marine / Sir Benfro Forol

SAC Covers an area of approximately 1380km2. Primary reason for designation: Annex I Habitats: Estuaries, large shallow inlets and bays and reefs. Annex II Species: Grey seal (Halichoerus grypus) and Shore dock (Rumex rupestris)

Qualifying features: Annex I Habitat: Sandbanks which are slightly covered by sea water all the time, mudflats and sandflats not covered by seawater at low tide, coastal lagoons, Atlantic salt meadows and submerged or partially submerged sea caves. Annex II Species: Sea lamprey (Petromyzon marinus), River lamprey (Lampetra fluviatilis), Allis shad (Alosa alosa), Twaite shad (Alosa fallax) and Otter (Lutra lutra).

Within Within project zone of influence

Skokholm and Skomer SPA Covers an area of approximately 4.3km2. This site qualifies under Article 4.1 of the Birds Directive (79/409/EEC) by supporting populations of European importance of the following species listed on Annex I of the Directive: Chough (Pyrrhocorax pyrrhocorax); Short-eared owl (Asio flammeus); Storm petrel (Hydrobates pelagicus); Lesser black-backed gull (Larus fuscus); Manx shearwater (Puffinus puffinus); Puffin (Fratercula arctica).

The area also qualifies under Article 4.2 of the Birds Directive by regularly supporting at least 20,000 seabirds. During breeding season Skokholm island supports a range of individual seabird species up to 67,278 in number.


Skomer MCZ Covers an area of approximately 10.5km2.

Includes species and habitats of national and international importance. These include grey seal, pink seafan (Eunicella verrucosa), sponge communities, eelgrass (Zostera) and algal communities.

6.7 Within project zone of influence

Grassholm SPA Covers an area of approximately 0.1km2. This site qualifies under Article 4.2 of the Birds Directive by supporting populations of European importance of the following migratory species:

▪ Gannet (Morus bassanus), 33,000 pairs present during the breeding season.



19 December 2016 55

Site Name Designation Feature of Conservation Interest Distance to proposed marine cable route (km)

Reason for inclusion

Ramsey and St David’s Peninsula Coast

SPA Covers an area of approximately 8.5km2. This site qualifies under Article 4.1 of the Birds Directive (79/409/EEC) by supporting populations of European importance of the following species listed on Annex I of the Directive: Chough (Pyrrhocorax pyrrhocorax)

20.9 Mobile species (seabirds)

Castlemartain Coast SPA Covers an area of approximately 11.2km2. This site qualifies under Article 4.1 of the Birds Directive (79/409/EEC) by supporting populations of European importance of the following species listed on Annex I of the Directive: Chough (Pyrrhocorax pyrrhocorax)


Arfordir Penrhyn Angle / Angle Peninsula Coast

SSSI Annex I habitats which justified designation: reefs; and submerged or partially submerged sea caves.

Populations of chough (Pyrrhocorax pyrrhocorax)


Broomhill Burrows SSSI Mobile dunes, dune grassland, dune slack vegetation, rare sand dune plants, populations of chough and the geological features of the cliff.


Castlemartin Range SSSI/SPA Wide range of internationally and nationally important special features. Inter-tidal rock communities, maritime and calcareous grassland, sand dune habitats, numerous rare plants, seabird populations including chough and geological features.


Arfordir Abereiddi SSSI The site is of special interest for its littoral zone including sea caves, its grey seals Halichoerus grypus, which breed and haul out along the foreshore. Approximately 5% of West Wales’ grey seal pups are born along this stretch of coast annually.

32.9 Mobile species (grey seal)

West Wales Marine pSAC Covers an area of approx. 7,377 km2. Identified as important area for the Annex II listed harbour porpoise (Phocoena phocoena).


Bristol Channel Approaches

pSAC Covers an area of approx. 5,851 km2. Identified as important area for the Annex II listed harbour porpoise (Phocoena phocoena).

22.5 Mobile species (harbour porpoise)

Pembrokeshire Coast National Park

National Park The Park is a unique environment including wildlife, habitats, farming, history, tourism, business and local communities.


Celtic Deep MCZ


Covers an area of approximately 347.79km2. Conservation features include: Deep water mud habitats, which are rare in the region, supporting seapens and other burrowing fauna. The area is characterized with high productivity during the summer, which supports large aggregations of copepods, which form an important food supply for basking sharks. Celtic Deep is an important aggregation area for seabirds and short beaked common dolphin (Delphinus delphis) and fin whales (Balaenoptera physalus).

33 Mobile species (short beaked common dolphin and fin whale)

Taw Torridge Estuaries MCZ


Covers an area of approximately 5km2. Taw Torridge Estuaries covers the upper parts of the Taw and Torridge estuaries, which are not covered by the SSSI designation. The area includes diverse habitats including: Subtidal mud and sand; Rocky shore; Saltmarsh; Reed beds.

These habitats form important nursery grounds for commercially important fish such as: European eel (Anguilla Anguilla); European seabass (Dicentrarchus labrax).

95 Mobile species (fish)


19 December 2016 56



▪ West Wales Marine and Bristol Channel Approaches pSACs important for harbour porpoise

populations.

▪ Pembrokeshire Marine SAC is an important area for grey seal, shore dock and otter populations.

▪ Skomer MCZ for its biodiversity.

▪ Skokholm and Skomer SPA important for bird species.


The potential impacts on protected sites will vary depending on the nature of the interest features

they are designated for. A protected site may include interest features from more than one receptor

group and the sensitivity of the interest features may vary according to receptor type. Potential

impacts on individual interest features will be covered in detail within each of the relevant receptor

topic chapters.

To determine the overall significance of the impact on the protected site, and in accordance with the

requirements of The Conservation of Habitats and Species Regulations 2012 (as amended) (the

Habitats Regulations) it will be necessary to undertake a Habitats Regulation Assessment (HRA) (see

Section 3.1.5). This will take the form of a Stage 1 screening assessment, which for each Natura 2000

site will look to answer the question “Is the proposal likely to have a significant effect on the site?”.

It is proposed that the HRA will be presented in the EA.


Table 5-9 Protected sites EA approach


Desk based review A desk based review of publicly available data will be used to describe all existing and potential designated sites. A Habitats Regulation Assessment (HRA) screening report will be prepared to assess whether any likely significant effects on the interest features of Natura 2000 sites will occur as a result of the project activities.

JNCC, NRW

Marine survey Benthic and if required, intertidal surveys, will identify any areas which contain PAIH.

Benthic survey

Consultation Existing useful data, local knowledge on Annex I habitats, updated information on progress of sites recommended for designation.

JNCC, NRW, BTO, RSPB


19 December 2016 57

6. HUMAN ENVIRONMENT

6.1 COMMERCIAL FISHERIES


Commercial fishing in the Irish and Celtic Sea is widely distributed and of the fisheries that are active,

demersal and shellfish are the most important. Demersal target species include; cod, haddock, ling,

monkfish, plaice, ray, skate and sole black whilst shellfish species include; Norwegian lobster, crabs,

scallops, razors and whelks. Pelagic fish landings from this area are mainly of herring and mackerel,

and of relatively less economic importance.

The closest fishing port to the project area is the Port of Milford Haven. In 2014, the number of

fishing vessels registered to the Port of Milford Haven was 466, 91% of which were 10m and under.

The number of fishermen based in the port was 850. From 2002 to 2014, the number of vessels

targeting demersal species in ICES sub-area VII (i.e. the region through which the proposed marine

cable route passes) fell by 28% due to decommissioning schemes, limited fishing opportunities and

quota controls. In 2014, 900 tonnes of demersal fish and 1000 tonnes of shellfish were landed at

this port representing values of £2.4 million and £1.6 million respectively (MMO 2014).

Fisheries within the Celtic Seas are managed through the EU Common Fisheries Policy (CFP) with

fisheries of some stocks managed by the North East Atlantic Fisheries Commission (NEAFC) and by

coastal state agreements.



▪ Important fishing grounds: Offshore trawling for plaice and other important flatfish bycatches.

▪ Any high density areas of static gear.


Displacement of fishing activity: Fishermen may have reduced access to their fishing grounds during

cable installation, repair and maintenance due to the mobile safety exclusion zone around the cable

installation, repair and maintenance spread. As the exclusion zone moves with the installation vessel

spread, potential impacts will be temporary and restricted to this relatively small zone. There is also

the possibility that if fixed gear such as pots are within the project area they may need to be

temporarily moved. This will be considered in further detail by the EA.

Reduction in water depth: Use of cable protection e.g. rock berms in water depths of less than 30m

has the potential to reduce chart datum by more than 5%; the threshold currently advised by the

Maritime and Coastguard Agency as acceptable. The EA will consider whether cable protection (if

proposed) has the potential to adversely affect the ability of vessels to navigate safely.


19 December 2016 58

Loss or damage to fisheries habitats/fish stocks: As a result of the loss or disturbance of benthic

habitat and fish and shellfish species, there is potential for an indirect impact to the commercial

fisheries resource within the footprint of the proposed marine cable. This is unlikely to be significant

but will be considered in more detail in the EA.

Compass deviation from emission of electromagnetic fields: The generation of EMF could cause a

small localised compass deviation in ships using magnetic compasses (or with autohelm controlled

by magnetic compasses). Impacts of this effect could result in a navigational and safety risk to

mariners. This will be assessed in the EA.

Contamination of stock: Fish and aquaculture stock could potentially be contaminated through two

impact-receptor pathways; the creation of a sediment plume by activities which disturb the seabed

e.g. ploughing and jet-trenching; and the unplanned release of hydrocarbons or chemicals. An

increase in turbidity from installation plumes has the potential to contaminate shellfish species such

as mussels and oysters. Changes to water quality, including the suspended particulate matter load,

resulting from installation and maintenance operations are typically within normal environmental

variability. Changes will be temporary and restricted to the immediate vicinity of the cable. This is

unlikely to cause significant impacts to commercial aquaculture but will be considered in more detail

in the EA.

The likelihood of a hydrocarbon spill from a project vessel is the same as from general shipping in the

region. The potential significance of any impacts on fish stocks will be assessed in the EA.

Snagging resulting from obstructions on the seabed: Certain project activities have the potential to

create temporary and longer term obstructions on the seabed. The introduction of new obstructions

has the potential to increase the risk of gear snagging. This will be considered in more detail in the

EA.


Table 6-1 Commercial fishing EA approach


Desk based review The specialist fisheries study will be supplemented with catch statistics to provide the baseline along the proposed marine cable route.

Cefas sensitivity maps (Coull et al 1998 and Ellis et al 2012);

ICES Landing statistics.

Baseline study A specialist study will be undertaken to identify key fishing grounds, seasons and activities. It will identify possible economic impacts of the project, provide analysis of catch landing statistics and review other publically available data.

Specialist commercial fisheries study

Consultation Meetings with fishing industry organisations and representatives.

The National Federation of Fishermen’s Organisations (NFFO);

Inshore Fisheries and Conservation Authorities (IFCA).


19 December 2016 59

6.2 SHIPPING AND NAVIGATION


The proposed marine cable route passes through UKCS oil and gas quadrats 103 and 102; shipping

density in this area is described as very low in relation to the UKCS as a whole. However, the

proposed marine cable route passes through the south-westerly corner of the ‘Off Smalls’ traffic

separation zone (TSS) (Figure 6-1). The TSS is located west of The Smalls and is an area where

navigation of ships is highly regulated with the aim of creating lanes in the water with ships specific

to a lane all going roughly in the same direction. This is to regulate the busy waterways and help

reduce congestion whist entering or leaving the Port of Milford Haven. This area is adopted by the

International Maritime Organisation.

There are multiple navigation lines on the approach to the Port of Milford Haven. Defined anchoring

areas are restricted to sites mapped in Figure 6-1.

A shipping and navigation risk assessment will be undertaken to inform the EA.



▪ Shipping routes


Displacement of vessels: The presence of the mobile safety exclusion zone around the vessel spread

during cable installation, repair and maintenance has the potential to disrupt shipping activity.

Vessels may be required to alter planned routes. The significance of the impact on shipping will be

assessed by the EA.





Risk of ship collisions: It is recognised that ship to ship collisions could potentially occur. All vessels

will comply with the International Regulations for Preventing Collisions at Sea 1972 and as such the

potential impact is considered to relate to safety, outside of the scope of this assessment. It is

therefore proposed that that this impact is scoped out of the EA at this stage.

Accidental anchoring or emergency anchoring on unburied / buried cable: During installation there

is the potential for a ship to accidentally anchor over unburied cable prior to its burial, snagging the

anchor and resulting in potential damage to the ship. There is also a potential risk that a ship

anchoring in the vicinity of the marine cables may drag anchor towards and over the cable. The

likelihood of a commercial vessel accidentally releasing its anchor in close proximity to the marine

cables is low, as the cables represent a small surface area of a larger area in which vessels can

operate. Incidents of accidental anchoring whereby a cable is struck have been reported, but these


19 December 2016 60

are typically been in close proximity to offshore structures such as platforms where the ratio of

surface areas of cables to operating area of the vessel is higher. Given the low likelihood of an

incident occurring it is proposed that this impact is scoped out of the EA at this stage.

EMF interference with navigation systems: The EMF that will be generated by the marine cables

during operation will have a localised effect which could potentially cause compass deviation in

vessels using magnetic compasses. Commercial vessels and military craft using inertial navigation

systems and GPS have negligible sensitivity to EMF as they are unaffected by external magnetic

fields. Few commercial vessels operate solely using magnetic compasses but they may still be used

as an auxiliary navigation system. This impact will therefore be given consideration by the EA.


Table 6-2 hipping and navigation EA approach


Desk based review The navigation and shipping baseline will be primarily based on the results of a specialist study.

Seazone digital data.

Admiralty charts.

Pilotage guides.

Automatic Information System (AIS) data

Baseline study A specialist study will provide data on maritime activity, shipping intensity and density in the study area and a risk assessment of potential shipping hazards such as collision risk and anchoring risks.

Shipping study and navigation risk assessment.

Consultation Consultation with key ports and the Maritime and Coastguard Agency (MCA) and other maritime stakeholders.

Port of Milford Haven, Trinity House, MCA.

.

Created ByReview ed By


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. Figure 6-1 Anthropogenic activities within closeproximity to the proposed marine cable route

Greenlink InterconnectorEnvironmental Scoping Report –

UK Marine Rou te

© Metoc Ltd, 2016.All righ ts reserved.


19 December 2016 62

6.3 INFRASTRUCTURE AND OTHER USERS


6.3.1.1 MINISTRY OF DEFENCE

The Castlemartin firing range is positioned to the south of the Milford Haven Waterway with the

military practice area covering approximately 24km2. The ranges are active for 44 weeks of the year

and when in use can include a coastal exclusion zone of 22km off the coast or as little as 5.6km

depending on equipment used (MHPA 2016). This exclusion zone restricts leisure boating and

anchorage in the area. The proposed marine cable route passes through the northern boundary of

this range as shown in Figure 6-1. There are no other military practice areas within the vicinity of the

proposed marine cable route.

6.3.1.2 DISPOSAL SITES

Dumping grounds are shown on Figure 6-1; these areas can be open/current or closed/historic and

are typically designated for dumping of dredged material or ship waste but can also include chemical

or munition waste. The dumping ground within close proximity to the proposed cable route was

historically used for disused explosives.

Consultation with the Port of Milford Haven alongside the Crown Estate conflict check identified that

the site closest to the harbour entry is closed. The proposed marine cable has been routed to avoid

the area.

6.3.1.3 OIL AND GAS INFRASTRUCTURE

There are ten abandoned wells in the lower section of the Celtic Sea, dating back to 1974.

Abandoned wells are left capped with no structures above the seabed. None are in the immediate

vicinity of the proposed marine cable route.

6.3.1.4 PIPELINES AND CABLES

Pipeline and cable crossings have been avoided where route development associated with avoiding

them has not significantly increased in route length. Minimising crossings has two benefits:

▪ Improved cable security; and

▪ Potential installation cost savings.

The proposed marine cable route crosses the active UK-Ireland crossing (Seg B) telecom cable which

runs between Ballinsker, Ireland to Crooklets Bay, UK shown on Figure 6-1. No pipelines have been

identified in the region.

6.3.1.5 OTHER MARINE DEVELOPMENTS

There are no marine aggregate extraction sites or windfarms (proposed, in construction or in

operation) in the vicinity of the proposed marine cable route.


19 December 2016 63

Wave Hub Ltd wave energy demonstration zone is located 13km (at the closest point) off the South

Pembrokeshire coastline approximately 16km from the proposed marine cable route (Figure 6-1).

The zone covers a 90km2 area of seabed with an aim to help marine energy developers test in open

sea conditions.

6.3.1.6 TOURISM AND RECREATION

The Pembrokeshire coast has some of the best and most attractive resources in the UK for coastal

tourism and leisure. Pembrokeshire tourism has grown to become the largest and most proactive

tourist association in Wales. In 2009, the value of tourism in Wales was placed at 6.18 billion, 13.3%

of the nation’s gross domestic product (Wales Tourism Alliance 2012).

The landfall at Freshwater West does not lie close to any settlements; however the excellent water

quality and beach still attracts tourists. This beach is popular with experienced surfers and is known

as one of the most consistent surfing spots in Wales holding waves up to around 6-8ft (Visit

Pembrokeshire 2016). The Welsh National Surfing Championships are regularly held at Freshwater

West around May.

Recreational cruising routes, general sailing and racing areas are also present off the Pembrokeshire

coast, as illustrated in Figure 6-2, with routes between Lands End and North Wales passing 10nm

offshore of the Pembrokeshire coast. Several large marinas are found within Milford Haven such as

the Milford Marina and Neyland Yacht Haven (DTI 2005c).

. Figure 6-2 RYA routes within close proximity of the proposed marine cable route



Tuesday, December 13, 2016 14:56:26WGS_1984_UTM_Zone_29N

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Greenlink InterconnectorEnvironmental Scoping Report -

UK Marine Route


19 December 2016 65



▪ Castlemartin firing range

▪ UK-Ireland crossing (Seg B) active telecom cable.

▪ Wave Hub Ltd wave energy demonstration zone

▪ Recreational activities e.g. boating, diving, surfing, fishing, beach walking / sunbathing.


Displacement of military and recreational users of the sea: The main potential impact on military

vessels and tourism and recreation in the project area is temporary displacement from the project

area during cable installation, repairs and maintenance. This potential impact will be covered in the

shipping and navigation chapter and so will not be assessed separately within the EA. The potential

impact will be localised and short term and is not expected to result in any significant impacts so

long as stakeholders are consulted with early in the EA process.

Restricted access to the beach: There is a potential for some restriction of access to the beach at the

landfall site during cable installation. This may potentially impact visitors to the coastal area during

the holiday season. The EA will consider this impact in further detail.





EMF interference with navigation systems: There is the potential that EMF generated by the marine

cables during operation will have a localised effect which could potentially cause compass deviation

in vessels using magnetic compasses. This potential impact will be covered in the shipping and

navigation chapter and will not be assessed separately for recreational and military vessels.

Damage to or interference of an external cable asset: There is the potential for installation and

maintenance activities to damage the existing active cable, particularly at the crossing point. The

cable asset will be crossed at 90°. Cable crossing agreements between Greenlink and the third party

cable operator will include design and installation methods for crossing arrangements. Therefore

the potential for the installation of Greenlink to damage the existing asset is greatly reduced. It is

proposed that this potential impact is scoped out of the EA at this stage.

Sterilisation of seabed limiting development options: There is likely to be a development exclusion

area in place either side of the proposed marine cables once installed. This is to protect them from

interference from future development. However, it effectively sterilises the seabed from other

development and potentially could reduce development options for future projects. Potentially this

could be pertinent for the Wave Hub Ltd wave energy development zone which may require export

cables to land in future. Consideration will be given to this potential impact in the EA.


19 December 2016 66

Unplanned release of hydrocarbons or chemicals leading to displacement of marine activities: The

presence of project vessels will marginally increase the risk of a pollution incident. Depending on the

nature and size of a spill this could potentially affect recreational sea users, displacing them from an

area whilst clean-up operations take place. This will be considered further in the EA.


Table 6-3 Infrastructure and other users EA approach


Desk based review A desk based review of publically available information will be used to describe the existing baseline and significance of impacts.

KISCA, UKDeal, SeaZone, RYA

Baseline study Geophysical survey data will be able to confirm the position of the cable asset.

Geophysical survey data

Consultation Consultation with asset owners/ operators will be undertaken to develop crossing agreements where appropriate.

Consultation with relevant recreational stakeholders.

Asset owners, RYA, Pembrokeshire Coast National Park Authority

6.4 MARINE ARCHAEOLOGY


There are a significant number of wrecks in and around the proposed marine cable route. There are

no known wrecks designated for protection however further information through consultation and /

or an archaeological specialised study is required to provide a comprehensive baseline description.

Storms of 2014 have exposed numerous wreckages on Freshwater West beach. The ‘Upside Down

Wreak’ is present at low tide with timbers measuring approximately 15.5m x 3.5m. Records suggest

that 19 wrecks are located around the Freshwater West beach area (Cundy and Turner 2014).

Furthermore, these storms also lowered sand levels substantially exposing peat beds with some tree

stumps, fallen trees, roots and branches. The compacted peat deposits in this area have been dated

to 5250-4550 BC.

Geophysical and geotechnical data from the marine route survey will be reviewed and analysed by

an experienced marine archaeologist to provide a comprehensive archaeological baseline.

If the option to use open-cut trenching across the beach at Freshwater West is progressed, a site

walkover of the beach and intertidal area will be undertaken by a qualified and experienced

archaeologist.



▪ Palaeo-landscape features.


19 December 2016 67

▪ Maritime wreck sites.

▪ Unknown wreck sites (aircraft or maritime).

▪ Submerged peat deposits.


Direct damage to archaeological asset: During cable installation, maintenance and repair there is a

potential that sites (e.g. shipwrecks, palaeo-landscapes) may be damaged and artefacts destroyed

within the immediate footprint of the works. The EA will consider the impact in further detail.

Indirect damage to archaeological asset: Potential indirect impacts arise when direct impacts have

effects beyond their primary footprint which can affect archaeological sites or materials some

distance away. These can include changes to erosion patterns or sediment transport as a result of

installation, maintenance or repair activities. These can have either negative effects e.g. increasing

the rate of deterioration of the asset as it is increasingly exposed or positive effects e.g. increasing

the sediment cover affording the asset additional protection. The EA will consider this impact in

further detail.

6.4.3 ENVIRONMENTAL APPRAISAL APPROVAL

Table 6-4 Marine archaeology EIA approach


Desk based review Desk based review Specialist study.

Baseline study Archaeological assessment of geophysical and geotechnical survey data to highlight areas of archaeological interest, assess potential impacts and identify appropriate mitigation measures.

Geophysical and geotechnical survey data

Consultation Request any relevant information on the potential for archaeological sensitivities.

CADW


19 December 2016 68

7. IMPACT ASSESSMENT METHODOLOGY

7.1 INTRODUCTION

This section describes the approach and methodology that will be used for the EA. The proposed

project has three distinct phases: installation, operation and decommissioning. The EA will consider

the impacts from cable installation and operation, including maintenance and repair only. The final

requirements of decommissioning the interconnector will be assessed separately, towards the end

of project life.

The Environmental Report (ER) will report on the EA process, its findings and conclusions. It will set

out proposed mitigation measures to avoid or reduce the level of impact to an acceptable level.

7.2 BASIS OF THE ASSESSMENT

The EA methodology follows the principles of Environmental Impact Assessment and draws upon

numerous guidance documents and regulations, including:

▪ The Institute of Environmental Management and Assessment (IEMA) Guidelines for

Environmental Impact Assessment, 2004.

▪ The Chartered Institute of Ecology and Environmental Management (CIEEM) Guidelines for

Ecological Impact Assessment in Britain and Ireland: Marine and Coastal, 2010.

▪ Scottish Natural Heritage (SNH); A handbook on environmental impact assessment: Guidance for

Competent Authorities, Consultees and others involved in the Environmental Impact Assessment

(EIA) Process in Scotland, 2013.

7.3 ENVIRONMENTAL ASSESSMENT APPROACH

The assessment process will involve the following steps:


19 December 2016 69

The steps are described in more detail below and will be followed and presented within the receptor

topics of the ER.

7.3.1 CHARACTERISATION OF THE EXISTING BASELINE

In order to assess the potential impacts resulting from the project it is necessary to first establish the

physical, biological, and human conditions that currently exist along and within the vicinity of the

submarine cable corridor.

A good understanding of the baseline for each environmental receptor will be achieved through four

activities:

▪ Review of primary baseline studies (field).

▪ Review of additional specialist baseline studies (desk-based).

▪ Detailed review of all secondary sources (i.e. existing documentation and literature).

▪ Stakeholder consultation.

The key data sources used to establish the baseline will be described in each topic Chapter.

For each receptor topic the baseline will be described in sequence following the submarine cable

corridor from the UK landfall to the UK median line.

7.3.2 ESTABLISH POTENTIAL IMPACTS AND ZONE OF INFLUENCE

Having established baseline conditions, the next step is to identify for each environmental receptor

(e.g. fish, birds, shipping, tourism) project activities which have the potential to interact with the

receiving environment and result in an impact. Activities undertaken during installation and

operation are considered in terms of their potential to directly or indirectly:

▪ Interact with the existing natural environment (including physical and biological elements) and /

or human environment in a manner that could alter the established baseline.

▪ Cause significant stakeholder concerns.

▪ Breach relevant legal standards, corporate environmental policy and management systems.

Both direct (resulting from a direct interaction between the project and the receiving environment)

and indirect (impacts which are not a direct result if the project, often produced away from or as a

result of complex pathway) impacts will be considered. Cumulative and in-combination impacts will

be assessed separately (see Section 7.3.10).

For each project activity its zone of influence – the spatial extent over which the activities are

predicted to have an impact on the receiving environment – will be established. This will vary for

different activities and for the different stages of the project (installation and operation).

Establishing the zone of influence for different activities and receptors will be undertaken

quantitatively where possible but also qualitatively where necessary based on the project


19 December 2016 70

description, project experience and literature reviews. Zones of influence will be established in the

project description.

Receptors which occur outside the zone of influence and cannot or are unlikely to travel into the

zone (e.g. benthic communities) will be screened out from being impacted by the project.

Conversely, mobile species and other mobile receptors such sea users can travel into the zone of

impact and therefore be impacted by the project.

Zones of influence will be considered for each potential impact on the receptor. Where a number of

project activities have the same impact (e.g. pre-sweeping, pre-lay grapnel run, trenching, resulting

in seabed disturbance) or the installation technique has not been determined, the worst case spatial

extent will be applied.

7.3.3 CHARACTERISATION OF THE CHANGE AND IMPACT

In order to fully characterise an impact or level of change from baseline conditions the following

parameters will be considered. These parameters are used to define the magnitude of change or the

magnitude value for the impact based on the definitions provided in Table 7-1.

Table 7-1 Criteria for characterising the magnitude of the impact

Magnitude Value

Definition

High Long term (> 5 years) and/or regional level loss or major alteration to key elements /features of the baseline condition such that post development character/composition of baseline will be fundamentally changed.

Medium Medium term (1- 5 years) loss and/or local level change (greater than the project footprint) or alteration to one or more key elements/features of the baseline conditions such that post development character/composition of the baseline condition will be materially changed.

Low Short term (<1 year), site specific and/or minor shift away from baseline conditions. Changes arising from the alteration will be detectable but not material; the underlying character /composition of the baseline condition will be similar to the pre-development situation.

Negligible Very little change from baseline conditions. Change is barely distinguishable, approximating to a “no change” situation.

• The magnitude refers to degree of change to the baseline environmentcaused by the impact being described.

Scale of Change

• The extent of an impact is the full area over which the impact occurs.Spatial extent

• The duration is the period within which the impact is expected to last priorto recovery or replacement of the feature. Frequency refers to how oftenthe impact will occur.

Duration & Frequency


19 December 2016 71

7.3.4 CHARACTERISATION OF THE RECEPTOR

The significance of an impact on a receptor or feature is characterised by the sensitivity,

recoverability and importance of the receptor or feature. Characterisation of the receptor is

achieved by balancing out these three considerations to determine the Receptors Value. Criteria

used for the assessment are presented in Table 7-2.

Table 7-2 Criteria for characterising the sensitivity of the receptor (receptor value)

Receptor Value

Definition

High Receptor has little or no ability to absorb change without fundamentally altering its character. For example:

Physical Biological Human

One or more combinations of: ▪ Receptor has low / no capacity

to return to baseline condition within project life e.g. low tolerance to change and low recoverability such as a physical feature formed over a geological time scale.

▪ The receptor is a designated feature of a protected site, or is rare or unique.

One or more combinations of: ▪ Receptor has low tolerance to

change e.g. the species population is likely to be killed or destroyed by the project activity (MarLin 2016).

▪ Recovery to baseline conditions over a very long period i.e. > 10 years or not at all (MarLin 2010).

▪ The receptor is a designating feature of an International protected site e.g. European Natura 2000 or RAMSAR site

▪ Receptor is very rare / unique / or ecologically important.

One or more combinations of: ▪ Receptor has low / no capacity

to return to baseline e.g. low tolerance to change and low recoverability such as loss of access with no alternatives.

▪ Damage to asset(s) e.g. at cable crossing, resulting in major financial consequences for the company.

▪ Receptor is economically valuable.

Medium Receptor has moderate capacity to absorb change without significantly altering its character; however some damage to the receptor will occur. For example:


One or more combinations of: ▪ Receptor has intermediate

tolerance to change. ▪ Medium capacity to return to

baseline condition e.g. >5 of up to 10 years.

▪ The receptor is valued but not

One or more combinations of: ▪ Receptor has intermediate tolerance

to change e.g. some individuals of the species may be killed/destroyed by the project activity and the viability of a species population may be reduced (MarLin 2016).

One or more combinations of: ▪ Receptor has intermediate

tolerance to change e.g. loss of access but acceptable alternatives, alteration to route but with no significant economic consequences.

• The sensitivity of the receptor relates to its sensitivity/vulnerability tochange (including its capacity to accommodate change i.e thetolerance/intolerance of the receptor to change).

Sensitivity

• The ability of the receptor to return to the baseline state before theproject impact caused the change.

Recoverability

• The importance of the receptor or feature is a measure of the valueassigned to that receptor based on biodiversity and ecosystemservices, social value and economic value. Importance of the receptoris also defined within a geographical context, whether it is importantinternationally, nationally or locally important.

Importance


19 December 2016 72

Receptor Value

Definition

protected. ▪ Recovery to baseline conditions over a long period i.e. > 5 or up to 10 years (MarLIN 2010).

▪ The receptor is designated as a national site e.g. SSSI, Nature Reserve, MCZ

▪ Uncommon or moderately valuable economically or ecologically but not rare or unique.

▪ Damage to asset(s) e.g. at cable crossings, resulting in financial consequences for the company.

Low The receptor is tolerant to change without significant detriment to its character. Some minor damage to the receptor may occur. For example:


One or more combinations of: ▪ Noticeable but short-term,

localised change in baseline condition e.g. within environmental quality standards or regulatory compliance levels, disturbance to seabed sediments, seabed features, geomorphological features, coastal processes or quality change within zone of influence.

▪ High capacity to return to baseline condition e.g. <1 year

▪ The receptor is common and/or widespread.

One or more combinations of: ▪ Localised or short term damage /

disturbance to portion of the population / habitat

▪ Recovery to baseline conditions within 1 year

▪ The receptor is neither rare, unique or of significance in terms of economic or ecological value.

One or more combinations of: ▪ May affect behaviour but is not

a nuisance to users. ▪ Minor / no financial

consequence to the company.

Negligible The receptor is tolerant to change with no effect on its character.

The project activity does not have a detectable effect on survival or viability of a species (MarLIN 2016). The habitat or species is expected to recover rapidly i.e. within a week (MarLIN 2010)

7.3.5 ASSESSMENT OF SIGNIFICANCE OF EFFECT

Having established the magnitude of change (magnitude value) and the sensitivity of the receptor

(receptor value), the significance of the effect will be assessed using the significance matrix adapted

from the SNH (2003) Handbook on EIA; presented in Table 7-3.

Table 7-3 Significance matrix

Magnitude of change

Negligible Low Medium High

Sen

siti

vity

of

rece

pto

r High Negligible Moderate Major Major

Medium Negligible Minor Moderate Major

Low Negligible Negligible Minor Moderate

Negligible Negligible Negligible Negligible Minor

The result of using this matrix approach is the assignment of the level of significance of the effect for

all project potential impacts. This is done prior to any mitigation.

Definitions of the significance levels are provided in Table 7-4 below.


19 December 2016 73

Table 7-4 Definitions of significance levels

Significance Definition

Negligible Generally considered as insignificant.

Minor Generally considered as insignificant and adequately controlled by best practice and legal controls. Opportunities to reduce effects further through mitigation may be limited and are unlikely to be cost effective.

Moderate Generally effects are those people are prepared to tolerate. However, it is expected that the residual effect has been subject to feasible and cost effective mitigation, and has been reduced to as low as reasonably practicable (ALARP) and that no further measures are feasible.

Major Generally regarded as unacceptable prior to any mitigation measures being considered.

The significance assessment is repeated taking into consideration the application of legal compliance

and appropriate mitigation. This determines whether there is likely to a residual impact. When

applied after mitigation, the resulting significance level is referred to as the residual significant

effect. Tables within the topic chapters will present the results of both assessments.

Residual effects assessed as moderate or major after consideration of proposed mitigation measures

will normally require additional analysis and consultation in order to discuss and possibly further

mitigate impacts where possible. Where further mitigation is not possible a residual effect may

remain.

7.3.6 UNPLANNED EVENTS

Unplanned events are incidents or non-routine events that have the potential to trigger impacts that

would otherwise not be anticipated during the normal course of installation or operation. The

severity of impact from the unplanned events of concern can be greater than the severity of

potential impacts associated with routine activities, however the probability of an unplanned event

occurring is typically much lower. Unplanned events which will be considered by the EA include:

▪ Hydrocarbon or chemical spill.

▪ Ship to marine mammal collision.

For unplanned events it is more appropriate to conduct a risk based assessment. Risk is a term in

general usage to express the combination of the likelihood of a specific impact occurring and the

severity of the consequences that might be expected to follow from it. The classifications used by

the assessment to determine likelihood and severity are provided in Table 7-5 and Table 7-6 below.

Table 7-5 Likelihood classifications - unplanned events

Likelihood Value Definition

Very Low Plausible during the life time of the project but no known occurrences in the industry

Low Plausible during the life time of the project and believed to have occurred in the industry

Medium Possible within the life time of the project - more than one incident per year in the UKCS

High Probable within the life time of the project i.e. several known occurrences per year in the UKCS

Source: Adapted from European Standard ISO 17776:2002 (BSI 2002)


19 December 2016 74

Table 7-6 Severity classifications - unplanned events

Severity Value

Definition

Environment Business or Asset

Negligible No effects < £10k

Minor Minor significance effects

Oil spill Tier 1 Local assistance required

£10k - 100k

Moderate Moderate significance effects

Oil spill Tier 2 Limited external assistance required

£100k - 1M Local publicity

Major Major significance effects

Oil spill Tier 3 Regional assistance required

£1M - 10M National publicity

Severe Major significance effects

Oil spill Tier 4 National assistance required

> £10M International publicity

Having established the likelihood and severity values the risk can be determined using the below

matrix (Table 7-7).

Table 7-7 Risk matrix - unplanned events

Likelihood

Very Low Low Medium High

Seve

rity

Severe Tolerable Tolerable Unacceptable Unacceptable

Major Tolerable Tolerable Unacceptable Unacceptable

Moderate Acceptable Tolerable Tolerable Tolerable

Minor Acceptable Acceptable Acceptable Tolerable

Negligible Acceptable Acceptable Acceptable Acceptable

Source: Adapted from European Standard ISO 17776:2002 (BSI 2002)

The coloured zones in Table 7-7 indicate broad risk acceptability and tolerability levels as follows:

Table 7-8 Risk acceptability levels

Acceptable Risks are accepted without further reduction other than the routine management process of continual improvement.

Tolerable Risks which are accepted in a given context based on the current values of society. This generally means provided that the risks are reduced to as low as reasonably practicable (ALARP).

Unacceptable Risks cannot be justified under the current criteria. Strategy needs to be implemented to manage the risk.

Source: Adapted from HSE Framework for Decisions on the Tolerability of Risk in UKOOA

(1999)

Given the high potential severity of unplanned events, they typically require plans specifically

designed to respond to the event as quickly and effectively as possible. For cable installation and

operation, the responsibility generally lies with the vessel contractor to prepare and implement

plans and mobilise resources, although additional resources from external parties such as

government agencies are often an inherent part of the incident response.


19 December 2016 75

7.3.7 ESTABLISH MITIGATION

Mitigation measures are the actions or systems proposed to manage or reduce the potential

negative impacts identified. Mitigation measures are sometimes confused with measures taken to

ensure legal compliance, which can be similar. Legislation is often designed to ensure impacts to the

environment are minimised. Legal compliance can therefore avoid or abate negative impacts.

Measures which are considered legal compliance will be listed within each topic Chapter as

appropriate.

Typically, mitigation measures are applied following the below hierarchy:

▪ Avoid or Prevent: In the first instance, mitigation should seek to avoid or prevent the adverse

effect at source for example, by routing the marine cables away from a sensitive receptor.

▪ Reduce: If the effect is unavoidable, mitigation measures should be implemented which seek to

reduce the significance of the effect.

▪ Offset: If the effect can neither be avoided nor reduced, mitigation should seek to offset the

effect through the implementation of compensatory mitigation.

Mitigation measures fall into two categories: mitigation which forms part of the project design; and

mitigation which is part of the construction and operation of the project. Mitigation measures which

form part of the design are an inherent part of the project and are considered the ‘base case’.

Mitigation measures which are to be adopted and implemented during the construction and

operation of the project are measures put in place to mitigate adverse effects, over and above legal

compliance.

Appropriate, feasible and cost effective mitigation measures will be proposed as necessary in each

topic Chapter.

7.3.8 ASSESSMENT OF SIGNIFICANCE OF RESIDUAL EFFECT

For those potential impacts which are determined to require project specific mitigation measures, a

further assessment will be made to determine if after the application of mitigation any residual

impacts will remain. The assessment process described above will be repeated to determine the

significance of the residual effect.

7.3.9 CUMULATIVE IMPACTS

The EA will give consideration to cumulative and indirect impacts and interactions. For the purposes

of the assessment, the definitions proposed by the European Commission (1999) will be used. The

definitions are as follows:

▪ Indirect Impacts (secondary impacts) – Impacts on the environment, which are not a direct result

of the project, often produced away from or as a result of a complex pathway.

▪ Cumulative Impacts – Impacts that result from incremental changes caused by other past,

present or reasonably foreseeable actions together with the project.

▪ Impact Interactions – The reactions between impacts whether between the impacts of just one

project or between the impacts of other projects in the area.


19 December 2016 76

For the purposes of the EA, the potential impacts of the development are considered in terms of

impacts on each of the discrete environmental topic areas. In reality, topic areas such as ‘water

quality’ or ‘ecology’ cannot always be considered in isolation since changes affecting one factor may

often have secondary implications for other areas. Thus, if one impact of the development is to alter

the quality of a watercourse, flora and fauna may be affected as a secondary effect. The EA will

identify and assess potential indirect or cumulative impacts and interactions between environmental

topic areas.

The assessment of cumulative impacts will be dependent on the public availability of consented

developments. It is generally acknowledged that there are difficulties in assessing cumulative

impacts via a single-project EA.

Cumulative effects resulting from the connection of the onshore cables will also be assessed.

7.3.10 TRANSBOUNDARY ASSESSMENT

Projects may affect environmental receptors over several maritime jurisdictions. Impact

assessments are required to cover the zone of influence irrespective of administrative boundaries to

inform authorities of potential effects.

Greenlink traverses two maritime jurisdictions (UK and Ireland) and as such transboundary

assessment will be an integral component of the environmental assessment. It is not envisaged that

the project will impact other maritime jurisdictions. However, if the assessment identifies a

potential interaction the transboundary effects will be discussed.

7.4 STRUCTURE OF THE ENVIRONMENTAL REPORT

An Environmental Report will be compiled which will report on the EA process, its findings and

conclusions. It will be divided in the principle chapters outlined in Table 7-9.

Table 7-9 Structure of the Environmental Report

Chapter Title Content

0 Executive Summary The aim of the Executive Summary is to enable communication with those unfamiliar with the environmental appraisal process and terminology by summarising the key findings of the ER in simple terms.

1 Introduction An introduction describing the developer, need for the project and summarising the project.

2 Policy and Legislative Framework

A description of the legislative frameworks which govern the project and the environmental appraisal.

3 Development of the Project and Alternatives

This chapter outlines why the project is preferable to alternative options.

4 Scoping and Consultation This chapter will present an overview of the results of the scoping consultation, and summarise the technical studies and specific surveys that have been undertaken to inform the EA.

5 Project Description A description of the project in terms of the activities that will be undertaken and emissions to the environment during construction and operation of Greenlink.

6 Impact Assessment A description of the process followed when conducting the


19 December 2016 77

Chapter Title Content

Methodology environmental appraisal.

7 Benthic and Intertidal Ecology

These chapters describe the physical, biological and human baseline environment in the project area including identification of key receptors and their sensitivity to possible impacts. The findings of the environmental appraisal are reported, which takes into consideration the nature, magnitude, duration of the potential impacts in order to determine their significance. If necessary, appropriate mitigation measures to avoid, reduce or remedy the effects identified are described.

The chapters are informed by the relevant studies and surveys undertaken by the project.

8 Fish and Shellfish

9 Birds

10 Marine Mammals and Reptiles

11 Protected Sites

12 Commercial Fisheries

13 Shipping and Navigation

14 Infrastructure and Other Users

15 Marine Archaeology

Cumulative and Transboundary Effects

Possible impacts from the overall scheme in combination with other power cable developments as well as other types of development in the vicinity will be assessed.

16 Schedule of Mitigation This chapter outlines the mitigation measures proposed in the assessment, and the minimum requirements contractors will need to take in order to implement them.

17 Conclusions This chapter provides overall conclusions on the significance of any impacts, proposed mitigation and how measures will be implemented.

- Appendices As required, but may include consultation feedback report, appropriate technical reports, key opinions from regulators on TEN-E process requirements.


19 December 2016 78

8. SUMMARY OF ASSESSMENT

An Environmental Report will be produce which will summarise the results of the EA of the project

including the potential for cumulative effects.

It is considered that the EA will provide a robust assessment of the potential impacts of the project

on the environment by:

▪ Establishing an reviewing the existing environmental conditions along the marine cable route and

within the surrounding area;

▪ Identify and assess any environmental impacts associated with the proposed project; and

▪ Identify appropriate, feasible and cost effective measures to mitigate any significant impacts (if

identified).

In order to determine the appropriate scope of the EA, a scoping study has been undertaken. Within

the physical, biological and human environment sections of this scoping study, a high level

preliminary assessment has been made to:

▪ Determine what the key sensitivities are (if any) per receptor group;

▪ Identify potential impacts on these receptors; and

▪ Determine the likely significance of the potential impacts.

Based on the findings of this scoping exercise, Table 8-1 presents a summary of the identified

potential impacts for each phase of the project and indicates which potential impacts are proposed

to be taken forward into the EA and which it is proposed to scope out.

As discussed previously, to determine the overall significance of any impacts on protected sites a

Habitats Regulation Stage 1 Screening Assessment will be undertaken and presented in the EA.

Table 8-1 Summary of potential impacts

Key for potential impact assessment

Significance of impact to be assessed in EA

x No or negligible impact – proposed scoped out of EA

Receptor Potential Impact Installation, Maintenance & Repair

Operation

Metocean conditions

Modifications of metocean regime x x

Change to seabed temperature x x

Physical conditions

Changes to seabed bathymetry and seabed features x

Changes to sediment regime and coastal processes x x

Disturbance of natural seabed sediments

Disturbance of contaminated sediments

Change in water / sediment quality

Benthic and intertidal

Temporary habitat loss (intertidal & subtidal species)

Smothering of species

Introduction of new substrate


19 December 2016 79

Receptor Potential Impact Installation, Maintenance & Repair

Operation

Emission of EMF x

Toxic effects from the unplanned release of hydrocarbons or chemicals

Fish and shellfish

Habitat disturbance

Substratum loss

Physical disturbance of mobile species x

Smothering of species

Reduced feeding success of visual species x

Toxic effects from disturbance of contaminated sediments

Disturbance from electromagnetic fields (EMF)

Disturbance or injury from underwater noise

Heating effects x

Collision of project vessels with basking sharks

Toxic effects of unplanned hydrocarbon or chemical release

Birds Physical disturbance

Temporary loss of food resources and habitat


Marine mammals and reptiles

Disturbance or injury from underwater noise

Collision risk

Physical disturbance

Magnetic fields interfering with cetacean navigation


Commercial fishing

Displacement of fishing activity

Change in water depth

Loss or damage to fisheries habitats/fish stocks

Compass deviation from emission of electromagnetic fields

Contamination of stock

Snagging resulting from obstructions on the seabed

Shipping & navigation

Displacement of vessels


Risk of ship collisions x

Accidental anchoring or emergency anchoring on unburied / buried cable

x

EMF interference with navigation systems

Other seabed users

Displacement of recreational users of the sea


Restricted access to the beach

Damage to or interference of an external cable asset x

Unplanned release of hydrocarbons or chemicals leading to displacement of marine activities

Marine archaeology

Direct damage to archaeological asset

Indirect damage to archaeological asset:


19 December 2016 80

9. SCOPING QUESTIONS

The scoping report is the first formal stage in an on-going consultation process. The aim of this

round of consultation is to ensure that the scope of the EA is fit for its purpose to assess the

potential environmental impacts of the proposed project.

In order to help focus responses consultees are asked to consider the following questions in

particular:

▪ Has the project identified all regulatory requirements that need to be addressed during the

project EA?

▪ Does the scoping report identify all possible environmental receptor types that need to be

considered in the EA? If not, please identify any additional receptors you feel should be

considered.

▪ Have all likely and possible environmental effects been identified? If not, please identify any

further effects that you feel should be addressed.

▪ Do you agree with the scoping in/out of issues in Table 8-1?

▪ Does the list of proposed consultees in Appendix A reflect the range of stakeholders that should

be considered as consultees for this project? If not, please suggest any additional organisations

you feel should be consulted.

▪ Do you feel that the scope of supporting studies is adequate to inform a full assessment of

possible environmental impacts?

▪ Do you have any comments on the proposed data sources? Please identify any further data

sources you think may be relevant and useful.


19 December 2016 81

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http://www.pembrokeshire.gov.uk/content.asp?nav=1626,2380,110,935&parent_directory_id=646&id=28859

http://www.pembrokeshiremarinesac.org.uk/


19 December 2016 83

34 Stone, C.J., Webb, A., Barton, C., Ratcliffe, N., Reed, T.C., Tasker, M.L., Camphuysen, C.J. and

Pienkowski, M.W. (1995). An atlas of seabird distribution in northwest European waters. JNCC,

Peterborough.

35 Tappin, D.R., Chadwick, R.A., Jackson, A.A., Wingfield, R.T.R. and Smith, N.J.P. (1994). United

Kingdom offshore regional report, the geology of Cardigan Bay and the Bristol Channel. London:

HMSO for the British Geological Society.

36 UK Offshore Operators Association (UKOOA) (1999). A Framework for Risk Related Decision

Support. Issue 1, May 1999.

37 UKMMAS (2010). Charting Progress 2. An assessment of the state of UK seas. Available at:

http://www.gov.scot/Topics/marine/science/atlas/CP2

38 Visit Pembrokeshire (2016). Available at: http://www.visitpembrokeshire.com/explore-

pembrokeshire/beaches/freshwater-west/ <Accessed 04/08/2016>.

39 Wales Tourism Alliance (2012). Wales tourism definitive value report.

http://www.gov.scot/Topics/marine/science/atlas/CP2

http://www.visitpembrokeshire.com/explore-pembrokeshire/beaches/freshwater-west/

http://www.visitpembrokeshire.com/explore-pembrokeshire/beaches/freshwater-west/


19 December 2016 84

APPENDIX A – CONSULTEE LIST

List of all consultees to whom a copy of this scoping report has been sent requesting a Scoping

Opinion.

▪ British Ports Association (BPA)

▪ BTO

▪ Celtic Seas Partnership

▪ Centre for Environment, Fisheries and Aquaculture Science (Cefas)

▪ Chamber of Shipping

▪ Devon and Severn IFCA

▪ Joint Nature Conservation Committee (JNCC)

▪ Level 3 Communications Ltd

▪ Marine Management Organisation (MMO)

▪ Maritime & Coastguard Agency (MCA)

▪ Ministry of Defence

▪ Ministry of Defence – Castlemartin Firing Range

▪ National Federation of Fishermen’s Organisations (NFFO)

▪ Natural Resources Wales (NRW)

▪ Oil and Gas Authority (OGA)

▪ Pembrokeshire Coast National Park Authority

▪ Pembrokeshire County Council

▪ Port of Milford Haven

▪ Royal Society for the Protection of Birds (RSPB)

▪ Royal Yachting Association (RYA)

▪ Tenby and District Angling Club

▪ The Crown Estate

▪ The Royal Commission on the Ancient and Historical Monuments of Wales

▪ The Welsh Fishermen's Association

▪ The Wildlife Trust of South and West Wales

▪ Trinity House Lighthouse Service

▪ UK Association of Fish Producers Organisation

▪ Wave Hub Ltd


19 December 2016 85

APPENDIX B – SCREENING OPINIONS

Lancaster HouseHampshire CourtNewcastle upon TyneNE4 7YH

T 0300 123 1032F 0191 376 2681www.gov.uk/mmo

Tom BrinicombeGreenwire Transmission Pembroke LtdUnit C Building 4200Cork Airport Business ParkCork, IrelandIreland

Case reference: EIA/2016/00041

7th November 2016 Dear Mr Brinicombe, The Marine Works (Environmental Impact Assessment) Regulations 2007 (asamended) ("the MWR")Request for a screening opinion - Greenlink Interconnector

Thank you for your marine licence enquiry dated 6 September 2016, requestinga Environmental Impact Assessment (EIA) Screening request from the MarineManagement Organisation (MMO) in respect of the Greenlink Interconnector project. Background

The MMO is required to consider such requests in accordance with the Marine Works(Environmental Impact Assessment) Regulations 2007 (as amended) ("the MWR").In doing so the MMO must determine whether the regulated activity proposed wouldconstitute a project which falls within Annex I or Annex II to European Directive 2011/92/EU ("the Directive").

An Environmental Impact Assessment ("EIA") is mandatory for projects falling withinAnnex I of the Directive.

Should the project be determined to be one which falls within Annex II of the Directive,consideration must be given to the nature of the project, having regard to its size,nature and location. In the event it is determined that the project is likely to give rise tosignificant effects on the environment an EIA will be required. MMO Screening Opinion On reviewing the information provided, I am of the opinion that the project does notfall within either Annex I or Annex II of the MWR. Greenlink Transmission PembrokeLimited will submit an Environmental Report in accordance with all relevant bestpractice, the Environmental Report will accompany marine licence applications toboth the MMO and Natural Resources Wales (NRW).

Lancaster HouseHampshire CourtNewcastle upon TyneNE4 7YH

T 0300 123 1032F 0191 376 2681www.gov.uk/mmo

Marine licensing requirements

Section 81 of Marine and Coastal Access Act 2009 (MCAA) states that a marinelicence is not required for laying or maintaining an offshore stretch of exempt submarinecable. However, a marine licence would be required under Part 4 of the MCAA for thedeposition of cable protection material as stated in your letter to the MMO dated 25August 2016.

Conclusion

The MMO is of the opinion that the project does not fall within Annex I or Annex II ofthe MWR, therefore, an EIA is not required. However, the proposed cable protectionworks will require a marine licence under Part 4 of the MCAA. Your feedback We are committed to providing excellent customer service and continually improvingour standards and we would be delighted to know what you thought of the serviceyou have received from us. Please help us by taking a few minutes to complete thefollowing short survey (https://www.surveymonkey.com/r/MMOMLcustomer). Finally, If you have any queries or require clarification on any of the above, thenplease do not hesitate to contact me. Yours sincerely, Rachel Rachel-Louisa Gardener

Marine Licensing Case OfficerD +44 (0)2082 256 657E [email protected]

SIGN_FIELD_1 SIGN_FIELD_1

SIGN_FIELD_1 SIGN_FIELD_1

Miss Rachel-Louisa Gardener+44 (0)2082 256 [email protected]

1

Anna Farley Intertek

From: Hudson, Jon <[email protected]>

Sent: 15 December 2016 10:00

To: Tom Brinicombe

Cc: Anna Farley Intertek; Pauls, Lily

Subject: RE: Screening

Hi Tom,

I agree that, on reviewing the information provided, the project does not fall within either Annex I or Annex II

of the MWR. I understand that Greenlink Transmission Pembroke Limited will submit an Environmental

Report in accordance with all relevant best practice and that the Environmental Report will accompany

marine licence applications to both the MMO and Natural Resources Wales (NRW).

NRW is of the opinion that the project does not fall within Annex I or Annex II and that therefore, an EIA is not

required. However, as pointed out by the MMO, the proposed cable protection works will require a marine

licence under Part 4 of the MCAA.

Regards Jon

From: Tom Brinicombe [mailto:[email protected]]

Sent: 15 December 2016 09:29

To: Hudson, Jon <[email protected]>

Cc: Anna Farley Intertek <[email protected]>

Subject: Screening

Hi Jon, I hope that you are getting on well. I understand that you are out on site today. I was wondering if you had an anticipated date for responding to our screening request? We are just finalising our scoping document and want to include that neither MMO nor NRW believe the project to be an EIA development. We can amend if required and apologies for chasing. Many thanks and all the best, Tom

Tom Brinicombe

Regus House Malthouse Avenue Cardiff Gate Business Park Cardiff

CF23 8RU

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