Kish Bank Exploration Well, 2012 Environmental Area ...

Kish Bank Exploration Well, 2012

Environmental Area Assessment

Support Document to Foreshore Application November 2011

Client Providence

Project Title Kish Bank Exploration Well, 2012

Document Title Environmental Area Assessment

Document No. MGE0272RP0003

DCS TOC Text List of Tables List of Figures No. of AppendicesThis Document

Comprises 1 1 60 1 1 0

Rev. Status Author(s) Reviewed By Approved By Office of Origin Issue Date

A01 Client Approval

J Massey Willie Madden Andrew Stenson

Galway 21st Sept 2011

F01 Final Galway 3rd Oct 2011

F02 Final Galway 16th Nov 2011

Confidentiality statement:

The information disclosed in this proposal should be treated as being strictly private and confidential and you are requested to take all reasonable precautions to maintain its status as such. You are requested to use and apply the information solely for the purpose of evaluating this proposal and are asked not at any time to disclose or otherwise make available the information to any third party except for those officers, employees and professional advisers who are required by you in the course of such evaluation to receive and consider the information and who agree to be bound by these non-disclosure terms.

Kish Bank Drilling EAA

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Table of Contents Executive Summary .............................................................................................i

Project Description ....................................................................................................................... i The Existing Environment............................................................................................................. i Summary of Environmental Hazards, Effects and Control Measures ......................................... iii Conclusions................................................................................................................................. v Habitat Directive Assessment Screening Conclusions ................................................................ v European Protected Species (Habitat Directive Annex IV species) Screening Conclusions........ v

1 Introduction ..................................................................................................7 1.1 The Project .........................................................................................................................7 1.2 Licence Option 08/2............................................................................................................7 1.3 The Applicant .....................................................................................................................8 1.4 Environmental Area Assessment ........................................................................................8 1.5 Structure of the Document..................................................................................................9

2 Project Description.....................................................................................10 2.1 Proposed Drilling Programme...........................................................................................10 2.2 Proposed Exploration Well ...............................................................................................10

2.2.1 Drilling Muds and Chemicals ....................................................................................11 2.2.2 Disposal of Drill Cuttings ..........................................................................................11 2.2.3 Well Clean-up and Testing .......................................................................................12 2.2.4 Completion ...............................................................................................................12

2.3 Operational Safety............................................................................................................12 2.3.1 Support Operations ..................................................................................................12

3 The Existing Environment..........................................................................13 3.1 Introduction.......................................................................................................................13 3.2 The Physical Environment ................................................................................................13 3.3 The Biological Environment ..............................................................................................15

3.3.1 Benthic .....................................................................................................................15 3.3.2 Fish ..........................................................................................................................15 3.3.3 Marine Mammals ......................................................................................................18 3.3.4 Marine Reptiles ........................................................................................................23 3.3.5 Birds .........................................................................................................................23

3.4 Protected Sites and Coastal Sensitivities .........................................................................27 3.4.1 Marine Protected Sites .............................................................................................27 3.4.2 Coastal Protected Sites ............................................................................................28 3.4.3 OSPAR Marine Protected Areas ..............................................................................30 3.4.4 Cultural Heritage and Protected Areas .....................................................................31

3.5 Socio-Economic Activity ...................................................................................................32 3.5.1 Shipping ...................................................................................................................32


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3.5.1.1 Navigation Assessment ........................................................................................33 3.5.2 Commercial Fishing..................................................................................................34 3.5.3 Other Activities .........................................................................................................35

4 Hazards, Effects and Mitigation Measures................................................38 4.1 Introduction.......................................................................................................................38 4.2 Environmental Impact Assessment Methodology .............................................................38

4.2.1 Routine Operations ..................................................................................................38 4.2.2 Non-Routine Events .................................................................................................39

4.3 Hazard Identification, Impacts and Proposed Mitigation Measures...................................40 4.3.1 Identification of Interactions......................................................................................40

4.4 Design Control Measures .................................................................................................40 4.5 Physical Presence ............................................................................................................41 4.6 Seabed Disturbance .........................................................................................................42

4.6.1 Deposition of Drill Cuttings .......................................................................................42 4.7 Noise and Vibration ..........................................................................................................42

4.7.1 Potential Impacts on Fish .........................................................................................44 4.7.2 Potential Impacts on Cetaceans ...............................................................................44

4.8 Atmospheric Emissions ....................................................................................................44 4.9 Marine Discharges............................................................................................................45

4.9.1 Water Based Drilling Mud (WBM).............................................................................45 4.9.2 Cement Chemicals ...................................................................................................46 4.9.3 Drainage Water and Sewage....................................................................................46 4.9.4 Accidental Spills .......................................................................................................46

4.10 Solid Wastes ................................................................................................................47 4.11 Loss of Containment.....................................................................................................47

4.11.1 Drilling Operations....................................................................................................47 4.12 Transboundary Impacts ................................................................................................54 4.13 Cumulative Impacts ......................................................................................................54 4.14 Assessment of Significance of Environmental Effects ..................................................54 4.15 Assessment of Significance of Navigational Effects .....................................................54 4.16 Habitats Directive Assessment of Significance of Effects (Screening)..........................55 4.17 European Protected Species Assessment of Significance of Effects (Screening) ........55

5 Environmental Management Plan..............................................................55 6 References..................................................................................................61


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Figures Figure 1.1 Location of the proposed exploration well ......................................................................7 Figure 2.1: Location of Kish Bank Exploration Well ......................................................................10 Figure 3.1 Distribution of seabed features and sediments in the Irish Sea IOSEA4 area (IOSEA4, in press; Croker et al., 2005; WWF, 2001) ....................................................................................14 Figure 3.2: Fish Spawning and Nursery Areas in the Kish Bank Area (from Coul et al, 2000 and IOSEA4 (in press))........................................................................................................................17 Figure 3.3 Toothed whale, dolphin and porpoise land-based or casual offshore sightings from 2006 – 2010, and offshore ship-based sightings from 2001 – 2009 in the IOSEA4 area (source: IWDG, in press (2011) ..................................................................................................................20 Figure 3.4 Location of whale and dolphin sanctuary around Ireland (extract from IOSEA2, DCENR, 2008) ..............................................................................................................................21 Figure 3.5 : Haul-out location of groups of harbour seals recorded along the Irish coast (DCENR, in press; O Cadhla et al, 2008) .....................................................................................................22 Figure 3.6 Location of grey seal breeding sites (DCENR, 2011; O Cadhla et al, 2008 - based on preliminary results provided by the NPWS from the 2005 population assessment) and grey seal grouped population estimates (O Cadhla et al 2008) ....................................................................23 Figure 3.7 Important seabird areas on the east coast of Ireland (Source: DCENR, in press) .......27 Figure 3.8. Natura 2000 Areas in the vicinity of the site survey area (NPWS, 2010) ....................28 Figure 3.9. Other Coastal Protected Areas in the vicinity of the site survey (NPWS, 2010) ..........30 Figure 3.10 Shipwrecks in the vicinity of the site survey area (DoEHLG, 2010) ..........................32 Figure 3.11 Average cargo, tanker and ferry distribution and deadweight tonnage in IOSEA 4 area (DCENR, in press; Anatec, 2010) .........................................................................................33 Figure 3.12 Shipping counts in the drilling area (Anatec, 2011) ...................................................33 Figure 3.13 Total effort (hours) in Ireland for otter trawls (OTX), Nephrops trawlers (TBN), demersal seiners (SX) and other non-identified gear (N_A) for Belgium, France, Ireland and United Kingdom. ...........................................................................................................................34 Figure 3.14 Marine cables in the vicinity of the survey area (UKHO 2010, DCENR, in press) .....36 Figure 4.1. Methodology for environmental impact assessment ..................................................38 Figure 4.2. Propagation of Sound in Water (from Richardson et al, 1995) ...................................43 Figure 4.3. Sound Pressure Thresholds for the Onset of Fish Injuries (after Turnpenny & Nedwell, 1994) ............................................................................................................................................44 Figure 4.4: Frequency and Size of Oil Spills during Offshore Drilling Operations per Rig per Year (data from UKCS and SINTEF Database).....................................................................................47 Figure 4.5: a) Current information for Dublin Bay (UKHO) from nearest tidal diamond, and b) Tide Tables for Dublin Bay for 2012 (UKHO) ........................................................................................50 Figure 4.6: Predicted cuttings deposition on the seabed around the drilling rig (axes display x-y distance from drilling rig (located at origin) in metres) ..................................................................51 Figure 5.1 . Providences HSEQ Policy Statement ........................................................................57


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Tables Table 2.1 Kish Bank Exploration Well Details ..............................................................................11 Table 3.1: Fish Spawning in the Site Survey Area (Coull et al, 1998) ...........................................16 Table 3.2: Cetacean observations in the vicinity of Kish Bank(Reid et al, 2003; DCENR, in press; O Cadhla et al, 2004 and IDWG, 2011) (red lines denote proposed survey period)......................19 Table 3.3 – Seabirds found in the vicinity of the proposed survey area (UKDMap, 1998; DCENR, in press) (red line denoted proposed survey period) .....................................................................24 Table 3.4 Coastal SPAs in the vicinity of the proposed Drilling location and their designated species (Source: NPWS, 2010) ....................................................................................................29 Table 3.5 – SACs in the vicinity of the site survey area (NPWS 2010; DCENR, in press) ...........29 Table 4.1: Assessment of significance of effect or hazard ...........................................................39 Table 4.2: Assessment of significance of hazard – non-routine events.........................................39 Table 4.3: Identification of environmental receptors which could be significantly impacted by the proposed survey ...........................................................................................................................40 Table 4.4: Typical Noise Levels Associated With Offshore Operations........................................43 Table 4.5: Predicted Atmospheric Emissions from Power Generation from Drilling ......................45 Table 4.6 Sources of Oil Spills and Control Measures Planned ....................................................48 Table 4.7 Discharge of Drill Cuttings for Kish Bank Exploration Well............................................50 Table 4.8. Assessment of impacts associated with the drilling operations ...................................55 Table 5.1 Environmental Management Plan ...............................................................................58


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Executive Summary

Project Description

Providence Resources Plc (hereafter referred to as “Providence”), along with its partners, propose to drill a single exploration well in the Kish Bank licence area in the Irish Sea (Figure 1.1).

A site survey is currently scheduled to commence in early 2012 and will be completed before the end of the year.

The exploratory well operations will take place within 6 months of the site survey. The well operations are anticipated to take 30 days – 60 days and up to a maximum of 90 days.

The drilling operation plan is to drill a vertical well into the upper ~1500 ft of the Sherwood sandstone to a test depth of up to 6200ftTVDss before logging and either plugging and abandoning (P&A) or suspending the well for future re-entry. If successful, drilling may continue into the Carboniferous deposits and a well test of hydrocarbon bearing intervals will be carried out.

The exact well location and profile will be based on the site survey, which will be undertaken in early 2012. The operations will occur in Block 33/21.

The Existing Environment

The baseline characterisation for this environmental assessment has concentrated on the key sensitive species likely to be impacted upon by the drilling of the exploratory well, namely benthos, fish, marine mammals and seabirds. In addition, shipping and commercial fishing activity within the vicinity of the proposed well have also been assessed. A summary of environmental hazards, effects and control measures is outlined at the end of this section.

The potential well area is a shallow sand and muddy sand seabed in approximately 25 – 30m of water, 7 km off the Dalkey and Bray coasts inshore of the Kish Bank. There are no designated areas in the immediate vicinity.

The nearest Annex 1 marine communities in the area are seagrass beds in coastal inshore areas to the south of the survey location and sea pen and burrowing megafauna beds at a significant distance to the south and east of the sampling locations. As all sampling will be contained within the survey area it is not anticipated that this activity will have any impact.

Fish identified as spawning within the proposed well area include haddock (Melanogrammus aeglefinus), blue whiting (Micromesistius poutassou), horse mackerel (Trachurus trachurus) and cod (Gadus morhua). In addition to spawning, the waters of the area also act as a nursery ground for mackerel (Scomber scombrus).

Cephalopod species including squids, octopuses and cuttlefish may all be present within the vicinity of the survey area.

Irish waters are some of the most important in Europe for a wide range of cetacean species (Berrow, 2001) and background evidence indicates that the Irish Sea is an area of low species richness for cetaceans, but moderate abundance of dolphin and porpoise species (O Cadhla et al, 2004).

Surveys conducted by JNCC (Seabirds at Sea Team), UK Mammal Society Cetacean Group and the Irish Whale and Dolphin Group indicate that the following species have the potential to be found within the survey location area: common dolphin, bottle-nosed dolphin, harbour porpoise, humpback whale and minke whale. Rissos dolphin, orcas and fin whales have been recorded to the south of the survey area.

Common (or harbour) seals (Phoca vitulina) and grey seals (Halichoerus grypus) are known to be present in the area and forage offshore, often straying up to 20 km from their haul-out sites but have been recorded up to 2,000 km. It is therefore likely that common


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and grey seals may be found in the vicinity of the survey location (JNCC, 2007; Connell et al. 1999, O’Cadhla et al 2008). There are known haulouts of grey seals to the south of the survey area (approx 10km away), and common seals are known to be sighted in the ports and harbours of this area of the coast.

A survey undertaken of the seabirds in the Irish Sea (Mackey et al, 2004) showed that Kish Bank had significant numbers of auks (guillemots, razorbills etc.) and terns in the area. Roseate, Common and Arctic Terns were recorded roosting on the Kish Lighthouse in late summer and peaked in numbers during late August and early September (Newton & Crowe, 2000). The presence of these bird species is indicative of feeding resources in the area. Breeding sites for a number Annex I bird species including sterna terns, storm petrels and barnacle geese have been designated as Special Protection Areas (SPAs). These are located on the Dalkey Island SPA or the Dublin Bay SPA (8 km away). A number of coastal areas are also designated as Ramsar sites and/or Important Bird Areas.

The most significant potential impacts are the production of small volumes of drill cuttings and subsea noise. The generation of subsea noise by the operation well can have an affect on seabirds, fish and marine mammals in close proximity (<3m) to the noise source and can cause avoidance and changes of behaviour at greater distances. By adhering to the proposed guidance (NPWS, 2007) and because of the short duration of the operation, these impacts can be mitigated against. There may be short periods of avoidance or behavioural changes associated with the drilling due to the rigs physical presence and operational noise. Where possible the operations will be scheduled outside period of marine mammal usage in summer, and avoid sensitive periods of seabird and fish life cycles, in doing this the potential for impact is significantly reduced.

The well drilling operations will generate small volumes of drilling muds, cuttings and drainage water as part of the process. All drilling and production chemicals will be assessed using the HOCNS methodology where appropriate, in accordance with the Offshore Chemicals Regulations 2002. Any chemicals with substitution warnings will be substituted where practicable. All of the chemicals used will be submitted to PAD using a Permit to Use or Discharge Added Chemicals (PUDAC).

The physical presence of the rig and the requirement for exclusions, has the potential to conflict with the usage of the area with fisheries and shipping. Due to the short duration of the operation (30-60 days), this is not considered to be a significant impact, however, reasonable measures will be taken to consult and warn fisheries, shipping and recreation vessels of the survey presence. These measures include the appointment of a Fisheries Liaison Officer, issuing a Notice to Mariners and employing a guard (support) vessel to mitigate interactions. The area is adjacent to areas of heavily trafficked waters in the approaches to Dublin Port, however the proposed drilling location is outside the main shipping lanes and transit areas.

If required, the rig and support vessels will be subject to Marine Radio Navigations Warnings for the duration of the operations.


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Summary of Environmental Hazards, Effects and Control Measures Hazard Mitigation Residual Impact

Physical Presence

Rig and vessels and safety zones could disrupt local shipping and fishing activity.

A specialist drilling contractor will be appointed to undertake the survey using Providences contractor selection and management procedures.

At the detailed planning stage the specific well and rig location based on the site survey data will have included consideration of the potential interference with shipping.

A shipping and navigation study was commissioned to assess the shipping density in the drilling area.

A 500 metre safety zone will be set up around the drilling rig. A safety stand-by vessel will be on stand-by for the duration of the rig programme and will enforce the 500 metre safety zone. Any interference with fishing will be limited to temporary restrictions around the drilling rig and safety zone. Prior to operations commencing, the appropriate notifications will be made & maritime notices posted. All vessel activities will be in accordance with national & international regulations. Appropriate navigation aids will be used to ensure other users of the sea are made aware of the presence of vessels.

Details of the work programme will be passed to the maritime authorities (including the Maritime Safety Directorate, the MRCC of the Irish Coast Guard and the Sea Fisheries Protection Agency of the DCENR) in advance of the survey to increase awareness amongst shipping traffic where relevant. Of note is that the Maritime Safety Directorate publishes Marine Notices advertising such operations.

Operating criteria for weather conditions (e.g. wind, waves and visibility) will be established and operations suspended if the criteria are exceeded.

A Providence representative will be on-board the rig at all times to ensure compliance with approved operating procedures, including those concerning environmental protection and to also ensure that the drilling is conducted safely.

The drilling rig and contractor will meet all national and international regulations for shipping including the appropriate signals and the regulations defined by the International Maritime Organisation for avoiding collisions at sea. State-of-the-art communications and positioning equipment will be on-board the survey vessel to maintain communications with all other shipping and provide accurate information on the position of the rig and safety zone.

Providence has contracted a Fisheries Liaison Officer, with knowledge of fisheries local to the drilling area, to assist with the well planning.

Minor

Fishing and shipping will be disrupted in the immediate vicinity of the rig. There is, however, sufficient area for ships to avoid the rig and support vessels.

The drilling location is outside the main shipping lanes. The exact position is to be determined but will be outside the shipping lanes. Transit vessels to and from the rig, and the transit of the rig to site will cross shipping lanes.

The work within the safety zone is expected to have only a limited effect on third parties. Given the sea room, water depth and the position of existing shipping routes relative to existing platforms in the area there will be minimal impact to the navigation of vessels in this area from the exploration well.

The drilling duration is relatively short occurring outside shipping areas.

Seabed Disturbance

Main source caused by the deposition of cuttings. Disturbance may also occur from the drilling rig.

It is estimated that drilling the well will generate a maximum total of 292 m2 of cuttings, which will be discharged at the seabed. The main effect generally associated with drilling operations is smothering of organisms living on the seabed from the accumulation of drilling cuttings, in a highly localized area. Effects on benthic organisms are expected to be limited to a relatively small area around the drilling rig and to last for only a short time period. Other smaller areas of seabed disturbance will occur as a result the feet (spud cans) and any anchors of the drilling rig on the seabed, however they are relatively small, highly localized and temporary effects..

Minor

Benthic communities found in the area of the proposed development are typical of those found over the Dublin Bay area. The sediments in the area are exposed and reasonable well sorted. Studies of similar sediment have shown rapid recovery.


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Hazard Mitigation Residual Impact

Acoustic Emissions

Behavioural disruption affecting marine mammal’s ability to find food and communicate and follow regular movements.

Short-term behavioural changes might be observed in fish populations in close proximity to the drilling operation.

The Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters Version 1.1 (NPWS, 2007) will be followed.

Dedicated, trained and qualified Marine Mammal Observers (MMOs) will have assessed the area during the site survey.

There will be a low number of additional vessel movements during well abandonment and drilling activities. Providence will ensure that the vessels associated with the proposed well will avoid using undue speed, cavitations of vessel propellers will be minimised and that vessels will not unnecessarily approach any marine mammals.

It is not anticipated that there will be any vessels on extended periods of dynamic positioning during the operations.

Providence has contracted a Fisheries Liaison Officer, with knowledge of fisheries local to the exploration well area, to assist with the survey planning.

Minor

Cetaceans are likely to avoid the area in the immediate vicinity of the drill site. Toothed whales may also be affected by the temporal avoidance reaction of fish during drilling operations. The area is mainly frequented by dolphin and porpoise species, and is highly trafficked.

The survey is located in inshore waters so seals may be present, however it is not located in the vicinity of known haul-out sites and occurs outside the most sensitive periods (mating, pupping and moulting).

Coull et al (1998) have identified that fish spawning within the vicinity of the proposed survey area, is sensitive to acoustic disturbance between March and July. The drilling operation is currently planned in the later part of the year, however, should it occur in early 2013, it is relatively short in duration and does not cover the entire spawning area of these species.

Atmospheric Emissions

The main source of atmospheric emissions will result from engine exhaust gases.

The emissions generated from the rig and support vessels will be controlled through fuel efficiency measures.

Additional power generation emissions during well drilling activities will be minimized by advanced planning to ensure efficient operations; well maintained and operated equipment and generators and regular monitoring of fuel consumption. Providence will ensure that contract specification and control processes require all equipment and generators to be well maintained and operated.

Negligible.

There will be no local effect although emissions from gas combustion will contribute towards global greenhouse gas emissions.

Marine Discharges

Discharge of sewage and grey water.

All discharges from the drilling rig and support vessels will be treated and discharged in accordance with the MARPOL Convention.

Negligible.

Solid Wastes

Wastes will include discharge of WBM & cuttings, drainage water, and sewage domestic refuse, scrap metals and packaging.

Providence will ensure that all wastes generated during the drilling rig and support vessels are adequately segregated in order that an appropriate onshore treatment and/or disposal route may be selected. As far as reasonably practicable. All material brought ashore will be sent for recycling or re-use.

Planned use of water based mud (WBM) for the upper well sections with a selection of most environmentally benign mud & cement chemicals, these may also be used for the lower sections

If Low Toxicity Organic Based Mud (LTOBM) are used, these will taken back to shore for processing and disposal.

Providence will ensure good housekeeping standards are maintained on the drill rig to control the amount of hydrocarbons & other contaminants entering the drainage system & that appropriate sewage treatment systems are on all vessels.

Minor

Due to the low toxicity of the majority of the discharges & the anticipated dilution & dispersion, all impacts are predicted to be short-term and localized. Studies indicate recovery of benthos following cuttings deposition will occur within months. Any LTOBM used will be skipped to shore for disposal

Any other solid wastes will be returned to shore for disposal


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Hazard Mitigation Residual Impact

All drilling and production chemicals will be assessed using the HOCNS methodology where appropriate, in accordance with the Offshore Chemicals Regulations. Any chemicals with substitution warnings will be substituted where practicable. All of the chemicals used will be submitted to PAD using a Permit to Discharge application.

An HSA audit of the rig and vessel will be carried out prior to commencing operations, this includes a review of waste management practices on board.

Spill Risk

Risk of spill of fuel from collision or offshore refuelling.

The Rig will have an externally certified Shipboard Oil Pollution Emergency Plan (SOPEP) as required under the 1973/1978 MARPOL Convention and robust offshore refuelling procedures.

The operation will have an approved Oil Spill Contingency Plan, with emergency response plan.

Negligible / Minor

The most likely cause of spill is spill risk of minor amounts of fuel or chemicals, all potential spills are assessed in the OSCP

Reservoir Spill Risk

Risk of blow out or catastrophic well failure

The operation will have an approved Oil Spill Contingency Plan, with emergency response plan.

Moderate

The most likely cause of spill is spill risk of minor amounts of fuel or chemicals, all potential spills are assessed in the OSCP.

Conclusions

In conclusion, although there is expected be some temporary environmental impact during the proposed drilling operations, long term environmental impacts from the well will be negligible providing that the appropriate mitigation measures are adopted.

Habitat Directive Assessment Screening Conclusions

The operations will be undertaken at a significant distance from the nearest Natura 2000 site (8 km from nearest SPA and 11 km from nearest SAC). Any impacts will be highly localised, no significant impacts are anticipated. The nearest SAC sites are designated predominantly for seacliffs and the SPA is designated for nesting Sterna terns, neither of which are affected by drilling or geotechnical investigation.

The nearest SAC for marine features is Dublin Bay over 11 km from the survey area. Prior to drilling, sediment and geotechnical sampling will be undertaken to confirm the habitats in the area. Drilling operations will occur at a significant distance from Natura 2000 sites (11 km from nearest SAC and 8 km from nearest SPA) with no impacts expected. Therefore the survey does not require further assessment.

European Protected Species (Habitat Directive Annex IV species) Screening Conclusions

Under the Habitats Directive (and the European Communities (Natural Habitats) Regulations 1997 and Wildlife (Amendment) Act 1976 & 2000), specific species, which includes all marine mammals, are prohibited from the deliberate capture, killing, injury or disturbance.

The Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish waters (NPWS, 2007) identifies that the activities that can disturb or harm marine mammals. All operations will be conducted in accordance with the Code of Practice (NPWS, 2007) which was developed to minimise any such disturbance and prevent harm to marine mammals and will be conducted in accordance with industry best practice. MMOs will be assigned to the seismic survey and will collect additional data during that operation.

Grey Seals and Harbour Seals are protected under Annex II of EC Habitats Directive and the Protected species of Wildlife (Amendment) Act. There are no known breeding sites in


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the vicinity of the survey and the survey will occur outside the sensitive pupping and moulting seasons. Otter (Lutra lutra) are an Annex IV species and are likely to be present along the coast adjacent to the survey area (Yoxon, 2008). However, they are predominantly found inshore and are highly unlikely to be present within the drilling area.

Given the short duration of the operations, which are likely to occur outside the peak period of cetacean presence in the area (summer months) and the implementation of the Code of Practice and industry best practice, there is minimal risk of any impacts to individual animals and no significant risk to marine mammals and therefore further assessment is not considered to be required.


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1 Introduction

1.1 The Project

Providence Resources Plc (hereafter referred to as “Providence”), along with its partners, propose to drill a single exploration well in the Kish Bank Basin in the Irish Sea (Figure 1.1) approximately 6 km from the nearest landfall.

A seismic and site survey is anticipated to commence in early 2012 and will take 10-15 days to complete.

Exploratory well operations will take place within 6 months of completion of the site survey. The well operations are anticipated to take between 30-60 days, and up to a maximum of 90 days.

The exact well location and profile will be based on the site survey, which is hoped will be undertaken in early 2012. The operations will occur in Block 33/21.

Figure 1.1 Location of the proposed exploration well

1.2 Licence Option 08/2

In August 2008, Providence and Star Energy Group Plc (“Star Energy”), (a subsidiary of Petronas, the Malaysian National Oil Company) were awarded a three-year Licence Option over eight blocks in the Kish Bank Basin. The agreed work programme focuses on the oil and gas exploration potential of the basin.

The Dalkey Island prospect is a shallow water (c. 20-30m) hydrocarbon target in the Kish Bank Basin, which lies c. 10 km offshore from Dublin. Geologically, the Kish Bank Basin is akin to the East Irish Sea Basin, which produces large volumes of oil and gas offshore in Liverpool Bay.


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Four wells drilled to date in the basin have proven the presence of excellent quality Sherwood Sandstone reservoir and Mercia Mudstone caprock, as well as gas and oil prone Carboniferous source rocks. In addition, oil shows in two of the four wells together with published airborne seep detection data and geochemical fingerprinting of oil shows suggests the presence of migrating oil in the basin. The Dalkey Island prospect is a Lower Triassic tilted fault block structure where seismic inversion analysis has revealed the presence of hydrocarbon indicators.

Providence is carrying out a survey in early 2012 to assess the seabed and sub-seabed for any hazards prior to locating the drilling rig. Once the site is confirmed and cleared, Providence will identify a jack-up drilling unit and specialist contractor to drill the Dalkey Island structure.

This exploration well will be drilled within 6 months of the site survey, as specified in the licence conditions.

1.3 The Applicant Providence Resources Plc is an international upstream oil and gas company currently actively involved in Ireland and the UK. Its portfolio is balanced between production, appraisal and exploration assets. Providence was founded in 1997, but has roots going back to 1981 when its predecessor company, Atlantic Resources plc, was formed. In 1991, Conroy Petroleum & Natural Resources Plc acquired Atlantic Resources Plc, and on completion of the acquisition, the new enlarged entity changed its name to Arcon International Resources Plc. In 1997, Arcon de-merged its hydrocarbon assets into a new company, Providence Resources Plc. which was listed on the Exploration Securities Market (ESM) of the Irish Stock Exchange. In 2005, Providence switched from ESM to the Irish Enterprise Exchange (IEX) and was also admitted to the Alternative Investment Market (AIM) in London.

1.4 Environmental Area Assessment This document is an Environmental Area Assessment, undertaken to ensure that appropriate control measures designed to minimise the potential environmental impacts from the operation are in place. The Environmental Area Assessment will follow a process that balances and prioritises environmental impact assessment considerations against socio-economic assessment that affect the design and operation of all exploration activities. The assessment will follow the main stages associated with the regulatory Environmental Impact Assessment (EIA), which is a hazard and effects management process that comprises four main stages:

• Identify environmental hazards associated with the activity and environmental characterisation;

• Assessment of the magnitude and significance of the hazards and effects;

• Implementation of control techniques to eliminate/lessen severity of effects and to manage the hazards; and

• Development of plans and procedures to manage the consequences of exceptional events.

This Environmental Area Assessment represents the results of the EIA and provides a summary Environmental Management Plan (EMP) outlining potential impacts and actions required to reduce and control the occurrence of those impacts.

This document has been drafted to support the Foreshore Licence application requirements (The Foreshore Acts 1933-2005) and fulfil the requirements of Part 3 Drilling Operations of the “Application to Drill, Re-enter or Deepen a Well” of the Rules and Procedures for Offshore Petroleum Exploration and Appraisal Operations (PAD, 2007, and Draft 2011 edition).


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1.5 Structure of the Document

This assessment is presented in five main sections:

Section 1: Introduction – provides a background to the project.

Section 2: Project Description – provides an outline of the drilling operations.

Section 3: Description of the Environment – describes the background environmental and socio-economic characteristics of the area.

Section 4: Hazards, Effects and Mitigation Measures – defines the potential impacts from the operation and the control measures to be implemented.

Section 5: Environmental Management Plan – provides an outline of how Providence will manage the exploration well to ensure protection of the environment.

In addition, the report includes a non-technical summary of the environmental assessment, highlights its main conclusions and provides a list of references used to obtain data and information to support the assessment.

Further information is included in the Oil Spill Contingency Plan and Drilling Concept Montage. The Drilling Plan will be subject to a Permit to Use or Discharge Added Chemicals (PUDAC) approval prior to operations commencing.


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2 Project Description

2.1 Proposed Drilling Programme

Providence is planning to drill the Kish Bank exploration well in 2012 / 2013, within 6 months of conducting a site survey. The Kish Bank exploration well is located in Block 33/21, approximately 6 km from nearest landfall (Figure 2.1).

Figure 2.1: Location of Kish Bank Exploration Well

Once the site survey is completed, the location of the Kish Bank Exploration well will be finalised. Further details on the drilling programme and characteristics of the Kish Bank exploration well are provided in Table 2.1. These are provisional and will be confirmed after a site and seismic survey in 2012. The site survey will survey an area of 3km x 3km. The well will be located within this area as near to the target location as possible.

2.2 Proposed Exploration Well

The proposed well is an exploration well planned to a depth of between 5,000-11,000ft TVDSS. Providence has prepared a conceptual well design which details proposed lithologies and depths at which these may be encountered, as well as proposed depths at which hydrocarbons are expected to be encountered, if present. Further information on the target and well will be confirmed from the data collected during the seismic survey.

A conceptual drilling plan montage has been prepared and is included in the application.


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Table 2.1 Kish Bank Exploration Well Details

Feature Characteristic

Well Surface Location X:302129; Y:5 904 406 (provisional to be confirmed by site survey)

Operator Providence Resources plc

Block Number 33/21

Nearest mainland Dalkey, Co. Dublin, Ireland

Water depth 85

Reservoir Depth 4500-11,000 ft

Anticipated Reservoir Hydrocarbons Gas, Condensate or Oil

Standby Vessel TBA

Drilling Rig TBA

Proposed Spud Date TBA

Drilling Duration Dry Hole: 30 days; Success Case: 60 days

Well test TBC

2.2.1 Drilling Muds and Chemicals

It is expected that the top hole sections of the well (36 and 17 ½ inch) will be drilled using Water Based Mud (WBM), which will be discharged into the marine environment. The lower sections (12¼ and 8 ½ inch) of the well will be drilled using either Water Based Mud (WBM) which will be discharged or Low Toxicity Oil Based Mud (LTOBM), which will be collected in skips and taken back to shore for disposal and processing. No LTOBM will be discharged to sea.

Cuttings samples will be collected from first returns. The sampling frequency may be varied (subject to approval from well-site Geologist / Operations Manager / PAD) depending on operational conditions. Missed samples will be indicated by inserting an empty bag with the relevant depth marked on it.

In addition to the mud chemicals, cementing chemicals will also be used to seal the well casing in place. Other contingency chemicals may be required if problems or emergencies are encountered during daily drilling. All chemicals will be selected to minimise the potential environmental impacts as much as possible. The vast majority (by volume) of planned chemicals have a UK OCNS category of E and are naturally occurring products (e.g. barite and bentonite) that are either biologically inert or readily dispersible or biodegradable.

The selection of chemicals will be submitted to PAD in an Application for Use and Discharge Added Chemicals Permit (PUDAC).

2.2.2 Disposal of Drill Cuttings

During the drilling of the well, the cuttings recovered in the WBM operations will return to the seabed where the mud volumes and cuttings will be discharged. During this operation there will not be a drilling riser in place.

Should Low Toxicity Oil Based Mud (LTOBM) be used in deeper sections, the casing will be cemented when the Blow Out Preventer (BOP) is installed along with the drilling riser and therefore full containment will be in place for the displacement to LTOBM. When drilling the subsequent sections if the LTOBM are used, the drilled cuttings will be recovered to the rig, where they will be treated by the cuttings containment equipment, spread with the cuttings, transferred to skips ready for backloading, and the recovered LTOBM re-used for drilling the section. If used, all LTOBM will be collected by the rig and returned onshore for processing and treatment with no LTOBM to be discharged to the sea at any time.


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2.2.3 Well Clean-up and Testing

It has not yet been determined if a well test or Drill Stem Test (DST) will be undertaken during the well project. A DST is a procedure for isolating and testing the surrounding geological formation through the drill stem. The test is a measurement of pressure behaviour at the drill stem and is a valuable way to obtain important sampling information on the formation fluid and to establish the potential for commercial production. If present, the total oil volume produced from such drill stem tests would be very low. Any produced oil will be stored in a special purpose tank for later transport to a shore facility.

2.2.4 Completion

When the drilling operation is completed, the well will be plugged and abandoned with cement if no hydrocarbons are encountered. If the well is successful and oil or gas (or both) is present then the well may be suspended for re-entry at a later date. In this case a metal trawl resistant cap is placed over head of the well by ROV.

Ultimately, the well will be abandoned a minimum of 3 metres below the seabed to prevent interference with bottom fishing equipment. A Remote Operated Vehicle (ROV) will be used for the inspection of the seabed, prior to leaving the location. The abandoned well is therefore not expected to have any impact on fishery activities in the area.

A separate programme will be submitted to PAD within the specified time prior to commencement of the plugging operations.

2.3 Operational Safety

The survey will be undertaken by a carefully selected specialist drilling contractor in compliance with all national and international shipping guidelines and approved by Providence and relevant government organisations (via the PAD application process).

Copies of the contractors Quality and Health, Safety and Environmental Management System (QHSE MS) will be submitted to the relevant organisations.

A well specific project HSE plan will be produced and approved prior to the commencement of the survey.

A well specific Oil Spill Contingency Plan will be produced and approved prior to the commencement of the survey.

Radio communications will be maintained among the rig and vessels taking part in the operations, with other maritime traffic and with the appropriate maritime authorities.

Lights and other internationally recognised identification/warning signals will be in place in line with international shipping regulations. On completion of the drilling operations the vessels will leave the area and there will be no evidence of the operation having been undertaken. The well will be plugged and abandoned, or suspended below the surface and there will be no hazard for future fishing or other operations in the area.

Crew change will be undertaken using helicopter, small boat transfer or port-call. A detailed risk matrix will be conducted for each option.

2.3.1 Support Operations

The drilling rig will be supported by a supply vessel and standby (guard) vessel with oil recovery capabilities, as per the Irish coastguard guidelines. Additional information is provided in the Oil Spill Contingency Plan Information document.


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3 The Existing Environment

3.1 Introduction

Knowledge of the characteristics of the local environment allows an understanding of the potential for the exploration well to interact with the environment so that appropriate controls can be adopted to mitigate negative impacts. Scientific studies have shown that drilling operations have the potential to impact on fish, marine mammals and seabirds depending on local biological characteristics; therefore this baseline characterisation has concentrated on these sensitivities. In addition, the socio-economic environment, namely shipping and commercial fishing activity within the vicinity of the proposed well have also been assessed.

Prior to drilling, the site survey will include grab samples to further characterise the site and biology of the site.

The location of the well will be determined from the results of the Site Survey and will be located at a position within the 3 x 3 km square. A preferred location is identified in the Site Map within this application, however for the purposes of this assessment the entire Site Survey Area has been evaluated.

This baseline assessment is largely based on the information available in the draft Fourth Strategic Environmental Assessment for Oil and Gas Activity in Ireland’s Offshore Atlantic Waters (DCENR, in press).

3.2 The Physical Environment

The drilling site is located in the Kish Bank Basin. The basin is located offshore Dublin City, 6 km from Dalkey Island in the western Irish Sea, in water depths of up to 100 m. Some 30 km by 40 km in extent, the basin is one of a series of basins likely to be remnants of a larger Permo-Triassic basin system, termed the Greater Irish Sea Basin that may have extended across the whole of the Irish Sea. The basin forms a northwest-dipping half graben bisected by a fault zone and separated from the Central Irish Sea Basin by an area of outcropping Carboniferous strata. The basin is bounded to the northwest by northeast - southwest trending faults. Four wells have been drilled in the basin with oil shows in two but no discoveries. Natural hydrocarbon seeps have been recorded in airborne surveys.

The Codling Fault Zone which is centrally located in the Basin is an area of sandy sediments with a high density of seep mounds with MDAC (Croker et al., 2005; Figure 3.1). In the Codling Fault Zone, there are 23 carbonate mounds each occupying an area of >20,000 m2 and standing 5–10 m above the normal seabed (Judd et al., 2007), often with associated MDAC slab formations (Croker et al., 2005). However, these are located to the north and east of the licenced area as shown in Figure 3.1. More detailed geological information on the well is included in the Well Conceptual Montage, which is included in this application. The well is in an area of quaternary to recent deposits of predominantly sandstones and claystones, which occur in the near surface below the seabed. At the Base Quaternary a major unconformity is evident which represents Tertiary uplift and erosion of a significant section of the geological record. No evidence of Jurassic or younger deposits exist from drilling to date, however some Jurassic and younger deposits may be present away from the basin structural highs.

The first lithology encountered by other wells in the basin beneath the Base Quaternary unconformity is the Upper Triassic Mercia mudstone group, a very thick section of interbedded mudstones and halites which provide the top seal for the primary reservoir, the Lower Triassic Sherwood Sandstone group. The Sherwood sandstone group represents a series of massive, laterally continuous aeolian and fluvial sands of excellent reservoir quality.

At the base of this thick section of the Sherwood group lies the Upper Permian Manchester Marl sequence, a claystone with interbeds of sandstone and siltstone, which


MGE0282RP002F05 14

overlies the Collyhurst Sandstone. Beneath the Collyhurst lie interbedded sands and silts with coals of Carboniferous age. These interbedded sands are often thin and well disbursed, Carboniferous sands are a secondary reservoir target. Geologically, the Kish Bank Basin is analogous to the East Irish Sea Basin.

Figure 3.1 Distribution of seabed features and sediments in the Irish Sea IOSEA4 area (IOSEA4, in press; Croker et al., 2005; WWF, 2001)

Repeat biological and geological surveys of Dublin Bay, west of the study area, have been performed mainly for assessing the fate and impact of dredge and sewage spoil (e.g. Naylor, 1965; Max et al., 1976; Harris, 1980; Keegan et al., 1983; Wilson, 1984; Keegan, 1989). These studies document the presence of rippled fine sand covering most of the bay. A dredge spoil site exists c.5 km due west of the Burford Bank which is mainly used for maintenance dredge spoil for Dublin Port and Dun Laoghaire Harbour, although it has also been used by Dublin City Council from deposition of other upstream and bedrock material.

Samples from historical surveys subjected to particle size analysis classified most of the sediments as ‘medium sand’ with a mean particle-size of 2 phi (0.25mm) to 1 phi (0.5mm). (Wheeler et al, 2001). Three dominant particle size modes are revealed whose variable representation dictates overall sediment type: a gravel mode (<-3 phi or <8mm), a sand mode (centred on 1 phi or 0.5 mm) and a silt mode (centred on 6.5 phi or 0.012mm).

Wheeler et al. (2001) concluded that there is a dominance of sandy sediment both on the bank and in the intervening areas. Gravely sediments are concentrated on the bank crest and silty sediments are restricted to deeper waters away from the banks. However, Wheeler et al note that they used a Van Essen Grab where large clasts may get caught in the jaws of the grab and cause fine sediments to be under-sampled. This may result in an apparent exaggeration of the degree to which samples coarsen on bank crests and towards the south. However, a coarsening of sediments to the south of Kish Bank (and an increase in sediment lag) is still implied (Wheeler et al, 2001).


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3.3 The Biological Environment

3.3.1 Benthic

The Kish Bank area is a sand bank of medium and muddy sands with coarser material on the bank crest. It is one of a number of banks in the Dublin Bay area. The bank itself has not been used for dredge spoil disposal, however a number of sites in the region have been used for this purpose, and a number of surveys have detected evidence of historic spoil across the area.

Two grab surveys were undertaken on behalf of National Parks & Wildlife Service on the Blackwater and Kish Banks in the Irish Sea during May and June 2005. A series of 12 stations with five replicates per station was sampled at each location and analysed for sediment, faunal composition and organic carbon content.

The Kish Bank survey revealed a sandy substratum, ranging from medium to very-fine sand with relatively low organic carbon. A total of 101 species, ascribed to 12 phyla, were delineated into four distinct faunal assemblages by classification/cluster analysis. These comprised the marine habitat biotopes: Glycera lapidum in impoverished infralittoral mobile gravel and sand (SS.SCS.ICS.Glap); Abra prismatica, Bathyporeia elegans and polychaetes in circalittoral fine sand (SS.SSA.CFiSa.ApriBatPo); Nephtys cirrosa and Bathyporeia spp. In infralittoral sand biotope (SS.SSA.IFiSa.NcirBat) and Abra alba and Nucula nitidosa in circalittoral muddy sand or slightly mixed sediment (SS.SSA.CMuSa.AalbNuc) although in some cases the species composition varied (Roche et al, 2007).

The NPWS attempted to link the faunal and environmental characteristics. The four environmental variables, which best matched the faunal data were medium sand, fine sand, very fine sand and silt-clay. These related to the sides of the bank, with sand material occurring inside the bank and muddier material offshore. The NPWS survey concluded that the crest of the bank is generally coarser materials and gravels. The survey area is therefore predominantly sands dominated by Abra spp, with mobile impoverished gravels on the crest of the bank.

Grab samples will be taken as part of the survey and infaunal analysis will be conducted to confirm community type of the jack up site area.

3.3.2 Fish

Shelf and coastal waters in Ireland are very productive, and they support a diverse community of fish and shellfish species (Hartley Anderson, 2005). Distribution is generally governed by sediment types in the Irish Sea, coarse sediments favoured by elasmobranches, cod, haddock, larger whiting and gurnards and areas of scallops, whereas sands support flatfish, anglerfish, smaller gadoids, hake, plaice and dabs and mud sediments provide habitats for burrowing crustaceans, such as nephrops.

The seasonal distribution of pelagic species such as mackerel, horse mackerel and herring are associated generally with the distribution and properties of the relatively warm surface waters in the Irish Sea and north east Atlantic (ACFM, 2004). These species are present within Irish waters largely on a seasonal basis, migrating between spawning and feeding grounds.

The effect of disturbance on fish is strongly related to their life cycle stage. Fish eggs and larvae of many fish species drift in, or close to, the upper sea surface and thus their spatial movements are determined by ocean and tidal currents. Therefore, they are potentially at risk to injury from a potential oil or chemical spill as their habitat coincides with upper pelagic areas. They are not affected by the rig position and drilling operation however, with the exception of the physical presence of the rig.


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Fish identified as spawning within the proposed Site Survey Area include mackerel (Scomber scombrus), blue whiting (Micromesistius poutassou) (Table 3.1 and Figure 3.2) as well as the Norwegian lobster Nephrops norwegicus. In addition to spawning, the waters of the survey area may also act as a nursery ground for Nephrops.

Table 3.1: Fish Spawning in the Site Survey Area (Coull et al, 1998)

Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Cod

Mackerel

Haddock

Horse Mackerel

Whiting N N N N N N N N N

Peak Spawning Spawning N Nursery

Basking sharks

Little is known about the distribution and abundance of the basking shark, or their biology, due to the elusive nature of this species. Individuals take 12 to 20 years to reach maturity, with young produced roughly every 4 years. This leaves the population vulnerable to exploitation.

In 1993, Berrow and Heardman (1994) made 142 sightings of 425 individuals around the entire Irish coast. Concentrations were evident off the east, south-west and northern coastlines, and sightings were made between April and November with peak in June and September. Surface sightings appear to correlate with a critical sea surface temperature of 11.5°C.

The Irish Whale and Dolphin Group (IWDG) and Marine Conservation Society (MCS) archives show sightings from 1987 to 2007 in the Irish Sea. Tagging studies (Berrow and Johnstone, 2009) show basking sharks moving up the Irish Sea in late season August to September) to northern Scotland. It is assumed, however, that basking sharks do occur in the Irish Sea, and could therefore be found in the survey and drilling area.

Atlantic salmon

Tagging for monitoring purposes has been carried out on a number of important wild salmon rivers along the west and northwest coast of Ireland since 1980 (White et al, 2002). Salmon migrate from the estuaries all around Ireland and Western England and Scotland. Research has revealed that salmon migrate northwards into waters off west Greenland and in particular the Norwegian Sea (White et al, 2002; Hansen & Quinn, 1998). When ready, salmon return to the same freshwater rivers to spawn. As a result of salmonid rivers in the Irish Sea area, they are likely to occur during migratory seasons Salmon run timing is dependant on seasonal factors. In 2011, the run occurred in December to January with hatching occurring in March or April. Where possible the drilling programme will be scheduled occurs outside this period in the latter half of 2012, occurring after spawning and before smolting, it is not anticipated there will be any significant number of salmon in the area.


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Figure 3.2: Fish Spawning and Nursery Areas in the Kish Bank Area (from Coul et al, 2000 and IOSEA4 (in press))

Cod Haddock

Horse mackerel Mackerel

Whiting


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Cephalopods

Cephalopod species include squids, octopuses and cuttlefish. They are characterized by rapid growth rates, and range in size from 1.5 centimetres (pygmy squid) to 20 metres (giant squid). Cephalopods are highly mobile as adults, and occupy similar ecological niches to predatory fish. Habitat ranges from shallow waters to a depth of 3,000 metres or more. In ecological terms, this means that the majority of the Irish Sea area is unsuitable habitat for cephalopods.

Information regarding the distribution and abundance of cephalopod species to the Irish Sea is limited (Hartley Anderson, 2005). The main source comes from fisheries records, both direct target fishing and by-catch. Distribution and abundance of these species is important, however, as they form an essential part of many marine mammal’s diets.

Squid abundance and species distribution is estimated for the Celtic Sea (Lordan et al, 2001). The veined squid (Loligo forbesi) was the most numerous in both numbers and weight, followed closely by the lesser flying squid (Todaropsis eblanae). Highest numbers of both species were caught in shallower inshore regions. Distribution was concentrated around the north and north-west coastlines of Ireland, with highest densities seen in winter, there is limited data and fisheries records for the Irish Sea

The elegant cuttlefish (Sepia elegans) is seen to be common and widespread off the west and southwest coasts of Ireland, with an estimated 174 individuals caught (Lordan et al, 2001). It is less common though recorded in the Irish Sea. Other species are present, such as the common cuttlefish (Sepia officinalis), common bobtail (Sepitta oweniana) and the little cuttlefish (Sepiola atlantica).

The curled octopus (Eledone cirrhosa) is fairly common off the coasts of Ireland, though more common in the south and west, as depths ranging from 100 – 500 metres (Lordan et al, 2001). It is therefore unlikely to occur in significant numbers in the survey area.

3.3.3 Marine Mammals

Cetaceans

Distribution and Abundance

Irish waters are some of the most important in Europe for a wide range of cetacean species (Berrow, 2001) and background evidence indicates that the Irish Sea is an area of low species richness for cetaceans, but moderate abundance of dolphin and porpoise species (O Cadhla et al, 2004).

Parturition (giving birth) in Irish waters has been confirmed for a number of cetacean species, including the harbour porpoise, common dolphin, bottlenose dolphin, Risso’s dolphin, white sided dolphin, white-beaked dolphin and pilot whale. Other species, such as the northern bottlenosed whale and minke whale are also suspected of breeding in the region, although there is no conclusive evidence to confirm this (DCENR, 2008). Many species are not known to breed in Irish waters, but migrate here annually. Most species are more common in the west of Ireland than the Irish Sea (Charif & Clark, 2000). Data suggests that some of these species (e.g. fin whale and humpback whale) feed year-round in the waters along the south coast and occur occasionally on the south east coast in late season (August to October, (DCENR, 2008), whereas others may over-winter in waters south of Ireland e.g. blue whale (Charif & Clark, 2000).

The most important factor governing cetacean distribution and abundance is the availability of prey (Evans, 1990). Physical factors such as sea temperature and salinity also have a profound impact on cetacean distribution, and in this region are often controlled by the north Atlantic Drift. In addition, complex bathymetry is also an important factor, particularly to deep diving species such as beaked whale, which are restricted to distinct areas of suitable habitat (Macleod, 2005).

There are two suborders of cetacean: the toothed whales or Odontoceti and the baleen whale or Mysticeti, characterized by having baleen plates for filtering food from water,


MGE0282RP002F01 19

rather than having teeth. Figure 3.3 shows the records of Odontoceti recorded in the IOSEA 4 area.

Baleen whales, such as minke whales and fin whales, not historically common in the Irish Sea preferring feeding grounds in deeper waters particularly along the continental shelf edge (Evans, 1990; Mackey et al, 2004b). Typically they feed on plankton, krill, and other small pelagic prey, and their distribution is often related to oceanographic features such as fronts, upwellings and association areas where prey availability is high. In the summer months, minke whale feed mainly on fish in the inshore waters (Pollock et al, 1997).

In contrast, the diet of toothed cetaceans, such as dolphins and porpoises, killer whales, sperm whales, and beaked whales, consists mainly of fish and squid, and is an important factor in determining their distribution. Many dolphins show seasonal movements into shallow coastal waters, which may coincide with calving or inshore feeding (Boelens et al, 1999).

Table 3.2 shows the seasonal presence / absence of cetaceans in the IOSEA 4 region (DCENR, in press). Surveys conducted by JNCC (Seabirds at Sea Team), UK Mammal Society Cetacean Group, and the Sea Mammal Research Unit and Irish Whale and Dolphin data the basis of the sightings and strandings. All of the species listed in the table have the potential to be found within the survey location area.

Table 3.2: Cetacean observations in the vicinity of Kish Bank(Reid et al, 2003; DCENR, in press; O Cadhla et al, 2004 and IDWG, 2011) (red lines denote proposed survey period)

Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Common Dolphin The most frequently recorded dolphin species in Irish waters. Present in the Irish Sea, predominantly in the summer and early autumn (Reid et al., 2003). Most abundant and breeding along the south and south west coasts of Ireland.

Bottle-nosed Dolphin Found in all Irish coastal waters and are the second most frequently recorded dolphin

species in Irish waters. They occur inshore around all Irish coasts with a semi resident group present at the mouth of Cork Harbour. They also occur offshore in the Celtic Sea and in the Irish Sea. They are present year round and breed in Irish waters. Inshore and offshore ecotypes may exist.

Risso’s dolphin Continental shelf species. Recorded throughout the year in Irish waters with a wide distribution (Aecom & Metoc, 2010). Some seasonal movements apparent (Baines & Evans 2009).

Regularly observed inshore and in bays along the southwest and southeast coasts (NPWS, 2008). Regularly occurring in the southern and central Irish Sea (Baines & Evans 2009). Breeds in Irish waters.

Harbour Porpoise Ireland’s only porpoise species. Abundant in the Irish Sea throughout the year and is abundant inshore along the south and southwest coasts. Breeds in Irish waters. Occurs throughout the Irish and Celtic Sea with some large aggregations noted off the south coast in the Autumn months. Some evidence for an offshore movement in spring between March and June (IWDG, 2010b) which may be linked to calving.

Killer whale Observed off all coasts and in the Irish Sea. Inshore sightings tend to increase during late summer and autumn (Berrow et al., 2010).

Minke Whale Smallest and most frequently sighted baleen whale in Irish waters (Berrow et al., 2010). Most abundant off the south and southwest coasts during autumn and winter. Occurs off all other coasts and in the Irish Sea. They are seasonally abundant in the western Irish Sea in Spring and early Summer (Wall & Murray, 2009). There is an inshore movement in April and May with peak sightings in August.


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Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Humpback whale This species occurs in the IOSEA4 area mainly over the period June - February, predominantly off the south and southeast coasts (Berrow et al., 2010). It has also been recorded in St. George’s Channel and the Irish Sea (IWDG, 2010c). Observed in all months of the year.

Fin whale The majority of inshore sightings come from counties Cork, Waterford and Wexford (Berrow et al., 2010). These species move inshore in early summer between May and June with a regular peak in sightings during November in west Cork.

There has only been one recorded sighting in the area from 2000-2009 (IWDG,2011) .

Key Absent Present

*indicates absence from survey results due either to lack of survey effort (in which case it is stated in the text) or a genuine absence from the area during a sampling period.

Figure 3.3 Toothed whale, dolphin and porpoise land-based or casual offshore sightings from 2006 – 2010, and offshore ship-based sightings from 2001 – 2009 in the IOSEA4 area (source: IWDG, in press (2011)

Cetacean Conservation

Ireland is a signatory to conservation-orientated agreements under:

• the Berne Convention on Conservation of European Wildlife and Natural Habitats (1982);

• the Bonn Convention on Migratory Species (1983);

• the OSPAR Convention for the Protection of the Marine Environment of the northeast Atlantic (1992); and

• the EC Habitats Directive on the Conservation of Natural Habitats and of Fauna and Flora (92/43/EEC, 1992).

All cetacean species occurring in European waters are now afforded protection as Annex IV species under the EC Habitats Directive. Two common species: bottlenose dolphin


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and harbour porpoise; are Annex II species (i.e. animal species of Community interest, whose conservation requires the designation of Special Areas of Conservation) (refer to Section 3.3.1).

In 1991, the Irish government declared all Irish waters extending to the outer Continental shelf a whale and dolphin sanctuary, claiming that this was a “clear indication of Ireland’s commitment to contribute to the preservation and protection of these magnificent creatures in their natural environment, and to do everything possible to ensure they should not be put in danger of extinction but should be preserved for future generations” (Rogan & Berrow, 1995). According to the declaration, the sanctuary was empowered under the legal framework already in place, which suggested that the Irish government considered the present legislation to be sufficient to provide full habitat protection to cetaceans within the continental shelf area. Figure 3.4 shows the area of the whale and dolphin sanctuary.

Figure 3.4 Location of whale and dolphin sanctuary around Ireland (extract from IOSEA2, DCENR, 2008)

Pinnipeds

Common (or harbour) seals (Phoca vitulina) and grey seals (Halichoerus grypus) are common in Irish waters, and are mainly concentrated inshore (DCENR, in press). Both the common seal and the grey seal are listed under Annex II of the EC Habitats and Species Directive as species whose conservation requires the designation of Special Areas of Conservation. In addition common and grey seals are protected under the Conservation of Seals Act 1970.

Seals are known to forage offshore, often straying up to 2,000 kilometres from their haul-out site (JNCC, 2007; Connell et al. 1999). There are no haulout sites in the immediate vicinity of the survey area, the nearest is Lambay Island (O Cadhla et al, 2008).

Common Seals

The common seal is the smaller of the two species of pinniped that breed in Ireland and is also an important predator in this area of the north Atlantic. The main prey of common seals is considered to be sandeels, lesser octopus, whiting, flounder and cod (Tollit &


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Thompson, 1996). During the pupping (June) and moulting seasons (late July/August) they spend more time ashore than at other times of the year.

Figure 3.5 shows the locations of groups of harbour seals recorded along the Irish coast. These haul-out groups have tended historically to be found among inshore bays and islands, coves and estuaries (Lockley, 1966; Summers et al, 1980), particularly around the hours of lowest tide.

Figure 3.5 : Haul-out location of groups of harbour seals recorded along the Irish coast (DCENR, in press; O Cadhla et al, 2008)

Grey Seals

Grey seals are widespread in Ireland, with the greatest concentrations found on the exposed south-western, western and northern coasts (Lyons, 2004). The largest populations of grey seal on the east coast of Ireland are found on Lambay Island.

Figure 3.6 illustrates the grey seal breeding sites on the east coast of Ireland adjacent to the proposed Providence licence area. Grey seals are gregarious at these haul-outs, sometimes forming large groups of several hundred animals, especially when they are moulting their fur in spring following the winter pupping season.

Tagging surveys by Hammond et al (2005) showed very low usage of the survey area by seals tagged in Wales, either indicating a separate population or lower area density of ‘at sea’ seals.


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Figure 3.6 Location of grey seal breeding sites (DCENR, 2011; O Cadhla et al, 2008 - based on preliminary results provided by the NPWS from the 2005 population assessment) and grey seal grouped population estimates (O Cadhla et al 2008)

3.3.4 Marine Reptiles

Five species of marine turtle have been recorded in UK and Irish waters (Brongersma, 1972; Penhallurick, 1990; Langton et al, 1996; Gaywood, 1997; Pierpoint & Penrose, 1999). Only one species, the Leatherback turtle (Dermochelys coriacea) is reported annually and is considered a regular and normal member of Irish marine fauna (Godley et al, 1998). Data on marine reptiles is largely generated from sightings, strandings and by-catch.

The leatherback turtle is the largest marine turtle occurring in warm waters. They breed circum-globally in tropical regions south of the survey area, but range widely to forage in temperate and boreal waters. Long-distance migration has been documented from tag returns and satellite telemetry. Seasonal peaks are seen in northern waters, with most turtle sightings occurring in the West of Ireland reported between August and October (Gaywood, 1997; Godley et al, 1998). Sightings in the east are less common, though leatherbacks are recorded in this area of the Irish Sea. A single kemps Ridleys turtle record is present in the area, however this is based on a single stranding in 1972 (Brongersma, 1972) near Howth.

Although distribution and abundance of turtles in the area is mainly based on strandings data, it has been shown that most turtles enter the Irish waters from the south and south west, moving northwards to the west of Ireland or through the Irish Sea (Pierpoint, 2000). It is therefore possible that turtles may be present within the proposed survey area.

3.3.5 Birds

Offshore Distribution

Islands in the Irish Sea and seacliffs near productive waters provide a perfect breeding habitat for some species of seabirds.

Shearwaters, gannets, gulls, terns and auks are common in the Irish Sea. The majority of these birds breed in colonies located on the southwest, south and east coasts of Ireland while others over-winter in Irish waters. Other species such as some species of shearwater and skua are passage migrants that use the area as a migratory corridor.

Other important biological factors affecting species distribution available nesting sites and social interactions. Human fishing can have an effect on the way bird species are distributed as many species obtain a high percentage of their food from fishing vessels,


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mostly at the shelf edge (Stone et al., 1995). Physical factors including water depth, wind and weather, water movement, sea temperature and salinity also directly and indirectly influence seabird distribution, often through prey distribution. Higher densities of certain seabird species such as little auk, Manx shearwaters, guillemots and razorbills are associated with frontal and upwelling systems (Pollock et al., 1997).

Table 3.3 shows the species likely to be found in the vicinity of the proposed Providence licensed area (UKDMap, 1998, DCENR, in press). A presence/absence scale has been used as low to high scales often do not give an accurate indication of population size.

Table 3.3 – Seabirds found in the vicinity of the proposed survey area (UKDMap, 1998; DCENR, in press) (red line denoted proposed survey period)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Northern Fulmar Northern Fulmars are a common and widespread seabird species along the British and Irish coasts, preferring offshore waters on both the shelf and continental slope. They are recorded throughout the year. From April to May most birds are feeding over the shelf break, building up reserves for the breeding season and are not present in the survey area.

European storm petrel The European storm petrel is a summer visitor to Ireland, nesting in burrows and

crevices on remote islands. Highest densities are recorded during spring and summer over the shelf, to the south in the Celtic Sea with only infrequent presence in the Survey area.

Manx shearwater Manx shearwaters are local breeders and are regularly recorded between March and October. Highest densities occur during spring and summer, in close proximity to the breeding colonies. Highest densities to the south of Ireland. Occasional winter records in the Irish and Celtic Seas

Sooty shearwater The sooty shearwater is a passage migrant that breeds on islands in the southern Pacific and Atlantic Oceans. Recorded in breeding season in the Irish sea during the summer months.

Cory’s shearwater Cory’s shearwaters are annual visitors to the Irish southwest coast, wintering in the

south Atlantic. Very occasional records in during July and August.

Northern gannet Widely distributed throughout the area and in all seasons. Breeding colonies in summer at Irelands Eye north of Howth Head.

Great skua Most widely recorded skua species off the west of Ireland. Large numbers recorded over the Celtic Sea and shelf waters east and north east of the Goban Spur. Also frequently recorded during winter months, mainly over the continental shelf. Rare in Irish Sea.

Pomarine skua Spring and autumn migrants in Irish waters. The two main migratory routes being the Irish Sea and off the west of Ireland. Recorded over the IOSEA4 area from April to December. Most birds seem to loosely follow the shelf break on their migration route. Abundance peaks occur in May, October and November.

Arctic skua


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Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Frequently recorded in coastal and inshore habitats during periods of migration, particularly from July to September. High densities recorded over coastal areas of the Celtic Sea. Long tailed skua The smallest and most pelagic of the Skua species, it rarely approaches coastal areas during migration. This is the least numerous seabird species recorded in the area. Sporadic sightings have occurred over the Irish Sea and east of the Goban Spur. Herring Gull Commonest and the most widespread of the three large breeding gulls in Britain and Ireland. Frequently recorded along the coast in all seasons. Offshore encounters are sporadic and limited to post-breeding and winter months over the continental slope in the north-eastern region of the IOSEA4 area.

Lesser black-backed gull Largest and most aggressive gull species breeding in Ireland. Coastal resident only

found in the north Atlantic. Spread their range over the Irish Shelf during winter months and the breeding season. Records over the IOSEA4 area have been reported all year round. Great black-

backed gull The largest and most aggressive gull species breeding in Ireland is a coastal resident found in the north Atlantic. Great black-backed gulls are more marine than other gull species, spreading their range over the Irish Shelf during winter months and the breeding season. Records of great black-backed gull over Blocks 35/8 and 35/9 occur from January to September. Kittiwake One of the most pelagic species and also one of the most numerous breeding seabirds in Ireland. Highest densities are associated during the winter with the Irish Shelf and continental shelf. Uncommon in the Irish Sea area, though recorded all year round.

Common

guillemot Largest of the four auk species breeding in Ireland. Prefer inshore waters during breeding season, becoming more widespread during autumn and winter. Low guillemot concentrations recorded in the northeastern section of the Irish Sea area in winter and spring.

Black guillemot

Least pelagic of the auk species in Britain and Ireland. Feeds mainly on the bottom and prefers sheltered and inshore waters throughout the year.

Razorbill Medium-sized auk species restricted to the north Atlantic. Commonly recorded in inshore waters close to their colonies. Highest densities were recorded over the Irish Sea and low to moderate densities were consistently recorded over St. George’s Channel throughout the year. Atlantic puffin Most pelagic of the four auk species breeding in Ireland. This species is widespread over the continental shelf, west of Britain, where it was recorded in low to moderate densities throughout the Irish Sea between April and September. Atlantic puffin were sparsely distributed during the winter and autumn.

KEY Presence Absence *

*indicates absence from survey results due either to lack of survey effort (in which case it is stated in the text) or a genuine absence from the area during a sampling period.

Vulnerability

Vulnerability of seabirds varies greatly between species. Due to heavy boat traffic in the area associated with the shipping lanes nearby, the presence of the drilling rig and support vessel and vulnerability of physical disturbance is unlikely to have a significant effect, however the vulnerability of seabirds to oil pollution differs greatly dependant on the species behaviour.


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The most vulnerable group of seabirds is the auks. The common guillemot, razorbill and Atlantic puffin spend a lot of time sitting on the sea surface forming big aggregations while preening and moulting, meaning they are classed as ‘very vulnerable to oil pollution’. The majority of dead oiled seabirds found on beaches are guillemots and razorbills (Mackey et al, 2004).

Fulmar and Manx shearwater are considered ‘very vulnerable to oil pollution’, due to the large amount of time they spend rafting on the sea surface. In addition to high tendency for rafting in large groups, 94% of the world population of Manx shearwater breed in Britain and Ireland.

Approximately 70% of the world’s northern Gannet population breed in Britain and Ireland. As there are relatively few colonies compared to other seabird species, an oil spill close to these colonies during breeding season could have serious consequences for gannets. Like fulmars, gannets spend more time at sea then other species and need to run along the sea surface with the headwinds to become airborne. Northern gannets are therefore considered to be ‘vulnerable to oil pollution’.

Great skua and kittiwakes are also regarded as being ‘vulnerable to oil pollution’ as they are present in high densities in the vicinity, and spend a large amount of time on the sea surface.

Lesser black-backed gull is a common and widespread species, which although spends a considerable amount of time in the marine environment has a high population in the area and a pollution event would therefore not be regarded as having a major impact on the population as a whole.

Species, including shearwaters, skuas and great black-backed gulls are highly aerial, widespread species that occur in low numbers within the proposed Providence licenced area. They are therefore regarded as ‘not threatened by oil pollution’ (Mackey et al, 2004).

Seabird Breeding Colonies

There are a number of important sea bird breeding colonies within the IOSEA4 area and these include Rockabill, Lambay Island, Ireland’s Eye, Howth Head, and Saltee Islands, There are smaller breeding sites all along the south east and south coast where suitable habitats occur. Figure 3.7 shows the locations of important breeding colonies and bird areas within the Irish Sea area. Highest concentrations of breeding seabirds in the Irish coast are located in the southwest and southeast regions (Mackey et al, 2004a). There are thirteen seabird species of European conservation concern breeding in Ireland, nine of which have an unfavourable conservation status in Europe. Nine Important Bird Areas (IBAs) (refer to Figure 3.7) on the Irish coast hold at least one percent of the global population of a seabird species for the following species: Atlantic puffin, European storm petrel, northern gannet, shag Phalacrocorax aristotelis and roseate tern Sterna dougallii.

Waders and Waterfowl

A common marine habitat on the east coast of Ireland is the estuary with examples at Carlingford Lough, Dundalk Bay, the mouth of the Boyne, Rodgerstown, Malahide, and inner Dublin Bay. These habitats provide feeding and rooting grounds for a long list of all native and visiting waders. These include heron, egret, moorhen, coot, rail species, oyster catcher, plover species, lapwing, sanderling, knot sandpiper species, turnstone, dunlin, stint species, shank species, godwit species, curlew, whimbrel, snipe species and ruff. A number of rare visitor species have been recorded in the Irish Sea coastal area and these include for example, yellow leg species and dowitcher species.

Ireland lies on the main migratory routes of the east Atlantic with many of the birds that winter in southern Europe and Africa passing through and staging along the coast. The estuaries, mudflats and sand flats listed above are of major importance for migrant waterfowl in spring and autumn. Waterfowl include divers, grebes, duck, geese, swans, Moor hen and coot.

A number of sites are designated as Ramsar and / or SPAs due to these species.


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Figure 3.7 Important seabird areas on the east coast of Ireland (Source: DCENR, in press)

3.4 Protected Sites and Coastal Sensitivities

3.4.1 Marine Protected Sites

In Ireland key legislation governing nature conservation includes the Wildlife (Amendment) Act 2000, the European Community (Conservation of Wild Birds) Regulations 1985 and the European Union (Natural Habitats) Regulations 1997.

To date, offshore the west coast of Ireland, four candidate Special Areas of Conservation (SACs) have been designated. There are no offshore SACs proposed in the vicinity of the survey area in Ireland or UK waters. There are Annex 1 habitats located in the Irish Sea, however none of these occur at the survey area. The nearest coastal SAC with marine habitats is Dublin Bay where the intertidal mud and sandflats are listed as a designated feature (see Section 3.4.2).

Harbour Porpoise, bottlenose dolphin, grey seal and common seal are all classified under Annex II of the Habitats Directive as a marine species whose conservation requires the designation of SACs. It is unlikely that any of the species will meet the criteria for site designation within, or adjacent to the proposed site survey and exploration well location.


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3.4.2 Coastal Protected Sites

The east coast of Ireland, including highly indented complex of headlands, embayments and estuaries with a diverse range of shore types and exposures supports a rich variety of habitats and species of international and national conservation importance.

Breeding sites for a number Annex I bird species including Arctic terns, storm petrels and barnacle geese have been designated as Special Protection Areas (SPAs). A number of wetland areas are also designated as Ramsar sites and numerous Important Bird Areas are dotted along the coastline (refer to Figure 3.8, Figure 3.9 and Table 3.4). Few SPAs in the area are designated for marine birds.

National areas of importance, or areas where boundary issue would make it difficult to designate SACs and SPAs, are protected as Natural Heritage Areas (NHAs) under the Wildlife (Amendment) Act 2000.

Figure 3.8 and Figure 3.9 illustrates the protected sites on the coast adjacent to the proposed 3 km x 3 km site survey area, in which the drilling site will be located. The closest Natura 2000 sites are located around 8 km to the east of the area. Table 3.5 lists those SACs nearest to the proposed drilling location and their qualifying features.

Those SACs with marine species (Annex II) listed as qualifying features are also highlighted in Table 3.4.

Figure 3.8. Natura 2000 Areas in the vicinity of the site survey area (NPWS, 2010)


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Table 3.4 Coastal SPAs in the vicinity of the proposed Drilling location and their designated species (Source: NPWS, 2010)

SPA County Distance from the 3km x 3km area

Annex I Birds

Dalkey Island (004172) Dublin 8 km Roseate Tern, Common Tern , Arctic Tern

Howth Head Coast (004113)

Dublin 11 km Peregrine Falcon

North Bull Island (004006) (also a UNESCO Heritage site)

Dublin 12.5 km Golden Plover, Bar-tailed Godwit, Ruff, Short-eared Owl

Murrough SPA (004186) Wicklow 14 km Red-throated Diver, Little Egret, Whooper Swan, Greenland White-fronted Goose, Golden Plover, Little Tern, Sandwich Tern, Short-eared Owl, Kingfisher

Skerries Island SPA (004122)

Dublin 15 km Golden Plover, Short-eared Owl

Baldoyle Bay (004016) Dublin 16 km Golden Plover, Bar-tailed Godwit South Dublin Bay and River Tolka Estuary (004024)

Dublin 16 km Bartailed Godwit, Mediterranean Gull, Common Tern, Arctic Tern

Broadmeadow/Swords Estuary (004025)

Dublin 21 km Golden Plover, Bar-tailed Godwit, Ruff

Ireland's Eye (004117) Dublin 22 km Peregrine Falcon Lambay Island (004069) Dublin 23.5 km Peregrine Falcon Rogerstown Estuary (004015)

Dublin 27 km Golden Plover

Wicklow Head (004127) Wicklow 28 km Peregrine Falcon Rockabill (004014) Dublin 36 km Roseate Tern, Common Tern, Arctic

Tern

The 3 km x 3 km potential drilling area is at a distance from the nearest Natura 2000 site (8 km from nearest SPA and 11 km from nearest SAC). The nearest SAC sites (Bray SAC) are designated predominantly for seacliffs and the SPA is designated for Sterna terns. The nearest SAC for marine features is Dublin Bay, 12.5 km from the licensed area. The drilling will occur at a significant distance from Natura 2000 sites (11 km from nearest SAC and 8 km from nearest SPA). Therefore the drilling of the exploratory well does not require further assessment as any impacts will be highly localised and of short duration.

Table 3.5 – SACs in the vicinity of the site survey area (NPWS 2010; DCENR, in press) SAC name County Distance

from the 3km x 3km

area

Qualifying Habitats Marine Qualifying

species

Baldoyle Bay

Dublin 15 km Mudflats and sandflats not covered by seawater at low tide, Salicornia and other annuals colonizing mud and sand, Spartina swards, Atlantic salt meadows, Mediterranean salt meadows

Howth Head Dublin 11 km Vegetated sea cliffs Lambay Island

Dublin 23.5 km Vegetated sea cliffs Grey seal Halichoerus grypus

Malahide Estuary

Dublin 21 km Mudflats and sandflats not covered by seawater at low tide, Salicornia and other annuals colonizing mud and sand, Spartina swards, Atlantic salt meadows, Mediterranean salt meadows, Fixed coastal dunes with herbaceous vegetation, Shifting dunes along the shoreline.


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SAC name County Distance from the

3km x 3km area

Qualifying Habitats Marine Qualifying

species

North Dublin Bay

Dublin 14 km Annual vegetation of drift lines, Salicornia and other annuals colonizing mud and sand, Spartina swards, Atlantic salt meadows, Mediterranean salt meadows, Embryonic shifting dunes, Shifting dunes along the shoreline, Fixed coastal dunes with herbaceous vegetation

Rogerstown Estuary

Dublin 27 km Estuaries, Mudflats and sandflats not covered by seawater at low tide, Salicornia and other annuals colonizing mud and sand, Spartina swards, Atlantic salt meadows, Mediterranean salt meadows, Shifting dunes along the shoreline, Fixed coastal dunes with herbaceous vegetation

South Dublin Bay

Dublin 11 km Mudflats and sandflats not covered by seawater at low tide

Ireland's Eye

Dublin 22 km Perennial vegetation of stony banks, Vegetated sea cliffs

Bray Head Wicklow 8 km Vegetated sea cliffs Magherabeg Dunes

Wicklow 30 km Annual vegetation of drift lines, Embryonic shifting dunes, Shifting dunes along the shoreline, Fixed coastal dunes with herbaceous vegetation, Atlantic decalcified fixed dunes

Wicklow Reef

Wicklow 27 km Reefs; biogenic reef Sabellaria alveolata Phaeostachys spinifera Eulalia ornata Unciola crenatipalma

3.4.3 OSPAR Marine Protected Areas

OSPAR Annex V ‘On the Protection and Conservation of the Ecosystems and Biological Diversity of the Maritime Area’ includes the development of an ecologically coherent network of Marine Protected Areas (MPAs). OSPAR has set the aim for this to be established by 2010, and work is ongoing in Ireland to identify potential MPA areas. The network is intended to make a significant contribution to the sustainable use, protection and conservation of marine biodiversity including in areas beyond national jurisdiction (OSPAR, 2010).

Those offshore habitats which have been specified as in decline and or threatened in OSPAR Region III (Celtic Seas) (OSPAR, 2008) and may be of potential relevance to the Irish Sea area are:

• Sea pen and burrowing megafauna communities; and

• Modiolus modiolus beds;

Neither of these occur within the proposed drilling area, the nearest is over 10 km from the survey area on the offshore side of the Kish Bank. The site survey will include grab sampling to confirm the habitats in the drilling area and confirm that such habitats are not present.

Figure 3.9. Other Coastal Protected Areas in the vicinity of the site survey (NPWS, 2010)


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3.4.4 Cultural Heritage and Protected Areas

Legislation acting to protect submarine archaeological remains in Ireland is based on provisions of the United Nations Convention on Law of the Sea (UNCLOS) 1982 and of the European Convention on the Protection of the Archaeological Heritage (Revised) 1992 (the Valletta convention), both of which oblige signatories to protect submerged archaeological remains. Wrecks more than 100 years old and underwater archaeological objects in Irish territorial and continental shelf waters are protected under the provisions of The National Monuments Acts 1930 to 1994. The act also allows the imposition of an Underwater Heritage Order, in order to protect sites of historical, archaeological or artistic importance.

These can include wrecks less than 100 years old (e.g. RMS Lusitania, sunk May 1915, was placed under such an order in 1995). Current proposals (National Monuments Service 2009) are likely to extend protection to later wrecks (e.g. World War II) if required. They will also allow Ireland to ratify the United Nations Educational, Scientific and Cultural Organisation (UNESCO) Convention on the Protection of Underwater Heritage 2001.

The present Irish coastline may contain a rich variety of archaeological remains; the understanding of this marine archaeological heritage is being continually expanded by the work of a number of national research institutes as well as the Underwater Archaeology Unit (UAU) and the National Monuments Service (NMS) which is part of the Department of the Environment, Heritage and Local Government.

The Irish Sea has been the focus of marine travel since the Mesolithic era (Bell et al 2006) and maritime history has shaped much of the east coast of Ireland, most notably Dublin Port and its history from the first Viking ships through medieval times, with sites old ships’ timbers and a medieval shipwreck across Dublin Bay (NMS, 2010). The Vesper was lost on Kish Bank in January 1876 and more recent wrecks of the MV Bolivar ran aground on the Kish Bank during a snow storm on 4th March 1947. The RMS Leinster, was torpedoed and sunk by a German submarine on 10th October 1918. It went down four miles east of the Kish Lighthouse with over 500 lives lost, the greatest single loss of life in the Irish Sea. Fifty-five wrecks are listed for the Kish Bank area at Irish Wrecks Online,


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although none are in the site survey or drilling area. The stormy and shifting conditions of the Irish Sea are attributed to the break up of wreck sites in the area, in addition many have been removed for safety due to the shipping activity. Known wrecks are shown in Figure 3.10.

The site survey will identify any potential obstructions within the site survey area prior to drilling, which will include a search for potential archaeological material (under the relevant Department of Arts, Heritage and the Gaeltacht licence). All obstructions and any potential archaeology will be avoided in the siting of the rig.

National monuments occur along the coast of this area and include marine features such as the structures and lighthouses of Dublin Port and coastal towns. None occur in the survey area.

Figure 3.10 Shipwrecks in the vicinity of the site survey area (DoEHLG, 2010)

3.5 Socio-Economic Activity

3.5.1 Shipping

Major trade routes between Europe, UK and Ireland and transatlantic connection routes all pass through the Irish Sea. The majority of traffic is shorthaul routes between Ireland, the UK and northern European ports. Average weight classes and types of different type of ship are shown in Figure 3.11.


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Figure 3.11 Average cargo, tanker and ferry distribution and deadweight tonnage in IOSEA 4 area (DCENR, in press; Anatec, 2010)

Due to the shipping activity a separate navigation assessment has been undertaken to assess the shipping density within the survey area.

3.5.1.1 Navigation Assessment

Figure 3.12 shows the vessel density assessment undertaken by ANATEC in the vicinity of the survey site. The assessment is based on commercial shipping data from the AIS (Automatic Identification System) records. The majority of ships routing through the study area have Dublin as either a destination or departure port. Dublin is the largest port in Ireland as well as the Irish Sea region as a whole, and accounts for 50% of all Ireland’s imports and exports as well as being a major passenger port. Rosslare, Cork and Waterford are the next most active east and south of the country. These ports all have regular ferry services visiting them, for example Dublin to Liverpool and Dublin to Holyhead. The recorded shipping density at the well site location is less than five vessels per annum.

Figure 3.12 Shipping counts in the drilling area (Anatec, 2011)


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3.5.2 Commercial Fishing

The waters around Ireland make up some of the most productive fishing grounds in the world. Fisheries in the area are important both nationally and internationally, with a wide range of fish and shellfish species targeted. A number of commercial fishing ports are located on the east coast, the major fishing ports being, Kilmore Quay, Howth and Clogherhead (Irish Sea Fisheries Board, 2010). In addition, numerous small ports are located along the coast; these are used by smallboat fisherman employing static fishery techniques close to the shore including potting and creeling.

Vessel sightings in the region are high. Irish, British, French and Spanish vessels are seen to dominate the fishing in and around the IOSEA2 area. In the survey location, Spanish and Irish vessels were recorded with highest numbers, with 2.3 Irish vessels per square kilometre and 2.7 Spanish vessels per square kilometre (average over year 2006) (Irish Naval Services, 2007).

Demersal fishing dominates in Irish waters, particularly in the west of Ireland, and fleets predominantly originate from Belgium, France, Spain, Ireland and UK. The main gear used is the otter trawl (Figure 3.13), which logs over double the number of effort hours when compared with other gear choices.

Figure 3.13 Total effort (hours) in Ireland for otter trawls (OTX), Nephrops trawlers (TBN), demersal seiners (SX) and other non-identified gear (N_A) for Belgium, France, Ireland and United Kingdom.

Total effort is seen to be relatively stable over the last 10 years. The main trend seems to be a decline in French otter trawlers fishing in the area.

Demersal fisheries in the Ireland are predominately mixed fisheries, with many stocks exploited together in various types of fisheries. Interactions between fisheries are common, and management of fisheries stocks is proving difficult (Stockbook, 2008).

ICES division VIIa (Irish Sea) supports important fisheries for demersal and pelagic finfish and shellfish, and the main fisheries involve otter, beam and Nephrops trawlers.

Otter trawlers target cod, haddock, whiting and plaice, although important by-catch species include anglerfish, hake, sole and skates and rays. Since the early 1980s there has been a development of semi-pelagic gear, which again targets cod, whiting and haddock. The beam trawl fishery in the Irish Sea involves vessels from Belgium, UK (England, Wales and Northern Ireland), Ireland, Holland and France. It commenced in the early 1960s to target sole and fishing effort peaked in the late 1980s, following a period of strong year classes of sole. The effort is currently about 60% of that peak value, and the fishery also lands plaice, rays, brill, turbot and anglerfish. There is also an important Nephrops fishery on the muddy grounds in the north-western Irish Sea, and this is one of


MGE0282RP002F01 35

the most valuable fisheries in the area. Other fisheries that operate in the Irish Sea deploy gillnets and tangle nets, often by inshore boats targeting cod, bass, grey mullet, sole, plaice and rays.

Longline fisheries targeting spurdog expanded in the 1980s, although this fishery has subsequently declined. There are also important fisheries for shellfish, notably scallop fisheries off the Isle of Man and pot fisheries for edible crab and lobster. Pelagic fisheries in the Irish Sea target herring. The fisheries of the area were described by Pawson et al. (2002).

Demersal fishery

Within the survey and drilling area (ICES area Viia) the majority of demersal fisheries are aimed at crustacean landings (nephrops, crab, velvet crab etc). These species predominantly prefer the muddier sediments in the offshore side of the Kish Bank and north central Irish Sea and as a result are less likely to be affected by the survey or drilling. Transit of these vessels may be temporarily affected as they traverse to their fisheries grounds. Advisory notes are in place for the demersal elasmobranch catch in this area (2011-2012). It is likely that effort may be reduced on previous years. The majority of this fishery does not occur in the survey area. Similarly, juvenile cod (codling) fisheries are now rare in the area due to limit and regulatory changes.

Pelagic fishery

Pelagic species are found in mid-water in large shoals, and typically undergo extensive migrations between feeding, spawning and over-wintering grounds. The principal species are mackerel, horse mackerel, herring and blue whiting, which are fished using gear such as pelagic trawled, trolled lures and surface long-lines. The normal annual season for pelagic fishing commences in early September and lasts until March. The very shallow waters of the bank make it unlikely that this area is actively fished, however, effort is likely to occur on the offshore side of the banks where such fish may congregate. This is outside the survey area.

Shellfish fishery

This fishery includes crustacean (crabs, lobsters and shrimps), bivalve molluscs (mussels, oysters and scallops) and cephalopods (squids and octopi). Peak landings are seen in May through to August.

There is an active whelk fishery in the region. This is a static gear fishery potting for whelks. Some of this fishing occurs on the Kish Bank, mainly by smaller vessels from local ports along the east coast. The main season is from February until July.

3.5.3 Other Activities

Military

The survey location is identified as a generic military exercise or transit area. Due to the heavy volume of shipping in the area and the shallow conditions of Kish Bank it is not thought that any exercise operations are carried out in the area, however military ships and submarines do use the area to transit. The nearest active firing range (marine) is 35km away. The nearest munitions dumping site (DCENR, 2007) is over 100 kilometres away.

Oil and Gas

Oil and gas exploration and development has been present in the waters offshore Ireland since the 1970’s, with over 200 wells drilled to date (DCENR, 2007). The Kish Bank Basin has seen little exploratory drilling in Irish waters, although four wells have been drilled in the basin (see Figure 1.1). Similar geological areas in UK waters are heavily explored with significant oil and gas production.


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Recent (2009) seismic and shallow drilling operations were conducted close to the 33/22-1 well drilled in 1977 by Amoco, to investigate the feasibility of an underground coal degasification project.

Cables

Submarine telecommunication cables represent an important use of the offshore area, with development rights being protected under the United Nations Convention on the Law of the Sea (UNCLOS). Submarine cables are safeguarded against natural and man made hazards by the International Cable Protection Committee (ICPC) who work closely with offshore industries to reduce the number of incidents of damage to cables (ICPC, 2010). An extensive network of telecommunication cables is present on the seafloor ensuring reliable telephone, electronic and telegraphic communication between countries and continents. Hibernia Atlantic (proposed 360 route), CONCERTO, and ESAT cables are significant cable operators in the Irish Sea and survey area (see Figure 3.14) (Kingfisher, 2010a,b). There are no cables in the vicinity of the sampling and coring operations. There is a proposed East West Power Interconnector across the Isih Sea to Dublin, however, the project is in route selection stage at present.

Windfarms

There is currently one offshore wind development, the Arklow Offshore Wind Power Plant, located on the Arklow Banks offshore County Wicklow, east of Ireland and south of the survey area. The plant is connected to the Arklow National Grid Substation via a submarine cable to the shore and an underground cable on land; the project has the capacity to produce in excess of 3 megawatts (SEAI, 2010). Eco Wind has full consent for a project at Codling Bank, although construction has not yet commenced. This will be connected to the onshore grid via a submarine cable and then a sub station at Caernarfon (National Offshore Wind Association of Ireland, 2010).

Other offshore wind projects being actively developed in the Irish Sea area are the Saorgus Dublin Array and Oriel Windfarm offshore at Dundalk. If these projects progress they will be connected to the shore via submarine cables (National Offshore Wind Association of Ireland, 2010). The Saorgus Dublin Array is located nearby the Kish Bank survey area, though on the offshore side of the area. There are currently no developments or proposed surveys expected in relation to this windfarm in 2011-2012. Preliminary investigation was undertaken in 2008.

Figure 3.14 Marine cables in the vicinity of the survey area (UKHO 2010, DCENR, in press)


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Recreation and recreational angling

There is no significant recreational or amenity activity anticipated in the survey area. There are some recreational sailing and angling activities in the area, however, the majority of the leisure activity will be confined to the Bullock Harbour and Killiney Bay areas and would be generally close to shore during the summer months particularly at weekends. Some recreational angling does occur in inshore areas at the western exent of the survey area (sport fishing for shark, bass and other species), however, these activities are predominately confined to summer weekends and are unlikely to interact with the survey or drilling.


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4 Hazards, Effects and Mitigation Measures

4.1 Introduction

The methodology used for environmental impact assessment follows the sequence summarised in Figure 4.1:

Figure 4.1. Methodology for environmental impact assessment

The main supporting information required for an assessment includes a description of both the project (Section 2) and the environment in which it will take place (Section 3).

In this section, the interactions between the seismic programme and the environment are identified for routine events and an environmental impact assessment undertaken by establishing a matrix of hazard against environmental sensitivity.

4.2 Environmental Impact Assessment Methodology

4.2.1 Routine Operations

For routine (planned) operations, the process of environmental impact assessment considers each interaction qualitatively on the basis of the criteria of expected consequence provided in Table 4.1. This qualitative scale helps to rank hazards on a relative basis and identify areas where additional control measures may be required.


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Table 4.1: Assessment of significance of effect or hazard

1 Major

May affect the whole population or species in sufficient magnitude to cause a change in abundance, distribution, or size of genetic pool such that natural recruitment would not return that population or species, or any population or species dependent on it.

Has a measurable effect on the livelihood of those using the resource over a period of months/years.

2 Moderate

May affect a portion of the population or species resulting in a change of abundance and/or distribution, or size of genetic pool but does not change the integrity of any population as a whole.

Has a measurable effect on the livelihood of those using the resource over a period of weeks/months.

3 Minor

May affect a specific group of individuals of a population in a localised area but does not affect other tropic levels or the integrity of the population itself.

May be noticed but does not affect the livelihood of those utilising the resource.

4 Negligible

May affect a specific group of individuals of a population in a localised area in a way similar in effect to small random changes in the population due to ambient environmental conditions.

Has no discernible effect on the environmental resource as a whole and is likely to go unnoticed by those who already use it.

None

No interaction and hence no change expected.

4.2.2 Non-Routine Events

Hazards associated with non-routine (unplanned) events, such as accidental fuel spills, have been assessed with reference to the expected frequency of occurrence as well as the consequence of an adverse impact on the environment (Table 4.2).

Table 4.2: Assessment of significance of hazard – non-routine events

Consequence of Impact (see Table 4.1) Frequency of Occurrence

4 3 2 1

(1 per 100-1000 or less unit yrs)

VL VL L M

(1 per 10-100 unit yrs)

VL L M H

(1 per 1-10 unit yrs)

VL L M H

(>1 per unit yr)

L M H H

Risks: VL=Very Low, L=Low, M= Medium, H = High

This classification assists in identifying the greatest risks to the environment from unplanned events. Those hazards resulting in negligible or minor consequence to the environment with a negligible to low expected frequency of occurrence are generally acceptable, whereas those resulting in severe consequences which have a high likelihood of occurring are not. Medium risks need to be reduced as far as reasonably practicable and procedures set in place to minimise impacts should an incident occur.


MGE0282RP002F05 40

4.3 Hazard Identification, Impacts and Proposed Mitigation Measures

4.3.1 Identification of Interactions

Table 4.3 identifies the key activities involved in the proposed drilling programme against the various environment receptors that could be significantly affected by the exploration well.

Table 4.3: Identification of environmental receptors which could be significantly impacted by the proposed survey

Receptor

Physical Biological Socio-Economic

Key Activity

Seab

ed Q

ualit

y

Wat

er Q

ualit

y

Air

Qua

lity

Plan

kton

Ben

thos

Fish

Seab

irds

Mar

ine

Mam

mal

s

Mar

ine

Turt

les

Prot

ecte

d Si

tes

Com

mer

cial

Fis

hing

Ship

ping

Mar

ine

Infr

astr

uctu

re

Tour

ism

/ Le

isur

e

Land

Use

Ons

hore

Physical Presence (rig and support vessels))

X X

Seabed Disturbance (rig positioning, drilling, drill cuttings)

Noise and Vibration (normal vessel operations, drilling)

Atmospheric Emission (engines/generators on the vessel)

Marine Discharges (drill cuttings)

X X X X

Solid wastes (none discharged)

Accidental Events (e.g. fuel spill)

X X X X X X X X X

The following sections discuss the environmental impacts and proposed mitigation measures for each of the identified key activities. The resulting residual impacts are then determined using the significance scale outlined in Section 4.2.

4.4 Design Control Measures

Environmental performance has been a key consideration in option selection and through the design process. Environmental studies and controls, implemented during the design stage of the project, ensure that additional control and mitigation measures required during the operational phases of the project are limited.

The major design controls include:

• Mud selection: use of WBM as the preferred option for the well sections with careful selection of components to reduce potential environmental effects.

• Waste: All solid waste and any LTOBM used will be returned to shore for appropriate

disposal.

• Management procedures will be in place to ensure environmental controls are operating effectively and efficiently. These are detailed in Section 5 of this document.

• Oil spill contingency plan and emergency response procedures will be in place.


MGE0282RP002F01 41

The environmental impact assessment undertaken for each phase of the project uses the design basis, with its integral design controls, as the bench mark for assessing potential impacts and identifying any additional control or mitigation methods required.

4.5 Physical Presence

The rig and support vessels can represent a temporary obstacle to other marine users (notably fishing and shipping) in the area during the duration of the drilling operations. The site survey is currently scheduled to commence in early 2012 and the drilling operation will occur within 6 months of the surveys completion. The drilling operation will take between 30 and 60 days.

The additional shipping associated with the rig and support vessels is considered to be insignificant when compared to existing levels of shipping in this region (refer to Section 3.5.1). Similarly, the displacement of fishing effort from the exploration well and the associated safety zone is small and temporary and is unlikely to significantly affect fishing revenue.

The rig placement and drilling operations will be undertaken following a strict plan and interference with shipping and fishing activity will be minimised by discussions with appropriate organisations (including the Maritime Safety Directorate, the MRCC of the Irish Coast Guard and the Sea Fisheries Protection Agency of the DCENR) during the planning stage. In addition, good communications with the relevant authorities, as well as with any shipping entering the drilling, will be maintained throughout the operation.

During the drilling operation, the rig will be jacked up on the seabed and stationary. The rig will be supported by a supply vessel and standby vessel to support the safety zone. The drilling area is within the lowest shipping density area and in an area likely to have the least impact on other sea users.

Overall, experience shows that interference with other sea users can be avoided over the drilling period by introducing good management practices. Specific mitigation measures that will be undertaken by Providence to ensure minimal interference include: • A specialist drilling contractor, has been appointed to undertake the operation. • A Fisheries Liaison Officer, with a knowledge of fisheries local to the survey area, will

be appointed during the survey works and a Pre-Survey Fisheries support will be prepared. The FLO will also undertake consultation with the relevant fisheries in he area and be present during the drilling operation.

• Details of the work programme will be passed to the maritime authorities (including the Maritime Safety Directorate, the MRCC of the Irish Coast Guard and the Sea Fisheries Protection Agency of the DCENR and Dublin Port Harbour Master) in advance of the drilling operation to increase awareness amongst shipping traffic where relevant. Of note is that the Maritime Safety Directorate publishes Marine Notices advertising such operations.

• The rig will maintain communications with the Dublin Port Harbour Master and inform other relevant Harbour masters (Dun Laoghaire, Bray, Greystones etc) of progress

• Operating criteria for weather conditions (e.g. wind, waves and visibility) will be established and operations suspended if the criteria are exceeded.

• A Providence representative will be on-board the rig or support vessel at all times to ensure compliance with approved operating procedures, including those concerning environmental protection and to also ensure that the survey is conducted safely.

• A support vessel will be available and the rig will monitor shipping and minimise interference.

• A shipping intensity assessment has been undertaken.

• The rig and support vessels will meet all national and international regulations for shipping including the appropriate signals and lights to indicate towing the cables and the regulations defined by the International Maritime Organisation for avoiding collisions at sea. State-of-the-art communications and positioning equipment will be


MGE0282RP002F05 42

on-board the rig to maintain communications with all other shipping and provide accurate information on the position of the rig and any support vessels.

Residual impacts to other sea users (fishing and shipping) resulting from the physical presence of the rig and support vessels are considered to be minor, particularly given the relatively short duration of the survey.

4.6 Seabed Disturbance

4.6.1 Deposition of Drill Cuttings

The main potential source of seabed disturbance from the Kish Bank well will be caused by the deposition of drill cuttings on the seabed in the vicinity of the rig. The major physical waste product of a drilling operation is the generation of rock cuttings and fine solids from the centrifuges. Other waste products include the discharge of cement during the cementing of the well casing for the top section of the well.

The deposition of cuttings and fine solids has the potential to directly affect the seabed fauna. Smothering effects and changes in the sediment grain size and chemistry combine to favour certain species over others. As a result, the population of seabed fauna within the area influenced by cuttings deposition may differ from that of the surrounding unaffected sediments. Such effects have been well studied and indicate an effect broadly mirroring the area of deposition of the cuttings. Studies have shown that impacts from smothering can occur where the depth of cuttings is one millimetre or more (Bakke et al., 1986).

As there are no toxic components within the discharge of the vast majority of cuttings, the impacted area will begin to recover soon after drilling operations have ceased. Re-colonisation of the impacted area can take place in a number of ways including mobile species moving in from the edges of the area, juvenile recruitment from the plankton or from burrowing species digging back to the surface.

For example in 1987 a benthic environmental survey was undertaken at a single well site in the central North Sea (AUMS, 1987). The well had been drilled five years prior to the survey using a WBM and a total of approximately 800 tonnes of cuttings had been deposited on the seabed. The results of the survey indicated that, with the exception of a slightly elevated barium concentration, levels of sediment metals and hydrocarbons were similar to background. The analysis of the benthic fauna indicated that, even at sites closest to the wellhead, full recovery of the impacted sediments had taken place. This well site was revisited by Oil and Gas UK (formerly UKOOA) in 2005 and results now show that the area is completely consistent with background conditions (Hartley Anderson Ltd, 2005). In addition, field studies in the United States of America have shown that recovery of benthic communities impacted with water based drilling discharges is likely to be very rapid (i.e. within a few months) (Neff, 1982).

4.7 Noise and Vibration

The Kish Bank well will generate noise, both above and below the sea surface, during drilling activities. Noise is considered to have the potential to disturb animals in the area, particularly cetaceans.

Typical subsea noise levels from offshore operations are shown in Table 4.4.


MGE0282RP002F01 43

Table 4.4: Typical Noise Levels Associated With Offshore Operations

Taking 150dB as an example of the typical noise level generated from drilling operations using a semi-submersible drilling rig (which would be greater than the noise emissions from a Jack up rig) and assuming a spherical propagation of noise from the source, it can be seen from Figure 4.2 that background noise levels will be reached within a kilometre of the source.

Studies from drilling / production platforms off California have indicated that the noise emitted was low frequency and was so weak as to be virtually undetectable from alongside the platform during sea states greater than three on the Beaufort scale (Gales, 1982 in Richardson et al, 1995). Noise from offshore operations is produced over a relatively large frequency range (typically between 7-4,000 Hertz), greater than that produced by ships (20-1,000 Hertz) (Richardson et al., 1995).

Figure 4.2. Propagation of Sound in Water (from Richardson et al, 1995)


MGE0282RP002F05 44

4.7.1 Potential Impacts on Fish

Given the magnitude of sounds expected to be produced by the proposed Kish Bank well activities there are not expected to be any physical impacts on fish (Figure 4.3).

Figure 4.3. Sound Pressure Thresholds for the Onset of Fish Injuries (after Turnpenny & Nedwell, 1994)

4.7.2 Potential Impacts on Cetaceans

Cetaceans are in general believed to be fairly tolerant to noise disturbance and are unlikely to be affected by the magnitude and frequency of noise produced during planned offshore operations (Richardson et al., 1995). The distribution of cetaceans appears to be unaltered by the presence of a facility, with sightings rates reported to be similar with or without the presence of a rig, although it has been suggested that cetaceans will react within five kilometres of a noise source (Richardson et al., 1995). Studies have indicated that even when the noise generated by a drill rig is well above the ambient (background) level, baleen whales exhibit no measurable change in behaviour and it is only at a distance of tens of metres from the rig that sound levels are likely to be high enough to initiate avoidance action (Richardson et al, 1995). In addition, anecdotal evidence indicates that cetaceans are not disturbed by the noise generated by large vessels.

A number of cetaceans breed in Irish waters, including the harbour porpoise, the common, bottlenose, Risso's, Atlantic white-sided and white-beaked dolphins, and the long-finned pilot whale (Berrow, 2002). In addition, a number also migrate annually along the western seaboard, including blue, fin and humpback whales.

However, due to the localised impact from noise associated with the proposed Kish Bank well, the overall impacts on cetaceans are therefore expected to be negligible.

4.8 Atmospheric Emissions

The main sources of atmospheric emissions during well drilling will result from diesel burnt for power generation for the drill rig, standby vessels. Diesel burnt for power generation will give rise to minor emissions of carbon dioxide (CO2), oxides of nitrogen


MGE0282RP002F01 45

(NOx), nitrogen dioxide (NO2) sulphur dioxide (SOx) and unburned hydrocarbons (Table 4.5).

Table 4.5: Predicted Atmospheric Emissions from Power Generation from Drilling

Practical steps to limit atmospheric emissions that will be adopted during the drilling programme include advanced planning to ensure efficient operations, well maintained and operated power generation equipment and regular monitoring of fuel consumption.

4.9 Marine Discharges

4.9.1 Water Based Drilling Mud (WBM)

WBM will be discharged as mud on cuttings and fine solids and, upon the completion of drilling each section of the well, the spent WBM will be discharged to sea. The drilling mud composition is essentially a brine solution, with naturally occurring barite and bentonite clay. Small amounts of chemicals are added to this to maintain the properties of the mud and to prevent damage to the well bore and the reservoir.

The main components of WBM will comprise natural products (for example, brine, bentonite and barite), which are biologically inert (UKONCS Category E). The muds typically have a very low toxicity, with an LC50 of more than 50,000 parts per million (Jones et al., 1986; Leuterman et al., 1989). In fact, the WBM comprises approximately 90 percent water and the vast majority of WBM discharged for the well (approximately 95 percent) are classified under Annex 6 of the OSPAR convention (OSPAR, 1999) as substances, which are considered to Pose Little Or No Risk to the environment (PLONOR chemicals).

Of the limited quantity of chemicals not classified as PLONOR and anticipated to be discharged along with the WBM, all are categorised as Category E or Gold (the lowest environmental risk category) under the UK Harmonised Offshore Chemical Notification Scheme.

Studies of the discharge of WBM into the water column in areas where currents are weak have found dilutions of 500 to 1,000 times within one to three metres of discharge (Ray and Meek, 1980). Dilution will therefore be rapid and this, together with the low toxicity, indicates that any impacts within the water column will be undetectable shortly after discharge. Discharge of the WBM will not contribute to any impacts on the local seabed communities through toxicity, bioaccumulation, low biodegradability or other aspects such as the endocrine disruption.

In some cases drilling muds may be associated with elevated levels of heavy metals. However, a wide range of studies have shown that these are not bio-available and do not therefore result in any direct affects on marine fauna and flora (Neff et al, 1989).


MGE0282RP002F05 46

4.9.2 Cement Chemicals

During drilling of the well, some surface returns of cement and associated chemicals will be lost to the seabed in the immediate vicinity of the well. The cement is comprised mostly of PLONOR chemicals.

4.9.3 Drainage Water and Sewage

Water generated from rig washdown may contain trace amounts of mud, lubricants and residual chemicals resulting from small leaks or spills and rainfall from open deck areas. The volume of these discharges depends on the frequency of washdown and amount of rainfall. Liquid storage areas and areas that might be contaminated with oil are segregated from other deck areas to ensure that any contaminated drainage water can be treated prior to discharge and accidental spills contained. Drainage water from these areas and machinery spaces is collected, treated to remove hydrocarbons (less than 15 parts per million hydrocarbons in water) as required under the MARPOL Convention and the cleaned water then discharged to sea. Black (sewage) and grey water is also collected, treated to meet the requirements of the MARPOL Convention and discharged to sea.

These are all relatively low volume discharges containing small residual quantities of contaminants. Providence will ensure that the rig is equipped with suitable containment, treatment and monitoring systems as part of the contract specification. Providence will also ensure good housekeeping standards are maintained to minimise the amount of hydrocarbons and other contaminants entering the drainage systems.

4.9.4 Accidental Spills

Pollution emergencies can occur at any time in the marine environment. There is a very low possibility of a major accidental spill of hydrocarbons occurring from the planned drilling operations (frequency classified as 1 per 100-1,000 or less unit yrs). The main potential source of an accidental spill would be from diesel oil contained in the storage tanks, released through accidental collision between the rig, support vessels and ‘other’ boats. Small volume spills may also occur as a result of leaks from generators and other machinery including hydraulic fluids etc. It should be noted that the risk of an operational spill occurring from the drilling programme is highly unlikely. A full Oil Spill Contingency Plan (OSCP) will be prepared assessed and submitted to the PAD. OSCP information for Kish Bank is included with this application.

Historical data suggests that small diesel spills of less than one tonne will represent the most likely oil spill scenario. Given the relatively low volumes of oil, coupled with the light nature of the oils likely to be spilled in any drilling operations accidental release, evaporation and dispersion of the spill would be rapid. This in turn means that impacts on water quality and on plankton communities will be limited due to the mobile and transient nature of water masses and their associated plankton mixing through the affected locality, in addition to the high reproductive rates of plankton during peak growth periods. There may potentially be some impacts on seabirds present on the surface of the water or on fish or marine mammals in the immediate vicinity of the spill. However, the numbers affected would be very small and the overall impacts likely to be minimal. Given the proximity of the nearest coast, it is possible in westerly weather conditions that an accidental spill could reach landfall, however, given the exposed nature of the coasts in the area and the likelihood of mixing and dispersal due to the prevalent conditions, it is unlikely that any significant quantities of the oil would be detected in coastal habitats.

In order to minimise the risk of a spill the rig and support vessels will have an externally certified Shipboard Oil Pollution Emergency Plan (SOPEP) as required under the 1973/1978 MARPOL Convention and Robust Offshore Refuelling Procedures.

The operations will also have an Oil Spill Contingency Plan prepared and assessed by the PAD. OSCP information is included with this application.

In addition, to reduce the risk of an accidental collision occurring during the survey, details of the work programme will be passed to the maritime authorities in advance of the operations to increase awareness amongst shipping traffic where relevant. The rig will


MGE0282RP002F01 47

monitor shipping and a support vessel will be available, thereby helping to enforce a safety zone around the rig.

Given the very low possibility of a major accidental spill of hydrocarbons during the drilling operation, as well as the low volumes and light nature of the oils that are likely to be involved if an accidental spill of fuel or chemicals was to occur, the risk to the environment from an accidental spill is considered to be very low.

The likelihood of any spill from the drilling operations is extremely low and full contingency and spill plans will be planned prior to operations.

4.10 Solid Wastes

Careful consideration is given to minimising the amount of waste generated and controlling its eventual disposal. Typically, 24 tonnes of waste are generated per month from a single well drilling programme. Bulk wastes (e.g. rubbish (municipal wastes), scrap etc.) generated on the drilling rig will be segregated by type, stored in covered, four tonne capacity skips. Periodically these will be transported to shore and the waste recycled or disposed of in a controlled manner through authorised waste contractors. Providence will ensure that a waste management programme is implemented to minimise the amounts generated and to ensure material such as scrap metal, waste oil and surplus chemicals are sent for re-cycle or re-use as far as practicable. Other waste will be sent to authorised landfills or incineration facilities, depending on its precise nature.

All discharges from the supporting vessels will be treated and discharged in according to the MARPOL convention (as relevant to the Atlantic Ocean). The MARPOL convention prohibits discharge of any garbage or solid wastes into the Atlantic Ocean.

All vessels, including the rig, will implement appropriate Waste Management Plans and store and dispose of all solid wastes onshore accordingly. Procedures for dealing with Special Waste will be implemented in accordance with regulatory guidelines.

4.11 Loss of Containment

4.11.1 Drilling Operations

Potential Spill Scenarios

The main environmental risk associated with rig operations is a risk of accidental hydrocarbon releases during drilling operations, mainly from fuel bunkering of diesel or a loss of well control.

In the UK, data recorded by DECC on oil spills entering the UKCS indicate that small spills are historically the most common ways by which oil enters the sea during drilling operations, although they are still quite rare occurrences (Figure 4.4). The historical frequency is 0.15 operational spills per exploration well drilled on the UK Continental Shelf between 1994 and 1997 for all recorded spills of ten tonnes or less.

Figure 4.4: Frequency and Size of Oil Spills during Offshore Drilling Operations per Rig per Year (data from UKCS and SINTEF Database)


MGE0282RP002F05 48

Accidental diesel spills during bunkering are identified as a moderate risk but the expected volumes of hydrocarbon released would be generally small (0.6 tonnes) (HSE, 1995). Such a volume would disperse rapidly and will not impact along the coast.

The five main sources of potential spills, from historical oil spill records are listed in Table 4.7 with the measures being taken by Providence within the drilling programme to minimise or eliminate the risks. These are discussed further in the sections below along with measures proposed by Providence in the unlikely event that a spill does occur. Further information on the likelihood of spills and the size and type of spill that may be expected from the Kish Bank well is also provided in the Oil Spill Contingency Plan information.

Table 4.6 Sources of Oil Spills and Control Measures Planned

Worst Case Scenario Definition

The worst case scenario would be a loss of the total diesel of the drilling rig in the event of a major accident to the rig during drilling of a well section. The likelihood of such an event occurring is in the range identified as low risk. The maximum oil storage capacity of the most drilling rigs is in the range of 1,000 tonnes of diesel for power generation. The worst estimated event for the purpose of this study has been defined as the loss of the largest oil storage tank of the drilling rig, which would result in the loss of 1,000 tonnes of diesel.

There is a small possibility (between 0.000123% and 0.2825%) that a well blow out could occur. A blow-out is the uncontrolled influx of reservoir fluids into the well. Due to the precautions taken to prevent their occurrence, they are very rare events. Uncontrolled


MGE0282RP002F01 49

flow is mostly associated with drilling into a shallow gas pocket or whilst drilling a deep gas well. Unlike recent overseas events this well is in shallow water, and there will be a number of protective features within the drilling plan, in addition detailed seismic data is being acquired by survey prior to the drilling operation which would identify any such features. The Oil Spill Contingency Plan outlines further details. The likelihood of a blow out in Irish waters is 0.2825% or once every 354 years, and due to the conditions, any such incident would be controllable within a short period of time.

Therefore the oil spill risk is primarily related to an incident, such as a collision, which could potentially cause the entire inventory of hydrocarbons stored on the rig or a vessel to be released to the sea (Table 4.6).

Muds and Cuttings Fate

The major waste product of a drilling operation is the generation of rock cuttings, plus residual mud (approximately 10 percent) adhering to the cuttings. Cuttings are inert solids, their composition reflecting the well geology.

The main source of seabed disturbance from the Kish Bank exploration well will be caused by the deposition of drill cuttings on the seabed in the vicinity of the exploration well. The major physical waste product of a drilling operation is the generation of rock cuttings and fine solids from the centrifuges. Other waste products include the possible discharge of cement during the cementing process.

Water Based Mud (WBM) will be used for all sections of the well. A total of 292 m2 of cuttings are expected to be generated by the well, all of which will be discharged to sea.

Cuttings discharged on the seabed will form a pile in the immediate vicinity of the well. Those cuttings discharged at the sea surface will sink to the seabed and be deposited there in a pattern that reflects the nature of the cuttings (particle size distribution), the water depth and the water movements at the time of discharge.

A simple analytical model has been used to estimate the deposition on the seabed of cuttings from the Kish Bank exploration well, based on simple well-established mathematical formulae. The model takes into account the particle size distribution and dispersion of cuttings by currents based on data given in Fugro-GEOS, 2001. It does not account for re-suspension or dispersion after initial deposition on the seabed. The model assumptions are detailed below.

Modelling of cuttings deposition on the seabed was done using a simple analytical model based on the Stokes Law equations for particle settling velocity. The model calculates the sinking rates of each of the particle size classes provided as input and calculates a location of seabed deposition based on hourly current speed and direction over a complete tidal cycle. The model assumptions are:

• Particles are spherical;

• There is no initial velocity on discharge;

• Currents speed and direction is continuous for one hour and then changes instantaneously;

• There is no re-suspension of cuttings after initial deposition.

The model does not provide accurate seabed contours because contouring of the results of particle tracking models results in a significant over estimation of the amount of cuttings discharge. The model only provides an indication of the extent of the area of deposition.


MGE0282RP002F05 50

Input parameters for the model are provided below in Table 4.7 and Figure 4.5.

Table 4.7 Discharge of Drill Cuttings for Kish Bank Exploration Well

Parameter Input data

Volume of cuttings 292

Current speed and direction See Figure 4.9

Particle size distribution (size classes in mm) 0.01, 0.1, 1, 5, 10

Water depth 25 metres (85ft)

Discharge depth (m below surface) 10 metres (32ft)

The model predicts that 38 percent of the cuttings will be found within a distance of 50 metres of the exploration well, 65 percent within 100 metres and 92 percent within 500 metres. The remaining 8 percent of cuttings, comprising the finer particles, travel up to 560 metres from the well but are likely to be so widely spread that they are unlikely to be detectable. The cuttings pile will be oriented along a north-east to south-west axis (Figure 4.6). The model also shows that the maximum predicted depth of cuttings deposition is 1.6 centimetres.

Figure 4.5: a) Current information for Dublin Bay (UKHO) from nearest tidal diamond, and b) Tide Tables for Dublin Bay for 2012 (UKHO)


MGE0282RP002F01 51

Figure 4.6: Predicted cuttings deposition on the seabed around the drilling rig (axes display x-y distance from drilling rig (located at origin) in metres)


MGE0282RP002F05 52

The deposition of cuttings and fine solids described above can have a direct effect on seabed fauna. Smothering effects and changes in the sediment grain size and chemistry combine to favour certain species over others. As a result, the population of seabed fauna can differ from that of the surrounding unaffected sediments. Such effects have been well studied and indicate an effect broadly mirroring the deposition of the cuttings. Studies have shown that impacts from smothering can occur where the depth of cuttings is one millimetre or more (Bakke et al., 1986).

As shown by the modelling, cuttings deposits will be 1.6 cm deep at their greatest depth. Given the research conducted by Bakke et al. (1986), smothering will be expected across the entire impact area. Smothering is likely to be temporary in nature. The main components of WBM are naturally occurring products (e.g. barite and bentonite clay), to which may be added various products so that the mud has suitable properties. The mud components are generally of low environmental risk and many are given the chemical label code of PLONOR (Pose Little or No Risk to the marine environment). The mud components and the calculated associated risks of their use and discharge will be detailed fully in the PUDAC application.

Given that the impact is purely physical, i.e. natural disturbance and smothering, and that the sediments will not have been contaminated, then it is anticipated that the sediment communities will begin to recover as soon as drilling operations have ceased. Impacts from the deposition of drilling cuttings would be greater in low current areas where these materials would stay in the well rather than be re-suspended and deposited in lower densities at greater distances. Re-colonisation of the impacted area can take place in a number of ways, including mobile species moving in from the edges of the area


MGE0282RP002F01 53

(immigration), juvenile recruitment from the plankton or from burrowing species digging back to the surface.

Recovery times for soft sediment faunal communities are difficult to predict although some studies have attempted to quantify timescales. Collie et al., (2000) examined impacts on benthic communities from bottom towed fishing gear and concluded that in general, sandy sediment communities were able to recover rapidly, although this was dependant upon the spatial scale of the impact. It was estimated that recovery from a small scale impact, such as a fishing trawl could occur within about 100 days. In this sort of impact, it was assumed that recolonisation was through immigration into the disturbed area rather than from settlement or reproduction within the area. It was also noted that whilst the recovery rate of small bodied taxa, such as the polychaetes which tend to dominate the data set, could be accurately predicted, sandy sediment communities often contain one or two long lived and therefore vulnerable species, e.g. Mya truncata, the recovery of which is far harder to predict.

Further, in a series of large scale field experiments, Dernie et al., (2003) investigated the response to physical disturbance of marine benthic communities within a variety of sediment types (clean sand, silty sand, muddy sand and mud). Of the four sediment types investigated, the communities from clean sands had the most rapid recovery rate following disturbance.

A wide range of studies have shown that there is little impact associated with the discharge of water based mud (National Research Council, 1983; Neff, 1987; Neff et al., 1987; Neff et al., 1989; Hinwood et al., 1994). Recolonisation of the impacted area can take place in a number of ways including mobile species moving in from the edges of the area, juvenile recruitment from the plankton or from burrowing species digging back to the surface. For example in 1987 a benthic environmental survey was undertaken at three single well sites in the central North Sea (at depths of 102m, 120m and 130m respectively) (AUMS, 1987). The wells had been drilled five years prior to the survey using a WBM and a total of approximately 800 tonnes of cuttings had been deposited on the seabed at each location. The results of the survey indicated that, with the exception of a slightly elevated barium concentration, levels of sediment metals and hydrocarbons were similar to background. The analysis of the benthic fauna indicated that, even at sites closest to the wellheads, full recovery of the impacted sediments had taken place. These well sites were revisited by Oil and Gas UK (formerly UKOOA) in 2005 and results now show that the area is completely consistent with background conditions (Hartley Anderson Ltd., 2005). In addition, field studies in the United States of America have shown that recovery of benthic communities impacted with water based drilling discharges is likely to be very rapid (i.e. within a few months) (Neff, 1982).

Effects on benthic organisms are expected to be limited to a relatively localised area around the drilling rig. It can be seen in Figure 4.6 that the majority of cuttings from the well lie within an area approximately 500 metres from the drilling rig. Numerous studies indicate that any impacts from cuttings disposal will only last for a relatively short period of time.

In addition, the model assumes that there is no re-suspension of cuttings after initial deposition. This is useful to give an indication of the initial settling locations of the discharged particles soon after drilling activities. However, it does not take into account the fact that sediment entrainment will occur after deposition of sediments. This is likely to take place within the area of the proposed Kish Bank exploration well location, where sea-surface and bottom currents are relatively strong, enabling relatively rapid dispersion of the discharged cuttings and integration of the cuttings into the sediment regimes of the surrounding area.

Predicted Potential Impact on the Coastal Environment

A site survey is currently scheduled to commence in early 2012. Within 6 months of the site survey completion the exploratory well operations will take place.


MGE0282RP002F05 54

For oil spill planning purposes, modelling (using the BMT OSIS 4.1 spill model) will be undertaken to estimate the minimum time to shore in the case of a worst case diesel spill of 1,000 tonnes, under extreme conditions of a constant 30 knot onshore wind. For the purposes of this report a simplistic model has been carried out based on the initial assessment of the well cutting estimates. A specific model will be run once the survey has been carried out and the volumes are confirmed.

Further modelling will be undertaken to confirm the fate of a possible diesel spill.

Mitigation Measures

A number of control measures will however be in place to minimise the risk of a spill (refer to Table 4.6). An Oil Spill Contingency Plan (OSCP) and an Emergency Procedures Plan will also be in place prior to any well drilling operations taking place to provide guidance on actions to be taken in the event of a release or spill. These measures will reduce the risk of a spill or release and provide control measures in the unlikely event of a spill occurring.

Given the very low possibility of a major accidental spill of hydrocarbons during the drilling operation, as well as the low volumes and light nature of the oils that are likely to be involved if an accidental spill of fuel or chemicals was to occur, the risk to the environment from an accidental spill is considered to be very low.

The likelihood of any spill from the drilling operations is extremely low and full contingency and spill plans will be planned prior to operations.

4.12 Transboundary Impacts

The issues with the potential for transboundary effects, in the context of this well, are atmospheric emissions and accidental events leading to an oil spill. The closest international boundary, between the UK and Ireland, is some 128 km distance from the exploration well. Atmospheric emissions are undetectable against background levels at 20 kilometres and there will be no transboundary impacts from these emissions.

4.13 Cumulative Impacts

The proposed Kish Bank well will be drilled by a single vertical well located in Block 33/21. A 500m safety zone will be set up around the drilling rig to mitigate disruptions to other sea users in the area, which are expected to be few. The general area is also undeveloped in terms of oil and gas exploration. There are currently no dredging or renewable energy activities in the area. The Kish Bank well will contribute to local environmental impacts including the discharge of water based drilling muds and cuttings at the seabed, as well as atmospheric and waste emissions from vessels and the drilling rig. In summary, environmental impacts will be largely confined to short term disruption from drilling and from one off discharges of drill cuttings. It is expected that cumulative impacts from Kish Bank will be negligible.

4.14 Assessment of Significance of Environmental Effects

The significance of the hazards and effects identified in Section 4.3 has been assessed, in Table 4.8 below, against the criteria presented in Tables 4.1 and 4.2.

In conclusion, although there is expected be some temporary environmental impact during the proposed drilling operations, long term environmental impacts will be negligible providing that the appropriate mitigation measures are adopted.

4.15 Assessment of Significance of Navigational Effects

Due to the location a navigation assessment has been carried out as part of the Environmental Area Assessment (see Section 3.5.1). The significance of the hazards and effects identified in Section 4.3 has been assessed, in Table 4.8 below, against the criteria presented in Tables 4.1 and 4.2.

In conclusion, although there is expected be some temporary navigational impact during the drilling and transit time. The interaction will be of short duration and suitable notices


MGE0282RP002F01 55

and mitigation will be implemented. The drilling occurs in an area of very low shipping density and should therefore be subject to minimal interaction. There will be no long term impacts from the drilling.

Table 4.8. Assessment of impacts associated with the drilling operations

Receptor

Physical Biological Socio-Economic

Key Activity

Seab

ed Q

ualit

y

Wat

er Q

ualit

y

Air

Qua

lity

Plan

kton

Ben

thos

Fish

Seab

irds

Mar

ine

Mam

mal

s

Mar

ine

Turt

les

Prot

ecte

d Si

tes

Com

mer

cial

Fis

hing

Ship

ping

Mar

ine

Infr

astr

uctu

re

Tour

ism

/ Le

isur

e

Land

Use

Ons

hore

Physical Presence (rig and support vessels))

5 5 4 4

Seabed Disturbance (rig positioning, drilling, drill cuttings)

4 3

Noise and Vibration (normal vessel operations, drilling)

5 5 5 5

Atmospheric Emission (engines/generators on the vessel)

5

Marine Discharges (drill cuttings)

5 5 5 5 5

Solid wastes (none discharged)

5

Accidental Events (e.g. fuel spill)

4 3 5 5 4 3 5 5 5

1 Severe 2 Major 3 Moderate 4 Minor 5 Negligible

4.16 Habitats Directive Assessment of Significance of Effects (Screening)

As there are no sites in the immediate proximity to the drilling area with marine features listed, the operations will not compromise the conservation objectives of Natura 2000 sites or proposed Natura 2000 sites in the area. As a result, further Habitats Directive Assessment and a Natura Impact Statement is not required.

4.17 European Protected Species Assessment of Significance of Effects (Screening)

Given the Code of Practice employed and industry best practice, the drilling operations outside peak cetacean abundance periods, the information from the MMO on the site survey and subsequent assessment, and short duration of the drilling operations, any affect on marine mammals from the operations is deemed to be minor and temporary. In addition, no semi-resident marine mammals have been identified in proximity to the drilling area. As a result any impact identified is not deemed to be significant, and therefore an Annex IV Species (European Protected Species) Impact Assessment is not considered to be required.

5 Environmental Management Plan

Providence recognises that effective health, safety, environmental and quality (HSEQ) management contributes significantly to the company’s long-term business success. Environmental management is an integral part of the Providences HSEQ Management System (MS). The HSEQ Policy (refer to Figure 5.1), HSEQ Standards and HSEQ Management System apply to all activities where Providence has any legal and/or moral


MGE0282RP002F05 56

accountability, or where they present any risk to the business. The HSEQ MS provides the framework for managing HSEQ issues within the business. This HSEQ MS is intended for application to all of Providence’s activities as directed under the OSPAR recommendation 2003/5 to promote the use and implementation of Environmental Management Systems by the Offshore Industry. Providence’s business is concentrated on oil and gas exploration activities in the offshore environment and includes seismic and drilling operations. The HSEQ MS therefore focuses on:

• clear assignment of responsibilities;

• excellence in HSEQ performance;

• sound risk management and decision making;

• efficient and cost effective planning and operations;

• legal compliance throughout all operations;

• a systematic approach to HSEQ critical business activities; and

• continual improvement.

The HSEQ MS has been designed to reflect the existing level of operational activity within Providence. Specific operations are therefore managed within the management systems of other contractors and the HSEQ MS sets standards and expectations against which those systems will be assessed. It is the responsibility of Providence and the HSEQ Committee to identify changes in operational activity that will require further development of the system. This would normally occur as part of the annual review process defined within this system but may be required outside of the review schedule.

The HSEQ MS Manual represents the top level of the HSEQ MS and is supported by specific guidelines that cover both operational activities and emergencies of both the parent company and its subsidiaries. These are developed as required by the Company’s operations.

As outlined in Section 4 above, the drilling operations will result in a range of operational releases to the environment and the potential for non-routine or accidental releases. The environmental impact assessment process has systematically identified and assessed all potential environmental impacts associated with the survey operations. As a result of the control measures and management processes in place, there should be no significant impacts resulting from the proposed operations.

The key hazards and their residual impacts following the implementation of mitigation measures are shown in the Environmental Management Plan in Table 5.1. The mitigation measures will ensure that all potential impacts are reduced to as low as reasonably practicable. Actions identified to manage the stated environmental impacts will be implemented and communicated to project personnel via a separate Health, Safety and Environment (HSE) plan.


MGE0282RP002F01 57

Figure 5.1 . Providences HSEQ Policy Statement

Kish Bank Survey ERA

58 MGE0282RP002F01

Table 5.1Environmental Management Plan

Hazard Potential Effect Mitigation Responsibility Residual Impact

A specialist drilling contractor has been appointed to undertake the well using Providence’s contractor selection and management procedures

Operations Manager

At the detailed planning stage the choice of the well location will included consideration of the potential interference with shipping.

Operations Manager

Details of the work programme will be passed to the maritime authorities (including the Maritime Safety Directorate, the MRCC of the Irish Coast Guard and the Sea Fisheries Protection Agency of the DCENR) in advance of the survey to increase awareness amongst shipping traffic where relevant. Of note is that the Maritime Safety Directorate publishes Marine Notices advertising such operations.

All operations will be co-ordinated with relevant authorities, Harbour Masters etc.

Operations Manager

Operating criteria for weather conditions (e.g. wind, waves and visibility) will be established and operations suspended if the criteria are exceeded.

Operations Manager

A Providence representative will be on-board the rig at all times to ensure compliance with approved operating procedures, including those concerning environmental protection and to also ensure that the survey is conducted safely.

Operations Manager

The rig and support vessels will monitor shipping and minimise interference by maintaining position near the end of the towed cables, thereby helping to enforce an safety zone around the rig.

Operations Manager

Physical Presence

Rig and support vessels could disrupt local shipping.

The rig and support vessels will meet all national & international regulations for shipping including the appropriate signals & lights to indicate rig and the regulations defined by the IMO for avoiding collisions at sea. State-of-the-art communications and positioning equipment will be on-board the survey vessel to maintain communications with all other shipping and provide accurate information on the position of the rig and support vessels.

A 500 metre safety zone will be set up around the drilling rig. A safety stand-by vessel will be on stand-by for the duration of the rig programme and will enforce the 500 metre safety zone. Any interference with fishing will be limited to temporary restrictions around the drilling rig and safety zone. Prior to operations commencing, the appropriate notifications will be made & maritime notices posted. All vessel activities will be in accordance with national & international regulations. Appropriate navigation aids will be used

Operations Manager

Minor

There is sufficient area for ships to easily avoid the survey vessel.

The drilling operations and sampling are occurring in an area of very low shipping density outside recognised shipping lanes.

Any safety zone enforcement will be of short duration.


MGE0282RP002F01 59

Hazard Potential Effect Mitigation Responsibility Residual Impact to ensure other users of the sea are made aware of the presence of vessels.

Measures implemented for avoiding impacts on shipping will also be effective in minimising impacts on fishing activities.

Operations Manager

Rig and support vessels could disrupt fishing activity causing vessels to stop fishing and/or move to new areas during the survey period.

A fisheries liaison officer, with a knowledge of fisheries local to the survey area, will be onboard the seismic vessel or guard vessel during the survey works and on support vessel during the rig positioning

Operations Manager

Minor

Fishing will be disrupted in the immediate vicinity of the rig and support vessels.

The Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters Version 1.1 (NPWS, 2007) will be followed.

Operations Manager

Behavioural disruption affecting marine mammal’s ability to find food and communicate and follow regular movements.

Dedicated, trained and qualified Marine Mammal Observers (MMOs) will be present onboard the survey at all times during the site survey and the results of their work will inform the rig deployment

Operations Manager

Acoustic Emissions

Short-term behavioural changes might be observed in fish populations in close proximity to the drilling rig or vessels on Dynamic positioning.

Providence shall ensure that a Fisheries Liaison Officer, with a knowledge of fisheries local to the survey area, will monitor activities onboard the rig and support vessels for the duration of the drilling works.

Operations Manager

Minor

Cetaceans are likely to avoid the area in the immediate vicinity of the drilling activity. Toothed whales may also be affected by the temporal avoidance or disturbance reaction of fish during operations.

Grey and common seals may be present in the area, however the survey occurs at a significant distance from known haulout and breeding sites and outside sensitive seasons.

Coull et al (1998) have identified that fish spawning within the vicinity of the proposed survey area, is sensitive to acoustic disturbance between March and July.

The proposed operations are currently scheduled for late 2012 / early 2013. They are of relatively short in duration and does not cover the entire spawning area of these species.

Atmospheric Emissions

The main source of atmospheric emissions will result from engine exhaust gases.

The emissions generated from the drilling operation will be controlled through fuel efficiency measures.

Operations Manager

Negligible

Discharge of sewage and grey water

All discharges from the seismic survey and supporting guard boats will be treated and discharged in accordance with the MARPOL Convention.

Operations Manager

Negligible

Marine Discharges

Drill cuttings a small amount of cuttings will be generated

Drill cuttings will be minimised during drilling operations. All drilling operations will be undertaken according to industry best practice.

Operations Manager

Minor


60 MGE0282RP002F01

Hazard Potential Effect Mitigation Responsibility Residual Impact through drilling operations It is estimated that drilling the well will generate a maximum total of 292 m2 of

cuttings, which will be discharged at the seabed. The main effect generally associated with drilling operations is smothering of organisms living on the seabed from the accumulation of drilling cuttings, in a highly localized area. Effects on benthic organisms are expected to be limited to a relatively small area around the drilling rig and to last for only a short time period. Other smaller areas of seabed disturbance will occur as a result the anchors of the drilling rig on the seabed, however they are relatively small in relation to the extent of the cuttings pile.

Benthic impact in the immediate footprint of the drilling operations. No sensitive habitats identified.

The habitats identified have a high recoverability to the proposed disturbance

Providence will ensure that all wastes generated during the survey are adequately segregated in order that an appropriate onshore treatment and/or disposal route may be selected. As far as reasonably practicable. All material brought ashore will be sent for recycling or re-use.

Operations Manager

Solid Wastes Wastes may include domestic refuse, scrap metals and packaging.

An HSE audit of the vessel will be carried out prior to commencing operations, this will include a review of waste management practices on board.

Operations Manager

Negligible

Spill Risk Risk of spill of fuel from collision or offshore refuelling.

The Rig and support vessels have an externally certified Shipboard Oil Pollution Emergency Plan (SOPEP) as required under the 1973/1978 MARPOL Convention and robust offshore refuelling procedures.

On oil Spill Contingency Plan has been prepared and is included in this application.

Operations Manager

Negligible


MGE0282RP002F01 61

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