Valero Energy Ltd
Ecological Impact Assessment – Cogen Project
Doc Ref: Cogen/DNS/ EcIA/C01
Final for Submission
June 2017 www.erm.com
Valero Energy Ltd
Ecological Impact Assessment– Cogen Project: Final for Submission
Doc Ref: Cogen/DNS/ EcIA/C01
June 2017
Prepared by: Naomi Shepherd
Technical review: Les Hatton
For and on behalf of Environmental Resources Management
Approved by: Geraint Bowden
Signed:
Position: Partner
Date: 21-06-2017
This report has been prepared by Environmental Resources Management the trading name of Environmental Resources Management Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client.
We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.
This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.
Environmental Resources Management Limited Incorporated in the United Kingdom with registration number 1014622 Registered Office: 2nd Floor, Exchequer Court, 33 St Mary Axe, London, EC3A 8AA CONTENTS
GLOSSARY
EXECUTIVE SUMMARY
1 INTRODUCTION 1
1.1 THE PROJECT 1 1.2 ECOLOGICAL IMPACT ASSESSMENT REPORT 1 1.2.1 Planning Policy and Legislation 2
2 METHODOLOGY 3
2.1 SCOPE OF THE ASSESSMENT 3 2.1.1 Zone of Influence 3 2.1.2 Consultation to Determine Scope of Assessment 3 2.2 DESK STUDY 4 2.3 FIELD SURVEYS 5 2.3.1 Extended Phase 1 Habitat survey 5 2.3.2 Bat survey 6 2.3.3 Badger survey 11 2.4 ASSESSMENT METHODOLOGY 12 2.4.1 Ecological Impact Assessment 12 2.4.2 Habitat Regulations Assessment 17 2.4.3 Air Quality Assessment for SSSIs and Ancient Woodland 18 2.4.4 Ecosystem Resilience Assessment 20
3 ECOLOGICAL BASELINE 21
3.1 SITE LOCATION AND GENERAL ECOLOGICAL CONTEXT 21 3.2 DESIGNATED SITES 21 3.2.1 Statutory and Non-statutory Designated Sites for Nature Conservation 21 3.3 HABITATS 22 3.3.1 Overview 22 3.3.2 Ancient Woodland and Priority Habitats 22 3.3.3 Local Biodiversity Action Plan habitats 23 3.3.4 Habitats within the Project Site 23 3.3.5 Ruderal vegetation 25 3.3.6 Notable plant species 27 3.3.7 Invasive plant species 27 3.4 FAUNA AND FLORA 28 3.4.1 Overview 28 3.4.2 European Protected Species 28 3.4.3 Nationally Protected Species 33 3.4.4 Summary of Ecological Baseline 37
4 ECOLOGICAL IMPACT ASSESSMENT 39
4.1 PROJECT DESCRIPTION 39 4.2 IMPACT ASSESSMENT 39 4.2.1 Designated sites 40 4.2.2 Habitats within the site and immediate vicinity 42 4.2.3 Species and species groups 43 4.2.4 Summary of Mitigation 46 4.3 RESIDUAL IMPACTS 46
5 CUMULATIVE AND IN-COMBINATION EFFECTS 47
5.1 CONSTRUCTION 47 5.1.1 Badgers 47 5.1.2 Bats 47 5.1.3 Birds 48 5.2 OPERATION 48 5.2.1 Air Quality 48 5.2.2 Bats 48
6 ENHANCEMENT AND MONITORING 50
7 ECOSYSTEM RESILIENCE ASSESSMENT 51
7.1 INTRODUCTION TO ECOSYSTEM RESILIENCE 51 7.2 SCOPE OF THE ECOSYSTEM RESILIENCE ASSESSMENT 52 7.3 ECOSYSTEM RESILIENCE ASSESSMENT 52 7.4 SUMMARY OF ECOSYSTEM RESILIENCE ASSESSMENT 56
ANNEXES
ANNEX A FIGURES ANNEX B LEGISLATION & PLANNING POLICY ANNEX C DESK STUDY AND CONSULTATION ANNEX D TARGET NOTES ANNEX E BADGER SURVEY RESULTS ANNEX F PHOTOGRAPHS ANNEX G EFFECTS OF AIR QUALITY ON SITES OF SPECIAL SCIENTIFIC INTEREST
GLOSSARY
Term/Abbreviation Definition > Greater than AA Appropriate Assessment AoI Area of Influence APIS Air Pollution Information System AW Ancient Woodland AWI Ancient Woodland Inventory BAP Biodiversity Action Plan BSBI Botanical Society of the British Isles CBD Convention on Biological Diversity CEMP Construction Environmental Management Plan CEMS Continuous Environmental Monitoring System CHP Combined Heat and Power CIEEM Chartered Institute of Ecology and Environmental Management CL Critical Load/Level Cogen Cogeneration plant cSAC Candidate Special Area of Conservation cSSSI Candidate Site of Special Scientific Interest CSZ core sustenance zones for foraging bats CTG combustion turbine generator Demin unit Demineralisation unit DNS Development of National Significance under Part 5 of the Planning (Wales) Act 2015 EC European Commission EcIA Ecological Impact Assessment ecosystem The term ecosystem refers to a community of plants, animals and smaller organisms that live, feed and reproduce in a specific area and the way in which these communities interact with other non-living elements such as the weather, water and soils. Ecosystem Resilience An assessment which follows the National Assembly for Wales Assessment Guidance and identifies the ecosystems present and how they will be likely to be affected EIA Environmental Impact Assessment ERM Environmental Resources Management Ltd EU European Union Extended Phase 1 An assessment of habitats and features of ecological interest within Habitat Surveys the Survey Area. They were based on Extended Phase 1 methodology and included the mapping of broad habitat types and identification of any notable features
EZoI Ecological Zones of Influence ha hectares HAP Habitat Action Plan HRA Habitat Regulations Assessment HRSG Heat Recovery Steam Generator KgN/ha/yr Kilograms of nitrogen per hectare per year km kilometres kV kilovolt LBAP Local Biodiversity Action Plan LWS Local Wildlife Sites m meters MWe megawatts electrical NERC Act 2006 Environment and Rural Communities Act 2006 NNR National Nature Reserve NRW Natural Resources Wales p Ramsar site Proposed Ramsar site
Term/Abbreviation Definition PC process contribution PCC Pembrokeshire County Council PEC Predicted Environmental Concentration PINS Wales Planning Inspector Wales pSPA Proposed Special Protection Area Ramsar site A Ramsar Site is a wetland site designated of international importance under the Ramsar Convention. The Convention on Wetlands, known as the Ramsar Convention, is an intergovernmental environmental treaty established in 1971 by UNESCO, and coming into force in 1975 SAC Special Area of Conservation Section 7 List of Living Section 7 of the Environment (Wales) Act 2016 list of the living Organisms of Principal organisms of principal importance for the purpose of maintaining and Importance enhancing biodiversity in relation to Wales. Section 7 List Priority Section 7 of the Environment (Wales) Act 2016 list of the habitats of Habitats principal importance for the purpose of maintaining and enhancing biodiversity in relation to Wales. SPA Special Protection Area SSSI Site of Special Scientific Interest TAN Technical Advice Note UK United Kingdom Valero Valero Energy Ltd WPD Western Power Distribution WWBIC West Wales Biodiversity Information Centre
EXECUTIVE SUMMARY
This report details the findings of an Ecological Impact Assessment (EcIA) of the proposed Cogeneration (Cogen) project (the Project) at Valero Energy Ltd’s (Valero) Refinery in Pembrokeshire, Wales.
The purpose of the EcIA is to identify and describe all potentially significant ecological effects associated with the Project. The EcIA sets out the mitigation measures required for compliance with nature conservation legislation, addresses potentially significant ecological effects and provides an assessment of the significance of any residual effects.
The baseline of the EcIA has been informed by an ecological desk study, consultation and a series of ecological field surveys including Extended Phase 1 Habitat Surveys, bat surveys and badger surveys, undertaken between August 2016 and February 2017.
The EcIA has been undertaken in accordance with standard assessment methods and criteria as set out in the Chartered Institute of Ecology and Environmental Management, (CIEEM) (2016) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd Edition (1).
A Habitat Regulations Assessment (HRA) has also been undertaken, due to the proximity of the Project to European Sites, and is reported separately (Doc Ref: Cogen/DNS/HRA/C01). In addition to the HRA, a similar assessment has been undertaken within this report for national level designated sites, including SSSIs and for other sensitive habitats including ancient woodlands to determine likely effects from air pollutants.
An Ecosystem Resilience Assessment also forms part of the assessment. This assessment follows the National Assembly for Wales Guidance (2) and identifies the ecosystems present and how they will be likely to be affected.
The EcIA concludes that there are no significant residual impacts on ecological features due to the construction or operation of the Project either directly or indirectly, alone or in combination with other Projects. The Ecosystems Resilience Assessment concluded that the ecosystems and their components parts identified within the Project either will not be affected, or are resilient to disturbance, resist damage, and if damaged will recover quickly.
(1) http://www.cieem.net/data/files/Publications/EcIA_Guidelines_Terrestrial_Freshwater_and_Coastal_Jan_2016.pdf
(2)http://www.assembly.wales/Research%20Documents/Ecosystems%20and%20the%20Ecosystem%20Approach%20- %20Quick%20guide-08032012-231338/qg12-0006-English.pdf
1 INTRODUCTION
1.1 THE PROJECT
Valero Energy Ltd (Valero) is developing a Cogeneration (Cogen) project (the Project) to provide the Refinery’s electrical power and supplement steam requirements. The Cogen plant will produce up to 49.9 megawatts electrical (MWe) output from the combustion of natural gas in a combustion turbine generator (CTG). Superheated steam will be generated via a heat recovery steam generator (HRSG). This will require connections to the Refinery’s steam infrastructure, as well as to natural gas and electrical distribution systems. All the elements of the Project are within the existing Refinery boundaries.
The Project is classified as a Development of National Significance (DNS) under Part 5 of the Planning (Wales) Act 2015 (henceforth, the Act) as it is a generating station with an installed generating capacity of between 10 and 50 MWe. It will therefore be consented under the DNS regime.
1.2 ECOLOGICAL IMPACT ASSESSMENT REPORT
This report details the findings of an Ecological Impact Assessment (EcIA) undertaken by Environmental Resources Management Ltd (ERM). This report identifies potentially significant ecological effects associated with the Project at the Refinery, as shown at Annex A – Figure A.1 Map of Site Location.
Previous reporting undertaken by ERM relevant to this assessment includes:
Extended Phase 1 Habitat Survey produced by ERM dated December 2016 and subsequent survey work. This EcIA report details the relevant findings of the Extended Phase 1 Habitat surveys commissioned by Valero and undertaken on 17 August 2016 and 25 October 2016.
The purpose of this report is:
To identify and describe all potentially significant ecological effects associated with the proposed development;
To set out the mitigation measures required for compliance with nature conservation legislation and to address any potentially significant ecological effects;
To identify how mitigation measures will/could be secured; and
To provide an assessment of the significance of any residual effects.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 1
1.2.1 Planning Policy and Legislation
Relevant National and Local biodiversity planning policies
The Project is classified as a Development of National Significance (DNS) under Part 5 of the Planning (Wales) Act 2015 (henceforth, the Act) as it is a generating station with an installed generating capacity of between 10 and 50 MWe. It will therefore be consented under the DNS regime.
The planning policies relevant to this assessment are provided in Annex B – Legislation and planning policy.
Biodiversity Action Plans and species lists
The biodiversity action plans and species lists relevant to this assessment are provided in Annex B – Legislation and planning policy.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 2 2 METHODOLOGY
2.1 SCOPE OF THE ASSESSMENT
2.1.1 Zone of Influence
Ecological Zones of Influence (EZoI) for a project are the areas over which ecological features may be subject to significant effects as a result of the proposed project and associated activities. The zone of influence will vary for different ecological features depending on their sensitivity to an environmental change. It may be appropriate to identify different zones of influence for different features.
For the Project the EZoI have been defined as follows:
• For most species and habitats an EZoI of the redline boundary plus 250m buffer, based on potential noise and disturbance impacts has been used.
• For bat species which are the designating feature of European designated sites, and European designated sites which may potentially be sensitive to changes in air quality, the EZoI has been agreed through consultation with Natural Resources Wales (NRW) as 15km.
• For SSSIs and Ancient woodland sites which may potentially be sensitive to changes in air quality, the EZoI has also been agreed as 15km for SSSIs and 2km for ancient woodland sites.
• For the Ecosystem Resilience Assessment the EZoIs identified above will also be relevant for each receptor.
2.1.2 Consultation to Determine Scope of Assessment
The following consultation has taken place in relation to determining the scope of the assessment:
• A request for Screening Direction in relation to the requirement for an Environmental Impact Assessment (EIA) was submitted in December 2016. The negative screening direction was issued on 17 January 2017, and as such an EIA is not a requirement of the DNS application.
• A scoping report was submitted on the 27 January 2017. Responses received confirmed the ecological approach to be taken and receptors to be included in the assessment. NRW identified some lichen rich communities requiring consideration and sites and species to be considered in the Habitats Regulations Assessment.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 3 • A site meeting was held on 15 February 2017 with NRW consultees representing planning, habitats and permitting to discuss and agree the scope of air quality modelling for the Habitat Regulations Assessment (HRA). During the meeting it was also agreed that SSSIs within 15km and Ancient woodland within 2km would be included in Stage 1 screening.
2.2 DESK STUDY
The West Wales Biodiversity Information Centre (WWBIC) was contacted in August 2016 to provide information on statutory and non-statutory designated sites, habitats and species of importance for nature conservation within a 2 km radius of the centre of the Survey Area (centred on grid reference SM 90506 02506) (see Annex A – Figure A.2 Map of Statutory And Non Statutory Nature Conservation Sites). Biological data was provided by WWBIC on the 31 August 2016.
The Pembrokeshire Biodiversity Partnership was contacted and provided copies of relevant Local BAPs.
In addition, the following individuals or organisations have been contacted to provide further data:
• NRW in relation to data for designated sites and habitats with potential sensitivity to air quality changes;
• local bat group;
• local bird recorder;
• local amphibian and reptile group;
• local badger group;
• county BSBI recorder;
• local bird ringing group; and
• biodiversity data collected by the Refinery for their biodiversity action plan.
Details of the information provided are listed in Annex C –Desk study and consultation.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 4 The following websites have also been used to inform the EcIA:
• NRW online mapping tool (1); and • Forestry Commission Ancient Woodland Inventory (AWI) (2).
2.3 FIELD SURVEYS
2.3.1 Extended Phase 1 Habitat survey
Extended Phase 1 Habitat Surveys of accessible areas of the site and immediate surrounds were undertaken by ERM on 17 August 2016 and on 25 October 2016, during suitable weather conditions.
The surveyed area included the extent of the potential siting options, laydown areas, substations and pipe runs as at the time of survey, as indicated at Annex A – Figure A.3 Map of Wider Survey Area. This area included the full extent of the DNS application. The habitats surveyed are shown at Annex A – Figure A.4 Extended Phase 1 Habitat Survey Map. Descriptions relevant to the Project site are included in the subsequent sections of this report. Annex D – Target Notes includes Target Notes from the Extended Phase 1 Habitat Surveys, and descriptions of habitats surveyed which lie outside the Project site, within the wider survey area.
The objective of the Extended Phase 1 habitat surveys were to carry out an assessment of habitats and features of ecological interest within the Survey Area. They were based on Extended Phase 1 methodology (3) and included the mapping of broad habitat types and identification of any notable features.
The surveys included searching for signs of fauna and areas of habitat that might be suitable for protected, notable or rare species in order to identify the need for any further protected species surveys and to inform potential mitigation requirements. A tablet computer was used to record survey findings and a tablet computer and camera were used to take photographs. Additional field notes were also recorded in a notepad during the survey.
There were operational constraints on access to some areas within the Survey Area; this is not considered a limitation to the survey results, as those areas were visible from vantage points. In addition, due to the industrial nature of the refinery it is considered likely that these areas were similar to those surveyed in detail.
(1) https://naturalresources.wales/conservation-biodiversity-and-wildlife/find-protected-areas-of-land-and- seas/designated-sites-search/?lang=en (2) http://maps.forestry.gov.uk/imf/imf.jsp?site=fcwales_ext& (3)Joint Nature Conservation Committee (2010) Handbook for Phase 1 Habitat Survey - A Technique for Environmental Audit, Joint Nature Conservation Committee (JNCC), Peterborough.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 5 The plantation woodland and embankment on the southern boundary were only partially accessible for survey due to dense vegetation and the steepness of the embankment. Mammal pathways were followed as far as was feasible.
2.3.2 Bat survey
As part of the initial assessment small numbers of lesser horseshoe bats (Rhinolophus hipposideros) were discovered roosting in the main substation (Building B12). The building is a critical part of the existing infrastructure and after a site meeting on 17 January 2017 with NRW’s species team it was agreed that a European protected species licence application would be made to exclude bats on urgent health and safety grounds. This licence application (75593 Valero, Pembrokeshire) has been approved by NRW. The appropriate mitigation has been completed and bats excluded from the substation. This includes a change of use of a dwelling and conversion into a permanent bat roost in Rhoscrowther. Surveys to inform this licence application form part of the baseline but this EcIA impact assessment is based on the roost being relocated to Rhoscrowther.
Bat records for the site and surrounding area (up to 2km) were requested from WWBIC, and the local bat group was consulted for any local records of lesser and greater horseshoe bats (Rhinolophus ferrumequinum) .
Bat surveys were undertaken in accordance with the Bat Conservation Trust’s Good Practice Guidelines (1) (2016).
Initial building assessments
A bat building assessment, including external and internal visual assessments, was undertaken by licenced bat ecologists from Biodiversity Solutions on 25 August 2016 to assess the potential for 17 buildings within the wider survey area to support roosting bats. Annex F - Extended Phase 1 Habitat Survey Map shows the building locations.
Evidence of bat activity, and the potential for any structures such as buildings and trees to support a bat roost, was searched for during the inspection survey. Any suitable roosting, foraging and commuting habitat were also recorded during the survey. Evidence of bat activity is usually detected by the following signs:
bat droppings (these will accumulate under an established roost); insect wings (from feeding); oil (from fur) and urine stains; scratch marks; and
(1) Collins, J (end). 2016. Bat survey for Professional Ecologists. Good Practise Guidelines. Bat Conservation Trust.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 6 actual sightings (including corpses).
The inspections were carried out using appropriate torches, endoscopes and a thermal imager and all areas deemed safe to access were surveyed.
The information gathered allowed the buildings to be classified as having high, moderate, low or negligible potential to support bats roosts based upon the number and quality of features present, and the buildings position in relation to the surrounding environs.
Tree assessment
A tree assessment was undertaken on 2 November 2016 by Biodiversity Solutions to identify whether the trees along the southern mixed plantation woodland embankment supported suitable features for roosting bats.
The trees were studied from the ground using binoculars and an endoscope to examine any cracks or crevices for their suitability for, or evidence of, roosting bats. The trees were inspected from both sides of the tree focusing on broken branches, large canker areas and other damage which may provide cavities.
Emergence surveys
The initial building inspection identified two buildings with low potential, old stores, and bulk store (B5 and B9), one with confirmed activity, the electrical workshop (B2) and one confirmed roost within the substation (B12). Building numbers and locations are shown in Annex F: Phase 1 Habitat Map.
Emergence surveys on these buildings were undertaken from 25 September 2016 to the 30 September 2016. The electrical workshop (B2) was resurveyed on 31st May, the old stores (B5) was resurveyed on 14th June and the bulk store (B9) were re-surveyed 2nd June 2017 as the earlier surveys were not within the main maternity season.
The surveys started 15 minutes before sunset and continued for up to two hours after sunset. Anabat SD2’s were used on all surveys to record bat passes. Handheld detectors; Batbox duet, Echometer touch, Pettersson and Magenta were also used.
These surveys were complemented with static detector deployment within the buildings as well as the use of a thermal imaging camera. Two wildlife camera traps were used within the confirmed bat roost in the substation. The static bat detectors are useful for gaining information on late emerging species that often fly around inside the roost prior to emergence. Caution should be exercised in using static detectors as they can detect bats flying outside the building.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 7 Thermal imaging cameras increase the precision in presence/absence surveys because bats are less likely to be missed if the camera is pointed at the relevant access points.
Table 2.1 Survey dates and conditions of emergence surveys
Date Survey Location Time Sunset Weather type 22 September 16 Emergence Electrical 1900- 1917 14oC, wind 11mph: Dry. workshop (B2) 2200 52percent cloud, 69percent humidity.
23 September 16 Emergence Main substation 1900- 1911 16oC, wind 20mph: Dry (B12) 2100 with light rain at end of survey. 99percent cloud: 84percent humidity.
29 September 16 Emergence Old stores (B5) 1845- 1901 13oC, wind 17mph: Dry. 2045 51percent cloud: 87percent humidity.
30 September 16 Emergence Bulk store (B9) 1844- 1859 11oC, wind 10mph: Dry. 2045 46percent cloud, 81percent humidity.
19 October 2016 Emergence Electrical 1800- 1816 11.7oC, wind 9mph NNW: workshop (B2) 1930 Dry.
26 October 2016 Emergence Old stores (B5) 1745- 1802 12.8oC, wind 9mph W: 1932 Dry.
27 October 2016 Emergence Bulk store (B9) 1745- 1801 13.9oC, wind 13mph 1931 WSW: Dry.
31 October 2016 Emergence Main substation 1635- 1653 12.7oC, wind 11mph ESE: (B12) 1820 Dry. 31st May 2017 Emergence Electrical 2115- 2128 12oC, wind 8 mph SSW; workshop (B2) 2330 Dry. 2nd June 2017 Emergence Bulk store (B9) 2115- 2130 14oC, wind 7mph SW; 2330 Dry. 14th June 2017 Emergence Old stores (B5) 2120 - 2140 14oC, wind 7mph SW; 2348 Dry
Static detector placement
Static detectors were used to complement the emergence surveys and to provide roost information on the confirmed bat roost. The statics recorded from 30 minutes prior to sunset, throughout the night, until 30 minutes after sunrise.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 8 Table 2.2 Static detector deployments
Electrical workshop (B2) Date Survey type Nights deployed 22 September to 3 October 2016 Static 11 19 October to 1 November 2016 Static 13 8 November to 30 November 2016 Static 22 1 December to 31 December 2016 Static 30 31 May to 7 June 2017 Static 8
Old stores (B5) Date Survey type Nights deployed 22 September to 3 October 2016 Static 11 19 October to 1 November 2016 Static 13 1 to 7 June 2017 Static 7
Bulk stores (B9) Date Survey type Nights deployed 22 September to 3 October 2016 Static 11 19 October to 1 November 2016 Static 13 1 to 7 June 2017 Static 7
Substation (B12) Date Survey Location Nights type deployed 22 September to 3 October 16 Static Main substation (B12) 11
19 October to 1 November 16 Static Main substation (B12) 13 19 October to 1 November 16 Static South cellar in main substation (B12) 13 19 October to 1 November 16 Static East cellar in main substation (B12) 13 8 November to 30 November 16 Static Main substation (B12) 22 8 November to 30 November 16 Static South cellar of main substation (B12) 22
8 November to 30 November 16 Static East cellar of main substation (B12) 22
1 December to 31 December 16 Static Main substation (B12) 30 1 December to 31December 16 Static South cellar of main substation (B12) 30 1 December to 31 December 16 Static East cellar of main substation (B12) 30 1 to 31 January 17 Static Main substation (B12) 30 1 to 31 January 17 Static South cellar of main substation (B12) 30 1 to 31 January 17 Static East cellar of main substation (B12) 30 1 to 28 February 17 Static Main substation (B12) 28 1 to 28 February 17 Static East cellar of main substation (B12) 28 1 to 28 February 17 Static South cellar of main substation (B12) 28
Internal building inspections were undertaken when visiting the static detectors to download data or replace batteries.
Two static detectors were also deployed at Fort Popton hibernacula to understand bat activity during the hibernation season. The statics were placed for 31 nights in January 2017 and for 28 nights in February 2017. The detectors recorded activity predominantly of greater horseshoe bats with
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 9 occasional passes of lesser horseshoe bats in the months of January and February 2017.
Bat roost characterisation surveys
When presence is established, roost characterisation surveys should be undertaken if sufficient data has not been collected to inform the impact assessment and design of mitigation measures.
Activity surveys
Activity surveys were undertaken along the southern mixed plantation woodland embankment and trees to identify whether it was used by commuting and foraging bats and if it provided an important feature for roosting bats. The high earth bank with trees and scrub on provides a sheltered area suitable for foraging bats and a suitable flight corridor for commuting bats.
The rest of the Refinery site did not support habitat that was deemed suitable for commuting and foraging bats as it is a well-lit, highly industrial with minimal vegetation.
The aims of the activity surveys were to identify:
the assemblage and abundance of bat(s) present; the location of bat flight corridors; and the presence of any core sustenance zones (CSZ).
Walked transects were undertaken along the southern mixed plantation woodland embankment during September and October and these walked transects were supplemented by static bat detectors which were put in place from November 2016 and will remain in place until June 2017.
Table 2.3 Survey data for walked activity transect along southern hedge bank
Date Time Sunset Weather 22 September 2016 1900- 2200 1917 14oC, wind 11mph: Dry. 52percent cloud, 69percent humidity.
Table 2.4 Static detector deployment and locations
Date Survey Location Nights type deployed 19 October 2016 to 1 Static Between main substation (B12) cellar and hedge. 13 November 16 One microphone within the hedge. 1 to 30 November 16 Static Between main substation (B12) cellar and hedge. 30 One microphone within the hedge. 1 to 30 November 16 Static Shelter-belt east. 30 1 to 30 November 16 Static Shelter-belt west. 30
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 10 Date Survey Location Nights type deployed 1 to 31 December 16 Static Between main substation (B12) cellar and hedge. 31 One microphone within the hedge. 1 to 31December 16 Static Shelter-belt east. 31 1 to 31December 16 Static Shelter-belt west. 31 1 to 31 January 17 Static Between main substation (B12) cellar and hedge. 31 One microphone within the hedge. 1 to 31January 17 Static Shelter-belt south-east. 31 1 to 31 January 17 Static Shelter-belt west. 31 25 to 31 January 17 Static Shelter-belt south-west end. 7 25 to 31 January 17 Static Shelter-belt south-east end. 7 1 to 28 February 17 Static Between main substation (B12) cellar and hedge. 28 One microphone within the hedge. 1 to 28 February 17 Static Shelter-belt south-east on bank. 28 1 to 28 February 17 Static Shelter-belt west. 28 1 to 28 February 17 Static Shelter-belt south-west end. 28 1 to 28 February 17 Static Shelter-belt south-east end. 28
Deviations/limitations
The walked transect surveys were conducted in September 2016. Standard guidance (BCT 2016) suggests that surveys in habitat with low suitability should be visited once per season (spring, summer and autumn). However, due to the proximity of the Refinery which is considered sub-optimal habitat for bats and retention of the existing vegetated embankment, the data gathered are considered to be sufficient to demonstrate the levels of bat activity along the hedgerow.
For static detector placement on activity surveys, standard guidance suggests that surveys are undertaken at one point on the transect for five nights during each season (spring, summer and autumn). Owing to the microclimate present on the site, these methods were adapted to provide information on how bats are using the southern mixed plantation woodland embankment throughout the autumn and winter period.
There are limitations when surveying for bats using ultrasonic detectors due to the variable properties in bat echolocation calls. Some bats, including brown long-eared bat (Plecotus auritus), have very directional and quiet calls and are only easily detectable when the bat detector is in close range and facing in the direction of the bat. Data analysis has allowed for identification of the majority of the calls to species level with the exception of Myotis species.
2.3.3 Badger survey
A badger (Meles meles) survey was conducted by ERM on 7 February 2017 and consisted of a systematic walkover of all suitable habitats in the Project site and within 100m of the site to obtain records of the following: setts; hairs;
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 11 badger paths/runs; mammal paths (possible badger); foraging signs; latrines; footprints; bedding material; and evidence of rabbit and fox.
For all setts identified during the walkover survey, entrances and the orientation of entrance holes were mapped. The setts were classified against the criteria laid out in Harris et al (1989) (1) as either a ‘main’, ‘annexe’, ‘subsidiary’ or ‘outlying’ sett. The level of use for each entrance was classified as either ‘active’, ‘partially active’ or ‘disused’.
The location and current use of any large entrances not currently utilised by badger were be recorded, in order that these entrances can be monitored for future use during the period up to construction.
A tablet computer was used to record survey findings and a tablet computer and camera were used to take photographs. In areas where topography and vegetation structure may have reduced the accuracy of recording this was noted as a constraint.
The results of the badger survey are shown at Annex E – Badger Survey Results Map. Descriptions included in the subsequent sections of this report and at Annex A – Figure A.5 Badger Survey Results.
2.4 ASSESSMENT METHODOLOGY
2.4.1 Ecological Impact Assessment
Methodology
The ecological impact assessment is undertaken in accordance with standard assessment methods and criteria as set out in the Chartered Institute of Ecology and Environmental Management, (CIEEM) (2016) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd Edition (2).
Defining the baseline
Ecological baseline conditions are those existing in the absence of proposed activities.
The baseline at the time of survey and assessment is not expected to change prior to the Project commencing. The habitats within the site are not expected to change, and therefore the species use of these habitats is likely to remain
(1) Harris, S., Cresswell, P., and Jefferies, D. (1989). Surveying Badgers. Occasional publication of the Mammals Society. 56 Protection (2) http://www.cieem.net/data/files/Publications/EcIA_Guidelines_Terrestrial_Freshwater_and_Coastal_Jan_2016.pdf
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 12 constant. No other factors which could potentially affect the ecological baseline are known about at the time of assessment.
The only exception is in relation to use by bats of a building (a substation). During baseline surveys lesser horseshoe, greater horseshoe and common pipistrelle (Pipistrellus pipistrellus) bats have been recorded in a main substation. A European protected species licence application has been made to exclude bats on urgent health and safety grounds. This licence application (75593 Valero, Pembrokeshire) has been approved by NRW. The appropriate mitigation has been completed and bats excluded from the substation.
Baseline value
Each potential ecological receptor has been evaluated against the following geographical frames of reference: international; national; regional; county; district/borough; local/parish; and negligible. The criteria for the evaluations are provided in Table 2.5 below.
Table 2.5 Criteria for baseline ecological value
Value of ecological resource Criteria and rationale for value International An internationally designated site or candidate/proposed site (SPA, pSPA, SAC, cSAC, pSAC and/or Ramsar site, pRamsar site).
A sustainable area of a habitat which is significant at an international level and which is capable of meeting the criteria for designation as a site of international importance.
A sustainable population of a species which is significant at an international level.
National A nationally designated site (SSSI, NNR, Marine Nature Reserve).
A sustainable area of a habitat which is significant at a national level and which is capable of meeting the criteria for designation as a site of national importance.
A sustainable population of a species which is significant at a national level.
Regional Sites/populations which exceed the County or Metropolitan- level designations but fall short of SSSI selection guidelines.
A sustainable population of a species which is significant at a regional level.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 13 Value of ecological resource Criteria and rationale for value County Some locally designated sites (including Local Wildlife Sites and Sites of Metropolitan Importance for nature conservation).
A sustainable area of a habitat which is significant at a county level and which is capable of meeting the criteria for designation as a site of county importance.
A sustainable population of a species which is significant at a county level.
Local Sites/populations, which appreciably enrich the immediate vicinity habitat resource (eg moderately species-rich hedgerows).
Negligible Habitats or species populations that do not appreciably enrich the ecological value of the immediate vicinity.
N.B. Local Nature Reserves may be of value at a range of geographic levels and professional judgement should be applied based on consideration of the specific features for which the site is designated.
Impact types
Potential impacts resulting from construction or operational activities for the Project are shown in Table 2.6.
Table 2.6 Impact types for construction and operation
Impact type Construction/ Scoping status Justification Operation/ Both Habitat loss due to Construction Scoped in Further assessment required temporary and permanent land take required for the land clearance and construction of the Cogen plant and associated infrastructure;
Disturbance from Both Scoped in Further assessment required changes in the noise and visual environment and changes in lighting
Air pollutants Both Scoped out for Construction - included construction within the Construction Environmental Management Plan (CEMP)
Scoped in for Operation – further operation assessment required
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 14 Impact type Construction/ Scoping status Justification Operation/ Both Dust deposition Construction Scoped out Part of the standard Valero operational management of Introduction of non- Construction Scoped out environmental risks and are native invasive species included within the Construction Environmental Accidental pollution Both Scoped out Management Plan (CEMP) for the Project
Hydrological effects, Both Scoped out The Geology and Hydrology from changes in water Report (1) concludes that the levels and/or flows as existing pollution controls these will be addressed measures are sufficient and by existing site no environmental risk is drainage; and expected. The report also concludes there will be no Effects on groundwater changes to the hydrological and any habitats reliant regime, including ground on them. water flows as a result of the construction or operation of Risk of water quality the Project changes from surface water runoff;
When describing ecological impacts consideration has been made of the following characteristics:
• positive or negative; • extent; • magnitude; • duration; • timing; • frequency; and • reversibility.
Impact significance
The approach to the impact significance is one of identifying whether effects are negative or positive, are they significant, or not significant on each biodiversity feature, and if so at what geographical level. The assessment of significance follows a matrix approach. The matrix approach considers the anticipated magnitude and effect on that feature against the value / sensitivity of the biodiversity feature as established during the baseline. Under certain circumstances, the value of a habitat, or species, may be upgraded (from
(1) ERM, 2017, Doc Ref: Cogen/DNS/Geo/B01 Geological, Hydrogeological, Hydrological and Land Condition Impact Assessment (2) http://gov.wales/docs/desh/publications/160330-dns-appendix-4-habitats-regulations-assessment-en.pdf
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 15 medium to high), for example if especially large numbers of a vulnerable species could be impacted.
Table 2.7 provides definitions of how the magnitude of impacts is determined, whilst Table 2.8 defines the determination of receptor sensitivity.
Table 2.7 Magnitude
Magnitude Criteria for Magnitude of Impact Positive impact An enhancement of some ecosystem or population parameter. Slight damage or loss over small area and/or temporary and reversible. Negligible Impacts unlikely to be discernible or measurable. impact No contribution to transboundary or cumulative impacts. Minor environmental damage, but no lasting impacts. Change in habitats or species which can be seen and measured but is at Small impact same scale as natural variability. Unlikely to contribute to transboundary or cumulative impacts. Environmental damage that will persist or require mitigation. Widespread change in habitats or species beyond natural variability Medium impact with recovery likely within 1-2 years following cessation of activities, or localized medium-term degradation with recovery in 2-5 years. Possible minor transboundary and cumulative impacts. Severe environmental damage that will require extensive measures to restore beneficial uses of the environment. Widespread degradation to the quality or availability of habitats and/or wildlife requiring significant long-term restoration effort. Large impact Recovery not expected for an extended period (>5 years following cessation of activity) or that cannot be readily rectified. Transboundary impacts or contribution to cumulative impacts anticipated.
Table 2.8 Sensitivity
Sensitivity Criteria for sensitivity Receptor with low value or importance attached to them, eg habitat or species Low which is abundant and not of conservation significance. Receptor of national importance, eg recognised as an area/species of potential Medium conservation significance and protected under national legislation such as a Schedule 1 bird species or an SSSI. Receptor of key importance eg recognised as an area/species of European High conservation significance with development restrictions for example European protected sites (SPA’s/SAC’s/Ramsar) or Annex I habitats or Annex IV species.
The next step in the assessments is to take the information on the magnitude of impacts, and explain what this means in terms of its importance. This step is referred to as the ‘evaluation of significance’ and it is one of the most important, and subjective, parts of the process. Magnitude of impact and sensitivity / importance of the receptor are assessed in combination to
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 16 evaluate whether an impact is significant and, if so, its degree of significance as is illustrated in Table 2.9.
Table 2.9 Evaluation of Significance
Sensitivity
Low Medium High
Positive Impact Positive Positive Positive
Negligible Negligible Negligible Negligible
Small Negligible Minor Moderate
Magnitude Medium Minor Moderate Major
Large Moderate Major Major
Project timescales:
The construction and commissioning period is anticipated to take 18 months to 2 years, with operation commencing before the end of 2019. No decommissioning date of the Project is specified and any decommissioning of the Project will be assessed as and when required.
2.4.2 Habitat Regulations Assessment
A HRA (Doc Ref Cogen/DNS/HRA/C01) has been undertaken as part of the DNS application, due to the proximity of the Project to European Sites.
The approach taken follows the guidance set out by PINS Wales (1), and guidance produced by the Defra / Environment Agency (EA) on screening risks from air emissions on protected areas for nature conservation (2). It has also taken account of a range of other guidance material such as the Planning Inspectorate’s Advice Note 10 (3), and guidance that produced by the European Commission (EC) (2011 (4), 2007 (5); 2002 (6), 2000 (7)).
(1) ERM, 2017, Habitat Regulations Assessment of the Proposed Cogeneration Project at Valero Energy Ltd (2) http://gov.wales/docs/desh/publications/160330-dns-appendix-4-habitats-regulations-assessment-en.pdf (3) https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit#screening-for- protected-conservation-areas (4) The Planning Inspectorate (2016) Advice note 10: Habitat Regulations Assessment relevant to nationally significant infrastructure projects (5) European Commission (2011) Guidelines on the Implementation of the Birds and Habitats Directives in Estuaries and Coastal Zones with Particular Attention to Port Development and Dredging. Advice Note 10 EC (6) European Commission (2007) Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC. EC (7) European Commission (2002) Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites. Methodological Guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. EC (8) European Commission (2000) Managing Natura 2000 Sites - The Provisions of Article 6 of the ‘Habitats’ Directive 92/43/CEE. EC
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 17 Key matters which the assessment had to consider are listed below:
Effects of air pollutants emitted by the operating Project on European sites within a 15km radius.
Effects on bats during construction, operation and decommissioning which form part of the qualifying interest of the Pembrokeshire Bat Sites and Bosherston Lakes Special Area of Conservation (SAC), even if they are located outside the SAC boundary.
In-combination effects with other pollution sources.
The European sites included in the assessment due to potential effects of air pollutants emitted by the operating Project are:
Pembrokeshire Marine SAC; Limestone Coast of South West Wales SAC; Castlemartin Coast SPA; West Wales Marine cSAC; Pembrokeshire Bat sites and Bosherston Lakes SAC; Skokholm and Skomer SPA Bristol Channel Approaches cSAC; and Cleddau Rivers SAC.
All other impacts arising from the Project are unlikely to have significant effects due to the lack of connectivity, and/or distance between the European sites and the Project.
The findings of the HRA are summarised in the assessment section.
2.4.3 Air Quality Assessment for SSSIs and Ancient Woodland
In addition to the HRA, a similar assessment has been undertaken within this report for SSSIs and for ancient woodlands.
It has been agreed in consultation with NRW that SSSIs sensitive to air pollution within 15km and ancient woodland sites within 2km are within the scope of the assessment.
The following SSSIs have been scoped out of assessment as they are insensitive to air quality effects:
Orielton Stable Block and Cellars SSSI (bat roost);
Stackpole Courtyard Flats and Walled Garden SSSI (bat roost);
Park House Outbuildings SSSI (bat roost);
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 18
Gas works lane section, Haverfordwest SSSI (Silurian geology);
Shoalshook Railway Cutting and Pit SSSI (geological); and
Minwear wood SSSI (identified by NRW but scoped out as 16.9km from the Project).
Table 2.10 lists those SSSIs that have been scoped in as potentially sensitive to air quality effects.
Table 2.10 SSSIs that have been scoped in as potentially sensitive to air quality effects
SSSI Potentially Sensitive to Air Quality Effects Distance from Project (km) Milford Haven Waterway SSSI 0.6 Broomhill Burrows SSSI 1.5 Castlemartin Corse SSSI 2.6 Angle Peninsula coast SSSI 3.0 Somerton Farm cSSSI1 (candidate SSSI proposed for grassland fungi) 3.1 Castlemartin Range (previously called Castlemartin Cliffs and Dunes SSSI) 3.2 Dale and South Marloes Coast SSSI 8.2 Stackpole SSSI 8.6 Hook Wood SSSI 10.7 Stackpole Quay to Trewent Point SSSI 10.8 St Bride’s Bay South SSSI 10.9 Newgale to Little Haven Coast SSSI 11.2 Freshwater East to Skrinkle Haven SSSI 12.2 Yerbeston moors SSSI 13.2 Western Cleddau River SSSI 13.4 Carew Castle SSSI 13.5 Marloes Mere SSSI 13.6
There are three blocks of ancient semi natural woodland and four blocks of restored ancient woodland within or partially within 2km of the application site (2). These are shown in Table 2.11.
Table 2.11 Ancient woodland within 2 km
Woodland Type Approx. Approx. distance and direction Area (ha) from the Project site (m) Ancient Semi Natural Woodland 0.49 ha 371 m south Restored Ancient Woodland Site 2.92 ha 899 m east Ancient Semi Natural Woodland 0.28 ha 1008 m north east
(1) The recent draft citation received from NRW refers to this site as Gweunydd Somerton Meadows SSSI. However, the site is referred to throughout the report as Somerton Farm SSSI for clarity as this was the original site name used during the consultation process. (2) Forestry Commission Wales website http://maps.forestry.gov.uk/imf/imf.jsp?site=fcwales_ext&, Accessed November 2016
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 19 Woodland Type Approx. Approx. distance and direction Area (ha) from the Project site (m) Restored Ancient Woodland Site 0.56 ha 1255 m north east Restored Ancient Woodland Site 0.76 ha 1277 m south west Restored Ancient Woodland Site 1.65 ha 1482 m north east Ancient Semi Natural Woodland 7.84 ha 1820 m north east
2.4.4 Ecosystem Resilience Assessment
The need to consider ecosystem resilience as specified by the Environment (Wales) Act 2016 also forms part of the assessment. This assessment follows the National Assembly for Wales Guidance (1) and identifies the ecosystems present and how they will be likely to be affected. The assessment then identifies the degree to which the identified ecosystems can respond to any identified disturbance by resisting damage and recovering quickly.
(1)http://www.assembly.wales/Research%20Documents/Ecosystems%20and%20the%20Ecosystem%20Approach%20- %20Quick%20guide-08032012-231338/qg12-0006-English.pdf
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 20 3 ECOLOGICAL BASELINE
3.1 SITE LOCATION AND GENERAL ECOLOGICAL CONTEXT
The Refinery is located approximately 7km west of Pembroke Dock. The Project site is located within the south-west corner of the Refinery. The Project site covers an area of approximately 1.00 ha The Project site includes areas of bare ground and hard standing with buildings, built structures, embankments between the differing levels within the refinery supporting semi-improved neutral grassland and scattered scrub, and a small band of plantation woodland. The Project site is bordered to the north and east by further areas of the existing refinery, while agricultural land is present to the south and west (see Photograph 1 at Annex F – Photographs).
3.2 DESIGNATED SITES
3.2.1 Statutory and Non-statutory Designated Sites for Nature Conservation
The Project site is not located within any statutory or non-statutory nature conservation designations. Statutory designated sites within 2 km of the Project site are listed in Table 3.1. No non-statutory nature conservation designations were identified by the WWBIC data within the 2km search area.
In addition, Pembrokeshire Coast National Park, comprising 62,900 ha, is located adjacent to the Survey Area to the west. The National Park was designated for the special qualities of coastline in this part of Wales.
Table 3.1 Statutory Designated Sites for Nature Conservation within 2 km of the Survey Area (in order of increasing distance from the Survey Area)
Site Name Approx. Approx. distance Reason for Designation Area (ha) and direction from the Project site (km) Pembrokeshire 138,069 ha 0.58km Annex I habitats (qualifying features); Marine SAC sandbanks, Mudflats & sandflats, coastal lagoons, Atlantic salt meadows & Submerged or partially submerged sea caves Annex II species (qualifying features): Grey seal (Halichoerus grypus), Shore dock (Rumex rupestris), Sea lamprey (Petromyzon marinus), River lamprey (Lampetra fluviatilis), Allis shad (Alosa alosa), Twaite shad (Alosa fallax), and otter (Lutra lutra).
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 21 Site Name Approx. Approx. distance Reason for Designation Area (ha) and direction from the Project site (km) Milford Haven 2,192 ha 0.58km west Ancient woodland, saltmarsh, swamp, saline Waterway SSSI lagoons, rare and scarce plants and invertebrates, nationally important numbers of migratory waterfowl, lesser horseshoe bat (Rhinolophus hipposideros ) and otter.
Limestone 1583.86 1.51km south- Annex I habitats (qualifying features); Coast of South Ha west Vegetated sea cliffs of the Atlantic and Baltic West Wales Coasts, Fixed coastal dunes with herbaceous SAC vegetation (‘grey dunes’) Annex II species (qualifying features): greater horseshoe bat (Rhinolophus ferrumequinum), Early gentian (Gentianella anglica).
Broomhill 201.1 ha 1.51km south- One of 'Pembrokeshire's largest dune systems Burrows SSSI west with the most extensive and most diverse dune slack vegetation including species-rich dune grassland and vestigial strandline vegetation occurs on the narrow shingle ridge. Numerous notable plants occur, including scarce lichens while notable insects include several rare beetles, flies, bugs and moths.
Castlemartin 1114 ha 1.84 km south 3.5percent of the GB breeding population of Coast SPA west Chough Pyrrhocorax pyrrhocorax (as of count at 1998)
3.3 HABITATS
3.3.1 Overview
The following sections describe the habitats of the Project site which are illustrated at Annex A –Figure A.4 Extended Phase 1 Habitat Survey Map. Where relevant, habitat types are identified as being of national, county or local importance for the conservation of biodiversity, or of negligible value. Target Notes and descriptions of habitats within the survey area and out with the Project site are presented within Annex D – Target Notes. Photographs of the habitats and features within the Project site are contained within Annex F – Photographs.
3.3.2 Ancient Woodland and Priority Habitats
There are no areas of ancient woodland within or adjacent to the site. There are three blocks of ancient semi natural woodland and four blocks of restored ancient woodland within or partially within 2km of the Survey Area.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 22
Ancient woodlands are potentially susceptible to both acid deposition and nitrogen deposition.
Acid deposition may affect tree health and epiphytic lichen communities, excluding acid sensitive species and causing changes in species composition. Nitrogen deposition can lead to changes in soil processes, nutrient imbalances, and an altered composition in mycorrhiza and ground vegetation.
There are no Section 7 List Priority Habitats within the Survey Area. Hedgerows likely to be Section 7 List Priority Habitat ‘Hedgerows’ are present within the vicinity of the site.
3.3.3 Local Biodiversity Action Plan habitats
Pembrokeshire Local Biodiversity Action Plan (LBAP) habitats within or adjacent to the Survey Area include potential habitats from the Grassland Habitat Action Plan, the Farmland Habitat Action Plan and the Urban / Brown Field / Buildings / Gardens Habitat Action Plan.
Where there are specific habitats within the site which may potentially be LBAP habitats, these are discussed in the relevant habitat sections.
3.3.4 Habitats within the Project Site
Mixed plantation woodland
An area of mixed plantation woodland is present within and extending from the south of the Project site, comprising pine (Pinus spp), sycamore (Acer pseudoplatanus), ash (Fraxinus excelsior) and willow (Salix spp. including Salix fragilis) (see Annex F– Photograph 2 and 3). This plantation woodland was planted from the late 1970s and roughly comprises three lines of planted trees on the southern side of a steep embankment. The embankment reaches up to 5m in height. A number of the trees were wind-blown and had partially or fully fallen over, and a number were not in a good state of health, appearing to have dead limbs. The plantation did not have any understory and the ground flora was dominated by ivy (Hedera helix) and bramble (Rubus fruticosus agg.) and in some places ferns were present including harts tongue (Asplenium scholopendrium) and male fern (Dryopteris filix mas). A series of floodlights are located along the top of the embankment.
The mixed plantation woodland is of limited ecological interest and of at most Local ecological value.
While woodland is a LBAP habitat, the LBAP focusses on the value of semi-natural woodlands, and therefore the small strip of mixed plantation woodland is not considered a LBAP habitat.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 23 Dense / continuous and scattered scrub
Areas of dense / continuous scrub are present on the various embankments within the Project site. These scrub patches are comprised of stands of including hawthorn (Crataegus monogyna), willow, buddleia, gorse, apple (Malus domestica), sycamore (Acer pseudoplatanus), mallow (Malva sylvestris), whitebeam (Sorbus aria agg.), sessile oak (Quercus petraea), blackthorn (Prunus spinosa), bramble and gorse (Ulex europaeus). Other species including horsetail, (Equisetum sp), bindweed (Convolvulus arvensis), willowherb (Epilobium sp.), lords and ladies (Arum maculatum), buddleia (Buddleja davidii.), and ivy were present (See Photograph 4, Annex J – Photographs).
There is ongoing regular management of vegetation on the embankments as part of the Refinery fire risk management strategy, such that the scrub is cut back where required.
The dense / continuous scrub is of limited ecological interest and of negligible ecological value.
Semi-improved neutral grassland
There are several areas of semi-improved neutral grassland on steep embankments which facilitate the level changes between areas of flat ground on which hardstanding and buildings are present and on embankments throughout this area of the Refinery site. The areas of semi-improved neutral grassland comprise a relatively tall sward of grassland supporting common species (see Photograph 5, Annex J – Photographs). Grass species included red fescue, (Festuca rubra), cocksfoot (Dactylis glomerata), Yorkshire-fog (Holcus lanatus), false oat grass (Arrhenatherum elatius) and crested dog’s tail (Cynosaurus cristatus) and the rush, soft rush (Juncus effuses). Frequent herb species included willowherb (Epilobium sp.), common nettle (Urtica dioica), broad-leaved dock (Rumex obtusifolis), common fleabane (Pulicaria dysenterica), bristly oxtongue (Picris echioides), ragwort (Senecio jacobaea), perforate St John’s-wort (Hypericum perforatum), teasel (Dipsacus fullonum), vipers bugloss (Echium vulgare), great mullein (Verbascum thapsus), hemp-agrimony (Eupatorium cannabinum), dandelion (Taraxacum agg.), selfheal (Prunella vulgaris), cow parsley (Anthriscus sylvestris), lords and ladies (Arum maculatum), hawkweed species (Hieracium sp.), white clover (Trifolium pratense), field bindweed (Convolvulus arvensis) creeping buttercup (Ranunculus repens) red campion (Silene dioica), hogweed (Heracleum sphondylium), Canadian fleabane (Conyza canadensis), common figwort (Scrophularia nodosa) and common bird’s-foot trefoil (Lotus corniculatus).
In some areas within the site, and in the wider Refinery, the grassland supports a greater herb diversity, finer grasses and orchid species. It is likely that the substrate across the site varies, facilitating the development of slightly different grassland communities.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 24
Small areas of semi-improved neutral grassland are present colonising at the edges the edges of gravel and tarmac areas within the Project site. Species were present including scarlet pimpernel (Anagallis arvensis), silverweed (Potentilla anseria), black medick (Medicago lupulina), ribwort plantain (Plantago lanceolota), greater plantain (Plantago major), herb robert (Geranium robertianum), yarrow (Achillea millefolium), tormentil (Potentilla erecta), common toadflax (Linaria vulgaris) and purple toadflax (Linaria purpurea). On some of the banks harts tongue fern and male fern were present.
The areas of semi-improved neutral grassland are very small and support common and widespread species, and are considered to be of no more than Local ecological value.
3.3.5 Ruderal vegetation
Ruderal vegetation is present in small areas amongst the grassland and scrub on site. Dominant species include willowherb species and common nettle.
The ruderal vegetation is of limited ecological interest and of negligible ecological value.
Ephemeral/ short perennial vegetation
Small areas of short perennial vegetation are present where areas of gravel or gaps and cracks in concrete or tarmac have been colonised and under the pipe runs on gravel (see Photograph 6.1, Annex J – Photographs) These areas seem to be subject to a weed killing regime, such that limited plant growth was present. Species present include Yorkshire fog, red fescue, ribwort plantain, broadleaved plantain, willowherb, buddleia, red valerian (Centranthus ruber), purple toadflax, teasel, scentless mayweed (Tripleurospermum inodorum), pineapple weed (Matricaria discoidea), common mouse-ear (Cerastium fontanum) and mosses.
In some areas under the pipe runs hot condensate from a steam trap is repeatedly released from the pipe systems, such that small areas of damp vegetation area present, with rushes, liverworts and mosses present (see Photograph 6.2, Annex J – Photographs).
The short perennial vegetation is of limited ecological interest and of negligible ecological value.
Amenity grassland
A small strip of amenity grassland is present either side of the perimeter fence on the south-western site boundary, adjacent to the road to Rhoscrowther village. The grassland is managed through regular mowing and supports a short sward dominated by perennial ryegrass (Lolium perenne), with self-heal and plantains also present.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 25
The amenity grassland is of limited ecological interest and of negligible ecological value.
Buildings and structures
The buildings present within the Project site include a workshop, contractor maintenance building and a small shed. Buildings were surveyed in the wider survey area, but only the following are within the Project site. Building numbering follows that of the original survey of the wider survey area.
Building B2, ‘Electrical Workshop is a single storey building of brick / breeze block construction for the lower 1-2m, followed by corrugated metal cladding on a metal frame (see Photograph 7, Annex J – Photographs). The pitched roof was also made of corrugated metal. Internally the building is partitioned, forming a number of former office spaces with false ceilings, although the central corridor of the building is open to the roof. This central corridor was partially inaccessible, and a thorough inspection was not possible. The building is currently disused with doors and windows to the building appearing to be permanently open. Swallows (Hirundo rustica) and their nests were recorded within the building.
Building B3, “Main workshop Area A” is made up of three connected large single storey warehouses of differing heights, set on level ground, such that it is significantly lower than the surrounding land to the north and west (see Photograph 8, Annex J – Photographs). The building is surrounded to the north and west by steep sided banks, covered in paving slabs, a retaining wall and pedestrian walkway. The building itself has brick / breeze block walls for the lower 2-3m above which is corrugated metal. The roof comprises three gently pitched sections and is made of the same corrugated metal as the walls. The roof has a number of large metal chimneys, and skylights within the roof. The building is not currently in use, and was surveyed from the outside. From the higher ground to the north, it could be seen that grasses and other plant species including red valerian were growing in the gutters and on the roof. Gulls were seen on the roof, and site reports suggest that herring gulls (Larus argentatus) nest and raise young on the roof each season.
Building B12, ‘Main substation ’, is a single storey concrete structure supporting a flat concrete roof. The building also has a partially underground basement (see Photograph 9, Annex J – Photographs). It was not possible to access this building during the survey due to the reported presence of bats.
The main operational areas of the Refinery comprise a complex system of metal pipework, furnaces, chimneys, pumps, storage vessels and boilers with
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 26 concrete pillars and metal supports (see Photograph 10, Annex J – Photographs). The majority of this area is of low ecological value and suitability to wildlife due to these industrial processes and elevated noise levels.
The buildings are of limited ecological interest, but do support breeding swallow and breeding herring gull and are of local ecological value. The exception is the Main Substation (B12) in relation to bats. This has been dealt with separately under an EPS licence on health and safety grounds.
Buildings are included in the LBAP habitat action plan for Habitat Action Plan: Urban / Brown Field / Buildings / Gardens.
Bare ground
Areas of bare ground in the form of concrete, tarmac and areas of gravel are present throughout the much of the Project site beneath the built structures, in the place of former built structures and forming laydown areas and access roads.
The bare ground is of limited ecological interest and of negligible ecological value.
3.3.6 Notable plant species
Records provided by the an associate of Biodiversity Solutions, include records of bee orchid (Ophrys apifera), early purple orchid (Orchis mascula), southern marsh orchid (Dactylorhiza praetermissa), pyramidal orchid (Anacamptis pyramidalis) and occasional records of heath spotted-orchid (Dactylorhiza maculata) from within the wider refinery site. Orchid species were recorded in the semi-improved neutral grassland within the Project site
A number of records of UK Red Data Book mosses and liverworts were returned by the data search from WWBIC, the closest record of which is located approximately 350 m to the south of the Project site.
No nationally or regionally rare or scarce species were recorded within the Project site during the survey and a detailed moss and liverwort survey was not undertaken. Given the absence of notable records and nature of the site it is unlikely such a survey would be warranted.
3.3.7 Invasive plant species
No invasive plant species, as listed on Schedule 9 of the Wildlife and Countryside Act 1981 (as amended), were recorded within the Project site during the survey. In addition, none have been reported within the wider Refinery site.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 27 3.4 FAUNA AND FLORA
3.4.1 Overview
This section provides a description of the use of the Project site, or likely use of the Project site by important species (protected species or national or local conservation priorities). The section draws upon a combination of desk study information, field survey data, and an assessment of the likely value of the habitats for each species present.
3.4.2 European Protected Species
Bats
The Refinery is surrounded by habitat suitable for bats including areas of agricultural pastures, hedgerows, water bodies and small areas of woodland. The mitigation roost at Rhoscrowther, a modified former dwelling house, is 40m from the Project site.
The data search returned numerous records of bats, of 10 species within the 2km search area. Various roosts are present within 2 km of the Project site, including maternity roosts and hibernacula.
Initial bat assessments
A small (no more than three bats present at any one time) lesser horseshoe roost was identified in the Main Substation A single greater horseshoe bat and a common pipistrelle have also been detected within the roost subsequent to the initial assessment, although there is no evidence the greater horseshoe bat roosted within it. As the building is a critical part of the existing infrastructure a European protected species licence application has been made to exclude bats on urgent health and safety grounds. This licence application (75593 Valero, Pembrokeshire) has been approved by NRW. The appropriate mitigation has been completed and bats excluded from the substation.
The electrical workshop (B2) supported foraging pipistrelles but no roosting bats. Two buildings were assigned low potential to support roosting bats, the old stores and the bulk store (B5 and B9).
The Main workshop Area A (B3) was identified as having negligible potential to support roosting bats and is not considered further in the assessment.
The remaining 11 buildings within the wider survey area were identified as having negligible potential to support roosting bats and are not considered further in the assessment.
Results of the building surveys can be found in Table 3.2:
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 28 Table 3.2 Results of the initial building surveys within the Project site
Building Building Features Signs Suitability Description B1 – Toilet Small concrete Open windows No evidence of Negligible block building. and doors. roosting bats.
B2 – Electrical Large industrial Open windows Scattered droppings Low – but workshop workshop, metal and doors. in low numbers. confirmed activity clad with Likely used by concrete supports flying/foraging and concrete bats. lower walls. Windows left open.
B3 - Area A Large industrial None No evidence of Negligible workshop building with roosting bats. skylights and windows.
B4 – ATCOST Industrial None No evidence of Negligible industrial building with roosting bats. building. corrugate asbestos sides and roof with skylights.
B4a – Electrical Concrete None No evidence of Negligible substation building with no roosting bats. attached to B4 cellar.
B5 – Old stores Concrete walls Access through No evidence of Low and floors with open doors plus roosting bats. the upper clad in gaps. metal sheeting. Pitched metal roof with skylights.
B6 – Inspection Containers None No evidence of Negligible building bonded together. roosting bats. Disused workshop space.
B7 – Paint store Small concrete None No evidence of Negligible building roosting bats. rendered on the outside with toughened glass windows and a metal door.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 29 Building Building Features Signs Suitability Description B8 – Lock-up Small concrete None No evidence of Negligible east of bottle building with roosting bats. store. concrete rendered walls and roof.
B9 – Bulk store Large industrial Some gaps No evidence of Low concrete block offering roosting bats. building with potential. metal sheets on upper sides and roof.
B10 – Roto, Very large and None No evidence of Negligible main modern roosting bats. workshop. industrial building, skylights and operational 24hrs a day.
B11 – Western Small metal box Doors open but No evidence of Negligible power shaped well- heavily used roosting bats. substation sealed building. and lit throughout the night.
B12 –main Concrete box Open hatch to Three piles of Confirmed – bats substation construction with the cellar and droppings (50 to excluded under a cellar. holes from 200) with urine NRW derogation cellar to the first staining suggesting licence. floor. three roost sites. One lesser horseshoe bat seen in-situ.
B13 – Concrete box None No evidence of Negligible substation 2 construction with roosting bats. no cellar.
Civils Two large sheds None No evidence of Negligible workshop constructed of roosting bats. corrugated metal sheeting. No access/egress points.
Grey Box Multiple None No evidence of Negligible containers roosting bats. welded together to make offices. Not in use.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 30 Tree assessments
The dominant tree species included ash and maritime pine (Pinus pinaster) with occasional willow and hawthorn).
The trees on the site were not suitable for climbing inspections and were surveyed from ground level. None of the trees showed sufficient potential to be used by roosting bats and no evidence of roosting bats was noted. These trees are considered to have negligible potential to support roosting bats and are not considered further in the assessment.
The southern mixed plantation woodland did provide suitable connectivity to the wider landscape and was situated adjacent to the confirmed roost (now closed) in B12.
Emergence surveys
No bats were seen or heard emerging from any potential or confirmed roosts within the Project site during any of the surveys.
Static results
No data were recorded on the detectors in B2, B5 and B9 in September and October 2016. Due to lack of bat activity during the autumn season, statics were not placed within the buildings over the winter period.
Static results from the lesser horseshoe bat roost in the substation B12 identified activity during the day and night of low numbers of lesser horseshoe bats in September, October, November, December and February. In January only two bat calls were recorded on the static detectors. This information was gathered to inform the NRW derogation licence application and is not relevant to the baseline.
Bat roost characterisation surveys
The only roost identified within the Project site is not to be considered further as an application has been made to exclude the bats under health and safety grounds, inclusive of appropriate mitigation measures.
Table 3.3 Walked Transect
Date Total species passes per hour (no. of passes divided by survey time) Ppy Pp P sp. M sp. Pa Rf Rh Nn 22nd September 2016 – 1900 to 4 76 16.3 3 4.8 2200
Ppy - soprano pipistrelle, Pp - common pipistrelle, P sp. - Pipistrelle bat species, M sp - Myotis bat species, Pa -brown long-eared bat, Rf – greater horseshoe bat, Rh – lesser horseshoe bat, Nn - noctule bat.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 31 Table 3.4 Static Transect
Date Location Peak number of passes per night Ppy Pp P sp. M sp. Pa Rf Rh Nn November 2016 Shelter-belt east* 3 93 2 5 December 2016 Shelter-belt east* 7 67 1 January 2017 Scrub outside B12 1 January 2017 Shelter-belt south- 7 east** February 2017 Scrub outside B12 10 February 2017 Shelter-belt south- 16 east** *No bats were recorded on statics placed to the west or in the scrub between B12 and the hedge. **No bats were recorded on statics placed to the west. Detectors were also placed to the south west of the hedge and to the south east but no records of bat passes were noted.
Moderate levels of common pipistrelle and low levels of soprano pipistrelle (Pipistrellus pygmaeus), Myotis species, brown long-eared bat, noctule (Nyctalus noctula) and greater horseshoe bat were recorded foraging along the southern mixed plantation woodland during the activity surveys.
The statics at Fort Popton identified that greater horseshoe bats were showing signs of activity during the winter period with occasional recordings of lesser horseshoe bat.
Discussion
Bats were not recorded within the old stores (B5) or the bulk store (B9) during the emergence surveys or on the static recorders in September and October.
Pipistrelle droppings were noted within the electrical workshop (B2), the results of the emergence and static surveys implied that the building is used infrequently as a sheltered foraging area used by common bat species such as pipistrelles.
There is little suitable roosting habitat associated with the Project Site and the buildings support foraging only. The Project site is of Local ecological value, with most buildings of negligible ecological value.
Low to moderate levels of foraging activity by common species and low levels of activity by rarer species including greater horseshoe bat and noctule bat, were recorded along the southern mixed plantation woodland. The Project Site is connected to better habitat in the wider countryside and is in close proximity to the wider Refinery site. The habitat is considered to be of Local ecological value to bats.
Other European protected species
The data search from WWBIC did not return any great crested newt (Triturus cristatus) or dormouse (Muscardinus avellanarius) records from the 2km search radius.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 32
Five records of otter (Lutra lutra) were returned, dating from 1988-1995, located approximately 0.9 km south of the Survey Area.
Biodiversity Solutions provided records of occasional otter road casualties at Glebe Cottages, over 1km east of the Project site, showing the species is present within the area.
The habitats present within the Project site and its immediate surroundings are not suitable to support dormouse or otter.
In the case of great crested newt, there are waterbodies within 250 m of the Project site. Some of these have operational purposes, eg for containment of storm and waste water and others are relatively isolated within the operational refinery site. Given this context, and that there are no records of great crested newt from within 2km of the Project site, it is unlikely any are present. Common toad (Bufo bufo) and palmate newt (Lissotriton helveticus) reportedly regularly breed in tank bund ditches and the final effluent ponds on the west side of the Refinery site.
The Project site is of negligible ecological value for great crested newt, otter or dormouse.
3.4.3 Nationally Protected Species
Badgers
The data search from WWBIC returned 10 records of badger from the agricultural land surrounding the refinery, the most recent of which was from 2014, located approximately 2km east of the Survey Area. All the other records were at least 1.4 km from the site and date from the 1970’s – 1995.
Evidence of badger was recorded along the southern site boundary during the survey in October 2016, and a badger survey was undertaken in February 2017 of the Project site and surrounding 100m. Results are shown at Photographs 11 – 16, Annex J – Photographs and Annex H – Badger Survey Results Map.
In summary, the survey recorded badger activity along the southern perimeter fence, on the mixed plantation woodland embankment and in dense scrub and in the surrounding agricultural fields. This included:
three separate active sett entrances (unlikely to be used for breeding due to depth and structure) in dense scrub to the south-west of the Project site;
evidence of surface nesting, in dense scrub in the south-west of the Project site; and
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 33 well-developed pathways and latrines with recent activity along the mixed plantation woodland embankment.
Access to these setts appears to be via a number of push-throughs under the Refinery perimeter fence to the south of the embankment
There was no additional activity recorded within the Refinery site, ie the area north of the embankment. A small single entrance hole which was recorded in August 2016 during the phase 1 survey showed no recent sign of use, and additional vegetation growth.
Further details of the survey findings are presented in Annex I – Badger Survey Results.
Three active sett entrances can be classified as a subsidiary sett, used as part of a wider network of more important setts by one badger family (or clan) within a defined territory. The subsidiary sett is unlikely to be used by breeding badgers and is not likely to be in use throughout the year.
The majority of the habitats present within the Project site and Survey Area out with the Project site offer limited opportunities for badgers being dominated by built structures and areas of bare ground (concrete, gravel, tarmac).
The use of the Project site by one badger family / clan is of no more than Local ecological value.
Breeding birds
There were over 130 records provided by WWBIC from grid references which include the Project site, referenced as the ‘tetrad (2km x 2km) of the refinery site’. As such, these records are from a wider area around the Project site. These records date predominantly from 1984-1988, 2003, 2006 and 2010, recorded as part of the Bird Atlas recording schemes. Numerous other records of birds were returned from the 2km search area, the next closest of which being within 500m.
Two records from specific locations in close proximity to the Project site, one of swallow and one of wintering golden plover (Pluvialis apricaria) were returned from the desk study dating from 2008 and 2010 respectively.
The local bird ringing group provided records of Schedule 1 bird species including peregrine (Falco peregrinus), barn owl (Tyto alba), and Cetti’s warbler (Cettia cetti) within the area. Cetti’s warbler occur at specific reedbed sites in the local area. Peregrine are found along the coastline and on coastal infrastructure. Known barn owl breeding sites are located over 700m from the
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 34 Project site, on the far side of the refinery. Barn owl have also been seen using buildings to the south and west of the refinery site, but not for breeding.
Biodiversity Solutions provided a list of species recorded to breed within the Refinery. These include species such as:
blackbird (Turdus merula), blackcap (Sylvia atricapilla), blue tit (Cyanistes caeruleus), chaffinch (Fringilla coelebs), chiffchaff (Phylloscopus collybita), dunnock (Prunella modularis), long-tailed tit (Aegithalos caudatus), magpie (Pica pica), great tit (Parus major ), greenfinch (Chloris chloris), robin (Erithacus rubecula), song thrush (Turdus philomelos), stonechat (Saxicola torquata), woodpigeon (Columba palumbus) and wren (Troglodytes troglodytes) all of which nest in the denser scrub on the tank bunds;
blue tit nest in pipes and nest boxes;
carrion crow(Corvus corone) and several pairs of mistle thrush (Turdus viscivorus) nest on the units;
approximately 30-40 pairs of herring gull breed on the jetty and various roofs and tanks;
approximately 50 pairs of house martin (Delichon urbica) nest on various tank shells and at the Administration building;
several pairs of house sparrow (Passer domesticus) and swallow nest in the store buildings and bulk stores;
one pair of kestrel (Falco tinnunculus) nest in a box on tank 212 in the north of the Refinery Site; and
approximately 10 pairs of lesser black-backed gulls (Larus fuscus) nest on tank roofs.
Current and old swallow nests were recorded in a number of the buildings on the Project site and in the Survey Area out with the Project site, with birds being seen on some of the nests. Herring gulls were seen on the roof of Building B3, ‘Main workshop Area A Workshops 41-B-014’, during the August 2016 survey, and site staff report that gulls nest of the roof and raise young each year. Magpies, swallows, crows, robin, blackbird and wren were also seen on site during the survey. The August 2016 survey was undertaken after the end of the bird breeding season, such that some species may not have been recorded. It is likely however, given the habitats within the Project site, that any other bird species present are common species.
Within the wider vicinity of the Project site, the Refinery extends over 1km to the east and north. The bird species within the wider Refinery are expected to
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 35 be similar to those recorded or known in the Survey Area, as the habitats are contiguous and similar.
Agricultural land lies to the south and west of the Project site which includes grazed pastures, a hedgerow network, residential properties and curtilages and small areas of woodland. The bird assemblages using these areas are likely to be primarily common and widespread species but containing a high proportion of Environment Act (Wales) 2016 schedule 7 species and some Wildlife and Countryside Act 1981 schedule 1 species such as barn owl.
Bird species present within the Refinery and on the Project site are common species but include a range of schedule 7 species such as breeding gulls. Overall such species are common within Pembrokeshire and the bird assemblages would be of Local ecological value.
The bird species in the wider vicinity are likely to be representative of the range of habitats present, and include Section 7 species, and possibly Schedule 1 species. Overall the assemblage would be of Local ecological value, and if barn owl is present in the wider vicinity this species is likely to be of County importance. This is not regarded as an important area for barn owl foraging and there are no records of nesting within the EZoI of the Cogen Project.
Reptiles
The data search from WWBIC returned nine records of common reptile species, including common lizard (Lacerta vivipara), slow worm (Anguis fragilis) and grass snake (Natrix natrix), from approximately 1.5 km west of the Project site, all dated from the 1990s.
Local recorders reported only low number of adder (Vipera berus; seen only once), and slow worm and common lizard (both seen several times) on embankments north of the Project site. All common reptile species are listed on Section 7 of the Environment (Wales) Act 2016 and are living organisms of principal importance for the purpose of maintaining and enhancing biodiversity in relation to Wales.
Limited suitable habitat to support reptiles is present within the Project site in the form of the embankments which are vegetated by semi-improved neutral grassland and scrub and the plantation woodland on the southern site boundary. The embankments offer small areas of potentially suitable habitat and are not directly linked to larger areas as they are isolated by bare ground and hardstanding. The grassland, scrub and plantation woodland on the southern site boundary offers potential for reptiles. At most these areas would support a small population of common reptiles.
If present, a small population of common reptile species would be of no more than Local ecological value.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 36
Invertebrates
Records of Section 7 (1) butterfly, moth, dragonfly, hymenopteran and beetle species have been returned from the data search from WWBIC, the closest of which is located immediately south of the Project site, attributed at Rhoscrowther.
The local Valero biodiversity lead reported the regular breeding of a number of common dragonfly species within the tank ditches in the wider Refinery site. A number of common bumble bee species were also recorded.
The embankments which are vegetated by semi-improved neutral grassland, scattered scrub and plantation woodland are likely to support a range of invertebrate species. Red admiral (Vanessa atalanta) butterfly, red and green grasshoppers (Orthoptera), and a number of bees were observed during the survey. However, the majority of habitats present within the Project site, (hardstanding bare ground and buildings) are not suitable to support invertebrates.
On the basis of the vegetation types present on the site and distance from areas supporting important invertebrate populations the Project site is likely to support only common and ubiquitous invertebrate species, with an assemblage of no more than Local ecological value.
3.4.4 Summary of Ecological Baseline
Table 3.5 summarises relevant ecological features within the Project site and the geographical context within which each is considered to be important.
Table 3.5 Summary of baseline value of ecological features
Relevant Ecological Ecological Rationale Feature Value Southern mixed Local Moderate levels of common species and low levels of plantation woodland for species including greater horseshoe bat and noctule, foraging bats were recorded foraging along the southern mixed plantation woodland, given the suitable connectivity to the wider landscape but the proximity to the oil refinery site this is considered to be of Local ecological value to bats.
B2 for foraging bats Local The electrical workshop (B2) is considered to be of Local ecological value for foraging bats.
(1) Section 7 of the Environment (Wales) Act 2016 Priority Habitats
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 37 Relevant Ecological Ecological Rationale Feature Value Mixed plantation Local The mixed plantation woodland is of limited ecological woodland interest and of at most Local ecological value.
Semi-improved neutral Local The areas of semi-improved neutral grassland are very grassland small and support common and widespread species, and are considered to be of Local value.
Badger Local The use of the Project site by one badger family in the form of a subsidiary sett is of Local value.
Birds within the Project Local It is likely, given the habitats on the Survey Area, that site any other bird species present are common species and the bird assemblages would be of Local value.
Birds in the local vicinity Local Bird assemblages are of local value but if barn owl is of the Project site present this may be up to County importance.
Common reptiles Local If present, a small population of common reptile species would be of no more than Local value due to the small areas of suitable habitat.
Terrestrial invertebrates Local On the basis of the vegetation types present on the site and distance from areas supporting important invertebrate populations the Project site is likely to support only common and ubiquitous invertebrate species.
Bats Local Trees and most buildings are of negligible value to bats. Foraging habitat within building B2 and along the southern embankment are of local value.
Great crested newt, otter Negligible The Project site is of negligible value for great crested and dormouse newt, otter or dormouse due to the absence of suitable habitat.
Dense / continuous Negligible The dense / continuous scrub is of limited ecological scrub interest and of negligible ecological value.
Ruderal vegetation Negligible The ruderal vegetation is of limited ecological interest and of negligible ecological value.
Short perennial Negligible The short perennial vegetation is of limited ecological vegetation interest and of negligible ecological value.
Amenity grassland Negligible The amenity grassland is of limited ecological interest and of negligible ecological value.
Buildings Negligible The buildings are of limited ecological interest and of negligible ecological value.
Bare ground Negligible The bare ground is of limited ecological interest and of negligible ecological value.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 38 4 ECOLOGICAL IMPACT ASSESSMENT
4.1 PROJECT DESCRIPTION
The Project will comprise the following major components:
the Combustion Gas Turbine (CTG); an acoustic enclosure to house the CTG; a single 35m stack; a Heat Recovery Steam Generator; cooling infrastructure; new switchgear; new 132kV meter infrastructure; control room instrumentation system; local instrumentation and control system; tie-ins to steam, boiler feed water and other plant systems as needed; a section of over-ground natural gas pipeline; electrical transmission cables; and CEMS.
All of these elements of the Project are within the land ownership of the Refinery.
No abstraction is proposed from natural water bodies. Similarly discharge water from the plant is limited and will be routed through the Refinery’s water treatment facilities in accordance with a variation to the Environmental Permit. No significant liquid discharges to local water bodies are proposed.
4.2 IMPACT ASSESSMENT
The following ecological receptors have been scoped out:
Dormouse, great crested newt and otter have been scoped out of the assessment due to the lack of suitable habitat and the absence of any desk study records.
Reptiles and terrestrial and aquatic invertebrates have been scoped out of the assessment because of the very limited areas of suitable habitat within the Project site.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 39 4.2.1 Designated sites
European Sites
An HRA has been undertaken to consider the potential for likely significant effects on European designated sites within 15km of the Project Site. The full methodology and results are presented in the HRA (Doc Ref: Cogen/DNS/HRA/C01).
The results of the Screening Assessment, Stage 1, is presented in Table 4.1.
Table 4.1 Screening Stage Summary for European Sites from Project Alone
European Site Distance from the Project Appropriate Assessment (km to nearest point) Required Pembrokeshire Marine SAC 0.4 No AA required Limestone Coast of South West 1.4 No AA required Wales SAC Castlemartin SPA 1.8 No AA required West Wales Marine cSAC 5.5 No AA required Pembrokeshire Bats Sites and 5.7 No AA required Bosherston Lakes SAC Skokholm and Skomer SPA 11.2 No AA required Bristol Channel Approaches 12.3 No AA required cSAC Cleddau Rivers SAC 13.4 No AA required
The screening assessment found no likely significant effects on the qualifying interest features of the European sites from the Project alone, or in- combination with other projects. Hence an AA is not considered necessary for the Project.
SSSIs
A similar assessment to the HRA has been undertaken within this EcIA report for SSSIs to determine whether or not the 1 percent and 70 percent critical loads are exceeded and there is a potential effect on habitats, and if further assessment is required.
Six SSSIs have been scoped out of assessment as they are insensitive to air quality effects (see Section 2.4.3). A further 17 sites have been identified as potentially sensitive to air quality effects within 15km.
The results of the Screening Assessment are presented in Table 4.2. The full assessment and detailed data tables are presented in Annex G Effects of Air Quality on Sites of Special Scientific Interest.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 40
Table 4.2 Screening Summary for SSSIs
SSSI Potentially Sensitive to Air Criteria not exceeded or can be Scoped out of requiring Quality Effects further assessment. Milford Haven Waterway SSSI Scoped out of requiring further assessment Broomhill Burrows SSSI Scoped out of requiring further assessment Castlemartin Corse SSSI Scoped out of requiring further assessment Angle Peninsula coast SSSI Scoped out of requiring further assessment Somerton Farm cSSSI (candidate Criteria not exceeded SSSI proposed for grassland Fungi) Castlemartin Range (previously Scoped out of requiring further assessment called Castlemartin Cliffs and Dunes SSSI) Dale and South Marloes Coast Scoped out of requiring further assessment SSSI Stackpole SSSI Scoped out of requiring further assessment Hook Wood SSSI Scoped out of requiring further assessment Stackpole Quay to Trewent Point Scoped out of requiring further assessment SSSI St Bride’s Bay South SSSI Scoped out of requiring further assessment Newgale to Little Haven Coast Scoped out of requiring further assessment SSSI Freshwater East to Skrinkle Haven Scoped out of requiring further assessment SSSI Yerbeston moors SSSI Scoped out of requiring further assessment Western Cleddau River SSSI Scoped out of requiring further assessment Carew Castle SSSI Criteria not exceeded Marloes Mere SSSI Scoped out of requiring further assessment
This shows that for all of the SSSIs either the criteria are not exceeded or further assessment is not required.
Local Wildlife Sites
There are no Local Level Wildlife Sites within 2km of the Development Site.
Ancient Woodland
Seven ancient woodland sites were identified with 2km of the Project site. As indicated in the Air Quality Impact Assessment, nutrient nitrogen deposition is the only air quality effects requiring further assessment for ecological receptors. Sulphur dioxide emissions, NOx concentrations and acid deposition did not require further assessment.
Critical loads for nitrogen deposition were taken from the APIS website and are based on broadleaved woodland (G1), using the upper and lower limit of 10 to 20 KgN/ha/yr.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 41 Existing background loads are not known; loads determined for woodland in the Limestone Coast of South West Wales SAC were used as it is within 1.5km of the Project. Background levels of nitrogen deposition are 20.3 KgN/ha/yr. These are conservative estimates.
Six of the seven woodland sites have a process contribution (PC) from the Project in excess of 1 percent. As the assumed critical load already exceeds the maximum critical load for the habitat, the Predicted Environmental Concentration (PEC), ie the process contribution added to the background loads, therefore also exceeds the >70 percent air quality assessment trigger at one or more receptor points. The receptors are mapped in Figure A.6, with those where it is predicted that the contribution from the Project will exceed both the 1 percent PEC and 70 percent PEC shown in red. These are sites where the existing background is presumed to be in excess of the critical load for nitrogen deposition, and the Project will make a further small contribution to the PEC.
The AWI does not provide an assessment of current condition, however woodland action plans and recent reports from Pembrokeshire Biodiversity Partnership (1) indicate that oak woodlands are in moderate and improving conditions. Nitrogen deposition is not identified as an impact of concern, with the key concerns being loss and fragmentation, lack of or inappropriate management, loss of genetic integrity, invasive species and climate change.
Given the small overall contribution to nitrogen deposition, and the lack of information indicating that this is a significant factor affecting the Ancient Woodlands in proximity of the Project site, no significant residual impact arising from air quality is anticipated for ancient woodlands.
4.2.2 Habitats within the site and immediate vicinity
Dense continuous scrub
There will be no loss of the dense continuous scrub due to the construction of the 132 kV meter skid.
As part of the mitigation for the closure of the bat roost in the substation, additional planting has been provided to the south of the southern embankment to increase connectivity and provide additional native scrub and hedge habitat. Although this activity is carried out separately from the DNS application the overall scrub resource within the wider area will be maintained.
There is no loss of dense continuous scrub, therefore there is no significant impact.
(1) Pembrokeshire Biodiversity Partnership. April 2016. The State of Wildlife in Pembrokeshire
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 42
Semi-improved neutral grassland
There will be a temporary loss of small areas, 0.06 ha (3 percent) of semi- improved grassland while the new pipe runs are installed. The pipe-runs are not expected to fragment the grassland habitat, as they will be on raised footings allowing species movement beneath the pipe-runs.
Once construction is complete, the semi-improved neutral grassland will naturally revegetate around and under the pipe-runs as is the case under the existing pipe run infrastructure.
The residual impact of the loss of the semi-improved neutral grassland, after mitigation will be not significant.
Ruderal vegetation
There will be a loss of small areas, 0.02 ha (17 percent) of ruderal vegetation due to the construction of 132kV meter skid and associated substations.
The residual impact of the loss of ruderal vegetation, without mitigation will be not significant.
Short perennial vegetation
There will be a temporary loss of small areas, 0.12 ha (12 percent) of short perennial vegetation while the new pipe runs are installed. The pipe-runs are not expected to fragment the short perennial vegetation habitat, as they will be on raised footings allowing species movement beneath the pipe-runs.
Once construction is complete, the short perennial vegetation will naturally revegetate around and under the pipe-runs as is the case under the existing pipe run infrastructure.
The residual impact of the loss of the short perennial vegetation, after mitigation will be not significant.
Other habitats
No significant impacts are predicted for any other habitats, (mixed plantation woodland, amenity grassland, buildings or bare ground).
4.2.3 Species and species groups
Bats
The potential effects of increased noise on bats are acute acoustic trauma, disturbance and displacement from important food resources.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 43
No changes in the existing sound baseline character are expected due to the current fluctuating soundscape occurring on and around the Project site throughout the year.
Noise emanating from regular construction and daily operational activities from the Refinery (including at night), already affects the embankment and yet bats continue to forage along it. Whilst the noise levels at the embankment are expected to increase during construction and operation of the Project, it is considered unlikely that they will be deterred from foraging. Even if they were displaced, a significant effect is not likely given the low numbers of bats and the extensive areas of suitable habitat in the surrounds that they can utilise.
During construction, if required, site lighting shall be positioned and directed so as to minimise impacts to the southern boundary. Appropriate measures will be used to direct light away from sensitive receptors. The Refinery is already well lit in the areas scheduled for construction, which are in active use, therefore no additional impact on the southern boundary is expected.
During operation, the lighting will be similar to the baseline conditions and will be used to illuminate walkways and process controls, rather than to flood the area. Replacement lighting is expected to be required in the vicinity of the Cogen plot, following the demolition of the existing structure (under a separate permission). Lighting around the ancillary infrastructure will similarly be used to illuminate walkways and process controls, rather than to flood the area and will be directed into the Refinery and away from the southern boundary. No significant additional light burden is anticipated on the southern bank which is already used by bats. The significance of effects on bats is not expected to change.
The bat roost established at No. 3 Pleasant View will not be affected by additional lighting from the Project in either construction or operational phases.
The residual impact on foraging and commuting bats during construction and operation will be not significant.
Badger
There will be negligible loss of scattered scrub and ruderal vegetation 0.02ha (17.5 percent) on the north side of the mixed plantation embankment which was not recorded to be used by foraging / commuting badgers during the field surveys, and is further than 30m from the badger setts. The lack of field signs indicate it is unlikely badgers use this area, probably due to its proximity to the operational refinery areas.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 44 All Project infrastructure will be sited on the north side of the mixed plantation woodland embankment, within the operational refinery and will have a negligible effect on badgers given the context of the existing operation refinery.
The residual impact on badgers during construction and operation will be not significant.
Birds
There will be no direct loss of habitat associated with the Project of any significant value for breeding birds, as the habitats to be lost are largely hardstanding and bare ground and one building, B3. The minor habitat losses associated with the Project are of such a small area that they will not result in significant permanent loss of any bird breeding territory, as plentiful other similar habitat is available within the immediate vicinity.
Birds in the wider vicinity of the site are unlikely to be adversely affected, as the majority of the construction works are within the refinery site boundary, and will be shielded by the embankment. Construction noise may exceed existing noise levels but this is within the context of a noisy working industrial site where currently a number of species, as described in the baseline, are already tolerating within the Refinery.
During operation the noise levels are likely to be of a similar level and a similar type of sound as the current refinery site.
Even if they birds were displaced, a significant effect is not likely given the low numbers of birds using the Refinery Site and immediate surrounds and the extensive areas of suitable habitat in the wider surroundings that they can utilise.
During construction, measures should be undertaken to ensure that there is no risk to nesting birds, their nests, young and/or eggs due to the Project. All permanently open buildings and roof areas where gulls nest which may be impacted during the Project should, if required, be demolished avoiding the nesting bird season (between mid-March to the end of September).
If it is not possible to avoid demolition during the bird nesting season, then deterrent measures should be employed to prevent nesting birds becoming established. Such measures could include blocking access to buildings prior to the start of the nesting bird season.
A check for active nests will be required immediately prior to demolition to confirm the absence of nesting birds. The check surveys need to be undertaken by a suitably experienced ecologist. If nesting activity is recorded within the permanently open buildings, demolition works affecting these
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 45 buildings should cease until such time that the chicks have fledged and nesting activity has finished.
The residual impact on birds during construction and operation, after mitigation will be not significant.
Other groups
No impacts are predicted on other species or species groups.
4.2.4 Summary of Mitigation
Mitigation measures during construction are detailed in the Construction Environmental Management Plan (CEMP), including controlling the risk of water quality changes from surface water runoff; accidental pollution; and introduction and spread of non-native invasive species.
These impacts have been scoped out as they are part of the standard Valero operational management of environmental risks and are included within the CEMP for the Project, during construction and during the Refinery operational practices once the Project is operational. In addition, Table 4.3 summarises the ecological mitigation measures will be included in the Project.
Table 4.3 Mitigation Register
Construction or Mitigation measure Receptor Location and Timing Operation Construction Maintain 30m construction Badger Duration of buffer zone from badger construction period. setts Within 30 and 100m of Maintain 100m percussive badger setts. piling buffer zone from badger setts.
Construction Ensure that there is no risk Birds Duration of to nesting birds, their construction period. nests, young and/or eggs avoiding the nesting bird season (between mid- March to the end of September).
4.3 RESIDUAL IMPACTS
There are no significant residual impacts on ecological features due to the construction or operation of the Project.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 46 5 CUMULATIVE AND IN-COMBINATION EFFECTS
5.1 CONSTRUCTION
None of the cumulative schemes identified in the Scoping process have the potential to cause cumulative impacts to ecological receptors during construction.
Since Scoping was completed, a further cumulative scheme has been identified, namely the installation of the Western Power Distribution infrastructure to the south of the southern Refinery boundary. This has the potential to impact badgers, birds and foraging bats as described below.
5.1.1 Badgers
The installation of the overhead and underground tie-ins for the 132kV meter skid to the existing WPD infrastructure will all be outside 30m for any construction activities and outside 100m from the setts for any piling, drilling or boring activities, therefore badgers will not be affected by noise or disturbance during construction.
There may be temporary disruption to movement along the mammal pathways in the fields immediately south of the refinery fence and along the southern mixed plantation woodland during installation of the overhead lines and underground connection. The expected duration of this is 2-3 months and is not anticipated to adversely affect badgers as other movement pathways are available.
Once construction works are complete, the land around the new overhead poles and the construction footprint of the underground bored connection will be re-instated to the current habitats. The permanent infrastructure will not adversely affect badger behaviour and there will be negligible impacts on badgers during the construction or operations.
5.1.2 Bats
The 132kV connection works may have a temporary and minor effect on foraging bats arising from lighting of the works. This can be minimised by using lighting cowls and minimising light spill. As the embankment supports only modest numbers of foraging bats and the bulk of the embankment will remain unlit (apart from the significant existing background lighting associated with the Refinery) these works are not expected to significantly adversely affect foraging bats.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 47 5.1.3 Birds
As the length of additional overhead line is small and the embankment area is of only local ecological interest for birds no significant adverse effect on birds is predicted.
5.2 OPERATION
The potential for the Project to have a likely significant effect on European sites cumulatively with other projects is reported in the HRA (Doc Ref: Cogen/DNS/HRA/C01). A summary of the findings of the assessment of cumulative effects is presented below.
5.2.1 Air Quality
The European sites listed below are predicted to receive levels of air pollutants from the Project which mean that further consideration of their effects in- combination with other projects is required:
Pembrokeshire Marine SAC; Limestone Coast of South West Wales SAC; and Castlemartin Coast SPA.
A review of the impacts on these European sites due to NOx and deposited nitrogen from other projects identified the need to consider effects cumulatively with:
South Hook CHP; and Egnedol Sustainable Energy Facility.
The screening assessment found no likely significant effects on the qualifying interest features of the European sites from the Project alone, or in- combination with other projects. Hence an AA is not considered necessary for the Project.
5.2.2 Bats
The HRA report describes how the Area of Influence for effects of the Project on bats which form part of the qualifying interest of the Pembrokeshire Bat Sites and Bosherston Lakes SAC is much smaller than that for the effects from air emission described above.
The Project area and immediate surroundings are used by horseshoe bats in very low numbers. No changes in the existing sound baseline character are expected due to the current fluctuating soundscape occurring on and around the Project site throughout the year. Whilst the noise levels at the
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 48 embankment are expected to increase during construction/commissioning of the Project, it is considered unlikely that they will be deterred from foraging. Even if they were displaced, a significant effect is not likely given the low numbers of bats and the extensive areas of suitable habitat in the surrounds that they can utilise. The roosts within SSSI and that which comprise the SAC components are beyond the noise parameters. The AoI is therefore considered to be 250m from the Project.
As there are no other developments within 250m of the Project, there are no cumulative effects to consider on bats which form part of part of the qualifying interest of the Pembrokeshire Bat Sites and Bosherston Lakes SAC.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 49 6 ENHANCEMENT AND MONITORING
As part of the wider Refinery Biodiversity Management, Valero has developed a Biodiversity Monitoring Framework and associated series of Biodiversity Actions Plans for their landholdings outside the refinery fence, with support from ecological consultancies.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 50 7 ECOSYSTEM RESILIENCE ASSESSMENT
7.1 INTRODUCTION TO ECOSYSTEM RESILIENCE
The Environment (Wales) Act 2016 specifies the need to consider ecosystem resilience as part of this assessment.
In the National Assembly for Wales Guidance1 an ecosystem is defined as:
‘The term ecosystem refers to a community of plants, animals and smaller organisms that live, feed and reproduce in a specific area and the way in which these communities interact with other non-living elements such as the weather, water and soils. (As referenced to the International Union for the Conservation of Nature, About Biodiversity, [accessed 15 February 2012]. )
Ecosystems are usually defined in terms of their dominant vegetation or environmental features. Describing and defining the natural world in terms of ecosystems allows us to scale the environment to suit our interests.
As such, ecosystems can be of any size depending on the question being asked or the decision being made’
Ecosystem resilience is defined as:
‘The resilience of an ecosystem is measured as the degree to which it can respond to disturbance by resisting damage and recovering quickly. Resilience is important as it helps reduce the potential negative effects of disturbance.’
In this context, disturbance is defined as:
‘Disturbance covers a range of natural and non-natural events including, but not limited to, fires, floods, storms, deforestation, over- grazing, water abstraction or the introduction of non-native species.
Disturbances can lead to the introduction or loss of elements within the ecosystem, which can have dramatic consequences by causing the death or displacement of some species within the ecosystem, or by changing the way that parts of the ecosystem interact with each other. These changes
1 http://www.assembly.wales/Research%20Documents/Ecosystems%20and%20the%20Ecosystem%20Approach%20- %20Quick%20guide-08032012-231338/qg12-0006-English.pdf
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 51 may be irreversible and can have knock-on consequences for the function of the ecosystem and its ability to provide key ecosystem services.
In Wales, the main threats to ecosystem resilience are climate change, habitat loss and degradation, pollution, development, changes in farming practice, non-native invasive species and wildlife crime, all of which act to fragment habitats, reduce native wildlife populations and increase the vulnerability of these ecosystems.’
7.2 SCOPE OF THE ECOSYSTEM RESILIENCE ASSESSMENT
The ecosystem resilience assessment includes the baseline features identified within the EcIA and their respective eZoI. This is assessed in Section 7.3.
The ecosystem resilience assessment also includes the HRA and air quality assessment of SSSIs and Ancient Woodland.
The HRA for bats and air quality effects on European designated sites and associated air quality assessment of SSSIs and Ancient Woodland have all concluded no effect on the integrity of sites and their supporting processes.
7.3 ECOSYSTEM RESILIENCE ASSESSMENT
Given the relatively small area of the Project site, it is considered ecologically appropriate to assess the Project site as one ecosystem.
The resilience of each feature has been assessed to consider the degree to which it can respond to disturbance by resisting damage and recovering quickly. (1)
The results of this assessment are presented in Table 7.1.
(1)http://www.assembly.wales/Research%20Documents/Ecosystems%20and%20the%20Ecosystem%20Approach%20- %20Quick%20guide-08032012-231338/qg12-0006-English.pdf
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD 52 Table 7.1 Ecosystem Resilience Assessment
Ecosystem Component Likely disturbance as a result of the Project Ecosystem components likely response to Ecosystem component’s likely ability to disturbance and ability to resist damage. recover quickly Southern mixed Limited temporary noise disturbance during It is likely that the increase noise levels are of a If bats are displaced by noise, once noise plantation woodland construction magnitude that will not significantly adversely impacts have moderated, the bats will resume supporting foraging bats affect foraging bats, and so will not damage current use of the ecosystem component. The this ecosystem component. Should there be foraging resource will be undamaged. any temporary adverse disturbance, significant alternative habitat is available within the wider area that bats can temporarily displace too.
B2 for foraging bats Limited temporary noise disturbance during It is likely that the increase noise levels are of a N/A construction magnitude that will not significantly adversely affect foraging bats, and so will not damage this ecosystem component.
Dense continuous scrub Permanent loss of small areas, 0.03 ha (4 percent) The loss permanent loss of such a small N/A of the dense continuous scrub due to the percentage of this ecosystem component will construction of the 132 kV meter skid not affect its functionality, so it is able to effectively resist functional damage and there will not be any adverse consequences on this ecosystem component or other components that interact with or depend on it.
Semi-improved neutral Temporary and very limited permanent loss of The temporary and very limited permanent N/A grassland small area 0.06 ha (3.2 percent) due to loss of such a small percentage of this construction of new pipe runs ecosystem component will not affect its functionality, so it is able to effectively resist functional damage and there will not be any adverse consequences on this ecosystem component or other components that interact with or depend on it.
Ecosystem Component Likely disturbance as a result of the Project Ecosystem components likely response to Ecosystem component’s likely ability to disturbance and ability to resist damage. recover quickly Badger Limited temporary noise disturbance during It is likely that the increase noise levels are of a N/A construction magnitude that will not significantly adversely affect this ecosystem component, and so will not damage this ecosystem component.
Birds within the Project Limited temporary noise disturbance during It is likely that the increase noise levels are of a N/A site construction magnitude that will not significantly adversely affect this ecosystem component, and so will not damage this ecosystem component.
Birds in the local vicinity Limited temporary noise disturbance during It is likely that the increase noise levels are of a N/A of the Project site construction magnitude that will not significantly adversely affect this ecosystem component, and so will not damage this ecosystem component.
Common reptiles Limited temporary disturbance during Temporary disturbance during construction of N/A construction the pipe run construction will affect a very small proportion of the habitat which may be used by this ecosystem component. Given the alternative habitat areas available, and the low likelihood of reptiles being present, it will not affect the functionality, so it is able to effectively resist functional damage and there will not be any adverse consequences on this ecosystem component.
Ecosystem Component Likely disturbance as a result of the Project Ecosystem components likely response to Ecosystem component’s likely ability to disturbance and ability to resist damage. recover quickly Terrestrial invertebrates Limited temporary disturbance during Temporary disturbance during construction of N/A construction the Project and associated infrastructure will affect a very small proportion of the habitat which may be used by this ecosystem component. Given the alternative habitat areas available, it will not affect the functionality, so it is able to effectively resist functional damage and there will not be any adverse consequences on this ecosystem component.
All other baseline features identified within the EcIA are, in the context of the Project site, of negligible ecological value and any temporary losses or disturbance will have insignificant effects on ecosystem resilience.
7.4 SUMMARY OF ECOSYSTEM RESILIENCE ASSESSMENT
The ecosystems and there components parts identified within the Project either will not be affected, or a resilient to disturbance, resist damage, and if damaged will recover quickly.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD
56 Annex A
Figures
Proje c t Re d line Bound ary Vale ro’s Existing Pe rm it Bound ary for Pe m b roke Re fine ry
Natural gas p ip e line to c onne c tion p oint with e xisting gas sup p ly
0 100 200 300 400 500 ! Me tre s Coge n p lant c om p rising: ± - CTG (c om b ustion turb ine ge ne rator) Ste am Conne c tions - HRSG (he at re c ove ry ste am ge ne rator) SCALE: 1:15,000 VERSIO N: A01
- De m in unit ! SIZ E: A4 DRAWN: WB
! PRO JECT: 0359804 CHECKED: NS
! ! DATE: 02/05/2017 APPRO VED: HB
! ! Figure A.1 132kV Me te r Skid Map of Site Location d i r G l a n Sub stations o i t a N h s i t i r B
: N O I T C E J O R P
Sourc e : Esri, DigitalGlob e , Ge oEye , Earthstar Ge ograp hic s, CNES/Airb us DS, USDA, USGS, Ae roGRID, IGN, and the GIS Use r Com m unity Path: \\ukb rsd c 02\Data\Bristol\Confid e ntial Proje c ts\0359804 Vale ro UK Proje c t Eagle .HB\Working Fold e rs\08. GIS\MAPS\Final Sub m ission Figure s\P0359804_Ec IA_Site Loc ation_A01.m xd Project Redline Boundary 2km Buffer of Project Redline Boundary 15km Buffer of Project Redline Boundary ^_ Proposed SSSI Location Special Area of Conservation (SAC) Special Protection Area (SPA) Site of Special Scientific Interest (SSSI) Ancient Woodland Inventory (2011) Local Nature Reserve Pembrokeshire Coast National Park
^_
0 1 2 3 4 5 Kilometres ± SCALE: 1:200,000 VERSION: A01
SIZE: A4 DRAWN: WB
PROJECT: 0359804 CHECKED: NS
DATE: 02/05/2017 APPROVED: HB Figure A.2 Map of Statutory And Non-Statutory Nature Conservation Sites d i r G l a n o i t a N h s i t i r B
: N O I T C E J O R P
© OpenStreetMap (and) contributors, CC-BY-SA; Contains Natural Resources Wales information © Natural Resources Wales and Path: \\ukbrsdc02\Data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Final Submission Figures\P0359804_EcIA_DesignatedSites_A01.mxd Database Right. All rights Reserved; Cadw 2016 Project Redline Boundary Survey Area
0 50 100 150 200 Metres ± SCALE: 1:5,000 VERSION: A01
SIZE: A4 DRAWN: WB
PROJECT: 0359804 CHECKED: NS
DATE: 18/04/2017 APPROVED: HB Figure A.3 Map of Wider Survey Area d i r G l a n o i t a N h s i t i r B
: N O I T C E J O R P
Source: Valero 2016 Path: \\ukbrsdc02\Data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Final Submission Figures\P0359804_EcIA_WiderSurveyArea_A01.mxd Project Redline Boundary Ecology - Phase 1 Habitats: A2.2 - Scrub - scattered A1.3.2 - Mixed woodland - plantation A2.1 - Scrub - dense/continuous SI SI B2.2 - Neutral grassland - semi-improved SII SII B4 - Improved grassland I I C3.1 - Other tall herb and fern - ruderal A A J1.2 - Cultivated/disturbed land - amenity A A grassland J1.3 - Cultivated/disturbed land - ephemeral/short perennial J3.6 - Buildings Hardstanding
B9 B4a
B7 B4 B8 B10 B6 B5 B15 0 20 40 60 80 100 B16 Metres ± SCALE: 1:2,500 VERSION: A01
SIZE: A4 DRAWN: WB
B3 PROJECT: 0359804 CHECKED: NS
DATE: 02/05/2017 APPROVED: HB Figure A.4 B1 B14 Extended Phase 1 Habitat Survey Map d i r B2 G l a B11a n
o B11 i B13 t B12 a N h s i t i r B
: N O I T C E J O R P
Source: Valero 2016 Path: \\ukbrsdc02\Data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Final Submission Figures\P0359804_EcIA_Phase1Survey_A01.mxd Project Redline Boundary Badger Sett Badger Day Nest Badger Latrine D Badger Hair Badger Footprint D Mammal Pathway With Badger Hair #
D# Mammal Pushthrough With Badger Hair Former Day Nest Foraging Signs Mammal Entrance #
# Mammal Pushthrough D Mammal Activity Indicative Mammal Pathway
0 50 100 150 200
D
##
D D ## D Metres
# D ± # D SCALE: 1:4,000 REF: A01
SIZE: A4 DRAWN: WB
PROJECT: 0359804 CHECKED: NS # # DATE: 18/04/2017 APPROVED: HB Figure A.5 Badger Survey Results Map d i r G l a n o i t a N h s
i D t i r B
: N O I T C E J O R P
Source: Valero 2016; Contains Natural Resources Wales information © Natural Resources Wales and Database Right. All rights Reserved; Cadw 2016 Path: \\ukbrsdc02\Data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Final Submission Figures\P0359804_EcIA_BadgerSurvey_A01.mxd Level of Impact on Ancient Woodland: Not Significant Exceeds Nitrogen deposition CL Project Redline Boundary 2km Buffer of Project Redline Boundary Ancient Woodland
0 0.5 1 1.5 2 Kilometres ± SCALE: 1:50,000 VERSION: A01
SIZE: A4 DRAWN: WB
PROJECT: 0359804 CHECKED: HB
DATE: 02/05/2017 APPROVED: DP Figure A.6 Air Quality Impacts on Ancient Woodland d i r ! G l a n o i t a N h s i t i r B
: N O I T C E J O R P
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community; Path: \\ukbrsdc02\Data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Final Submission Figures\P0359804_EcIA_AQAncientWoodland_A01.mxd Contains Natural Resources Wales information © Natural Resources Wales and Database Right. All rights Reserved; Cadw 2016
Annex B
Legislation & Planning Policy
1 ANNEX B - LEGISLATION
1.1 RELEVANT NATIONAL AND LOCAL BIODIVERSITY PLANNING POLICIES
The application for the Cogen project is being decided under the DNS in Wales. The planning policies relevant to this assessment are provided in Table B1.1.
Table B1.1 Planning Policies
Planning Policy Summary of Planning Policy Planning Policy Planning Policy Wales (PPW) sets out the land use planning Planning Policy Wales – policies of the Welsh Government. It is supplemented by a Edition 9, 2016 1 series of Technical Advice Notes. Procedural advice is given in circulars and policy clarification letters. It translates the Welsh Government’s commitment to sustainable development into the planning system so that it can play an appropriate role in moving towards sustainability.
Technical Advice Note Technical Advice Note 5 of the National Assembly of Wales (TAN) 5, Nature Planning Division refers to Nature Conservation and Planning Conservation and Planning TAN 5 (2009). TAN 5 is concerned with the protection of (2009) 2 statutorily designated site and habitats, the conservation of protected and priority species and protecting and enhancing biodiversity and nature conservation in the wider countryside within Wales.
Planning (Wales) Act 2015 3 The Planning (Wales) Act (2015) supports the previous two acts by improving the planning process. It ensures planning must take place in the spirit of sustainability, including how it pertains to biodiversity, detailed in Environmental (Wales) Act (2016) and the Well-being of Future Generations (Wales) Act (2015).
One Wales: One Planet (2009) The One Wales: One Planet states that sustainable development 4 in Wales means enhancing the economic, social and environmental wellbeing of people and communities, achieving a better quality of life for our own and future generations in ways which promote social justice and equality of opportunity and which enhance the natural and cultural environment and respect its limits using only our fair share of the earth’s resources and sustaining our cultural legacy. It also states that sustainable development is a core principle within the National Assembly’s founding statute, and the Welsh Government has a statutory duty under the Government of Wales Act 2006 (Section 79), to
(1) http://gov.wales/topics/planning/policy/ppw/?lang=en
(2) http://gov.wales/topics/planning/policy/tans/tan5/?lang=en
(3) http://gov.wales/topics/planning/legislation/planning-wales-act-2015/?lang=en
(4) http://www.wales.nhs.uk/sitesplus/documents/829/One%20Wales-%20One%20Planet%20%282009%29.pdf
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD B1 Planning Policy Summary of Planning Policy develop a scheme setting out how they propose, in the exercise of their functions, to promote sustainable development. Some of the actions set out in the document for achieving this relate to sustaining the environment, including the natural environment.
Environment Strategy for The Environment Strategy for Wales was published in 2006 and Wales (2006) 5 outlines the Welsh Government’s long-term strategy for the environment of Wales, for the next 20 years. It provides a framework within which to achieve an environment, which is clean, healthy, biologically diverse and valued by the people of Wales.
Woodlands for Wales (2011) 6 The Woodlands for Wales strategy was published in 2011 as part of the Environmental Strategy for Wales (2006). It sets out an action plan for protecting Welsh woodlands with a focus on nature, quality, distribution and management. The most relevant theme is concerned with environmental quality by making a positive contribution to biodiversity, landscapes and heritage, and reducing other environmental pressures through management of trees and woodlands.
Pembrokeshire local This Pembrokeshire local development plan lays out future development plan (2013) 7 plans for the development and use of land within Pembrokeshire until 2021. It provides the policy context for directing development to appropriate locations, conserving the natural environment and providing a basis for rational and consistent decision-making on planning applications.
Convention on Biological The CBD strategic plans lay out five strategies for enhancing and Diversity (CBD)- strategic protected biodiversity at a local and national level. plan for 2011-2020 (2010) 8 The EU Biodiversity Strategy The EU adopted strategy, in conjunction with CBDs strategy, (2011) 9 outlines the management system to halt the loss of biodiversity and ecosystem services in the EU by 2020.
The Nature Recovery Plan Legislation sets out how Wales will deliver the commitments of for Wales (2015) the UN Convention on Biological Diversity and the EU Biodiversity Strategy to halt the decline in biodiversity by 2020 and then reverse that decline.
(5) http://gov.wales/topics/environmentcountryside/epq/envstratforwales/?lang=en
(6) http://gov.wales/topics/environmentcountryside/forestry/our-strategy/?lang=en
(7) https://www.pembrokeshire.gov.uk/content.asp?nav=1626,109,2045
(8) https://www.cbd.int/decision/cop/?id=12268
(9) http://ec.europa.eu/environment/nature/biodiversity/strategy/index_en.htm
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD B2 1.2 RELEVANT BIODIVERSITY LEGISLATION FOR PROTECTED OR NOTABLE HABITATS OR SPECIES
The following table lists legislation relevant to this assessment due to the presence of protected or notable habitats or species.
Table 1.2 Legislation for Protected Species and Habitats
Legislation Summary of Legislation Conservation of The legislation lays out the framework for the creation of European Habitats and Species protected sites and the protection of species and habitats within Regulations (2010) (and Europe. subsequent amendments) 10 Ramsar Convention on The legislation provides the framework for the conservation and wise Wetlands of use of wetlands and their resources by designation of protected International Ramsar sites. Importance, (1971) 11 Wildlife and The primary UK legislation that provides the legal framework for the Countryside Act 1981 protection of species and sites. Schedule 9 provides the legal (as amended)12. framework for the management of invasive non-native species. Countryside and Rights The Act regulates public access to certain types of land, amends the of Way Act (2000) 13 law relating to public rights of way, increases measures for the management and protection for Sites of Special Scientific Interest (SSSI) and strengthens wildlife enforcement legislation. Environmental (Wales) Part 1, Section 6 and 7 of the Environmental (Wales) Act deal with the Act (2016) 14 sustainable management of resources with reference to biodiversity. Public authorities must seek to maintain and enhance biodiversity in the exercise of their functions in relation to Wales (section 6) and also seek to ‘promote the resilience of ecosystems’. Welsh ministers must also organise a list of protected organisms and habitats that are important for the maintaining and enhancing of biodiversity in relation to Wales (section 7). This list is available at http://www.biodiversitywales.org.uk/Environment-Wales-Bill).
Natural Environment The Act made amendments to the both the Wildlife and Countryside and Rural Act 1981 and the Countryside and Rights of Way (CROW) Act 2000. Communities (NERC) For example, it extended the CROW biodiversity duty to public bodies Act (2006) 15 and statutory undertakers, and altering enforcement powers in connection with wildlife prosecution.
Protection of Badgers The act affords special protection to badgers and their setts within the Act (1992) 16 UK. Marine and Coastal The act puts in place a mechanism to help ensure biologically diverse
(10) http://www.legislation.gov.uk/uksi/2010/490/contents/made
(11) http://www.ramsar.org/about-the-ramsar-convention
(12) http://www.legislation.gov.uk/ukpga/1981/69
(13) http://www.legislation.gov.uk/ukpga/2000/37/contents
(14) http://gov.wales/topics/environmentcountryside/consmanagement/natural-resources-management/environment- act/?lang=en
(15) http://www.legislation.gov.uk/ukpga/2006/16/pdfs/ukpga_20060016_en.pdf
(16) http://www.legislation.gov.uk/ukpga/1992/51/contents
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD B3 Legislation Summary of Legislation Access Act (2009) 17 oceans and seas by managing and protecting coastal and marine environments by the designation of marine protected sites.
1.3 BATS
All British bats are classed as European Protected Species and are afforded legislative protection under the ‘Conservation of Habitats and Species Regulations 2010’. In addition, all species of bat resident in the UK receive legal protection under the terms of Schedule 5 and 6 of the Wildlife and Countryside Act 1981 (as amended). Together this legislation means it is an offence, with certain exceptions, to:
deliberately capture, injure or kill bats;
damage or destroy a breeding or resting place, even when bats are not present;
obstruct access to their resting or sheltering places, even when bats are not present;
possess, sell, control or transport live or dead bats, or parts of them; and
intentionally or recklessly disturb a bat while it’s in a structure or place of shelter or protection.
Eight species of bat are listed as “living organisms of principal importance” in Wales under Section 7 of the Environment (Wales) Act 2016.
1.4 OTHER EUROPEAN PROTECTED SPECIES
Great crested newt (Triturus cristatus), otter (Lutra lutra) and dormouse (Muscardinus avellanarius) are afforded the same legislative protection as bats under the ‘Conservation of Habitats and Species Regulations 2010’ and the terms of Schedule 5 and 6 of the Wildlife and Countryside Act 1981 (as amended).
Great crested newt, otter and dormouse are also listed as “living organisms of principal importance” in Wales under Section 7 of the Environment (Wales) Act 2016.
1.5 BADGERS
Badgers and their setts are protected under the Protection of Badgers Act 1992, which sets out a series of offenses relating to badgers and their habitats which include:
(17) http://www.legislation.gov.uk/ukpga/2009/23/contents
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD B4
Wilfully killing, injures or takes, or attempts to kill, injure or take, a badger.
Cruelly ill-treating a badger, digging for badgers, using badger tongs, using a firearm other than the type specified under the exceptions within the Act.
Interfering with a badger sett by damaging, destroying, obstructing, causing a dog to enter a sett, disturbing an occupied sett - either by intent or by negligence.
Selling or offering for sale a live badger, having possession or control of a live badger.
Marking a badger or attaching any ring, tag, or other marking device to a badger.
Exceptions may be granted in the case of development, as defined in section 55(1) of the Town and Country Planning Act 1990, to interfere with a badger sett within an area specified in the licence by any means so specified.
1.6 BREEDING BIRDS
All birds, their nests and eggs are protected by the Wildlife and Countryside Act 1981 (as amended) and it is thus an offence, with certain exceptions (see below) intentionally to:
Kill, injure or take any wild bird.
Take, damage or destroy the nest of any wild bird while it is in use or being built.
Take or destroy the egg of any wild bird.
Further protection is afforded to Schedule 1 species for which it is an offence to disturb any wild bird whilst is nest building, or at a nest containing eggs or young, or disturb the dependent young of such a bird.
51 bird species are also listed “living organisms of principal importance” in Wales under Section 7 of the Environment (Wales) Act 2016.
1.7 REPTILES
Common reptile species are afforded ‘partial protection’ under the amended Wildlife and Countryside Act 1981 (as amended, which prohibits the deliberate killing or injury of individuals. There is no direct protection extended to the habitats which support these species.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD B5
All three common reptile species are also listed “living organisms of principal importance” in Wales under Section 7 of the Environment (Wales) Act 2016.
1.8 INVERTEBRATES
Upwards of 30,000 species of invertebrates are recorded in Britain, occurring in every available habitat. About 40 species are afforded full statutory protection in the UK under either European or British legislation. 118 species are listed as “living organisms of principal importance” in Wales under Section 7 of the Environment (Wales) Act 2016.
1.9 BIODIVERSITY ACTION PLANS AND SPECIES LISTS
Environmental (Wales) Act (2016) – Section 7
Section 7 replaces the duty in Section 42 of the NERC Act 2006 and so requires the Welsh Ministers to publish, review and revise lists of living organisms and types of habitat in Wales, which they consider are of key significance to sustain and improve biodiversity in relation to Wales.
The Welsh Ministers must also take all reasonable steps to maintain and enhance the living organisms and types of habitat included in any list published under this section, and encourage others to take such steps.
Local Action Plans
The Local Biodiversity Action Plan (LBAP) for Pembrokeshire (2011) lays out the framework within which existing and new actions are co-ordinated to conserve and enhance biodiversity in Pembrokeshire, taking account of local and national priorities. The project must take into account the conservation and enhancement of biodiversity with reference to the LBAP.
The current Habitat Local Action Plans (HAPs) are grouped as follows:
• Urban/ Brown Field/Buildings/ Gardens; • Grassland; • Farmland; and • Woodland.
The Population Status of Birds in Wales 2 (2009)
This report is similar to the Birds of Conservation Concern 3 list but is considered from a Welsh perspective rather than a UK perspective. The findings are broadly similar but there are have important differences in the classification of conservation concern for a small number of species. A total of
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD B6 213 species have been assessed, there are 45 species on the red list, 100 on the amber list and 68 on the green list
Annex C
Desk Study and Consultation
Topic (General / Species) Contacts / website Actions Dates West Wales Biodiversity West Wales Biodiversity Information Centre – Colin Requested sites, habitat and species data within 2km. Subsequent Aug 2016 Information Centre Russell
Pembrokeshire Rogers, Anthony Requested LBAP, received copies of the available LBAPs. No Dec 2016-Jan 2017 Biodiversity Partnership
Bats http://www.pembsbats.org.uk/home Enhanced desk study contacted local bat groups. No further action. 25.01.2017
NRW/BCT in relation to monitoring data held on NRW data request submitted, information received. No further 25.01.2017 The Pembrokeshire Bats Sites and Bosherston Lakes action. SAC.
Birds http://pembrokeshirebirdgroup.blogspot.co.uk/ Emailed. 26.01.2017 County Recorder, Jon Green, at [email protected]. Response received confirming that would already have received all 30.01.2017 available records for all bird species in the area via WWBIC https://drive.google.com/file/d/0B4wBRJMo- Reviewed for information relevant to the assessment. January – February 2017 MZVTDNXblpRVnJQZFk/view - Pembrokeshire bird report 2015 http://www.birdsinwales.org.uk/downloads/PSo B2.pdf
Amphibians and Reptiles http://groups.arguk.org/SWWARG/ Emailed. Response received to say WWBIC hold all records. No 26.01.2017 Contact Email: [email protected] further action.
Badger Pembrokeshire badger watch and rescue Emailed. 26.01.2017 http://www.badgerland.co.uk/badgergroups/wal No response received. es/pembrokeshirebadgerwatch.html Mike Sharratt, Cwm Coile, Whitland, Pembrokeshire, Wales, SA23 OLU West Wales Badger Group Joy Hands, Highgarth, The Ridgeway, SAUNDERSFOOT, Pembrokeshire, Wales, SA69 9LN Email [email protected]
BSBI http://bsbi.org/local-botany 45 Pembrokeshire: Emailed. 26.01.2017
Topic (General / Species) Contacts / website Actions Dates Stephen Evans [email protected] No response received.
Local bird ringing group Contact details are not publicly available, so are not Emailed. Information received about ringing sites and local January – February 2017 replicated here. Schedule 1 species.
An individual associated Contact details are not publicly available, so are not Emailed requesting any biodiversity records from the past 10 years January – March 2017. with Biodiversity Solutions replicated here. within the Cogen Project Site, wider Valero Refinery Site, and Valero who records and monitors landholdings out with the Refinery site. biodiversity at the Valero Response received for all species groups monitored. Clarification Refinery. sought on some locations. No further actions.
Annex D
Target Notes
EXTENDED PHASE 1 SURVEY TARGET NOTES FROM AUGUST 2016 AND OCTOBER 2016
Target Note 1. – A single small mammal entrance in a western facing embankment. The mammal entrance was partially overgrown by vegetation and no recent signs of use such as hairs, droppings, scrapes or footprints were recorded. Due to the size and depth of the entrance, this is considered too small to be due to badger activity.
Target Note 2. – A mammal push-through in the south-west corner under the perimeter fence. No hairs or footprints were recorded.
Target Note 3. - A mammal push-through under the perimeter fence. Badger hair was recorded from this location. Mammal pathways lead away from here through the adjacent semi-improved grassland and up the embankment
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Annex E
Badger Survey Results
The badger survey was undertaken primarily along the southern mixed plantation woodland embankment and in a survey area of up to 100m from the greatest extent of the currently understood development site (as of 7 February 2017).
Badger setts and active day nests were recorded including:
1 active entrance hole under a fallen tree amongst dense bramble at the bottom of the embankment (only 1-2 feet deep);
1 active entrance hole in a collapsed man hole drain under dense bramble and blackthorn closer to the perimeter fence (2-3 ft vertical, then ceramic pipe – depth unknown);
1 active entrance hole under an arched tree trunk (2ft + deep, but narrowing); and
1 “active” surface nest constructed with hay from the nearby cattle hay rick in the field to south (approx. 2ft by 2ft mound), with badger hairs. (This is considered active, because the hay was fresh and a hair was found) under dense vegetation of bramble and blackthorn.
In addition, three former/inactive surface nests, of decomposing hay with small fresh grass growth, under dense vegetation of bramble and blackthorn All the above were linked by clear pathways through bramble and ivy. One large area of latrines was recorded, with fresh badger droppings, and other older latrine pits in different locations.
Across the embankment and fields there were numerous mammal pathways. Some lead to pushthroughs under the refinery perimeter fence, and a number of these pushthroughs badger hairs were recorded, showing badgers use the mammal pathways and pushthrough.
The pushthrough under the middle of the perimeter fence has been expanded since the survey in October 2016, and there are a number of new attempts at pushthroughs under the fence line, unsuccessful because the perimeter fence is footed by concrete in these areas. There were also scratch marks on the pedestrian access gate in the south-east adjacent to the lane.
There was no additional activity recorded within the refinery site. The small single entrance hole which was recorded in August 2016 showed no recent sign of use, and additional vegetation growth.
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Annex F
Photographs
Photograph 1. Site Overview
Photograph 2. Plantation Woodland
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Photograph 3. Plantation woodland
Photograph 4. Dense / continuous and Scattered Scrub
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Photograph 5 Semi-improved neutral grassland
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Photograph 6.1 and 6.2 Perennial vegetation near hardstanding and perennial vegetation under the pipe runs
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Photograph 7. Building B2, the electrical workshop
Photograph 8. Building B3, Main workshop Area A
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Photograph 9. Building B12
Photograph 10. Operational areas of the refinery within the Survey Area
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Photograph 11. Mammal push through at the southern perimeter fence
Photograph 12. Mammal pathway on southern boundary embankment
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Photograph 13. Mammal entrance in embankment within the site
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Photograph 14. Badger sett entrance under fallen tree
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Photograph 15. Badger sett entrance down a collapsed manhole
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Photograph 16. Badger day nest
(Glove is included for scale.)
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Annex G
Effects of Air Quality on Sites of Special Scientific Interest
1 ANNEX G - INTRODUCTION
1.1 PURPOSE OF THIS ANNEX
This Annex provides an assessment on the likely effects of air quality on Sites of Special Scientific Interest (SSSIs) from the Cogeneration (Cogen) project (the Project) during operation.
1.2 APPROACH TO THE AIR QUALITY ASSESSMENT FOR SSSI
1.2.1 Overview to Screening SSSIs
The approach taken follows the guidance set out by PINS Wales (1), for Habitat Regulations Assessment (HRA) and guidance produced by the Defra / Environment Agency (EA) on screening risks from air emissions on protected areas for nature conservation (2). It has also taken account of a range of other guidance material such as the Planning Inspectorate’s Advice Note 10 (3) and guidance that produced by the European Commission (EC) (2011 (4), 2007 (5); 2002 (6), 2000 (7)).
This process follows the HRA process by initially Screening to identify the likely effects of a project on a SSSI and consider whether there are likely to be adverse effects.
1.2.2 Consultation and Key Issues
The process of compiling this report included regular dialogue with Natural Resources Wales (NRW), as well as discussions with PINS Wales and Pembrokeshire County Council (PCC).
A consultation meeting was held with NRW and PCC on 15 February 2017 to present an overview of the approach that would be taken to the assessment. NRW consultees representing planning, habitats and permitting discussed and agreed the scope of air quality modelling for the HRA. During the meeting it was also agreed that SSSIs within 15 km and ancient woodland within 2 km would be included in Stage 1 screening.
(1) http://gov.wales/docs/desh/publications/160330-dns-appendix-4-habitats-regulations-assessment-en.pdf (2) https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit#screening-for-protected- conservation-areas (3) The Planning Inspectorate (2016) Advice note 10: Habitat Regulations Assessment relevant to nationally significant infrastructure projects (4) European Commission (2011) Guidelines on the Implementation of the Birds and Habitats Directives in Estuaries and Coastal Zones with Particular Attention to Port Development and Dredging. Advice Note 10 EC (5) European Commission (2007) Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC. EC (6) European Commission (2002) Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites. Methodological Guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. EC (7) European Commission (2000) Managing Natura 2000 Sites - The Provisions of Article 6 of the ‘Habitats’ Directive 92/43/CEE. EC ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD G1
1.2.3 Sites of Special Scientific Interest
SSSIs are legally protected under the Wildlife and Countryside Act 1981 (as amended). SSSIs are important as they support plants, animals and habitats that are rare, declining or unique, they also protect the best examples of Wales’s geology. Many SSSIs are also designated under other schemes too, recognising them as the very best examples of natural heritage sites in Wales, the UK, Europe and worldwide.
The Project is located wholly within the Refinery, and no SSSIs will be directly affected by the Project.
In line with the guidance, SSSIs which could be affected by air pollutants from the Project were identified as those which fell within the Project Area of Influence (AoI), based on the air quality modelling presented in the Air Quality Impact Assessment Report (1). This AoI comprises a radius of 15 km from the Project, adopting the worst case distance for effects from larger emitters, as defined by Defra / EA Guidance (2).
Table 1.1 lists those SSSIs that have been scoped in as potentially sensitive to air quality effects. Those sites in grey have been scoped out of assessment as they are insensitive to air quality effects.
Table 1.1 SSSIs within 15 km of the Project SSSI Distance Citation features from site in km Milford Haven 0.58 Ancient woodland, saltmarsh, swamp, saline lagoons, rare and Waterway scarce plants and invertebrates, nationally important numbers of migratory waterfowl, lesser horseshoe bat (Rhinolophus hipposideros ) and otter.
Broomhill 1.51 One of 'Pembrokeshire's largest dune systems with the most Burrows extensive and most diverse dune slack vegetation including species- rich dune grassland and vestigial strandline vegetation occurs on the narrow shingle ridge. Numerous notable plants occur, including scarce lichens while notable insects include several rare beetles, flies, bugs and moths.
Castlemartin 2.56 Described as the best example of calcareous fen in Pembrokeshire. Corse Calcareous flushes support rare plant communities. Reed-bed is largest and most diverse in Pembroke.
(1)ERM, 2017, Air Quality Impact Assessment Report. (2)https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit First accessed 01/02/17 ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD G2
SSSI Distance Citation features from site in km Angle Peninsula 3.01 Characterised by high cliffs, ridges, bedrock slabs, rock pools and Coast /Arfordir rugged pinnacles that extend the width of the shore. Small breeding Penrhyn Angle population of chough (Pyrrhocorrax pyrrhocorrax) - One or 2 pairs a year -and significant proportion of South Pembrokeshire’s non- breeding population. Peregrine falcon (Falco peregrinus) regularly seen.
Somerton Farm 3.01 Soon to be designated SSSI, is of special interest for its grassland cSSSI (1) fungi assemblage and unimproved neutral grassland. It is one of the best grassland fungi sites in Wales. Castlemartin 3.23 Of special interest for marine biology, sand dunes, wetland habitats, Range calcareous grassland, cliff, coastal grassland and heath together with the most extensive area of species-rich grassland in Wales.
Orielton stable 5.78 Designated for bat roost buildings the site contains one of the largest block and nursery roosts of lesser horseshoe bat in Pembrokeshire. cellars Dale and South 8.19 The site is of special interest for its rocky and sandy shore marine Marloes Coast communities, maritime grassland and maritime heath, maritime cliff crevice and ledge vegetation, coastal scrub, assemblage of nationally rare and scarce lichens, feeding and roosting area for chough, assemblage of nationally rare and scarce plants, and its geology.
Stackpole 8.57 An exceptionally biologically diverse site incorporating a wide range of internationally and nationally important habitats and species including limestone and sandy cliffs, marl lakes, epiphytic lichens, otters and invertebrates.
Stackpole 9.06 The clock tower loft contains the most important breeding colony of Courtyard Flats greater horseshoe bat in Wales and the Courtyard Flats lesser and Walled horseshoe nursery bat roost is one of seven confirmed roosts in Garden Pembrokeshire. Park House 9.74 Designated for lesser and greater horseshoe bat roosts in out- Outbuildings, buildings, the site contains one of nine known nursery roosts of Stackpole lesser horseshoe bat in Pembrokeshire.
Hook Wood 10.71 An ancient estuarine woodland of sessile oak (Quercus petraea) clothing the steep outer banks of a major meander of the Western Cleddau estuary. It has numerous ancient woodland indicator plants among the 130 higher plants recorded, and is one of the most diverse of the oak woods that characterise the steeper rocky shorelines of Milford Haven.
Stackpole Quay 10.76 Vegetation typical of moderately sheltered sea-cliffs with much - Trewent Point bracken and gorse dominated scrub swathes the cliffs. The limestone cliffs support species-rich crevice communities
St Bride's Bay 10.88 Vegetation communities include Atlantic sea-cliff grassland, South / De maritime cliffs and slopes, shrub heathland and upland oak Porth Sain woodland dominated by sessile oak. Ffraid
(1) The recent draft citation received from NRW refers to this site as Gweunydd Somerton Meadows SSSI. However, the site is referred to throughout the report as Somerton Farm SSSI for clarity as this was the original site name used during the consultation process. ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD G3
SSSI Distance Citation features from site in km Newgale To 11.16 The site consists of sedimentary cliffs, a series of small sandy bays Little Haven that lie between rocky headlands, intertidal bedrock, boulders and Coast/ Arfordir extensive areas of lower shore sandflats. Further inland the Niwgwl - Aber vegetated coastal slopes support a mixture of maritime grasslands. Bach Breeding peregrine and over-wintering greater horseshoe bats have also been recorded.
Freshwater East 12.17 The site is of special interest for its Old Red Sandstone cliff Cliffs to exposures, plant fossils, and coastal cliff habitats and a number of Skrinkle Haven rare and scarce plants and invertebrates. Yerbeston 13.15 The site consists of 11 areas of wet, rough land which are known Moors/ locally as ‘moors’. The site is of special interest for areas of marshy Rhosydd grassland and neutral grassland, and for populations of the rare Yerbeston marsh fritillary butterfly (Eurodryas aurinia). Some of the moors also have wetter areas with swamp and flush. Most are surrounded by mixtures of broadleaved woodland, scrub and bracken.
Western 13.42 The site is of special interest for brook, river and sea lamprey Cleddau River (Lampetra planeri, Lampetra fluviatilis and Petromyzon marinus) and /Afon Cleddau otter, Ranunculion fluitantis and Callitricho-Batrachion vegetation and Gorllewinol associated riverside habitats. Carew Castle 13.51 Carew Castle and surrounds lie at the head of the Carew River estuary and provide important transitory roosting and feeding sites for greater horseshoe bats (Rhinolophus ferrumequinum) and other bat species. Gas Works Lane 13.51 Geological interest; (Silurian sedimentary rocks exposed in a road Section cutting). The marine fauna of the Haverford Formation is known as (Haverfordwest) one of the richest in the lower Llandovery, including numerous brachiopods, trilobites, corals, bryozoa, crinoids, tentaculitids and nautiloids. A key site for study of lower Silurian stratigraphy and biotas. Marloes Mere 13.62 The site is of special interest for wet acidic pasture vegetation. The shallow winter waters and ponds are frequented by waterfowl. Rare plants present include three-lobed crowfoot (Ranunculus tripartitus) and tubular water-dropwort (Oenanthe fistulosa). Shoalshook 15.33 This, the type-locality of the Cautleyan-Rawtheyan (Ashgill) Railway Cutting Shoalshook Limestone, is a classical geological section. Almost the and Pit entire succession of the limestone development of the Haverfordwest area is exposed, forming the most complete continuously exposed section in the outcrop area of the Shoalshook Limestone. Note: Those sites in grey have been scoped out of assessment as they are insensitive to air quality effects.
Minwear wood SSSI was identified by NRW but scoped out as 16.9 km from the Project.
The locations of these SSSIs are shown at Figure G.1.
The approach to assessing the effects on habitats and species from air emissions is more prescriptive and complex, and further details have been provided in Section 1.3.
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Project Redline Boundary
Gas Works Lane Section 15km Buffer of Project Redline Boundary Afon Cleddau Gorllewinol/ ! (Haverfordwest) Site of Special Scientific Interest (SSSI)
Western Cleddau River !
Minwear Wood !
! Arfordir Niwgwl - Aber Bach/ De Porth Sain Ffraid/ Newgale to Little Haven Coast St Bride's Bay South Rhosydd Yerbeston/ !
! Yerbeston Moors Hook Wood ! !
!
!
!
Milford Haven
Waterway ! ! Marloes Mere
! !
! Dale and South ! Marloes Coast Carew Castle
! Arfordir Penrhyn Angle / ! ! Angle Peninsula Coast ! Somerton Farm Stackpole Quay - Trewent Point Proposed SSSI
Broomhill ! Burrows 0 1 2 3 4 5 Orielton Stable Block and Cellars Kilometres
!
! ±
Castlemartin Corse ! SCALE: 1:175,000 VERSION: A01 ! ! SIZE: A4 DRAWN: WB
Freshwater East Cliffs to ! PROJECT: 0359804 CHECKED: NS Skrinkle Haven DATE: 18/04/2017 APPROVED: HB
Park House Outbuildings, Figure G.1 Stackpole Castlemartin Stackpole SSSIs within 15km Range Stackpole Courtyard Flats d i r and Walled Garden G l a n o i t a N h s i t i r B
: N O I T C E J O R P
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community; Contains Natural Path: \\ukbrsdc02\Data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Final Submission Figures\P0359804_EcIA_AQSSSIs_A01.mxd Resources Wales information © Natural Resources Wales and Database Right. All rights Reserved; Cadw 2016 1.3 APPROACH TO ASSESSING THE EFFECTS ON SSSIS FROM AIR EMISSIONS
Information about the relative sensitivity to air pollutants of qualifying interest habitats and plant species, and habitats supporting qualifying interest fauna species of the SSSIs, was obtained from the Air Pollution Information System (APIS) (1). For SACs and SPAs, the APIS results page shows a list of all relevant features identified at that site. However, this process has not yet been completed for Welsh SSSIs. The categories used to define habitat interest features are very broad in their classification and have not yet been narrowed down to a site-specific list (2). Therefore, the SSSI citations were used to identify relevant habitats and form a site habitat list for each SSSI for the assessment. Where the specific EUNIS (3) habitat type could not be confirmed from the information provided, BAP (Biodiversity Action Plan) Broad Habitat types were used instead.
The critical levels (4) and critical loads (5), used as tools for helping to assess the risk of air pollutants on habitats, were obtained from APIS. Critical levels (eg
for effects from NOx, SO2) are not assessed on a habitat or species-specific basis; rather they are assessed against standards which are applied for all habitat types and locations. These standards are 30 µg m-3 annual average for NOx and
20 µg m-3 annual average for SO2. Effects relating to acid and nutrient nitrogen deposition are considered by a habitat and species specific approach, against the specific critical loads listed in APIS.
The Process Contributions (PC) (6) have been predicted to include concentrations in both the short (24 hr averages) and long term (annual averages).
The screening approach to determine whether the PCs were insignificant, or required further assessment, was undertaken by comparing the PCs, and where necessary Predicted Environmental Contributions (PECs), against the percentages of the critical levels / loads set out in the Defra / EA guidance (7) (see Table 1.2).
(1) http://www.apis.ac.uk/ (2) http://www.apis.ac.uk/srcl/user-guide#SSSI not England (3) EUNIS is a European habitat classification upon which nutrient nitrogen critical loads are based. (4) Critical levels are defined as "concentrations of pollutants in the atmosphere above which direct adverse effects on receptors, such as human beings, plants, ecosystems or materials, may occur according to present knowledge". (Source: www.unece.org/env/lrtap/WorkingGroups/wge/definitions.htm) (5) Critical Loads are defined as: " a quantitative estimate of exposure to one or more pollutants below which significant harmful effects on specified sensitive elements of the environment do not occur according to present knowledge" (Source: www.unece.org/env/lrtap/WorkingGroups/wge/definitions.htm) (6) Process Contribution (PC) is the environmental concentrations of each substance emitted to air (https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit#screening-for-protected- conservation-areas) (7) https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit#screening-for-protected- conservation-areas ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD G6
Table 1.2 Assessment Criteria for Habitats and Species Criterion Assessment Long Term / Short Term PC < 1% of CL Insignificant contribution either alone, or in-combination with (long) other projects. No further assessment required, and PC < 10% of considered in the ecological assessment to have no likely CL (short) significant effect. PC > 1% of CL Insignificant contribution and considered in the ecological (long) or >10% assessment to have no likely significant effect for the Project of CL (short) alone, but further assessment may be required in-combination PEC (1) < 70% with other projects to determine the effects on habitats and of CL species. PC > 1% of CL Potential for significant (2) contribution and considered in the (long) or > ecological assessment to have a likely significant effect for the 10% of CL Project alone, and further assessment may be required in- (short) combination with other projects to determine the effects on PEC > 70% of habitats and species. CL
The levels and loads of air pollutants at habitats in the SSSIs within a 15 km radius from the Project were predicted by air dispersion modelling. Details about the model and its input data can be found in the Air Quality Impact Assessment Report (Doc Ref: Cogen/DNS/AQIA/A01). The predicted levels / loads used in this assessment are based on the Reasonable Worst Case.
The effects on sensitive habitats were initially defined on the basis of the highest predicted levels / loads arising at any point in the designated site within the 15 km radius. If these levels / loads were 1% or more of the CLs, further analyses were undertaken based on the distribution of the affected habitat(s) within the SSSIs, as predicted levels / loads often varied across the SSSI.
1.4 SCREENING FOR POTENTIAL EFFECTS ON SSSIS
1.4.1 Introduction
This section summarises the findings of the screening assessment for the SSSIs. The assessment of SSSIs follows the HRA (Doc Ref: Cogen/DNS/HRA/A01) as a number of the SSSIs are component parts of European Sites. The HRA indicates
that SO2 is not an important component of the Cogen emissions and is therefore not considered further.
(1) Predicted Environmental Concentration (PEC) is the PC for each substance plus the concentration of the substance already present in the environment. The screening test is a PEC of <70%. This is a precautionary value set by the Defra/EA guidance to allow for uncertainties, being well below the previous value of 100%. (2) The term ‘significant’ is used here in the context of its meaning within the Defra/EA guidance and not within the context of the EIA Regulations. ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD G7
Table 1.3 contains details of the predicted levels of nutrient nitrogen deposition. Table 1.4 contains details of the acid deposition and Table 1.5 and Table 1.6 NOx at each of the SSSIs affected, and the PC/PEC as percentages of the CLs.
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Table 1.3 Predicted Nutrient Nitrogen Deposition at Ecological Receptors (Annual Mean) – for Reasonable Worst Case
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Milford Haven Supralittoral rock Waterway SSSI Fen, marsh and swamp D5: sedge and reedbeds, normally Sensitive but no 0.2740 n/a n/a 18.2 n/a n/a n/a n/a without free-standing water CL
Inshore sublittoral rock A3. .1:: infralittoral rock very exposed to wave action and/or currents and tidal streams; A3.2: infralittoral rock moderately exposed to wave action and/or currents and Not sensitive 0.2740 n/a n/a 13.72 n/a n/a n/a n/a tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams
Inshore sublittoral sediment A5: deep sea bed Lowland heathland (priority 10 20 0.2740 2.74 1.37 18.2 18.47 185 92 Yes habitat) F4.2: dry heaths Supralittoral sediment B1:
coastal dune and sand habitats 8 15 0.2740 3.42 1.83 18.2 18.47 231 123 Yes (type: coastal stable dune
grasslands)
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Littoral sediment A2
Littoral rock A1 Not sensitive 0.2740 n/a n/a 18.2 n/a n/a n/a n/a
Lowland meadows (priority
habitat); calcareous E2.2: low 20 30 0.2740 1.37 <1 18.2 18.47 92 62 Yes and medium altitude hay
meadows
Lowland mixed deciduous 10 20 0.2740 5.48 2.74 29.96 30.51 305 153 Yes woodland (priority habitat)
Broomhill Calcareous grassland E1.2: Burrows SSSI perennial calcareous grassland 15 25 0.0585 <1 <1 10.78 - - - No and basic steppes,
Littoral sediment Not sensitive 0.0585 n/a n/a 10.78 n/a n/a n/a n/a
Maritime cliff and slopes (priority habitat) B3.4: soft sea- cliffs, often vegetated; B3.3: rock Sensitive but no cliffs, ledges and shores with CL 0.0585 n/a n/a 8.68 n/a n/a n/a n/a halophytic angiosperms,
Lowland meadows (priority habitat); acid E2.2: low and 20 30 0.0585 <1 <1 10.78 - - - No medium altitude hay meadows
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Coastal vegetated shingle (priority habitat) B2.4: fixed shingle beaches, with herbaceous vegetation, 10.78 8 15 0.0585 <1 <1 - - - No
Coastal sand dunes (priority habitat) B1: coastal dune and sand habitats (type: coastal stable dune grasslands)
Lowland fens (priority habitat) 15 30 0.0585 <1 <1 10.78 - - - No D4: base-rich fens
Castlemartin Lowland fens (priority habitat) 0.0377 15 30 <1 <1 11.62 - - - No Corse SSSI D4: base-rich fens Angle Peninsula Acid grassland E1.9: Non- Coast/ Arfordir Mediterranean dry acid and Penrhyn Angle neutral open grassland, SSSI including inland dune grassland 8 15 0.0221 <1 <1 9.1 - - - No Supralittoral sediment B1: coastal dune and sand habitats (type: coastal stable dune grasslands) Sensitive but no Supralittoral rock CL 0.0221 n/a n/a 9.1 n/a n/a n/a n/a
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Inshore sublittoral rock A3.1: infralittoral rock very exposed to wave action and/or currents and tidal streams; A3.2: infralittoral Not Sensitive 0.0221 rock moderately exposed to n/a n/a 7.56 n/a n/a n/a n/a
wave action and/or currents and tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams Littoral rock A1: Littoral rock and other hard substrata Not Sensitive 0.0221 n/a n/a 9.1 n/a n/a n/a n/a
Littoral sediment Maritime cliff and slopes (priority habitat) B3.3: rock cliffs, Sensitive but no ledges and shores with CL 0.0221 n/a n/a 7.56 n/a n/a n/a n/a halophytic angiosperms; B3.4: soft sea-cliffs, often vegetated Somerton Farm Grassland 20 30 0.0849 <1 <1 1.5 - - - No cSSSI Castlemartin Calcareous grassland E1.2: Range SSSI perennial calcareous grassland 15 25 0.0339 <1 <1 12.32 - - - No and basic steppes
Lowland heathland (priority 10 20 0.0339 <1 <1 12.32 - - - No habitat) F4.2: dry heaths
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Inshore sublittoral rock A3.1: infralittoral rock very exposed to wave action and/or currents and tidal streams; A3.2: infralittoral rock moderately exposed to Not sensitive 0.0339 n/a n/a 8.54 n/a n/a n/a n/a wave action and/or currents and tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams Littoral rock A1: Littoral rock and other hard substrata Not Sensitive 0.0339 n/a n/a 12.32 n/a n/a n/a n/a
Littoral sediment Maritime cliff and slopes (priority habitat) B3.3: rock cliffs, Sensitive but no ledges and shores with CL 0.0339 n/a n/a 8.54 n/a n/a n/a n/a halophytic angiosperms; B3.4:
soft sea-cliffs, often vegetated
Lowland meadows (priority habitat); calcareous E2.2: low 20 30 <1 <1 12.32 - - - No and medium altitude hay 0.0339 meadows Lowland fens (priority habitat) 15 30 0.0339 <1 <1 12.32 n/a n/a n/a No D4: base-rich fens
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Dale and South Dwarf shrub heath F4: 0.0135 10 20 <1 <1 - - - No Marloes Coast Temperate shrub heathland 9.24 SSSI Littoral rock A1: Littoral rock Not sensitive 0.0135 and other hard substrata n/a n/a 9.24 n/a n/a n/a n/a
Bracken
Maritime cliff and slopes (priority habitat) B3.3: rock cliffs, ledges and shores with halophytic angiosperms; B3.4: soft sea-cliffs, often vegetated
Not sensitive Inshore sublittoral rock A3.1: 0.0135 n/a n/a 6.02 n/a n/a n/a n/a
infralittoral rock very exposed to wave action and/or currents and Tidal streams; A3.2: infralittoral rock moderately exposed to wave action and/or currents and tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams Lowland meadows (priority 0.0135 habitat); acid E2.2: low and 20 30 <1 <1 - - - No 9.24 medium altitude hay meadows
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Stackpole SSSI Coastal heathland - dwarf shrub heath 0.0279 10 20 <1 <1 12.32 - - - No
Lowland Lichen/bryophyte Heath - dwarf shrub heath
0.0279 Continuous bracken – bracken Not sensitive n/a n/a 8.54 n/a n/a n/a n/a
0.0279 Fen - fen, marsh and swamp 10 15 <1 <1 - - - No 12.32 Maritime cliff & associated ledges and crevices - maritime cliff and slopes
Sensitive but no 0.0279 8.54 Other: marginal/inundation - n/a n/a n/a n/a n/a n/a CL standing open water and canals
Standing water, standing open water and canals Lowland meadows (priority habitat); calcareous E2.2: low 0.0279 20 30 <1 <1 12.32 - - - No and medium altitude hay meadows 0.0279 Rockpools Not sensitive n/a n/a 12.32 n/a n/a n/a n/a
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Scrub - wet woodland 0.0558 20.3 10 20 <1 <1 - - - No Semi-natural woodland - lowland mixed dec wl 0.0558 20.3 Scrub - lowland mixed dec wl 10 20 <1 <1 - - - No
Soft paddock bored substrata - 0.0279 12.32 Not sensitive n/a n/a n/a n/a n/a n/a littoral sediment Stackpole Quay Dwarf shrub heath F4: 0.0241 12.32 10 20 <1 <1 - - - No Trewent Point Temperate shrub heathland SSSI Maritime cliff and slopes (priority habitat) B3.3: rock cliffs, Sensitive but no 8.54 ledges and shores with ds n/a n/a n/a n/a n/a n/a CL halophytic angiosperms; B3.4: soft sea-cliffs, often vegetated Inshore sublittoral rock A3.1: infralittoral rock very exposed to wave action and/or currents and tidal streams; A3.2: infralittoral 0.0241 rock moderately exposed to Not sensitive n/a n/a 8.54 n/a n/a n/a n/a
wave action and/or currents and tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams Littoral rock A1: Littoral rock and other hard substrata 0.0241 Not sensitive n/a n/a 12.32 n/a n/a n/a n/a
Littoral sediment
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Hook Wood SSSI Fen, marsh and swamp D2: No 0.0174 15.68 valley mires, poor fens and 10 15 <1 <1 - - -
transition mires Lowland mixed deciduous 0.0348 26.04 10 20 <1 <1 - - - No woodland (priority habitat) De Porth Sain Coastal grassland - supralittoral Sensitive but no 0.0120 Ffraid/ St Bride’s rock n/a n/a 12.46 n/a n/a n/a n/a CL Bay South SSSI Coastal heathland - dwarf shrub 0.0120 10 20 <1 <1 12.46 - - - No heath Continuous bracken - bracken
Sensitive but no 0.0120 Maritime cliff & associated n/a n/a 8.26 n/a n/a n/a n/a CL ledges and crevices - maritime cliff and slopes Moderately exposed rock - 0.0120 Not sensitive n/a n/a 8.26 n/a n/a n/a n/a inshore sublittoral rock 0.0241 21 No Scrub - lowland mixed dec wl 10 20 <1 <1 - - -
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Arfordir Niwgwl- Sensitive but no Aber Bach/ Supralittoral rock CL 0.0054 n/a n/a 13.58 n/a n/a n/a n/a Newgale To Little Haven Coast Inshore sublittoral rock A3.1: SSSI infralittoral rock very exposed to wave action and/or currents and tidal streams; A3.2: infralittoral rock moderately exposed to Not Sensitive 0.0054 n/a n/a 8.68 n/a n/a n/a n/a wave action and/or currents and Tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams Littoral rock A1: Littoral rock and other hard substrata Not Sensitive 0.0054 n/a n/a n/a n/a n/a n/a n/a
Lowland meadows (priority No habitat); calcareous E2.2: low 20 30 0.0054 <1 <1 13.58 - - - and medium altitude hay meadows
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Freshwater East Dwarf shrub heath F4: 0.0221 10 20 <1 <1 10.92 - - - No Cliffs To Temperate shrub heathland Skrinkle Haven Inshore sublittoral rock A3.1: SSSI infralittoral rock very exposed to wave action and/or currents and tidal streams; A3.2: infralittoral 0.0221 rock moderately exposed to Not sensitive n/a n/a 8.12 n/a n/a n/a n/a
wave action and/or currents and tidal streams; A3.3: infralittoral rock sheltered from wave action and current and tidal streams Maritime cliff and slopes (priority habitat) B3.3: rock cliffs, 0.0221 ledges and shores with Sensitive but no n/a n/a n/a n/a n/a n/a 8.12 halophytic angiosperms; B3.4: CL soft sea-cliffs, often vegetated Lowland meadows (priority No habitat); calcareous E2.2: low 0.0221 10.92 20 30 <1 <1 - - - and medium altitude hay meadows Coastal sand dunes (priority No habitat) and supralittoral 0.0221 sediment B1: coastal dune and 8 15 <1 <1 10.92 - - -
sand habitats (type: coastal stable dune grasslands)
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Littoral rock A1: Littoral rock and other hard substrata 0.0221 Not sensitive n/a n/a 10.92 n/a n/a n/a n/a
Littoral sediment Lowland mixed deciduous 0.0443 18.06 No 10 20 <1 <1 - - - woodland (priority habitat) Rhosydd 0.0223 13.72 Bracken Not sensitive n/a n/a n/a n/a n/a n/a Yerberston/ Yerbeston Moors Purple moor grass and rush No SSSI pastures (priority habitat) E3.51: [Molinia caerulea] meadows and
related communities 0.0223 15 25 <1 <1 16.8 - - -
Fen, marsh and swamp E3.5: moist or wet oligotrophic grassland Lowland meadows (priority No 0.0223 habitat); acid E2.2: low and 20 30 <1 <1 16.8 - - -
medium altitude hay meadows
Standing open water and canals Sensitive but no 0.0223 n/a n/a 13.72 n/a n/a n/a n/a J5.1; J5.3; C1; C3 CL
Lowland mixed deciduous 0.0447 26.88 No 10 20 <1 <1 - - - woodland (priority habitat)
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Afon Cleddau Fen, marsh and swamp D2: No 0.0081 Gorllewinol/ valley mires, poor fens and 10 15 <1 <1 20.02 - - -
Western Cleddau transition mires River SSSI Marshy grassland - neutral grassland Sensitive but no 0.0081 n/a n/a 20.02 n/a n/a n/a n/a CL
Fen - purple moor grass and 0.0081 15 25 <1 <1 20.02 - - - No rush pastures
Inter-tidal - littoral sediment 0.0081 20.02 Not sensitive n/a n/a n/a n/a n/a n/a
0.0081 20.02 No Raised bog, lowland raised bog 5 10 <1 <1 - - -
Other, broadleaved Plantation - No wet woodland 10 20 0.0162 <1 <1 32.48 - - - Other, broadleaved Plantation - lowland mixed dec Woodland Marloes Mere Sensitive but no Standing open water and canals SSSI CL 0.0101 n/a n/a n/a n/a n/a n/a J5.1; J5.3; C1; C3 5.46
Fen, marsh and swamp E3.5: No 0.0101 moist or wet oligotrophic 15 25 <1 <1 6.86 - - -
grassland
SSSI SSSI Critical Load Process PC/CL (%) Background PEC PEC/CL (%) Potential Air Citation (CL) for Contribution Nutrient Nitrogen (kgN Quality Effect feature Nutrient (PC) (kgN Deposition (kgN ha-1 Nitrogen ha-1 yr-1) ha-1 yr-1) yr-1) Deposition (kgN ha-1 yr-1) Min Max Min Max Min Max Carew Castle No SSSI Calcerous grassland 10 15 0.0316 <1 <1 14.7 - - -
No Neutral grassland - lowland 0.0316 20 30 <1 <1 14.7 - - - meadows
Other, built-up areas - built-up 0.0316 Not sensitive n/a n/a 10.08 n/a n/a n/a n/a areas and gardens
Table 1.4 Predicted Acid Deposition at Ecological Receptors (Annual Mean) - Reasonable Worst Case for most sensitive qualifying features (low range)
Site Most Sensitive Habitat Feature Critical Load (CL) for Acid Background Acid PCtotal PECtotal Significance Deposition (keq ha-1 yr-1) Deposition (keq ha-1 as % of as % of CL yr-1) CL total total
CL max CL min CL max S N S N N baseline baseline Milford Haven Waterway Coastal Vegetated Shingle (Priority Habitat) 0.39 0.223 0.756 0.5 1.3 <1 - Insignificant SSSI B2.6: Shingle And Gravel Beach Woodland Broomhill Burrows SSSI Coastal Vegetated Shingle (Priority Habitat) 0.8 0.223 1.23 0.5 0.77 <1 - Insignificant B2.6: Shingle And Gravel Beach Woodland Castlemartin Corse SSSI Lowland Beech And Yew Woodland (Priority 2.562 0.142 2.919 0.24 1.39 <1 - Insignificant Habitat) G3.971: Atlantic [Taxus baccata] Woods Arfordir Penrhyn Angle / Coastal Vegetated Shingle (Priority Habitat) 0.8 0.223 1.23 0.28 0.65 <1 - Insignificant Angle Peninsula Coast B2.6: Shingle And Gravel Beach Woodland SSSI
Site Most Sensitive Habitat Feature Critical Load (CL) for Acid Background Acid PCtotal PECtotal Significance Deposition (keq ha-1 yr-1) Deposition (keq ha-1 as % of as % of CL yr-1) CL total total
CL max CL min CL max S N S N N baseline baseline Somerton Farm cSSSI Grassland ------Castlemartin Range SSSI Lowland Beech And Yew Woodland (Priority 1.799 0.142 1.941 0.26 1.45 <1 - Insignificant Habitat) G3.971: Atlantic [Taxus baccata] Woods Dale And South Marloes Lowland Beech And Yew Woodland (Priority 0.886 0.142 1.166 0.24 1.13 <1 - Insignificant Coast SSSI Habitat) G3.971: Atlantic [Taxus baccata] Woods Stackpole SSSI scrub - lowland beech and yew woodland 1.782 0.142 1.924 0.26 1.45 <1 - Insignificant Hook Wood SSSI Native Pine Woodlands (Priority Habitat) 1.563 0.142 1.748 0.34 1.86 <1 - Insignificant Stackpole Quay - Trewent Lowland Beech And Yew Woodland (Priority 1.783 0.142 1.925 0.26 1.45 <1 - Insignificant Point SSSI Habitat) G3.971: Atlantic [Taxus baccata] Woods De Porth Sain Ffraid / St Scrub - Lowland Beech And Yew Woodland 0.882 0.142 1.167 0.26 1.5 <1 - Insignificant Bride's Bay South SSSI Arfordir Niwgwl - Aber Broadleaved, Mixed And Yew Woodland F3.1; 1.513 0.142 1.655 0.26 1.65 <1 - Insignificant Bach / Newgale To Little F9.1; F9.2; G; G1; G2; G4; G5.2; G5.3; G5.5; Haven Coast SSSI G5.6; G5.7; G5.81; E5.2 Freshwater East Cliffs To Coastal Vegetated Shingle (Priority Habitat) 0.8 0.223 1.23 0.21 0.78 <1 - Insignificant Skrinkle Haven SSSI B2.6: Shingle And Gravel Beach Woodland Rhosydd Yerbeston / Lowland Beech And Yew Woodland (Priority 1.598 0.142 1.744 0.34 1.92 <1 - Insignificant Yerbeston Moors SSSI Habitat) G3.971: Atlantic [Taxus baccata] Woods Afon Cleddau Raised Bog 0.275 0.321 0.596 0.27 1.43 <1 - Insignificant Gorllewinol / Western Cleddau River SSSI Carew Castle SSSI Neutral Grassland - Upland Hay Meadows 4.5 0.223 4.273 0.27 1.05 <1 - Insignificant
Marloes Mere SSSI Neutral Grassland 0.39 0.366 0.756 0.16 0.49 <1 - Insignificant
Table 1.5 Predicted NOx at Ecological Receptors (Annual Mean) – Reasonable Worst Case
Background Critical Level Sites Conditions (µg m- PC (µg m-3) PC / CL (%) PEC (µg m-3) PEC / CL(%) Significance (µg m-3) 3) Milford Haven Waterway SSSI 30 19.0 1.9046 6.35 20.9 69.6 Insignificant Broomhill Burrows SSSI 30 12.0 0.4065 1.36 12.4 41.2 Insignificant Castlemartin Corse SSSI 30 9.39 0.2622 <1 - - Insignificant Arfordir Penrhyn Angle / Angle Peninsula Coast 30 9.70 0.1536 <1 - - Insignificant SSSI Somerton Farm cSSSI 30 10.64 0.614 2.05 11.25 37.5 Insignificant Castlemartin Range SSSI 30 9.22 0.2354 <1 - - Insignificant Dale And South Marloes Coast SSSI 30 8.42 0.0937 <1 - - Insignificant Stackpole SSSI 30 7.47 0.1940 <1 - - Insignificant Hook Wood SSSI 30 10.0 0.1211 <1 - - Insignificant Stackpole Quay - Trewent Point SSSI 30 7.23 0.1678 <1 - - Insignificant De Porth Sain Ffraid / St Bride's Bay 30 7.98 0.0837 <1 - - Insignificant Arfordir Niwgwl - Aber Bach / Newgale To Little 30 7.98 0.0376 <1 - - Insignificant Haven Coast SSSI Freshwater East Cliffs To Skrinkle Haven SSSI 30 7.76 0.1539 <1 - - Insignificant
30 8.87 0.1552 <1 - - Insignificant Rhosydd Yerbeston/Yerbeston Moors SSSI Afon Cleddau Gorllewinol/Western Cleddau River 30 15.43 0.0562 <1 - - Insignificant SSSI Carew Castle SSSI 30 9.70 0.2197 <1 - - Insignificant Marloes Mere SSSI 30 6.50 0.0701 <1 - - Insignificant
Table 1.6 Predicted NOx at Ecological Receptors (24 hr Mean) – Reasonable Worst Case
Background Critical Level Sites Conditions (µg m- PC (µg m-3) PC / CL (%) PEC (µg m-3) PEC / CL(%) Significance (µg m-3) 3) Milford Haven Waterway SSSI 75 37.9 12.30 16.4 50.2 67.0 Insignificant Broomhill Burrows SSSI 75 23.9 10.77 14.4 34.7 46.3 Insignificant Castlemartin Corse SSSI 75 18.8 7.24 <10 - - Insignificant Arfordir Penrhyn Angle / Angle Peninsula Coast SSSI 75 19.4 7.40 <10 - - Insignificant Somerton Farm cSSSI 75 21.3 7.18 <10 - - Insignificant Castlemartin Range SSSI 75 18.4 6.37 <10 - - Insignificant Dale And South Marloes Coast SSSI 75 16.8 2.94 <10 - - Insignificant Stackpole SSSI 75 14.9 3.23 <10 - - Insignificant Hook Wood SSSI 75 20.0 2.20 <10 - - Insignificant Stackpole Quay - Trewent Point SSSI 75 14.5 2.76 <10 - - Insignificant De Porth Sain Ffraid / St Bride's Bay South SSSI 75 16.0 1.80 <10 - - Insignificant Arfordir Niwgwl - Aber Bach / Newgale To Little Insignificant 75 16.0 2.03 <10 - - Haven Coast SSSI Freshwater East Cliffs To Skrinkle Haven SSSI 75 15.5 2.05 <10 - - Insignificant Rhosydd Yerbeston/Yerbeston Moors SSSI 75 17.7 2.68 <10 - - Insignificant Afon Cleddau Gorllewinol/Western Cleddau River Insignificant 75 30.9 1.93 <10 - - SSSI Carew Castle SSSI 75 19.4 2.02 <10 - - Insignificant Marloes Mere SSSI 75 13.0 1.92 <10 - - Insignificant
1.4.2 Screening Assessment
Table 1.7 summarises the screening assessment for each SSSI, detailing where potential effects from nutrient nitrogen deposition have been identified and providing an assessment of these potential effects on the citation features.
ENVIRONMENTAL RESOURCES MANAGEMENT VALERO ENERGY LTD G19
Table.1.7 Screening Summary for SSSIs
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment. Milford Haven Waterway SSSI Scoped out of requiring further The AQ assessment identified potential secondary effects from deposited nitrogen on the assessment following habitats: supralittoral sediment (coastal dune and sand habitats) (min PC > 1% of CL (3.42%) and min PEC > 70% of CL (231%); lowland mixed deciduous woodland (min PC > 1% of CL (5.48%) and min PEC > 70% of CL (305%); and lowland meadows (min PC > 1% of CL (1.37%) and min PEC > 70% (92%).
In addition, no CLs were available for fen, marsh and swamp habitat. For supralittoral sediment and fen, marsh and swamp habitats, nutrient nitrogen inputs for these habitats are influenced predominantly by water based nutrient loadings (eg from tidal inputs where subject to regular inundation, or from agricultural run-off in drier and more densely vegetated areas) rather than by air emissions.
For lowland meadows, the min PC only marginally exceeds the 1% criteria and the max PC is under the criteria (0.91%). In addition, the grassland habitats are referred to in the citation in the context of providing foraging areas for bats. It is unlikely that any small increase in nitrogen deposition from air emissions will adversely affect the grassland habitats function for foraging bats and therefore no significant effects are predicted.
For the lowland mixed deciduous woodland, a recent report from Pembrokeshire Biodiversity Partnership (1) does not identify nitrogen deposition as an impact of concern, with the key concerns being loss and fragmentation, lack of or inappropriate management, loss of genetic integrity, invasive species and climate change. Therefore, no significant effects on the woodland habitat including the lichen communities at Lawrenny Wood are predicted.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
(1) Pembrokeshire Biodiversity Partnership. April 2016. The State of Wildlife in Pembrokeshire
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment.
Other habitats are also present which are not sensitive.
Additional information has been provided (see Figures G.2 and G.3) in response to a request by NRW (letter dated 12 June 2017) which shows locations where the predicted NOx PECs for annual mean and 24 hr max are greater than 65% of the CLs (all predicted NOx PECs were less than 70%), and where those locations also lie above high water within the SSSI (ie is not submerged, or subject to regular washing by water). The boundary of the SSSI is considerably larger than shown in the figures. The figures focus on the few locations where PEC>65% and the location is above the high water mark.
Broomhill Burrows SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: calcareous grassland; lowland meadows; coastal vegetated shingle; coastal sand dunes; or lowland fens.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Castlemartin Corse SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on lowland fen habitat.
Angle Peninsula coast SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: acid grassland; and supralittoral sediment (coastal dune and sand habitats).
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment. No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Somerton Farm cSSSI (candidate SSSI proposed Criteria not exceeded The site is dominated by unimproved neutral grassland that supports important grassland fungi for grassland fungi) communities. As this is a candidate site, no information is currently available on the APIS website regarding critical loads. An assumed CL (20 – 30) was used for the assessment, as this is the standard CL for neutral grasslands.
The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen on the grassland habitat.
Castlemartin Range (previously called Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen Castlemartin Cliffs and Dunes SSSI) assessment on: calcareous grassland; lowland heathland; lowland meadows; and lowland fens.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Dale and South Marloes Coast SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: dwarf shrub heath; and lowland meadows.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment. slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Stackpole SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: dwarf shrub heath; fen, marsh and swamp; lowland meadows; wet woodland; and lowland mixed deciduous woodland.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
No CLs were available for the assessment of standing open water and canal habitats. However, nutrient nitrogen inputs for these habitats are influenced predominantly by water based nutrient loadings (eg from tidal inputs where subject to regular inundation, or from agricultural run-off in drier and more densely vegetated areas) rather than by air emissions.
Other habitats are also present which are not sensitive.
Hook Wood SSSI Criteria not exceeded The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen on: lowland mixed deciduous woodland; and fen, marsh and swamp.
Stackpole Quay to Trewent Point SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on dwarf shrub heath.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment. slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
St Bride’s Bay South SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: dwarf shrub heath; and lowland mixed deciduous woodland.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Newgale to Little Haven Coast SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on lowland meadows.
No CLs were available for the assessment of supralittoral rock habitats (maritime cliffs and slopes). However, eutrophication is not a key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Freshwater East to Skrinkle Haven SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: dwarf shrub heath; lowland meadows; coastal sand dunes; and lowland mixed deciduous woodland.
No CLs were available for the assessment of maritime cliffs and slopes. Eutrophication is not a
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment. key risk for this habitat type and therefore no significant effects are predicted.
Other habitats are also present which are not sensitive.
Yerbeston Moors SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: purple moor grass and rush pastures; fen, marsh and swamp; lowland meadows; and lowland mixed deciduous woodland.
No CLs were available for the assessment of standing open water and canals, but nutrient nitrogen inputs for these habitats are influenced predominantly by water based nutrient loadings (eg from agricultural run-off) rather than by air emissions, suggesting that the effects on this habitat are unlikely to be significant.
Other habitats are also present which are not sensitive.
Western Cleddau River SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on: purple moor grass and rush pastures; fen, marsh and swamp; wet woodland; lowland mixed deciduous woodland; and raised bog.
No CLs were available for the assessment of marshy grassland – neutral grassland, but comparison to other similar habitat types with varying critical loads suggests that these would also not be significant.
Other habitats are also present which are not sensitive.
SSSI Potentially Sensitive to Air Quality Criteria not exceeded or can be Rationale for Assessment Effects Scoped out of requiring further assessment. Carew Castle SSSI Criteria not exceeded The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen on: calcareous grassland; and neutral grassland – lowland meadows.
Other habitats are also present which are not sensitive.
Marloes Mere SSSI Scoped out of requiring further The AQ assessment found no significant effects (< 1% max PC) as a result of deposited nitrogen assessment on fen, marsh and swamp habitat.
No CLs were available for the assessment of standing open water and canals, but nutrient nitrogen inputs for these habitats are influenced predominantly by water based nutrient loadings (eg from agricultural run-off) rather than by air emissions, suggesting that the effects on this habitat will not be significant.
Modelled Prediction Grid Locations Figure G.2 0 0.5 1 1.5 2 NOX Annual Mean PEC - Milford Haven Projected NOX Annual Mean - PEC Kilometres Waterway SSSI 65% - 70% of Critical Level Within Area Of SSSI Above High Water Line (Estimated maximum PEC is less than 70% at all modelled locations) ± Area Within SSSI Boundary and Above High Water Line SCALE: 1:40,000 VERSION: A01 SIZE: A3 DRAWN: WB Milford Haven Waterway SSSI PROJECT: 0359804 CHECKED: AC
Project Redline Boundary DATE: 19/09/2014 APPROVED: DP PROJECTION:British National Grid
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Path: \\ukbrsdc02\data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Air Quality\Milford Haven Waterway SSSI\P0359804_ValeroCogen_NOxAnnMean_PEC_A01.mxd Modelled Prediction Grid Locations Figure G.3 0 0.5 1 1.5 2 NOX 24 Hour Maximum PEC - Milford Haven Projected NOX 24 Hour Max. - PEC Kilometres Waterway SSSI 65% - 70% of Critical Level Within Area Of SSSI Above High Water Line (Estimated maximum PEC is less than 70% at all modelled locations) ± Area Within SSSI Boundary and Above High Water Line SCALE: 1:40,000 VERSION: A01 SIZE: A3 DRAWN: WB Milford Haven Waterway SSSI PROJECT: 0359804 CHECKED: AC
Project Redline Boundary DATE: 19/09/2014 APPROVED: DP PROJECTION:British National Grid
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Path: \\ukbrsdc02\data\Bristol\Confidential Projects\0359804 Valero UK Project Eagle.HB\Working Folders\08. GIS\MAPS\Air Quality\Milford Haven Waterway SSSI\P0359804_ValeroCogen_NOx24HrMax_PEC_A01.mxd 1.4.3 Findings of Screening Assessment
Six SSSIs have been scoped out of assessment as they are insensitive to air quality effects (see Table 1.1). A further 17 sites were identified as potentially sensitive to air quality effects within 15 km of the Project.
The air quality modelling concluded that the effects of acid deposition, SO2 and long and short term NOx are not significant for any site. The results of the Screening Assessment for nitrogen deposition are presented in Table 1.7. This shows that for all of the relevant citation features of the SSSIs, either the criteria is not exceeded or further assessment is not required. No significant effects are predicted.
1.5 ASSESSMENT OF IN-COMBINATION EFFECTS
Only information from South Hook and Egnedol were available. Both concluded air quality PC and PEC limits were not exceeded.
The Air Quality (1) and EcIA (2) Reports for South Hook concluded that there will be no likely significant effect on the habitats within national sites within 2 km of the emissions point, Milford Haven Waterway SSSI, as a result of emissions from the CHP Plant.
The Air Quality Report3 for Egnedol indicates that the 60 foot stack and dispersion will result in very small additional nitrogen deposition on Hook Wood SSSI. The Egnedol AQ assessment concluded that given that both the process contributions and background concentrations of acidifying pollutants are likely to be over predictions, along with the seemingly low critical load threshold predicted for the Hook Wood site, it can safely be assumed that the development is unlikely to significantly contribute to acid deposition at these sites.
1.6 SUMMARY
The screening assessment concluded there is no potential effect on the SSSI citation interest features of all the SSSIs from the Project alone or in combination with other projects.
1 https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/EN010054/EN010054-000226- ES%20Chapter%2011%20Air%20Quality%20FINAL.pdf 2 https://infrastructure.planninginspectorate.gov.uk/document/1828877
3 http://www.egnedol.wales/assets/eg-eia-8.pdf
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