Environmental Report

Foreshore Licence Application FS006889 America Europe Connect 2 Ltd – Old Head, Louisburgh, Co. Mayo

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DOCUMENT DETAILS

Project Title: Foreshore Licence Application FS006889 America Europe Connect 2 Ltd – Old Head, Louisburgh, Co. Mayo

MKO Project Ref: 200630

Document Title: Environmental Report

Document File Name: Foreshore Licence - ER F - 2020.11.27

Prepared By: MKO Tuam Road Galway Ireland H91 VW84

Rev Status Date Author(s) Approved By 01 Draft 09/11/2020 DN/LM MW 02 Draft 23/11/2020 DN/LM MW 03 Final 27/11/2020 DN/LM MW

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Table of Contents

1. INTRODUCTION ...... 1-1 1.1 Introduction ...... 1-1 1.2 Overview of the Proposed Development ...... 1-1 1.2.1 Project Context ...... 1-1 1.2.2 The Applicant ...... 1-2 1.2.3 Legislative Context ...... 1-2 1.3 Format of the Environmental Report ...... 1-3 1.3.1 Purpose of Report ...... 1-3 1.3.2 Report Structure ...... 1-3 1.3.3 Description of Impacts ...... 1-4 1.4 Project Team ...... 1-6 1.4.1 MKO ...... 1-8 1.4.2 MERC Consultants ...... 1-9 1.4.3 Geomara ...... 1-10 1.4.4 Anne Carey Archaeological Consultant ...... 1-10 2. BACKGROUND TO THE PROPOSED DEVELOPMENT ...... 2-1 2.1 Site Location ...... 2-1 2.1.1 Cable Route and Landfall Location ...... 2-1 2.1.2 Access ...... 2-3 2.2 Policy Context ...... 2-3 2.2.1 National Policy ...... 2-3 2.2.2 Regional Policy ...... 2-6 2.2.3 Local Policy ...... 2-7 2.3 Planning History ...... 2-8 2.4 Cumulative Assessment ...... 2-9 2.4.1 Methodology ...... 2-9 2.4.2 Projects Considered in Cumulative Assessment ...... 2-10 3. DESCRIPTION OF THE PROPOSED DEVELOPMENT ...... 3-1 3.1 Introduction ...... 3-1 3.2 Proposed Cable Installation ...... 3-1 3.3 Construction Methodology ...... 3-2 3.3.1 Pre-Lay Grapnel Run ...... 3-2 3.3.2 Direct Landing ...... 3-2 3.3.3 Beach Works ...... 3-3 3.3.4 Shallow Water Works...... 3-4 3.3.5 Main Lay ...... 3-6 3.3.6 Post Lay Inspection and Burial ...... 3-8 3.4 Decommissioning ...... 3-8 3.4.1 Current Decommissioning Processes ...... 3-9 3.5 Sequencing of Events ...... 3-9 3.5.1 Mobilisation ...... 3-9 3.5.2 Beach / Site Set-up and Cable Quadrant Placement ...... 3-10 3.5.3 Hold-Back Anchors ...... 3-10 3.5.4 Diver Pre-Lay Survey and Messenger Line Placement ...... 3-10 3.5.5 Shore End Landing (Pulling Vessel): Phase 1 ...... 3-11 3.5.6 Shore End Landing (Transition): Phase 2 ...... 3-12 3.5.7 Shore End Landing (Cable Positioning and Floats Removal) ...... 3-13 3.5.8 Beach Manhole Cable Installation ...... 3-13 3.5.9 Post-Lay Video Inspection ...... 3-13 3.5.10 Ocean Ground Bed Installation ...... 3-14 3.5.11 Articulated Pipe Installation and Beach Burial Operations ...... 3-14 3.5.12 Inshore Burial Operations ...... 3-14 3.5.13 Site Restoration ...... 3-14

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3.5.14 Weather and Environmental Conditions ...... 3-15 3.6 Protection of Local Receptors ...... 3-15 3.6.1 Old Head Water Quality ...... 3-15 3.6.2 Local Access ...... 3-15 3.6.3 Local Stand Up Paddleboard (SUP) Business ...... 3-16 3.6.4 Recreational Water Users ...... 3-16 3.6.5 Old Head Blueway ...... 3-16 3.6.6 Commercial Vessel Use of Old Head Pier ...... 3-17 3.6.7 Local Residents ...... 3-17 3.6.8 Fisheries Engagement ...... 3-17 4. POPULATION AND HUMAN HEALTH ...... 4-1 4.1 Introduction ...... 4-1 4.2 Receiving Environment ...... 4-1 4.2.1 Settlement and Land-Use ...... 4-1 4.2.2 Services and Amenities ...... 4-1 4.3 Tourism ...... 4-3 4.4 Human Health ...... 4-4 4.5 Potential Impacts ...... 4-4 4.5.1 ‘Do-Nothing’ Scenario ...... 4-4 4.5.2 Cable Installation Phase ...... 4-4 4.5.3 Operational Phase ...... 4-7 4.5.4 Decommissioning Phase ...... 4-7 4.5.5 Cumulative Effects ...... 4-7 5. BIODIVERSITY ...... 5-1 5.1 Benthic Ecology ...... 5-1 5.1.1 Approach and Methodology ...... 5-1 5.1.2 Receiving Environment ...... 5-1 5.1.3 Assessment of Likely Significant Effects ...... 5-8 5.1.4 Mitigation of Likely Risks ...... 5-9 5.2 Marine Mammals ...... 5-10 5.2.1 Approach and Methodology ...... 5-10 5.2.2 Receiving Environment ...... 5-10 5.2.3 Assessment of Likely Significant Effects ...... 5-11 5.2.4 Mitigation of Likely Risks ...... 5-13 5.3 Birds ...... 5-13 5.3.1 Approach and Methodology ...... 5-13 5.3.2 Results ...... 5-18 5.3.3 Potential Impacts and Associated Mitigation Measures ...... 5-18 6. LAND, SOILS AND GEOLOGY ...... 6-1 6.1 Introduction ...... 6-1 6.2 Methodology ...... 6-1 6.2.1 Relevant Guidance ...... 6-1 6.2.2 Desk Study ...... 6-1 6.2.3 Impact Assessment Methodology ...... 6-1 6.3 Existing Environment ...... 6-3 6.3.1 Site Description ...... 6-3 6.3.2 Soils and Subsoils ...... 6-4 6.3.3 Bedrock Geology ...... 6-4 6.3.4 Geological Resource Importance ...... 6-5 6.3.5 Geological Heritage and Designated Sites ...... 6-5 6.4 Potential Impacts ...... 6-8 6.4.1 ‘Do-Nothing’ Scenario ...... 6-8 6.4.2 Cable Installation Phase ...... 6-8 6.4.3 Human Health ...... 6-9 6.4.4 Operational Phase ...... 6-9 6.4.5 Decommissioning Phase ...... 6-9 6.4.6 Cumulative Effects ...... 6-9

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7. WATER ...... 7-1 7.1 Introduction ...... 7-1 7.2 Methodology ...... 7-1 7.2.1 Relevant Guidance ...... 7-1 7.2.2 Desk Study ...... 7-1 7.2.3 Impact Assessment Methodology ...... 7-2 7.3 Existing Environment ...... 7-2 7.3.1 Local Hydrology and Site Drainage ...... 7-2 7.3.2 Flood Risk Identification ...... 7-4 7.3.3 Marine Water Quality ...... 7-4 7.3.4 Hydrogeology ...... 7-5 7.3.5 Groundwater Vulnerability ...... 7-5 7.3.6 Water Framework Directive Status and Risk Result ...... 7-5 7.3.7 Designated Sites ...... 7-5 7.3.8 Local Water Supplies ...... 7-5 7.3.9 Receptor Sensitivity ...... 7-5 7.4 Potential Impacts ...... 7-6 7.4.1 ‘Do-Nothing’ Scenario ...... 7-6 7.4.2 Cable Installation Phase ...... 7-6 7.4.3 Human Health Effects ...... 7-7 7.4.4 Operational Phase ...... 7-7 7.4.5 Decommissioning Phase ...... 7-7 7.4.6 Cumulative Hydrological Effects ...... 7-8 8. AIR, CLIMATE AND NOISE ...... 8-1 8.1 Introduction ...... 8-1 8.2 Air Quality – Existing Environment ...... 8-1 8.2.1 Air Quality Zones ...... 8-1 8.2.2 Existing Air Quality ...... 8-1 8.3 Climate – Existing Environment ...... 8-4 8.4 Noise – Existing Environment ...... 8 - 4 8.4.1 Acoustic Terminology ...... 8-4 8.4.2 Construction Noise ...... 8-5 8.5 Potential Impacts ...... 8-6 8.5.1 ‘Do-Nothing’ Scenario ...... 8-6 8.5.2 Cable Installation Phase ...... 8-6 8.5.3 Operational Phase ...... 8-8 8.5.4 Decommissioning Phase ...... 8-8 8.5.5 Cumulative Effects ...... 8-8 9. LANDSCAPE AND VISUAL ...... 9-1 9.1 Introduction ...... 9-1 9.2 Methodology ...... 9-1 9.2.1 Guidance Documents ...... 9-1 9.2.2 Study Area ...... 9-1 9.2.3 Assessing Landscape Effects ...... 9-2 9.2.4 Visual Receptors - Assessing Magnitude and Sensitivity ...... 9-2 9.3 Landscape Policy Context ...... 9-2 9.3.1 Mayo County Development Plan 2014-2020 ...... 9-2 9.3.2 Regional Seascape Character Assessment for Ireland 2020 ...... 9-3 9.4 Landscape Character ...... 9-3 9.4.1 Physical Unit ...... 9-3 9.4.2 Visual Unit ...... 9-9 9.4.3 Landscape Sensitivity ...... 9-10 9.5 Potential Impacts ...... 9-10 9.5.1 ‘Do-Nothing’ Scenario ...... 9-10 9.5.2 Cable Installation Phase ...... 9-10 9.5.3 Operational Phase ...... 9-10 9.5.4 Decommissioning Phase ...... 9-11 9.5.5 Cumulative Effects ...... 9-11

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10. ARCHAEOLOGY AND CULTURAL HERITAGE ...... 10-1 10.1 Introduction ...... 10-1 10.2 Receiving Environment ...... 10-1 10.2.1 Marine Environment ...... 10-1 10.2.2 Terrestrial Environment ...... 10-3 10.3 Potential Impacts ...... 10-3 10.3.1 ‘Do-Nothing’ Scenario ...... 10-3 10.3.2 Cable Installation Phase ...... 10-3 10.3.3 Operational Phase ...... 10-4 10.3.4 Decommissioning Phase ...... 10-4 10.3.5 Cumulative Effects ...... 10-4 11. MATERIAL ASSESTS ...... 11-1 11.1 Introduction ...... 11-1 11.2 Receiving Environment ...... 11-1 11.2.1 Traffic and Transportation ...... 11-1 11.2.2 Services and Utilities ...... 11-2 11.3 Potential Impacts ...... 11-2 11.3.1 ‘Do-Nothing’ Scenario ...... 11-2 11.3.2 Cable Installation Phase ...... 11-2 11.3.3 Operational Phase ...... 11-3 11.3.4 Decommissioning Phase ...... 11-3 11.3.5 Cumulative Effects ...... 11-4 12. BIBLIOGRAPHY ...... 12-1

TABLE OF TABLES Table 1-1 Impact Classification Terminology (EPA, 2017) ...... 1-4 Table 1-2 Companies and Staff Responsible for Report Completion ...... 1-7 Table 2-1 AEC2 Installation permits ...... 2-8 Table 2-2 Valid Planning Application within 1km of Proposed Infrastructure ...... 2-9 Table 3-1 Proposed Development Works Components ...... 3-1 Table 3-2 Expected Accuracy of Cable Lay Position Based on Water Depth ...... 3-7 Table 3-3 Lines Used in Cable Pull ...... 3-11 Table 3-4 Equipment to be used on beach ...... 3-12 Table 3-5 Local Access to Beach and Health and Safety Requirements ...... 3-15 Table 5-1 Infomar station data for Shipek grab samples collected in 2019 ...... 5-4 Table 5-2 Macro algal species recorded (30/9/2020) ...... 5-8 Table 5-3 Auditory bandwidth for species within the zone of influence ...... 5-12 Table 5-4 IWeBS site summary data for Clew Bay in County Mayo ...... 5-15 Table 6-1 Estimation of Importance of Soil and Geology Criteria (NRA, 2008)...... 6-1 Table 6-2 Additional Impact Characteristics...... 6-2 Table 6-3 Impact descriptors related to the receiving environment...... 6-3 Table 7-1 Receptor Sensitivity Criteria (Adapted from www.sepa.org.uk)...... 7-2 Table 8-1 Sulphur Dioxide Data for Galway City in 2001 ...... 8-2 Table 8-2 Particulate Matter (PM10) Data for Castlebar in 2015 ...... 8-2 Table 8-3 Nitrogen Dioxide and Oxides of Nitrogen Data for Castlebar in 2015 ...... 8-3 Table 8-4 Carbon Monoxide Data for Galway City in 2001 ...... 8-3 Table 8-5 Summary statistics for O3 concentrations for 2015: Castlebar ...... 8-4

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Table 8-6 Typical Construction Noise Emission Levels ...... 8-6 Table 9-1 Features of Landscape Value ...... 9-9

TABLE OF PLATES Plate 2-1 Existing Landing Station ...... 2-10 Plate 2-2 Existing Beach Manhole Location (Source: SubCom) ...... 2-11 Plate 3-1 Floating Haul Line (Source: SubCom) ...... 3-3 Plate 3-2 Typical Beach Landing Using a Quadrant (Source: SubCom) ...... 3-4 Plate 3-3 Typical Jetting Sled (Source: SubCom) ...... 3-5 Plate 3-4 Diver Jetting (Source: SubCom) ...... 3-5 Plate 3-5 Plough Burial (Source: SubCom) ...... 3-6 Plate 3-6 Cable Plough (Source: SubCom) ...... 3-6 Plate 3-7 Conformance of the cable along the designed route by RIBS (Source: SubCom) ...... 3-11 Plate 3-8 Schematic of Beach Pull (Source: SubCom) ...... 3-13 Plate 6-1 Fallduff Strand, looking out to Clew Bay ...... 6-4 Plate 8-1 The level of typical common sounds on the dB(A) scale (NRA Guidelines for the Treatment of Noise and Vibration in National Road Schemes, 2004) ...... 8-5 Plate 9-1 View from Fallduff Strand looking east across the bay towards Croagh Patrick ...... 9-4 Plate 9-2 View from Old Head pier looking back towards the Beach and Cable Landing Station ...... 9-4 Plate 9-3 View from higher ground looking over the Old Head public car park down to Fallduff Strand ...... 9-5 Plate 9-4 View looking toward the holiday apartments on the coastline ...... 9-6 Plate 9-5 View looking from the R335 toward the Oldhead Holiday Village road ...... 9-6 Plate 9-6 View from the junction of Oldhead Holiday Village and Oldhead Woods Road, looking towards Fallduff Strand...... 9-7 Plate 9-7 Existing Cable Landing Station ...... 9-8 Plate 9-8 Existing Cable Route Connecting the Beach Manhole to the Landing Station, trenched through road and carpark area ...... 9-8 Plate 9-9 Beach Boundary Wall ...... 9-9 Plate 10-1 Recorded Sites and Monuments at Old Head (Source: Geomara) ...... 10-2 Plate 10-2 Cable Route and Possible Wreck Site (Source: Geomara) ...... 10-3

TABLE OF FIGURES Figure 1-1 America Europe Connect 2 Transatlantic Cable Route ...... 1-1 Figure 2-1 Proposed Cable Route in Clew Bay, Co. Mayo ...... 2-1 Figure 2-2 Landing Station and Cable Landfall Location at Fallduff Strand, Old Head ...... 2-2 Figure 2-3 Aerial View – Cable Landfall Location at Fallduff Strand, Old Head ...... 2-3 Figure 4-1 Dwelling Locations ...... 4-2 Figure 5-1 Designated Sites ...... 5-1 Figure 5-2 Predominant habitats alone the cable route corridor within the Irish segment. Source Marine Strategy Framework Directive Irelands Marine Atlas V1 ...... 5-2 Figure 5-3 Grab sample locations. Infomar survey of Clew Bay 2019...... 5-3 Figure 6-1 Subsoil Geology ...... 6-6

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Figure 6-2 Bedrock Geology ...... 6-7 Figure 7-1 Local Hydrology ...... 7-3

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1. INTRODUCTION

1.1 Introduction

MKO and SubCom LLC have been appointed by America Europe Connect 2 to assist in the collation of the foreshore licence application for the America Europe Connect 2 subsea fibre optic telecoms cable landing at Fallduff Strand, Old Head, near Louisburgh, County Mayo.

The America Europe Connect 2 project was previously issued a Foreshore Licence (Ref: FS006889) by the Department of Housing, Planning and Local Government (DHPLG) on 6th February 2020. This licence was quashed by the High Court following a third-party legal challenge and with the consent of the Minister, and the application has been remitted to the Minister to be considered and determined in accordance with law. This Environmental Report is being submitted as part of the remitted application process.

1.2 Overview of the Proposed Development

1.2.1 Project Context

America Europe Connect 2 (AEC2) is a branch of a larger transatlantic subsea fibre optic telecommunication cable system, named Havfrue, which runs for approximately 7,866 kilometres (km) across the Atlantic Ocean seabed from New Jersey in the USA to Denmark, with a branch into each of Ireland and Norway (see Figure 1-1).

Figure 1-1 America Europe Connect 2 Transatlantic Cable Route

As of 1st November 2020, cable landings associated with the cable system have already been carried out in USA, Denmark and Norway. 7,716 km or 98.1% of the cable route has already been installed and is operational. 140 km of the Irish branch has also already been installed. This remaining uninstalled 150 km of the Irish branch accounts for 1.9% of the overall system.

It is proposed that the Irish branch (the subject matter of this application) will extend from a sub-sea branching unit in the deep waters of the Rockall Trough some 300km north of the Mayo coastline to the landing point at Fallduff Strand, Old Head, Louisburg, Co. Mayo. The proposed cable route has been designed to avail of optimum sea-bed conditions, to avoid areas which could be problematic from the point of view of cable installation, including environmental and underwater archaeological constraints.

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The ‘proposed development’ for which consent is sought under the Foreshore Act 1933, as amended, comprises the main lay of the fibre optic cable from the 12 Nautical Mile limit off the Mayo coastline, connecting at landfall at Fallduff Strand, Old Head. The cable will connect to an existing landing station, constructed in 2019 (including beach manhole and underground cabling) under Mayo County Council Planning Reference No. 18/833. The landing station is located on the southern side of Clew Bay, approximately 3.3 km northeast of the village of Louisburgh and approximately 20 km west of Westport, Co. Mayo. This landing station will provide the interface between the transatlantic subsea cable and the terrestrial network in Ireland.

1.2.2 The Applicant

The applicant for the foreshore licence is America Europe Connect 2 Ltd, which is part of the Aqua Comms Group. Aqua Comms is a provider of bandwidth infrastructure services including dark fibre, wavelengths and ethernet whose subsea fibre optic networks are designed to meet the needs of content providers, cloud-based networks, data centres, IT companies and the global media. The company specialises in sub-sea telecoms and owns and operates the AEConnect-1 TransAtlantic cable (Killala to New York) and CeltixConnect-1 Cable (which runs from Dublin to Anglesey in the UK).

1.2.3 Legislative Context

The application is for a foreshore licence pursuant to Section 3 of the Foreshore Act 1933, as amended. The Minister may grant a foreshore licence where, in the opinion of the Minister, it is in the public interest to do so, subject to the provisions of the Act.

Section 13A(5) of the Foreshore Act 1933, as amended, provides that “relevant application” means inter alia an application for a foreshore licence under section 3 of the Act.

Section 13A(1)(a) provides that the Minister shall, as part of the consideration of a “relevant application”, in accordance with sub-paragraph (b), ensure that, before a decision is made on the application, a project likely to have a significant effect on the environment by virtue, inter alia, of its nature, size or location, is made subject to an EIA.

Sub-paragraph (b)(i) provides that an EIA shall be carried out where the proposed development would be of a class specified in (I) Part 1 of Schedule 5 of the Planning and Development Regulations 2001, as amended, and would be above-threshold where a threshold is applicable, or would be of a class specified in (II) Part 2 of Schedule 5 of the Regulations and either no threshold is applicable or the proposed development would be above-threshold.

Sub-paragraph (b)(ii) provides that an EIA may be required to be carried out for projects in Part 2 of Schedule 5 which are below the specified threshold. Screening for EIA must be carried out of below- threshold projects as a minimum, and where, following screening, the Minister determines that the project would be likely to have significant effects on the environment, an EIA shall be carried out by the Minister prior to the grant of the licence.

Therefore, the obligation in s.13A(1)(a) to ensure that a project is subject to EIA where it is likely to have a significant effect on the environment must be understood by reference to the classes of project specified in sub-paragraph (b). EIA and screening for EIA are not required for every project type. As is clear from Articles 2 and 4 of the EIA Directive 2011/92/EU as amended by Directive 2014/52/EU, the requirements of the Directive apply only to the projects specified in Annex I and Annex II. This was confirmed by Mr Justice O’Moore in Kavanagh v An Bord Pleanála and Highfield Solar [2020] IEHC 259. In a written judgment delivered on 29 May 2020, the Court set out the recitals to the EIA Directive and then held:

11. However, it is of great importance that the Directive then goes on to require an EIA be carried out in respect of carefully defined types of projects. The obligations placed on Member States by the Directive are limited by reference to the classes of projects or developments set out in the Annexes, and do not extend beyond them.

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Having considered an argument that a development of significant scale should be subject to EIA under Article 2 of the Directive notwithstanding that the solar project at issue was not a class of project defined in Article 4, the Court held:

35. This argument ignores the last sentence of Article 2. While the purpose of the EIA Directives is relatively open textured, in that they are designed to secure appropriate environmental assessment for certain projects, the way in which this purpose is to be achieved is carefully defined and limited. A project which could have a significant effect on the environment is nonetheless not caught by Article 2 unless it also falls within Article 4.

It is clear, therefore, that unless the Minister determines that the proposed installation of a subsea fibre optic cable comes within a specified class of project in Annex I or II of the EIA Directive or Parts 1 or 2 of Schedule 5 of the 2001 Regulations, there is no requirement to carry out screening for EIA or EIA of the proposed development.

As it is ultimately a matter for the Minister to determine, an Environmental Impact Assessment (EIA) screening report has been prepared in accordance with the requirements of the European Union (Environmental Impact Assessment and Appropriate Assessment) (Foreshore) Regulations 2014 (S.I. No. 544 of 2014). As noted in the EIA screening report, it is the applicant’s position that the proposed development does not come within any class of project to which the EIA Directives apply, and that there is no requirement to carry out screening for EIA, or EIA, prior to the grant of a licence.

The situation under the Habitats and Birds Directives is different. All proposed plans, projects and activities likely to have a significant effect on a European site are required to be subject to a stage 1 screening for appropriate assessment in accordance with the first part of Article 6(3) of the Habitats Directive. If the likelihood of significant effects cannot be excluded on the basis of objective information, a stage 2 appropriate assessment is required in accordance with the second part of Article 6(3) of the Habitats Directive. For the purposes of an application for a licence under section 3 of the Foreshore Act 1933, as amended, the appropriate assessment process is governed by SI 477/2011 - EC (Birds and Natural Habitats) Regulations 2011, as amended. In accordance with the Birds and Natural Habitats Regulations SI 477/2011, a stage 1 screening for appropriate assessment report and stage 2 Natura Impact Statement (NIS) are submitted with the application. The NIS provides the Minister with objective and conclusive evidence that the proposed development is not likely to have any adverse effects on the integrity of a European site

As determined by Ms Justice Murphy in the High Court in Casey v Minister for Housing, Planning and Local Government [2020] IEHC 227, in a written decision delivered 20 May 2020, section 21A of the Foreshore Act 1933 as amended provides that, where the Minister grants a licence under s.3 of the Act, whether or not the EIA or Habitats Directive is applicable, the Minister is required to publish a notice of the decision in Iris Oifigiúil and in one or more newspapers circulating in the area, and the foreshore licence does not become legally operative until this is done.

1.3 Format of the Environmental Report

1.3.1 Purpose of Report

The purpose of this Environmental Report is to provide the Minister with objective information on which to assess the environmental effects of the proposed development on the receiving environment, in accordance with the Foreshore Act 1933, as amended. This Environmental Report documents the current state of the environment in the vicinity of the proposed development in an effort to quantify its effects, if any, on the environment, and to highlight how design and mitigation were implemented to minimise impacts on the environment.

1.3.2 Report Structure

This Environmental Report uses the grouped structure method to describe the existing environment, the potential impacts of the proposed development thereon and the proposed mitigation measures. Potential impacts are identified, assessed and mitigated under the following headings:

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Chapter 4: Population and Human Health Chapter 5: Biodiversity Chapter 6: Land, Soils and Geology Chapter 7: Water Chapter 8: Air, Climate and Noise Chapter 9: Landscape and Visual Chapter 10: Cultural Heritage Chapter 11: Material Assets

Chapter 2 of this Report sets out the Background to the Proposed Development, including the relevant policy. Chapter 3 provides Description of the Proposed Development, including the construction, operational and decommissioning stages.

1.3.3 Description of Impacts

The description of impacts in this report uses the standard impact classification terminology recommended by the Environmental Protection Agency in ‘Guidelines on the Information to be contained in Environmental Impact Assessment Reports’ (EPA, 2017). The use of existing standardised terms for the classification of impacts ensures that this Environmental Report employs a systematic approach, which can be replicated across all disciplines.

The glossary of EPA impact classification terminology is provided in Table 1-1 below for reference. These terms are used to describe impacts in terms of magnitude, duration, consequences and significance.

Table 1-1 Impact Classification Terminology (EPA, 2017)

Impact Term Description Characteristic

Positive A change which improves the quality of the environment

Neutral No effects or effects that are imperceptible, within Quality normal bounds of variation or within the margin of forecasting error.

Negative A change which reduces the quality of the environment

Imperceptible An effect capable of measurement but without significant consequences

Not significant An effect which causes noticeable changes in the character of the environment but without significant consequences.

Slight An effect which causes noticeable changes in the Significance character of the environment without affecting its sensitivities

Moderate An effect that alters the character of the environment in a manner consistent with existing and emerging baseline trends

Significant An effect, which by its character, magnitude, duration or intensity alters a sensitive aspect of the environment

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Impact Term Description Characteristic

Very significant An effect which, by its character, magnitude, duration or intensity significantly alters most of a sensitive aspect of the environment

Profound An effect which obliterates sensitive characteristics

Extent Describe the size of the area, number of sites and the proportion of a population affected by an effect Extent & Context Context Describe whether the extent, duration, or frequency will conform or contrast with established (baseline) conditions

Likely Effects that can reasonably be expected to occur because of the planned project if all mitigation measures are properly implemented Probability Unlikely Effects that can reasonably be expected not to occur because of the planned project if all mitigation measures are properly implemented

Momentary Effects lasting from seconds to minutes

Brief Effects lasting less than a day

Temporary Effects lasting less than a year

Short-term Effects lasting one to seven years

Medium-term Effects lasting seven to fifteen years Duration and Frequency Long-term Effects lasting fifteen to sixty years

Permanent Effect lasting over sixty years

Reversible Effects that can be undone, for example through remediation or restoration

Frequency Describe how often the effect will occur. (once, rarely, occasionally, frequently, constantly – or hourly, daily, weekly, monthly, annually)

Indirect Impacts on the environment, which are not a direct result of the project, often produced away from the project site or because of a complex pathway Type Cumulative The addition of many minor or significant effects, including effects of other projects, to create larger, more significant effects.

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Impact Term Description Characteristic

Do Nothing The environment as it would be in the future should the subject project not be carried out

Worst Case The effects arising from a project in the case where mitigation measures substantially fail

Indeterminable When the full consequences of a change in the environment cannot be described

Irreversible When the character, distinctiveness, diversity, or reproductive capacity of an environment is permanently lost

Residual Degree of environmental change that will occur after the proposed mitigation measures have taken effect

Synergistic Where the resultant effect is of greater significance than the sum of its constituents

Each impact is described in terms of its quality, significance, extent, probability, duration and type (including cumulative), where relevant. Where potential impacts are envisaged, remedial and/or mitigation measures that are practical and reasonable are included. Where there is a requirement for environmental monitoring during the construction and/or operational phases, such requirements are described together with the proposed methods for carrying out such monitoring.

1.4 Project Team

The companies and staff listed in Table 1-2 were responsible for completion of this Environmental Report. A brief CV for each team member is also presented below, highlighting their relevant area of expertise.

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Table 1-2 Companies and Staff Responsible for Report Completion

Consultants Principal Staff Involved in Input Project

MKO Michael Watson Preparation of sections: 1. Introduction Tuam Road Lorraine Meehan 2. Background to the Proposed Galway David Naughton Development 3. Description of the Proposed H91 VW84 Jordan Baxter Development John Hynes 4. Population & Human Health 5. Biodiversity 6. Land, Soils and Geology 7. Water 8. Air, Climate and Noise 9. Landscape & Visual 10. Cultural Heritage 11. Material Assets

MERC Consultants Dr. Louise Scally Preparation of section:

Loughaunbeg 6. Biodiversity (benthic ecology)

Inverin

Co. Galway

Geomara Finn Delaney Preparation of Appendix 10-1 – ‘Marine Archaeological Assessment. Marine CoisCuain Mark Kelly Survey and Site Investigation Works within the Havfrue Cable Route Ballynamanagh Corridor’

Clarinbridge Preparation of Appendix 10-2 – ‘Marine Archaeological Assessment of the Co. Galway Preferred Route within the Havfrue Cable Route Corridor’

Anne Carey Anne Carey Preparation of Appendix 10-3 – ‘Archaeological Assessment (Field and Archaeological Desk) at Old Head, Louisburgh, Co. Consultant Mayo’

80 Portacarron

Ballymoneen Road

Galway

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1.4.1 MKO

Michael Watson – Project Director

Michael Watson is Project Director and head of the Environment Team at MKO. Michael has extensive experience as project strategy advisor and coordinator on large multi-disciplinary teams on complex projects requiring Environmental Impact Assessment, Environmental Protection Agency (EPA) Licence applications, hydrogeological assessments, environmental due diligence and general environmental assessment on behalf of clients in the renewable energy, waste management, public, commercial and industrial sectors nationally.

Michael has over 19 years’ experience in the environmental sector. Following the completion of his Master’s Degree in Environmental Resource Management from National University of Ireland, Maynooth he worked for the Geological Survey of Ireland and then a prominent private environmental & hydrogeological consultancy. Michael also has a Bachelor of Arts Degree in Geography and Economics from NUI Maynooth, is a Member of IEMA, a Chartered Environmentalist and Professional Geologist. Michael’s key strengths include project strategy advice, project management and liaising with the relevant local authorities, EPA and statutory consultees as well as coordinating the project teams and sub- contractors.

Lorraine Meehan – Project Manager, Senior Environmental Scientist

Lorraine Meehan is a Senior Environmental Scientist with MKO, with over 12 years of experience. Lorraine graduated from NUI Galway in 2006 with a first class honours B.Sc. in Environmental Science and has gained extensive experience since joining MKO in 2007, working primarily as an Environmental Scientist and Project Manager on a wide range of projects and plans requiring environmental assessment. Key project experience includes renewable energy projects up to 100 MW in scale, electricity infrastructure, roads, waste management facilities, and municipal services projects.

Lorraine’s key strengths and responsibilities relate to the efficient and effective management of projects, including coordination of multidisciplinary project teams, engagement with the relevant authorities, stakeholders and members of the public on proposed and ongoing projects, organisation of extensive scoping and consultation exercises, and coordination and production of final project outputs, including Environmental Impact Assessment Reports, Environmental Reports, Strategic Environmental Assessment Reports, and Constraints & Feasibility and Site Selection Studies. Within MKO, Lorraine is also involved in the training of junior members of staff and review of outputs, and completes mapping, desk studies and report-writing for a range of development and strategy-related projects.

David Naughton – Assistant Environmental Scientist

David Naughton is an Environmental Scientist with MKO ltd. with over three years of experience. David graduated with an honours B.Sc. degree in Environmental Science from NUIG in 2016. David has experience as an Environmental Clerk of Works (ECoW) including monitoring, oversight and reporting of the implementation of all planning and environmental requirements for on-site developments. David has a wide range of ecological experience including bird surveys, vegetation surveys, terrestrial invertebrate surveys, freshwater invertebrate surveys, river surveys for salmonids and other fish species, small mammal surveys and habitat identification. David is also very accomplished in GIS software systems for use in interpreting ecological data, including QGIS, Mapinfo and ArcGIS. David is experienced in report writing and has been involved in the production of several EIS/EIARs for various windfarm projects. David has also been responsible for the production of collision risk modelling for avian populations at MKO for several windfarm sites, many of which have been peer reviewed by experts in CRM and were found to be appropriate. David’s key strengths and areas of expertise lie in report writing, project management, applications of GIS systems and SUA (drone) surveying. Since joining MKO David has been involved in a wide range of projects, acting as project manager for many bird survey projects while providing a pivotal contact link between clients and field surveyors.

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Jordan Baxter – Assistant Planner

Jordan Baxter is a Planner with MKO with over 2 years of experience in private consultancy practice. Jordan holds a BA in Psychology and a Master’s in Planning and Development from Queen’s University Belfast. Prior to taking up his position with MKO in 2019, Jordan worked as an Environmental Planner with Mott MacDonald Ireland Ltd. and Wood plc for three years on infrastructure projects within the energy, water and general industry sectors. As part of these roles, Jordan both managed and assisted with the coordination of Planning Applications through the statutory planning process from preparation to final grant of permission.

Jordan is a Licentiate Member of the Royal Town Planning Institute (RTPI) with specialist knowledge in national, regional and local planning policy and guidance, development management and strategic planning analysis for energy infrastructure. Within MKO, Jordan works as part of a larger multi- disciplinary team to coordinate the development of planning applications for renewable energy infrastructure for submission to both local and national Planning Authorities. Jordan has both managed and contributed on a range of infrastructure projects across Ireland and the UK and is currently progressing towards chartered membership with the RTPI.

John Hynes – Senior Ecologist

John Hynes is a Senior Ecologist and Project Director of the MKO Ecology team, with over nine years post-graduate experience in private practice and local authorities. John has specialist knowledge in flora and fauna surveys (including bats, Marsh Fritillary and Freshwater Pearl Mussel), Geographic Information Systems, Data analysis, Appropriate Assessment, Ecological Impact Assessment and Environmental Impact Assessment. John’s experience covers a significant range of projects for the public and private sector including energy infrastructure, national roads and private/public development projects. John has also been a Project Manager and Senior Ecologist on large-scale ecological and GIS projects requiring coordination assessment of multiple large-scale sites in recent years.

John is an approved Environmentalist in relation to agri-environment schemes with the Department of Agriculture. Prior to consultancy, John worked for Galway County Council in the Western River Basin District Office as GIS and Assistant Coordinator where he developed significant GIS and mapping skills.

1.4.2 MERC Consultants

Dr. Louise Scally

Louise Scally is a professional ecologist with a wide range of experience in the field of conservation biology, marine habitat mapping and ecology. She completed a M.Sc. in ecology and taxonomy at the Botany Department Trinity College Dublin in 1989 and a Ph.D. in taxonomy also at the Botany Department Trinity College Dublin in 2001. For the last 15 years she has specialised in the ecology of marine ecosystems.

She has conducted field surveys and assessments for a range of habitats over the last 15 years for private and public sector clients including the National Parks and Wildlife Service, The Marine Institute, Inland Fisheries Ireland, Coillte Teo. Environmental Protection Agency, SEAI and ESB Networks Ltd.

Louise was the senior ecologist and field survey team member of the 2015‐2018 National Parks & Wildlife Service (NPWS) national monitoring of marine Annex I habitats for compliance under Article 17 of the EU Habitats Directive. In this context she was responsible for the assessment and reporting of marine Annex I habitats and was lead author of all Article 17 reports and the overarching site monitoring reports. She was also a field team member and author of the ecology sections of the EIS and NIS for the AMETS and lead author for the preparation of the Department of Communications, Climate Action and Environment (2018). Guidance on Marine Baseline Ecological Assessments and Monitoring Activities - Offshore Renewable Energy Projects Part 1 and Part 2.

In addition to her scientific expertise, Louise has an in‐depth knowledge of Irish and European Environmental legislation and policy. In 2011 she prepared the text describing Activities Requiring

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Consent (ARCs) for inclusion in a handbook detailing the regulatory framework for all developments within designated sites in Ireland on behalf of the National Parks and Wildlife Service. She has also produced numerous Conservation Management Plans for the same department. To‐date she has conducted in excess of 100 ecological reports in support of Appropriate Assessment under Article 6(3) of the EU Habitats Directive

1.4.3 Geomara

Finn Delaney

Finn Delaney is Managing Director of Geomara subsea survey providers. Finn is an IHO (International Hydrographic Organisation) qualified Hydrographic surveyor. He has managed Geomara’s role on large- scale projects including the Dublin Port, Term Dredging Survey contract, Multi-annual Fleet wide OWF Bathymetric surveys for EON and The Grand Harbour Valetta Surveys for Transport Malta. Finn has also developed, implemented and maintains Geomara’s ISO 9001 approved Quality Management System.

Mark Kelly

Mark is a Marine Archaeologist with Geomara. He has managed numerous marine archaeological projects for Geomara since 2010, including the preparation of pre planning reports and marine dredge monitoring. Mark is also the director of the School of Irish Archaeology.

1.4.4 Anne Carey Archaeological Consultant

Anne Carey is an archaeologist with over 24 years’ experience in Archaeological consultancy in Ireland. She holds a Master of Arts, in Archaeology from NUIG, an M.U.B.C in Urban and Building Conservation from UCD and a Certificate in World Heritage from UCD. Anne has worked on a wide range of development-led projects working, providing archaeological services which include excavation, pre-development testing, monitoring, EIAR, Field and Desk studies and Impact Assessments.

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2. BACKGROUND TO THE PROPOSED DEVELOPMENT

2.1 Site Location

2.1.1 Cable Route and Landfall Location

The America Europe Connect 2 (AEC2) system is part of a larger transatlantic a subsea fibre optic telecommunication cable system (called Havfrue) which runs for approximately 7,866 kilometres (km) across the Atlantic Ocean seabed from New Jersey in the USA to Denmark, with a branch into each of Ireland and Norway. The proposed Irish branch of the cable system extends from a sub-sea branching unit in the deep waters of the Rockall Trough approximately 290 km north of the Irish coastline to a landing point at Fallduff Strand, Old Head, near Louisburg, Co. Mayo.

The proposed AEC2 cable route through Clew Bay to Old Head is shown in Figure 2-1.

Figure 2-1 Proposed Cable Route in Clew Bay, Co. Mayo

The proposed AEC2 cable will connect to an existing landing station at Old Head, the location of which is shown in Figure 2-2. The landing station is located on the southern side of Clew Bay, approximately 3.3 km northeast of the village of Louisburgh and approximately 20 km west of Westport, Co. Mayo. The landing station and associated beach manhole (BMH), including front haul cabling measuring approximately 180 metres between both structures, were constructed in 2019 under Mayo County Council Planning Reference No. 18/833.

SEA002-0023-5747182-2 2-1 Map Legend

Fibre Optic Cable Route

Existing Landing Station and Infrastructure Ordnance Survey Ireland Ordnance Licence AR No. Survey 0021820© Ireland/Government of Ireland Microsoft Microsoft product screen reprinted shots with permission from Microsoft Corporation Drawing Title Site Location Map Project Title AEC2 Foreshore Licence Application

Drawn By Checked By DN LM Project No. Drawing No. 200630 2-2 Scale Date 28.10.2020

MKO Planning and Environmental Consultants Tuam Road, Galway Ireland, H91 VW84 +353 (0) 91 735611 email:[email protected] Website: ww.mkoireland.ie Foreshore Licence - ER F - 2020.11.27

An aerial view of the cable landfall location and connecting route to the existing landing station is shown in Figure 2-3.

Figure 2-3 Aerial View – Cable Landfall Location at Fallduff Strand, Old Head

2.1.2 Access

Within the public road network, Fallduff Strand, Old Head is accessed via the Oldhead Holiday Village Road from the R335 Regional Road. From the Oldhead Holiday Village Road, Fallduff Strand is accessible directly to the east, with the existing cable landing station accessed to the west via Oldhead Close road and the beach car park.

2.2 Policy Context

2.2.1 National Policy

2.2.1.1 National Planning Framework 2018

The National Planning Framework (NPF), published by the Department of Housing, Planning and Local Government in February 2018, forms the top tier of the national planning policy structure which establishes the policy context for the Regional Spatial and Economic Strategies (RSES) and local level development plans. In an effort to move away from developer-led development to one informed by the needs and requirements of society up to 2040, a number of objectives and policies have been put in place in order for Ireland to grow and develop in a sustainable manner. These include:

Developing a new region-focused strategy for managing growth; Linking this to a new 10-year investment plan, the Project Ireland 2040 National Development Plan 2018 – 2027; Using state lands for certain strategic purposes; Supporting this with strengthened, more environmentally focused planning at local level; and Backing the framework up in law with an Independent Office of the Planning Regulator.

The NPF notes that the population of Ireland is projected to increase by approximately 1 million people by 2040 which will result in a population of roughly 5.7 million. This population growth will place further demand on both the built environment with regard to the necessary services and public infrastructure

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required to accommodate this growth, including telecommunications. Connectivity in the 21st Century is of fundamental significance as advances in digital technology continue to influence how societies and economies engage with one another at varying scales of governance. The provision of high-speed digital infrastructure and telecommunication networks is therefore critical to realising potential employment opportunities and facilitating innovation. Specifically, the NPF states that,

“In the short term, opportunities provided by access to high quality broadband services will be fully exploited through the roll-out of the State intervention segment of the National Broadband Plan, delivering a step‐change in digital connectivity and ensuring that coverage extends to remoter areas including villages, rural areas and islands.

Ireland is very attractive in terms of international digital connectivity, climatic factors and current and future renewable energy sources for the development of international digital infrastructures, such as data centres.”

Identifying and capitalising on potential opportunities to further develop Ireland’s global connectivity and improved digitisation of its urban and rural areas is an important component of the NPF as referenced above. Investing in these types of technologies, such as telecommunications, can provide secondary benefits towards e-literacy skills, access to e-health and other basic services, promotion of local products supported by technology and ICT (Information and Communications Technology), implementing and taking full benefit of smart specialisation agri-food projects, tourism and cultural activities. The following objectives are considered key determinants in developing Ireland’s connectivity and improving its telecommunication network:

Implementation of the National Broadband Plan; Enhancing international fibre communication links, including full interconnection between the fibre networks in Northern Ireland and the Republic of Ireland; Promotion of Ireland as a sustainable international destination for ICT infrastructures such as data centres and associated economic activities; Promoting our cities as demonstrators of 5G information and communications technology

The NPF acknowledges that telecommunication networks play a crucial role in enabling social and economic activity at both an international level and within local communities and households. As such, there is a clear impetus on the government to facilitate further strengthening of communications links in an all-island context; specifically, the NPF references further enhancement of links between the North American continent and the island of Ireland and Europe, direct access to international backbone data systems and the roll-out of appropriate public policy and investment interventions such as the National Broadband Plan.

National Policy Objective 48 - In co-operation with relevant Departments in Northern Ireland, develop a stable, innovative and secure digital communications and services infrastructure on an all-island basis.

The proposed America Europe Connect 2 subsea fibre-optic telecoms cable is an international subsea cable connecting countries together. Itis not of the type that can provide localised broadband connectivity directly from the cable. The AEC2 cable will carry internet traffic to and from Ireland as a carrier system and is in line with the policies and objectives of the NPF, and furthermore, will directly contribute to strengthening Ireland’s connectivity and telecommunications network as required to support Ireland’s growing population demand.

2.2.1.2 Draft National Marine Planning Framework 2019

European Directive 2014/89/EU on establishing a framework for maritime spatial planning, set the requirement for member states to prepare and implement a framework for Marine Spatial Planning (MSP) by March 2021. The MSP Directive was originally transposed into Irish legislation by way of regulations made in 2016 (SI 352 of 2016). In October 2018, the regulations were repealed and replaced by Part 5 of the Planning and Development (Amendment) Act 2018 which re-transposes the Directive in primary legislation and contains a number of measures that are additional to those required by the Directive 2014/89/EU, including:

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Adoption of the National Marine Planning Framework (NMPF) by both Houses of the Oireachtas; Review and replacement of the NMPF every 6 years; and Obligation for marine regulatory bodies to secure the objectives of the NMPF when making policies, plans, or granting consents

The NMPF will cover Ireland’s maritime area, including internal waters (sea area), territorial seas, exclusive economic zone (EEZ) and continental shelf. The maritime area comprises approx. 490,000 km2 and extends from mean high water mark at the coast seaward to in excess of 200 nautical miles in parts. Ireland’s final NMPF, to be published in 2020 / 2021, will be the key consideration for decision-makers on all marine consents over a 20 year horizon; specifically, the NMPF will sit at the top of the hierarchy of plans and sectoral policies for the marine area. All applications for activity or development in Ireland’s maritime area, including those made within the new development management system being provided for under the proposed new Marine Planning and Development Management Bill, will be considered in terms of its consistency with the objectives of the NMPF.

The NMPF is a parallel document to the NPF. In the future, it will be equally important in turn that national, regional and local terrestrial plans are also consistent with the NMPF as many activities and uses that take place on land or in the sea can have impacts on both the land and the maritime area. The Overarching Marine Planning Policies (OMPPs) presented within the NMPF apply to all proposals capable of having impacts in the maritime area. Similarly, the OMPPs equally apply to proposals that would be located in the maritime area and those proposals that would be located outside of the maritime area, but capable of having an impact in the maritime area.

The draft NMPF recognises that guaranteeing existing and future international telecommunications connectivity is critically important to support the future needs of society and enterprise in Ireland and includes the following draft policies:

Telecommunications Policy 1: Proposals that guarantee existing and future international telecommunications connectivity which is critically important to support the future needs of society and enterprise in Ireland, should be supported; Telecommunications Policy 2: Preference should be given to proposals where evidence is provided of an approach to development and activity that integrates the needs of cables and pipelines. An integrated approach should ensure compatibility through, in order of preference: o avoiding, or o minimising, or o mitigating adverse impacts. o If it is not possible to mitigate adverse impacts, proposals should state the case for proceeding Telecommunications Policy 3: Preference should be given to proposals which protect submarine cables whilst achieving successful seabed user coexistence, such as bundling of cables (electricity and communications) as well as pipelines for multiple activities. In the case of removing redundant submarine cables, a risk-based approach should be applied with consideration given to cables being left in situ where this would minimise significant impacts on the physical, natural, societal, historic, and economic value of the area. Telecommunications Policy 4: Proposals that ensure and enhance connectivity of Ireland’s rural and island communities to high quality telecommunications networks should be supported

As reflected in both the NPF and the draft NMPF, Ireland’s international and national digital connectivity is critically important to maintaining and enhancing Ireland’s competitiveness in global markets and in the knowledge and information economy. The NMPF’s three objectives concerning telecommunication technology further elaborates upon the significance of this public infrastructure:

Facilitate international high-speed connectivity between Ireland and other countries. Ensure that our island communities can avail of the opportunities that high-speed communications networks can bring; and Protect existing telecommunications cables and to facilitate future growth in the sector.

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The draft NMPF states that high quality access to international telecommunications networks is a key driver in social, economic and industrial growth and development of the regions and of State as a whole. The successful implementation of the America Europe Connect 2 subsea fibre-optic telecoms cable will assist in ensuring that enterprises, individuals and the public sector will realise significant productivity growth, improved global competitiveness, increased innovation and exports, more and higher quality jobs and better and more efficient public services. While the draft NMPF has yet to be adopted, the policies stated within the draft NMPF are directed towards achieving the objectives of the MSP Directive. It is completely consistent with EU law for the Minister to exercise his or her functions in a manner consistent with the draft NMPF prior to its formal adoption and the completion of the transposition process.

2.2.1.3 International Connectivity for Telecommunications

Paragraph 18.10 of the NMPF identified an area for potential development in the future is increased direct capacity between Ireland and continental Europe, without the need to traverse the UK. The benefits of such direct connectivity have come more into focus recently, in the context of the UK leaving the European Union. AEC2 Cable will be the first submarine cable to connect the US with Northern Europe, but more significantly from Ireland’s perspective, it will be the first subsea fibre optic cable between Ireland and mainland Europe. All other connections with Europe are routed through Great Britain. A major driver for this cable is the ability to route data from Ireland to Europe without traversing the UK. This is strategically important in the post-Brexit era.

A public consultation exercise is currently underway by the Department of the Environment, Climate and Communications (DECC) regarding Ireland’s International Connectivity for Telecommunications. The purpose of this public consultation is to seek the views of interested parties on the status of international connectivity for telecommunications in Ireland. This will allow DECC to gather information and consider views from relevant stakeholders to inform policy development and decision making.

The public consultation Communications on International Connectivity for Telecommunications document states that high quality access to international telecommunications networks is a key driver in the growth of social, economic and industrial development of regions and countries. It states that “in recent times, Ireland has experienced growth in demand for international connectivity with capacity demand on the Atlantic running at a compound annual growth rate of 26% between 2015-2019”.

The document further notes that there are currently no submarine cable routes from Ireland directly to continental Europe (without traversing UK) and this is seen as an area for potential development. The AEC2 cable will provide connectivity from North America to Denmark, with branches to Norway and Ireland. The public consultation document states that DECC recognises the importance of subsea telecommunications cables in underpinning so much of the economy and our digital future and is working with other Departments to ensure that Ireland remains an attractive location for providers of international connectivity.

Submissions on the consultation document are being invited by the Department up until 27th November 2020.

2.2.2 Regional Policy

2.2.2.1 Northern and Western Regional Spatial and Economic Strategy (2020)

The Northern and Western Regional Assembly (NWRA) has a recognised leadership role in setting out regional policies and coordinating initiatives which support the delivery and implementation of the National Planning Framework (NPF). The primary vehicle for this is the preparation and implementation of the Regional Spatial and Economic Strategy (RSES). It provides a 12-year strategy to deliver the transformational change that is necessary to achieve the objectives and vision of the Assembly. The RSES is based on partnership and collaboration with a clear focus on place-based regional economic development and effective regional planning. Objectives underpinning this regional economic strategy include, but are not limited to:

Increasing the emphasis on developing our Irish owned enterprises;

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Collaboration and clustering; and Realise the full potential of our regions through investments in place-making - developing places that are attractive for business investment and for people to live and work

The above strategy is characterised by the RSES as ‘place-making’, which focuses on ‘tapping into the economic potential that remains unused to outside agencies, so that all parts of cities and regions can contribute to the quality of life’. The overarching principle of placemaking most applicable to the proposed development is that of connectivity:

“Connectivity - rural, regional, national and international - enabling the mobility of people and goods and making use of smart technologies to deliver enhanced productivity, competitiveness and quality of life”

The RSES acknowledges the need to consider opportunities, benefits and challenges that smart technologies can offer beyond the traditional applications in a mostly urban context. As such, an overarching aim of the strategy is to produce a high-tech intensive and advanced approach that connects people, information, governance and policies using new and existing technologies to create a ‘Smart Region’ where smart technologies have been deployed to benefit the economic growth, quality of life and wellbeing of citizens. A failure to implement a ‘Smart Strategy’ will exacerbate digital inequality and increase exclusivity investment in innovation, infrastructure and networks.

The RSES supports actions to strengthen communications links to develop a stable, innovative and secure digital communications and services infrastructure on an all-island basis. The enhancement of such links between the North American continent and the island of Ireland and Europe, as exemplified by the proposed development, will be key to delivering a connected and smart Northern and Western region.

2.2.3 Local Policy

2.2.3.1 Mayo County Development Plan 2014 – 2020 (as varied)

The Mayo County Development Plan 2014 – 2020 (as varied), hereafter referred to as the CDP, is a spatial planning framework that gives effect to the delivery of sustainable and planned economic and social development in a manner consistent with higher levels plans and strategies. Mayo County Council has commenced the review process for preparing the Mayo County Development Plan 2021– 2027 with a Draft Plan due to be published in Q4 2020.

The CDP acknowledges that Mayo County Council has an important role in delivering national and reginal strategies, targets and actions at a local level by:

“Continuing to support and promote innovation in business; develop the Green Economy; enhance environmental protection; and provide infrastructure essential to support enterprise and employment.”

The CDP provides an economic framework that encourages sustainable growth in the County, through the provision of services, access, appropriately zoned lands, infrastructure and clear sustainable policies and objectives to attract investment and people into the County. In this regard, the CDP identifies the following to be implemented to ensure the infrastructure in the County is of high standard that allows Mayo to be competitive:

Continued investment in telecommunications including high speed broadband; Identifying and providing other key infrastructure to allow for the sustainable development of marine and land based: tourism, energy and renewable energy, ICT, fishing and aquaculture, food, agriculture and other emerging sector development.

The CDP notes that the Council is responsible for the provision of some forms of infrastructure but the majority of infrastructure will ultimately be provided by state agencies and private providers, and in such cases, the Council works to facilitate the provision of infrastructure.

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PY-02: It is the policy of the Council, in conjunction with all relevant statutory agencies and infrastructure providers to provide, or facilitate the provision of, high quality sustainable infrastructure to serve the economic and social needs of the County through the implementation of the objectives below; TC-01: It is an objective of the Council to support and facilitate the delivery of high capacity ICT infrastructure, broadband networks and digital broadcasting in the County having regard to the Government Guidelines Telecommunications Antennae and Support Structures‐Guidelines for Planning Authorities 1996 (DoEHLG) and Circular Letter PL 07/12 and where it can be demonstrated that the development will not have significant adverse effects on the environment including the integrity of the Natura 2000 network.

Whilst the proposed cable will not directly deliver high capacity ICT infrastructure, broadband networks and digital broadcasting in the County (TC-01), it will directly contribute to strengthening Ireland’s international connectivity and telecommunications network as required to support Ireland’s growing population demand. Installation of the proposed America Europe Connect 2 subsea fibre-optic telecoms cable will not constrain, or adversely impact, the achievement of any of the policy objectives set out within the CDP’s Local Area Plan for Louisburgh, particularly regarding tourism (KTLB-03) and the protection / enhancement of significant views (KTLB-08).

2.3 Planning History

This section of the Environmental Report sets out the relevant planning history of the proposed development, planning applications in the immediate vicinity of the proposed works and other applications within the wider area.

A number of permits have been secured from local and national authorities to support the installation of the proposed America Europe Connect 2 cable system. Details of these permits are set out below in Table 2-1.

Table 2-1 AEC2 Installation permits Permitting Permit Ref. No. Jurisdictional Reach Date Authority Received Dept of Planning, Foreshore FS006889 Marine area up to High Water Mark 06/02/20 Housing and Licence (quashed Local and Government remitted) Mayo County Planning 18/833 Cable Landing Station, Terrestrial 11/03/19 Council Permission cable route, BMH and duct down to High Water Mark Mayo County Road N/A Terrestrial from High Water Mark 08/04/19 Council opening licence Private Lands Wayleave N/A Terrestrial from High Water Mark 01/06/19 Agreement

A review of the Mayo County Council Planning Register was undertaken on 23rd November 2020 to identify valid planning applications proximate to the proposed cable landfall location. A 1-km radius was considered adequately robust in the context of the scale and nature of the proposed works to guide this review in confirming up to date records of potential sensitive receptors within the immediate setting of the site.

Four valid applications have been lodged within the vicinity of the proposed cable landfall location in the past five years as set out below in Table 2-2.

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Table 2-2 Valid Planning Application within 1km of Proposed Infrastructure Planning Description of Development Lodgement Decision Distance to Ref. Date Landfall Location (km) 16/937 Construct extension to an existing shed 01/12/2016 Conditional 1.2 km Permission 16/1026 Construct single storey organic dwelling 22/12/2016 Refusal 1.1 km house with concealed basement 18/955 Demolition of an existing dwelling and 30/11/2018 Conditional 0.22 km the construction of a replacement Permission dwelling, including an ancillary shed, with all associated site works and connection to services 18/1036 Construct dwelling house, domestic 21/12/2018 Conditional 0.28 km garage and connection to public Permission services, together with ancillary site works

As indicated above in Table 2-2, the planning applications lodged within the immediate vicinity of the proposed development relate to the provision and/or alteration of residential development and agricultural infrastructure. There are no other existing or permitted developments in the area considered likely to have a significant cumulative effect on the environment or interaction with the proposed development. The above developments listed in Table 2-2 have been considered as part of the cumulative impact assessments within this report, as described in Section 2.4 below.

2.4 Cumulative Assessment

2.4.1 Methodology

This Environmental Report, which includes a description of the likely significant impacts of the proposed development, also includes an assessment of potential cumulative impacts that may arise in combination with other projects or developments. Cumulative impacts are assessed in the report under the relevant environmental headings of Population & Human Health (Chapter 4), Biodiversity (Chapter 5), Land, Soils & Geology (Chapter 6), Water (Chapter 7), Air, Climate & Noise (Chapter 8), Landscape & Visual (Chapter 9), Cultural Heritage (Chapter 10) and Material Assets (Chapter 11).

The cumulative impact assessment has been carried out with the purpose of identifying what influence the proposed development will have on the surrounding environment when considered cumulatively and in combination with relevant permitted, proposed and constructed projects in the vicinity of the proposed site.

The cumulative impact assessment encompasses four key steps, as follows:

1. To establish the range and nature of existing projects within the cumulative impact study area. 2. To identify the projects that hold the potential for cumulative interaction with the proposed development and discard projects that will neither directly nor indirectly contribute to cumulative impacts. 3. To summarise the relevant projects which have a potential to create cumulative impacts. 4. To assess anticipated cumulative impacts under each environmental heading.

Assessment material for the cumulative impact assessment was compiled with regard to the relevant developments or projects identified within the vicinity of the proposed development site. This material was gathered through a search of the Mayo County Council online Planning Register, including the associated planning application details, drawings and environmental reports. These projects are summarised in Section 2.4.2 below.

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2.4.2 Projects Considered in Cumulative Assessment

The proposed development is considered in combination with other projects in the area that could result in cumulative effects on the environment.

The online planning system for Mayo County Council was consulted on 23rd November 2020, as referred to in Section 2.3 above. The following developments were identified for inclusion in the cumulative impact assessment:

Planning Reference No. 18/833 – Cable Landing Station

“Construct a single storey cable landing station with associated fencing, underground cabling, plant and all ancillary works”

This application was permitted in February 2019 and the infrastructure constructed in 2019. The proposed AEC2 cable will connect to this landing station, a view of which is shown below in Plate 2-1. Planning Reference No. 18/833 also encompasses the Beach Manhole (BMH) at Fallduff Strand. The Beach Manhole, with its associated ducts, is also completed, with associated landscaping undertaken as shown in Plate 2-2 below. The front haul cabling between the Beach Manhole and the Cable Landing Station is also complete.

Plate 2-1 Existing Landing Station

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Plate 2-2 Existing Beach Manhole Location (Source: SubCom)

Planning Reference No. 18/1036 – Dwelling House

“Construct dwelling house, domestic garage and connection to public services, together with ancillary site works”

This application was permitted in August 2019.

Planning Reference No. 18/955 – Dwelling House

“Demolition of an existing dwelling and the construction of a replacement dwelling, including an ancillary shed, with all associated site works and connection to services”

This application was permitted in January 2019.

Each relevant chapter within this Environmental Report includes a cumulative impact assessment where appropriate. Given the nature and size of the above developments, i.e. the small single-storey landing station, underground cabling, beach manhole and other associated work culminating in a total area of 0.58 acres, as well as single residential units, the potential for ongoing environmental effects and associated potential cumulative effects with the current proposed development is low.

There are a number of active licensed sites for aquaculture (Oysters) within Clew Bay and in the waters off Clare island (Fin fish). The proposed cable route does not cross any of these aquaculture sites. Given the nature and scale of the proposed cable works, there is no potential for any impacts arising from the proposed project that could combine with these activities to cause a cumulative impact.

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3. DESCRIPTION OF THE PROPOSED DEVELOPMENT

3.1 Introduction

This section of the Environmental Report provides a description of the proposed development, including construction methodologies and environmental controls.

As presented in Chapter 1 of this report, America Europe Connect 2 (AEC2) is part of a transatlantic subsea fibre optic telecommunications cable system (called Havfrue) which runs for approximately 7,866 kilometres (km) across the Atlantic Ocean seabed from New Jersey in the USA to Denmark, with a branch into each of Ireland and Norway. It is proposed that the Irish branch will extend from a sub-sea branching unit in the deep waters of the Rockall Trough some 300km north of the Mayo coastline to the landing point at Old Head, Louisburg, Co. Mayo.

Site location maps are provided in Section 2.1 of Chapter 2 of this report.

3.2 Proposed Cable Installation

The works and associated timeframes associated with the proposed cable installation are presented in Table 3-1.

Table 3-1 Proposed Development Works Components

Component Description Duration

Pre-lay grapnel run Carried out immediately prior to cable installation 1 day to clear the seabed of any surface debris such as wire, discarded fishing gear, etc. that may have deposited along the cable route

Direct Landing Deployment and laying of the cable from the cable 1 day vessel at 12-metre (m) water depth to Fallduff Strand, Old Head. Will be undertaken using marine based divers and small boats

Beach Works Excavation of beach trench from Low Water Mark 1 to 2 days at Fallduff Strand, Old Head to existing conduit at Beach boundary wall (Pl. Ref. 18/833). This excavation will be undertaken by land excavator

Shallow Water Works Water jetting of landed cable into the seafloor 2 to 3 days from 12m water depth to Low Water Mark at Fallduff Strand, Old Head. Will be undertaken using a marine based jetting sled

Main Lay Plough installation of cable into the seafloor from Up to 8 days an area adjacent to the offshore cable branch in to 12m water depth, approximately 1.2 km offshore from Fallduff Strand, Old Head.

Post Lay inspection and Post Lay inspection and burial – In areas where 2-6 days burial cable burial was not achieved, the Remotely Operated Vehicle will use the jetting tool to attempt additional cable burial. These operations would be undertaken from the Main Lay vessel.

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Whereas the above components are intended to be sequential, there are overlapping elements such that it is anticipated the entire installation process will take approximately 20 days to complete, subject to tide and weather conditions, with the Beach Works to take 1-2 days to complete.

Each works component associated with the proposed cable installation is described in further detail in Section 3.3 below.

The technical and environmental characteristics of the underwater cable are included as Appendix 1 to this Environmental Report.

3.3 Construction Methodology

3.3.1 Pre-Lay Grapnel Run

Immediately prior to installation of the subsea cable, a Pre-Lay Grapnel Run (PLGR) will be carried out along the centreline of the proposed cable route at each location where burial is planned. The intention of the PLGR is to clear seabed surface debris (e.g. wires or hawsers, discarded fishing gear) that may have been deposited on the seabed along the route.

During PLGR operations, the vessel will lower a suitable grapnel to the seabed and proceed to tow the grapnel, at a speed of between 1 and 4 knots, across the seabed along the cable route. Should the first pass encounter any type of debris, two additional parallel passes, on either side of the centre line, will be made. The impact area of each pass will be approximately 0.75 m, with spacing up to 50 m apart. As the grapnel is pulled across the seabed, typical blade seabed penetration of up to 40 centimetres (cm) is achieved, depending on seabed composition. The grapnel activity will not be conducted in hard bottom areas. It will avoid existing cables which are present only in the EEZ (i.e. beyond the 12 Nautical mile limit). Debris recovered to the cable ship during these operations will be disposed of appropriately onshore upon completion of the operation.

3.3.2 Direct Landing

Direct landings are used in areas where sea conditions are favourable, no sensitive subsea resources are present, and water depths allow for the main-lay vessel to safely position close enough to shore. This is the case with Fallduff Strand, Old Head and its adjacent shallow waters. Direct landing operations are typically conducted within one day. The first step of this process is the establishment of a clearly defined working safety perimeter along with final notification and coordination with local authorities.

Direct landing involves deployment and laying of the cable from the cable vessel at 12m water depth to Fallduff Strand. It will be undertaken using marine based divers and small boats.

Once the working safety perimeter has been established, the seaward end of the Beach Manhole (BMH) ducts will be exposed. This is a very short works package undertaken in the upper beach using a mechanical excavator. A floating hauling line will then be run from the cable lay vessel (located 1.2km from the shore) to the shore. Once the floating line arrives on the beach, the cable lay vessel attaches the cable end to the hauling line. It then attaches floats to the cable at regularly spaced intervals. The shore end of the hauling line is then pulled, whilst the cable vessel simultaneously pays out the cable, see Plate 3-1.

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Plate 3-1 Floating Haul Line (Source: SubCom)

The cable then floats to the shore. A mobile beach quadrant will be used to assist with the cable landing. A beach quadrant is a metal quarter circle which allows excessive cable slack to be landed safely on the beach. Once sufficient cable has been landed, the floats are removed, and divers assist in placing the cable on the seabed to its pre-engineered route.

3.3.3 Beach Works

The beach works comprise excavation of a beach trench from Low Water Mark at Fallduff Strand, Old Head to existing conduit at the Beach boundary wall.

A typical technique for cable beach trenching involves the excavation of a trench up to 2 m (6.6 ft) deep (subject to geophysical conditions) and up to 2 m wide, using equipment such as a backhoe. Articulated pipe will be installed over the beach segment of the cable. The articulated pipe adds additional protection to the cable in the shallow water areas and is applied (after cable landing) by the shore-end team/divers. Articulated pipe is preferred in coastal systems, as it adds extra external protection to the cable.

A beach team will arrive prior to the cable landing to prepare the site. For the standard shore end operations, the beach preparations consist of:

Excavating and exposing the entry ducts; Erecting and/or instituting traffic and/or safety control measures as required; Arranging security if and as required; Mobilizing required equipment to the site; Preparation of articulated pipe;

Excavators prepare the beach by setting up in beach pulling mode (one excavator is positioned near the landing point with a quadrant and the other excavator prepared with necessary rigging and pulling rope). Typically, a small workboat will meet with the main lay vessel and connect a hauling line to the cable. This allows the principal excavator to begin pulling the cable to the beach. A second excavator is used at the landing site as an anchor point for the quadrant. The quadrant allows the pulling rope to make the 90 degree turn around the quadrant from the direction of landing. The principal excavator pulls the rope attached to the cable, around the quadrant, for a distance of approximately 100 to 200 m along the beach.

During this time, the main-lay vessel will pay out cable with floats at the same rate at which the principal excavator performs the beach pulls. The cable will be secured each time the excavator needs to reposition to perform a new pull. Beach pulls will continue until all required cable has been safely landed on the beach. Safety officers may be used in some areas to enable safe public access to the beach and

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acknowledgement of safe working zones. These areas will be delineated by hazard tape erected on temporary stakes.

Plate 3-2 Typical Beach Landing Using a Quadrant (Source: SubCom)

The AEC2 landing requires the installation of an Ocean Ground Bed (OGB). An OGB serves as an earthing rod, typically situated close to the project Beach Manhole (BMH) and buried below ground level. The OGB is an array of buried anodes that terminates the land cable and provides a return path for powering the undersea system. The typical electrical parameters for an operating OGB are on the order of only 2 V based on a DC current of 1 A and resistance of 2 Ω between the anode array and Earth. The magnetic field at the undersea cable surface is on the order of 30 μT to 38 μT which is distributed and reduced when spread across multiple anodes in the OGB. Considering that the OGB is buried and separated by at least 1 m of sediment from any observer, the resulting magnetic field from the OGB is significantly less than 0.30 μT to 0.38 μT.

The OGB will be placed in the beach area at Fallduff Strand, Old Head, along the permitted cable corridor and close to the beach boundary wall. This small cable will connect the OGB to the BMH through the existing duct. As such there will be no requirement for additional terrestrial excavations.

After installation, neither the cable nor the OGB will be visible and the beach will be restored to a condition at least equivalent to that which was found prior to operations.

3.3.4 Shallow Water Works

The shallow water works will comprise water jetting of the landed cable into the seafloor from 12m water depth to Low Water Mark at Fallduff Strand, Old Head. This work will be undertaken using a marine based jetting sled.

Diver/water jetting is used to conduct cable burial (in shallow water) after the cable has been laid (post-lay inspection and burial) and is conducted using a hand-held or mechanical jetting tool that fluidises the sediment and the cable is placed in the trench they produce. The jetting sled is a wheeled vehicle, measuring 2.9 m in width. It creates a narrow cable trench measuring up to 50 cm in width, depending on depth. A typical jetting sled is shown in Plate 3-3.

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Plate 3-3 Typical Jetting Sled (Source: SubCom)

The inshore jetting process produces some localised turbidity. The trench fills over the cable at varying rates, depending on local currents, sediment characteristics, and movement of sediments. The jetting process is a common burial method utilised by the submarine cable industry to protect cables in nearshore environments. It allows for accurate and careful positioning of the cable to ensure it is protected and placed in the correct position. Suspended seafloor sediments are temporary and localised to the area along the cable route. Sediments will settle back to the seafloor once the jetting operation is complete. Typical jetting progress is 200-500 m per day.

Plate 3-4 Diver Jetting (Source: SubCom)

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3.3.5 Main Lay

The main lay operation will involve plough installation of the cable into the seafloor from an area adjacent to the offshore cable branch to 12m water depth, approximately 1.2 km offshore from Fallduff Strand, Old Head.

Through non-bedrock seabed areas, the cable ship will install and bury the cable simultaneously using a sea plough, as shown in Plate 3-5. The sea plough, as shown in Plate 3-6, is a burial tool resembling a large sled, approximately 5 m wide, attached to the cable ship with a tow wire. It allows for mechanical burial of the cable to a desired depth by creating a furrow approximately 0.75 m wide and feeding the cable to the bottom of the furrow. As the plough is pulled forward by the installation vessel, the cable lies in the bottom of the furrow and is backfilled via the movement of sediment on the seafloor as the plough is towed across the bed. Typical operational plough speeds are less than 1 knot, depending on the stiffness of the seabed and other factors such as sea state, weather, current speed etc.

Plate 3-5 Plough Burial (Source: SubCom)

Plate 3-6 Cable Plough (Source: SubCom)

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Subsea cable installation using a sea plough within the main lay is not possible in areas of exposed bedrock. The cable is instead laid directly onto the seafloor but can use seabed features such as sand pockets and crevices, to enable opportunistic PLIB burial, optimise cable security and minimise free spans. Computerised modelling and tracking from the cable ship (see Section 3.3.5.1 below for further details) are used to control position and tension of the cable during laying activities, as well as correct for external factors such as wind and ocean currents. See section 3.3.6 below for additional steps that will be taken by Subcom in areas of exposed bedrock to secure the cable on the seafloor.

Use of the cable lay software and advanced installation methodologies during installation reduces the likelihood of unwanted cable suspensions and assists in accurately placing the cable along the planned route. In areas where the cable is laid and buried, it maintains position on the seabed due to burial methods (avoiding cable slack), the weight of the cable and the burial depth

3.3.5.1 Main Lay Navigation

The main lay vessel will use state of the art navigational systems and cable installation software (MakaiLay or equivalent) that allow precise surface positioning and prediction of the installed cable position on the seafloor. Makailay (or equivalent) allows real time data inputs for finite elements.

Information such as the planned cable route, bathymetry, ship heading, position, speed, cable characteristics and layout speed are integrated into the software to optimise the real-time monitoring of the cable installation. This software will use an advanced 2D force-based cable model to predict touchdown. The ship route will then be adjusted by the predicted offset distance calculated by the model to ensure the cable touchdown point will be closely positioned along the planned route. Current vector data may also be used to improve prediction of as-laid accuracy within certain depth ranges.

Surface lay accuracy will be limited to the accuracy of the dual frequency GPS receivers, the motion of the vessel and the force-based software touchdown calculations based on cable type. Therefore, accuracy figures for the cable position relative to the planned route are to be given in relation to water depth, except in shallow water areas where the ship surface positioning is more critical. Based on experience using MakaiLay (or equivalent) and previous cable installations, expected positioning accuracy figures are presented in Table 3-2 below.

Table 3-2 Expected Accuracy of Cable Lay Position Based on Water Depth

Water Depth Range (metres, m) Precision

< 25 m +/- 5 m in water depth

25 to 100 m +/- 10 m in water depth

100 to 1,000 m +/- 30 m in water depth

> 1,000 m +/- 100 m in water depth

3.3.5.2 Main Lay Vessel Speeds and Operations

Throughout the majority of cable installation activities, the main-lay vessel is underway travelling from 1 - 5 knots (9.26 km/h) in open ocean waters but speeds will vary depending on weather, seabed, and location.

Cable laying activities will be closely monitored by the SubCom team. SubCom operates a fleet of 150 m “Reliance Class” vessels. Each vessel is outfitted with a cable trenching Remotely Operated Vehicle (ROV) and sea-plough system suitable for the target 2.0 m burial depth. Cable handling machinery includes two 30-ton cable drums and 20-wheel pair linear cable engines allowing for precise handling and monitoring of all aspects of the cable lay.

For landing operations, the main-lay vessel maintains position by dynamic positioning. This system uses computer-controlled vessel thrusters to maintain position. Depending on depth when operating, the

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thrusters are typically enclosed in the hull, positioned in a sideways and downwards direction. The bow and stern enclosed thrusters thrust in a horizontal plane, 50 m aft and 25 m to either side. They create minimal turbulence in a sideways and downwards direction, due to their effective and efficient design. This turbulence can occur in a horizontal axis up to 2 m from the source.

With regard to the utilisation of the cable installation vessel – the following provides a consideration of the operations in relation to the environment:

Fuel consumption of main-lay cable installation vessels may vary with activity and weather/tide/current conditions, but it is likely to average the following for each vessel: 4 to 18 metric tons/day. Up to 80 crew/personnel can be on board for marine cable installation – crew/personnel are accommodated on the vessel. Vessel will comply with national and international environmental regulations prohibiting discharge of waste from vessels while operating nearshore. Waste from vessels will be sequestered on board and discharged at appropriate port facility. Vessel sanitary wastewater will be treated in on-board sewage treatment plant. Outside MARPOL limits (3NM) only treated wastewater may discharged at sea. Ships are also equipped with an oily water separator. Used/unwanted oil is collected for recycling. Main lay vessel has Rolls Royce Marine AS diesel engines (main propulsion/auxiliary power) compliant with emission standards of regulation 13(3)(a) in accordance with the NOx Technical Code. The installation vessels also carry a valid International Air Pollution Prevention Certificate. Statistics for vessel sound are for levels measured within accommodation and spaces utilised by crew and are in accordance with IMO Resolution A.468(XII). Construction sound will be temporary and short term. Possible sources of underwater noise and vibration, and electromagnetic fields, are identified and assessed in the Natura Impact Statement that accompanies this application. Once installed the subsea fibre optic cable has no requirement for operational maintenance. If a fault/break is caused to the cable, a repair operation would be undertaken by a cable vessel, retrieving the faulted section of cable to the vessel and repairing on board. The repaired cable would then be returned and reburied in the seabed, using the ROV mounted cable burial technique, to the approximate original location.

3.3.6 Post Lay Inspection and Burial

SubCom will undertake Post Lay inspection and burial (PLIB). This work is undertaken using a remotely operated jetting platform based on the Main Lay vessel. The tracked Remotely Operated Vehicle (ROV) will travel along the selected section of cable recording the depth of cable burial. In areas where burial was not achieved, the ROV can use the jetting tool to attempt additional cable burial. The jetting tool uses ambient water to fluidise the seafloor, thereby creating a trench for the cable to be inserted.

PLIB will not be possible in areas of exposed bedrock. It may be possible in sand pockets between exposed bedrock areas. Determination of the suitability of the sand pockets for PLIB will be carried out during operations.

3.4 Decommissioning

There are three principal options for cable decommissioning of the AEC2 System: These are:

1) Do nothing, leave the cable in-situ or 2) Recover the cable from the seabed. 3) Partial recovery of portions of the cable from the seabed

At this time, it is not appropriate to commit to a final system decommissioning strategy as decommissioning techniques and principles may change between now and the cessation of the system operations.

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Prior to the cessation of system operations, the owners will consult the relevant bodies in order to agree a preferred decommissioning plan for the system.

In the event that the cables are removed, decommissioning will be agreed in consultation with the authorities on the basis of the condition of the cable, ecological criteria, applicable legislation, relevant industry guidelines (European Subsea Cables Association (ESCA) and International Cable Protection Committee (ICPC)) and a technical-financial evaluation of the techniques available at that time.

3.4.1 Current Decommissioning Processes

Option 1: Leave in situ. In this scenario no seabed or habitats will be disturbed, this includes those at the time of installation and any that may have formed above the cable since it’s installation.

Option 2 and Option 3: Cable recovery. This scenario involves recovering any cable that has not been crossed by live cables after its installation. In this event final cable recovery plans will be agreed with relevant authorities prior to the commencement of work and where applicable licences will be obtained. Selection of cable recovery supplier will be the responsibility of the system owner at the time of decommissioning.

Using current decommissioning techniques, attempts would be made to remove all sections of cable in Territorial Waters, except at crossing locations or locations prohibited by the authorities. At crossing locations, a section of cable, either side of the crossing point, is likely to remain on the seabed in line with the ICPC recommendations to allow this cable to “remain undisturbed” on the seabed.

On the beach and intertidal area, the cable would be excavated, exposed, cut and recovered using a land- based team supported by excavators.

For nearshore cables, the cable ship would be positioned at the 12-15m depth contour and would establish a messenger line/rope/wire to beach with the use of small support vessels. A pulling wire/rope from vessel would be connected to seaward section of exposed cable end on beach. The cable ship would peel back the out-of-service cable which would be pulled out of the seabed and the cable would be recovered to the cable ship.

Where the 12-15m depth contour is more than 3km from beach, a dedicated barge would be mobilised with necessary winches and storage space. The dedicated barge would perform cable recovery with the same nearshore procedure outlined above.

For offshore cable, a grapnel would be used to locate the cable and cut the cable. The loose end would be winched aboard and pulled from the sediment. The cable would be rinsed as it is pulled onto the vessel to remove any sediment and biological material that may be attached.

The recovered cable would be offloaded and treated as per local rules at the time of decommissioning, for possible re-processing/scrapping of recovered cable product.

Typically, no post-recovery survey would be planned as the recovery operation would precisely document what cable has been recovered from A to B, where it could be easily recovered and pulled out of seabed or recovered from hard ground areas where the cable is surface laid. The detailed information of cable recovery locations would be shared with the relevant authorities for inclusion on subsequent updates of Admiralty Charts.

3.5 Sequencing of Events

3.5.1 Mobilisation

The following preparation activities will take place prior to commencing the shore side cable pull in.

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3.5.1.1 Personnel

SubCom will mobilise an Advance Team (Engineer in Charge / Beach Master / Offshore Manager / Lead Technician) prior to the expected landing date for final inspections and preparations for the Shore end landing (direct landing). SubCom will mobilise the remaining team to country ahead of the expected landing date.

3.5.1.2 Equipment and Support Vessels

Equipment will include:

1. Specialised Equipment: All specialised project equipment (Beach Quadrant & Rollers, Surface Supply Dive Spreads, electronics etc.) will be shipped and will be temporarily stored in a warehouse in Westport in readiness for the beach landing. 2. General Equipment: All general support equipment (rigging spreads, dive spreads etc.) will be shipped and will be temporarily stored in a warehouse in Westport in readiness for the beach landing. 3. Land Equipment: Land Excavators for the onshore trenching and supportive activities have been tentatively committed by local subcontractors and will be mobilised on-site prior to the beach landing.

Support Vessels will include Pulling Boats & Dive Support Vessels, and Burial / Support Boats.

3.5.2 Beach / Site Set-up and Cable Quadrant Placement

The beach area surrounding the Beach Manhole will be prepared in advance of the shore end operations including the removal of debris as required. This will be a very quick exercise (1-2 hour). It will not result in any significant beach access restrictions.

With the site area prepared, a quadrant will be set in place at the appropriate position along the cable route by attaching it to a tracked Excavator which will act as an anchor. The quadrant will be attached to the DMA / excavator via 4 legged chains attached to a pad-eye on the base of the excavator, and 4 pad eyes on the quadrant. These activities will be undertaken within the safe working zone.

3.5.3 Hold-Back Anchors

Prior to the Shore End Landing, 2 x 25 kg “Bruce” anchors (or similar) shall be installed adjacent to the main lay vessel (1.2 km from shore). These will be positioned, using divers, adjacent to the location of the Cable Plough deployment (1.2 km from shore). The purpose of the anchors is to ensure that no dragging of the cable will occur during plough deployment and commencement of the offshore lay with the Cable Ship. This will further ensure no slack is removed from the Shore End Section.

Within the marine environment, safety boats will be in position on either side of the cable route to deter any oncoming marine traffic and guard for natural phenomena as required during the shore-end landing and cable installation stages. They will be employed on a 24-hour basis until works have been completed.

3.5.4 Diver Pre-Lay Survey and Messenger Line Placement

A diver swim video survey will be completed 1-2 days in advance of cable landing operations. It will extend from the Low Water Mark to the Stand-off Position of the Cable-lay Vessel. This will be done so as to confirm the surf zone distance and to identify any seabed hazards that can be removed / avoided including but not limited to rock/boulder outcrops and seabed debris.

A nearshore safety boat will be deployed for the preparation of the Pre-Lay Survey operation. It will first place a high visibility sinking line on the seabed along the cable route, tagged every 20 m to simulate the cable during the video survey. The video survey will be subject to the underwater visibility. If visibility

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does not permit video, then a diver will swim along the seabed to feel out any obstructions along the route by hand.

Following the placement of the sinking line, the dive support boat will load a complete dive Spread and a full dive team for the video pre lay survey. Details regarding the protection of local receptors during the works are presented in Section 3.6 below.

3.5.5 Shore End Landing (Pulling Vessel): Phase 1

Table 3-3 provides a description of the line types that will be used throughout the pull-in or cable landing operation.

Table 3-3 Lines Used in Cable Pull

Pulling Line Name Type Connection Point

Pulling Head 2 x Yale grips (or 1 x preformed Connected to the Product (Cable) stopper) c/w thimble – bullet swivel – thimble arrangement

Pulling Line 36mm (Floating) Cable Pulling Head to Messenger Line Ashore

Pulling Line Tail 25m by 36mm (Floating) Cable Pulling Head to Pulling Vessel Tow Bridle

The pulling of the cable from the SubCom’s Cable Lay Vessel will be performed in a three-phase operation as follows:

The pulling vessel will be deployed to the stern of the Cable Lay Vessel ready to receive the pulling line.

The pulling line will be passed to the pulling vessel via a weighted “throw line” and will be manually pulled onto the pulling vessel. The pulling line will be coiled on the deck and the 25 m pulling line tail will be secured to the tow frame via a 10 M/T SWL galvanised D-shackles connecting to a towing bridle.

Once the connection is made, the Offshore Manager will instruct to commence paying out cable. The pulling vessel will commence pulling the cable, supported on floats (A4 Buoys every 10 m) in a straight line towards the shore in a carefully coordinated process of pulling and pay out, from the Cable Lay Vessel.

Two support boats ( RIBS or Local Support Boats) as shown in Plate 3-7, will attend this operation and if required assist the pulling vessel by pulling the “belly” of the cable up current to reduce the cable catenary as necessary to conform to the design route.

Plate 3-7 Conformance of the cable along the designed route by RIBS (Source: SubCom)

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The support boats will attach to the cable via two lace-up Chinese fingers attached to the cable with the soft eyes facing each Chinese Finger at a 3 m separation in-between. The two soft eyes on the Chinese fingers will be attached to the assist boats via a 10 Tn Shackle connecting a 10 m Tow line (36 mm Polypropylene) to the bollards on the stern on the boat. The lace-up Chinese fingers are to be pre- positioned on the cable at intervals to be determined during the Pre-Lay Meeting on-board the Cable Lay Vessel.

The pull-in of the cable will continue until the pulling vessel reaches the pre-positioned waiting line, attached to the buoy. The Offshore Manager will instruct the Cable Lay Vessel to stop paying out of the cable and the pulling vessel will hold position. A safety boat will pick up the loose end of the rope on board the pulling vessel and attach it to the waiting line.

Nearshore safety boats will be in position on either side of the cable route to deter any oncoming marine traffic and guard for natural phenomena as required.

3.5.6 Shore End Landing (Transition): Phase 2

The beach equipment will include the items listed in Table 3-4.

Table 3-4 Equipment to be used on beach

Equipment Type Comments

Cable Pulling Machine 20T Tracked Excavator Primary Pulling machine (Excavator 1)

Dead Man Anchor 20T Tracked Excavator Secondary Pulling machine if (Excavator 2) required – Primary Anchor Point for Beach Quadrant

Beach Quadrant / Cable 1.5m Radius Steel 180’ quadrant Load Tested to 20.5MT Diverter with rollers

With the lines attached, the waiting line will be connected to the beach excavator 1 via 10M/T Shackles (x2) connecting a calibrated 10M/T load cell to the pad-eye on the base of excavator 1.

Once excavator 1 is engaged with the messenger line, it will take 1m interval movements until tension taken up on the pulling line.

When the cable tension from the pulling vessel is taken by excavator 1, the pulling line tail from the tow post of the pulling vessel will be released. Pulling of the cable is now transferred to the beach team. The pulling vessel will move to a safety distance of 100m from the cable and remain on stand-by for assistance where required.

The entire shore end transition operation is estimated to take 4-6 hours to complete.

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Plate 3-8 Schematic of Beach Pull (Source: SubCom)

3.5.7 Shore End Landing (Cable Positioning and Floats Removal)

Following the completion of the shore side pull-in, a support boat will move along the cable route, and with the use of a handheld GPS unit (pre-programed with the Route coordinates) will confirm if the cable is along the planned route. Final remediation to the floating cable’s position will be made as required prior to the sinking of the cable to the seabed.

Once all floats are removed a diver will swim the cable to check on the condition of the cable on the bottom. Adjustments will be made as needed to reduce and/or eliminate suspensions and chaffing points.

Cable slack will be reserved for diver cable arrangements along the positioned cable on the seabed. Following the completion of shore end operations, a diving team will proceed to perform the post-lay video survey, apply the articulated pipes, and proceed with the offshore burial. The Offshore Installation vessel will proceed with the further laying operations.

3.5.8 Beach Manhole Cable Installation

Following completion of the direct shore end landing, the shore stopper will be removed, and the cable will be manually fed into the appropriate duct leading to the Beach Manhole. Once the cable is brought into the Beach Manhole in sufficient lengths, the shore end team will remove the armour wires and apply the Armour Clamp. Once the Armour Clamp is applied, the offshore stoppers can be removed.

The cable slack will be utilised for moving the cable out of the way during the shore trench excavation. With the shore trench excavated, the cable will be manhandled into the trench.

3.5.9 Post-Lay Video Inspection

Following the cable landing operation, the divers will inspect by video the surface laid cable up to the Main Lay Vessel Stand Position and as required in certain areas.

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3.5.10 Ocean Ground Bed Installation

The ocean ground bed (OGB) installation involves the following activities:

1. Identification of the location of any in-service cables or metallic structures in the area on the beach as well as seawards from the Low Water Mark. 2. Trench excavation and placement of the OGB plate into the trench 3. Trench excavation from the earth plate position to the extremity of the seaward ducts of the Beach Manhole and installation of the earth plate cable into the trench. 4. Installation of the earth plate cable into the Beach Manhole through one of the vacant ducts. 5. Articulated Pipe installation on the OGB cable 6. Laying of suitable warning marker tape approximately 0.5m above the cable and earth plate during the reinstatement of the beach. 7. Backfilling of all excavations

3.5.11 Articulated Pipe Installation and Beach Burial Operations

The beach trenching operations will be undertaken segmentally. Following the completion of each segment of beach excavation, the cable will be placed into the trench and the segment of the trench is then covered with the excavated material

Within the trench, the cable will be protected by bolted Articulated Pipes (AP) running from Beach Manhole headwall seawards and from the OGB plate position up to the Beach Manhole headwall (ground cable).

Two bolts will be installed to every section of split pipe within the high surf zone area, and on the beach as well as in the open water, two bolts shall be installed to every 5 m of Articulated Pipe.

3.5.12 Inshore Burial Operations

For the inshore burial operations, it will be ensured that any equipment or burial techniques will not damage or cause deterioration of the cable or plant. Should any cable or plant be damaged or subject to excessive stress, strain, bending or exceed qualified design limits in any respect, SubCom will immediately notify SubCom and agree on the remedial action to be taken.

For the inshore burial operations, an inshore jetting trencher will be utilised to achieve the target burial depth and a diver Hand jetting system will also be available if needed.

3.5.13 Site Restoration

Following cable installation, the beach will be restored to its prior condition, as required by the local authorities. All materials and equipment will be retrieved and the site area, at each location, will be cleaned and cleared of rubbish. This will entail:

Remove all debris and project related (and generated) material, supplies and equipment from the site at the completion of the work. Remove all evidence of machinery presence. That is if there are track marks in the sand grade them so that they are removed. If there have been oil marks or tire track marks, clean up and erase. Replant any vegetation damaged during the shore end. Repair any damage to structures such as curbs, fences, retaining walls, concrete pads, gates, etc. Close manholes

Before the site is completely vacated the Beach Master will meet with the SubCom Engineer in charge on site to make sure that there are no issues

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3.5.14 Weather and Environmental Conditions

In the event that the weather and environmental conditions in the field deteriorate to a point where the Project Manager deems that the operation should be halted, the works will be halted. SubCom will then continuously review the weather forecast, to determine an acceptable timeline for recommencement of operations. Once the timeline has been confirmed, SubCom will develop a recommencement methodology in consideration of all relevant requirements.

3.6 Protection of Local Receptors

3.6.1 Old Head Water Quality

Fallduff Strand, Old Head currently has a monthly water quality testing regime, to comply with EU bathing water quality requirements (SI 79/2008, SI 351/2011, SI 163/2016 – Bathing Water Quality Regulations). Under the Bathing Water Quality Regulations, ‘bathing season’ means 1 June to 15 September each year. Mayo County Council is responsible, under the Regulations, for putting in place a monitoring programme for bathing waters in its functional area, and for submitting a monitoring calendar to the Environmental Protection Agency (EPA) by the end of March each year. On average, Mayo County Council’s monitoring calendar for Fallduff Strand, Old Head, has commenced in or around the third week of May and continued until approximately the first or second week in September each year (https://www.beaches.ie/find-a- beach/#/beach/IEWEBWC340_0000_0300). Mayo County Council may, in accordance with the Bathing Water Quality Regulations and with the approval of the EPA, suspend the monitoring calendar in certain situations, for example during the course of scheduled work in or around the bathing waters in question.

In accordance with the Bathing Water Quality Regulations, SubCom will liaise with the Environment section of Mayo County Council to ensure that all necessary approvals from the Council and the EPA, including if necessary for the suspension of the monitoring calendar, are obtained prior to installation.

3.6.2 Local Access

SubCom is committed to providing continued access to Fallduff Strand during the cable installation works insofar as is possible. While the cable landing operations are short-lived and access to the beach will continue during works (with the temporary exception of the immediate works area), the following measures will nevertheless be employed:

Table 3-5 Local Access to Beach and Health and Safety Requirements

Aspect Predicted Restriction

Site Preparation The only restrictions anticipated surrounding site preparations are safety zones surrounding machinery. Safety officers will accompany all machinery and alert the public to their operations. The public will then be asked to continue a safe distance from the operating machinery. Site preparation activities will be undertaken in advance of cable landing. There will be no access restrictions in place at this time.

Exposure of Beach Localised restriction immediately surrounding the exposed ducts – Manhole ducts at the restriction will take the form of Harris fence, 2m x 2m or hazard types and beach boundary wall stakes. It will be in place for 24 hours.

Cable Landing on Restriction in the form of a safety zone only required around machinery, beach quadrant and moving cable. These safety zones will be administered by safety operative advising people of the operations and asking then to continue a safe distance from the operating machinery and moving cable. When landed, the cable will be inert. It will partially bury in the sand and will not pose a threat to the public. Cable landing operations on the beach

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Aspect Predicted Restriction are anticipated to take 4-5 hours. The operations will be undertaken to coincide with Low Water.

Cable burial in beach During cable burial in beach, restrictions in the form of a safety zone will be required around open trenches and the associated excavator. The excavator will dig a short length of trench, approximately 10m at a time, adjacent to the cable and place it in. Once the cable has been situated at the base of the trench, the excavator will immediately backfill the section, returning the beach to its original form. The excavator will then commence excavation of a new length of trench adjacent to the cable. The safety zones required for these operations will be administered by safety operative. They will advise people of the operations and ask then to continue a safe distance from the operating machinery and open trench. No form of fencing is anticipated to be required. These segmented operations are predicted to last 1 day and will not result in closure of the beach.

Site Remediation and The only restrictions anticipated surrounding site remediation and demobilisation demobilisation are safety zones surrounding machinery. Safety officers will accompany all machinery and alert the public to their operations. The public will then be asked to continue a safe distance from the operating machinery. Site preparation activities are predicted to be undertaken 1-2 days after cable landing. Consistent with the Safety Health and Welfare at Work (Construction) Regulations, no open trenches will remain open overnight and all equipment will be stored in the secure Car Park/CLS compound.

3.6.3 Local Stand Up Paddleboard (SUP) Business

SubCom have contacted the owner of Summer SUP at Old Head. Depending on timing of the cable installation, a deconfliction protocol may need to be agreed to allow the two activities to co-exist. Initial discussions have been carried out with the owner in this regard, but the full details of any possible protocol cannot be agreed until such time as the cable installation period has been confirmed. As previously described, the beach landing operations will be a short duration operation, so overlap will be short. Additionally, the inshore cable burial activities will have small boat support. These small boats will be able to provide protective cover to both divers and SUP, if required.

3.6.4 Recreational Water Users

SubCom are aware of the importance of Old Head as a centre for recreation water use. The proposed operations are short-lived and will have minimal impact on recreational water users of the area. Notice to Mariners and operations notifications will be provided to marine users in the area.

The beach landing operations will be a short duration operation, so overlap with recreational water users will be short. The inshore cable burial activities will have small boat support. These small boats will be able to act as safety boat against external boat encroachment on the works area. They will also act as cover and support to both divers and recreational boat users, if required.

Advance notification of all operations will be broadcast by the Coastguard. All works boats will carry a VHF radio on dual watch channel 16 and the local working channel. This arrangement will allow local water users to contact and notify the works vessels.

3.6.5 Old Head Blueway

SubCom are aware of the importance of the Old Head Blueway to Old Head and the County of Mayo. SubCom will work with Mayo County Council to ensure that the AEC2 installation works do not hinder

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use and appreciation of the Old Head Blueway. The cable landing operations will be a short duration operation.

3.6.6 Commercial Vessel Use of Old Head Pier

Old Head pier is currently only accessed by commercial vessels during times of inclement weather. No cable landing operations will be undertaken during inclement weather. Should Old Head Pier be developed in the future, AEC2 have provided assurances to Mayo County Council that, in such an event, the in-situ cable can be re-routed in agreement with Mayo County Council to accommodate the final design.

3.6.7 Local Residents

The cable landing works will have no significant effects on local residents for Old Head. No road closure is required, and the main body of work is on the beach. Throughout the project, SubCom have engaged with the residents of Old Head, including house calls and distribution of project newsletters. SubCom intend to continue this engagement. SubCom will notify local residents in advance of the cable installation works by means of newsletter.

3.6.8 Fisheries Engagement

The project has had extensive fisheries engagement with both commercial and recreational fisheries groups. A dedicated Fisheries Liaison Officer (FLO) was appointed in 2018 and has had numerous engagements with all fisheries groups, presenting the project, as well as addressing their questions and concerns. The FLO in association with other SubCom and AEC2 personnel have attended meetings of the North West Regional Inshore Fisheries Federation (NW RIFF) to discuss the project with the fishermen (November 2018, January 2019). They have also held local meetings on Clare Island and Achill Island (January 2018, April 2019, May 2019). It was that these meetings that the details of the cable awareness, project snag protocol and fisheries disruption were discussed and confirmed.

The Fisheries Liaison Officer, Subcom and AEC2 will continue to work with local fisheries groups throughout the application and cable installation process. Once the cable has been installed, AEC2 will operate a 24- hour snag hotline to deal with any cable snag issues and will continue to liaise with the local fisheries groups on an ongoing basis.

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4. POPULATION AND HUMAN HEALTH

4.1 Introduction

This section of the Environmental Report (ER) identifies, describes and assesses the potential impacts and effects of the proposed development on human beings, population and human health and has been completed in accordance with the guidance set out in Section 1.3.3 of Chapter 1: Introduction.

One of the principal concerns in the development process is that individuals or communities, should experience no significant diminution in their quality of life from the direct or indirect effects arising from the construction or operation of a development. Ultimately, all the impacts of a development have the potential to impinge on human health, directly and indirectly, positively and negatively. The key issues examined in this chapter of the ER include population, human health, land-use, residential amenity, community facilities and services, tourism, noise and health and safety.

Potential cumulative impacts are also addressed in this chapter, however potential impacts on human beings are also addressed in additional chapters including Air, Climate and Noise (Chapter 8), Water (Chapter 7) and Material Assets (Chapter 11).

A full description of the proposed development is provided in Chapter 3 of this ER.

4.2 Receiving Environment

The proposed development is not located within any townlands for the majority of the route, except for the area of Fallduff Strand, Old Head where the cable makes landfall, located in the townland of Fallduff. The landfall site is located approximately 3.3 km northeast of the village of Louisburgh and approximately 20 km west of Westport, Co. Mayo. Please refer to Figures 2-1 to 2-3 of Chapter 2: Background to the Proposed Development, for site location maps.

4.2.1 Settlement and Land-Use

The geographic extent of the proposed works is predominantly located on the sea floor off the coast of Ireland, with only a very short segment (c. 200m) of the cable to be located in intertidal habitat, along Fallduff Strand, Old Head in Clew Bay, County Mayo. The total length of the proposed Irish branch of the AEC2 cable is approximately 290 km in total. Therefore, the total amount of the cable which will be located in intertidal habitat, (i.e. beach) is less than 0.1% of the total route.

The overall level of residential development in the area around Fallduff Strand, Old Head is low and comprises a holiday village and one-off houses. There are 60 dwellings located within 1 km of the proposed development site as shown in Figure 4-1, based on Eircode data, including permanent and holiday residences. The nearest dwellings to the proposed cable installation location comprise holiday apartments, located within 20 metres of the proposed works, at their nearest point.

4.2.2 Services and Amenities

The nearest settlement to the proposed development site is the village of Louisburgh, which is located approximately 3.3 km southwest of the site. Small retail, schools, hotels, B&B’s and a post office are located within the village of Louisburgh. Larger-scale retail and services such as supermarkets, and amenities such as a golf course, escape rooms etc, are located in the town of Westport, approximately 20 km east of the proposed development.

SEA002-0023-5747182-2 4-1 Map Legend

Fibre Optic Cable Route

Existing Landing Station and Infrastructure

1km Buffer of Cable Route

Dwellings Ordnance Survey Ireland Ordnance Licence AR No. Survey 0021820© Ireland/Government of Ireland Drawing Title Microsoft product screen reprinted shots with permission from Microsoft Corporation Dwellings within 1km of Cable Project Title TE Subcom Foreshore Licence Application Drawn By Checked By DN LM Project No. Drawing No. 200630 4-1 Scale Date 28.10.2020

MKO Planning and Environmental Consultants Tuam Road, Galway Ireland, H91 VW84 +353 (0) 91 735611 email:[email protected] Website: ww.mkoireland.ie Foreshore Licence - ER F - 2020.11.27

4.2.2.2 Education

The nearest primary school to the proposed development is Scoil Naisiúnta Padraig Naofa, located approximately 2.5km southwest of the proposed development site in the village of Louisburgh. The nearest secondary school is Sancta Maria College, which lies approximately 2.7 km to the southwest of the proposed development in the village of Louisburgh.

4.2.2.3 Access and Public Transport

The proposed development site at Fallduff Strand is accessed via the Old Head Holiday Village Road, which links Old Head Close to the R335 Regional Road to the south of the proposed development. The R335 Regional Road, to the south of Fallduff Strand, runs in an east-west direction, connecting the village of Louisburgh and the town of Westport.

The nearest train station to the proposed development is located in Westport, approximately 20 km east of the site. There are daily Bus Eireann connections between Louisburgh and Westport from Monday to Saturday. A significant number of bus routes are available from Westport from which a significant number of destinations may be reached. Knock Airport is located approximately 62 km to the east of the site.

4.2.2.4 Amenities and Community Facilities

The majority of amenities and community facilities, including GAA and other sports clubs, youth clubs and recreational areas available in the area are located in the centres of settlement throughout the wider area such as Louisburgh and Westport. Retail and personal services within the vicinity are provided in the larger settlement of Westport. Saint Patrick’s Church is located approximately 2.7 km southwest of the proposed development in the village of Louisburgh. Larger-scale amenities are located in the town of Westport, approximately 20 km east of the proposed development site. Croagh Patrick pilgrimage site is located approximately 8.5 km east of the proposed development, which offers hiking opportunities. There are a number of walking and cycling routes located in Louisburgh and surrounding areas.

The proposed works area along the beach is located adjacent to Old Head Holiday Village. The beach offers a number of amenities including walking and swimming. Access to the beach will continue to be available during all the proposed works here (i.e. the 1-2 days on which the cable trench will be excavated), with just the immediate works area temporarily restricted for safety. Throughout the project, SubCom have informed locals of the status of project and will notify them in advance of commencement of the onshore activities. SubCom are aware of the importance of Old Head as a centre for recreation water use. The proposed works are temporary and will have minimal impact on recreational water users of the area. Notice to Mariners and operations notifications will be provided to marine users in the area.

The beach landing operations will be temporary, so overlap with recreational water users will be minimal. Please see Section 3.2.2 in Chapter 3 of this report for details on the duration of the proposed works. The inshore cable burial activities will have small boat support. These small boats will be able to act as safety boat against external boat encroachment on the works area. They will also act as cover and support to both divers and recreational boat users, if required. Advance notification of all operations will be broadcast by the Coastguard. All works boats will carry a VHF radio on dual watch channel 16 and the local working channel. This arrangement will allow local water users to contact and notify the works vessels.

4.3 Tourism

Ireland is divided into eight tourism regions. The West Region, in which the site of the proposed development is located, comprises Counties Galway, Mayo and Roscommon. This Region benefited from approximately 13.7% of the total number of overseas tourists to the country and approximately 13.9% of the total tourism income generated in Ireland in 2018 (the most recent period for which regional figures are available).

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Fallduff Strand, Old Head acts as an important area of public amenity and recreation for local residents and tourists alike. Directly adjacent to the area of works on Fallduff Strand is Old Head Holiday Village, which provides self-catering accommodation with coastal views over Fallduff Strand.

The nearest tourist centre to the proposed development site is The Granuaile Visitor Centre within Louisburgh, located approximately 2.8 km southwest of the proposed development. Croagh Patrick is located approximately 8.5 km east of the proposed development. Tourist attractions within the nearby town of Westport include Westport House and Pirate Adventure Park, Wild Atlantic Way Clew Bay Boat Tours, Westport Golf Club, Éalú Escape Rooms, Clew Bay Heritage Centre and Westport Cruises. Westport and Achill Island in Clew Bay are key tourist attractions within County Mayo, alongside Croagh Patrick.

Scenic Routes are considered a tourism resource for the county. There are no designated Scenic Routes located within the proposed development site. Further details on scenic routes in the surrounding area are presented in Chapter 9 of this ER. The potential for visual impacts arising from the proposed development is assessed in Chapter 9 of this ER and concludes that the project will have a negligible impact.

4.4 Human Health

The consideration of potential impacts on human health are examined separately in the Water, Air, Climate and Noise, and Material Assets Chapters of this ER. These chapters should be consulted for information on potential impacts, however a brief summary of the key information is provided in Section 4.5 below. Potential issues relating to health and safety, and amenity concerns are also discussed below.

4.5 Potential Impacts

4.5.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment. The potential for additional investment and employment in Ireland as a result of the benefits brought about by fibre optic telecommunications connecting Ireland with the USA and Continental Europe would be lost. The potential for local employment during the beach excavation and cable installation works would be lost. It is intended to use local contractors where possible during this work (given the specialist nature of the works, some contractors will travel to the site from outside the area).

4.5.2 Cable Installation Phase

4.5.2.1 Health and Safety

The proposed development will be constructed in accordance with all relevant Health and Safety Legislation, including:

Safety, Health and Welfare at Work Act 2005 (No. 10 of 2005); Safety, Health and Welfare at Work (General Application) Regulations 2007 (S.I. No. 299 of 2007), as amended. Diving at Work regulations (Si 422-1981

During construction of the proposed development, all staff will be made aware of and adhere to the Health & Safety Authority’s ‘Guidelines on the Procurement, Design and Management Requirements of the Safety, Health and Welfare at Work (Construction) Regulations 2006’. This will encompass the use of all necessary Personal Protective Equipment, Risk Assessment and Method Statements and adherence to the Health and Safety Plan.

Local residents will be notified ahead of works by means of newsletter. Temporary hazard tape will be erected in areas of the site where uncontrolled access is not permitted. Appropriate health and safety

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signage will also be erected. Site safety officers will be designated to ensure that locals and beach users are diverted from the active works areas. Please see Table 3-5 in Section 3.6.2 of Chapter 3 of this ER for further details on the protection of Health and Safety for workers, locals and beachgoers during the proposed cable installation.

Impact and Significance of Effects

With the implementation of the above, there will no impact or any significant effects on health and safety during the construction phase (i.e. the cable installation phase) of the proposed development.

4.5.2.2 Population

Those working on the construction phase of the proposed development will travel daily to the site from the wider area.

Impact and Significance of Effects

The construction phase will have no impact or any significant effects on the population of the area in terms of changes to population trends or density, household size or age structure.

4.5.2.3 Land-use

The existing land-use and public access to Fallduff Strand, Old Head will continue where possible, during cable installation with the active works areas fenced off prohibiting public access. The cable will be laid in a trench along the beach and will not alter or affect the current land use in any way once installed. There is no potential for subsidence. The trench will be reinstated in a manner such that the base of the trench is reinstated with the material excavated from the base of the trench and the material excavated the middle area of the trench is reinstated with the material excavated from the middle of the trench, etc. When the trench is fully reinstated, it will be compacted to ensure that there are no soft spots.

Impact and Significance of Effects

The proposed development will have no impact on existing land-uses.

4.5.2.4 Tourism and Amenity

As outlined above, public access to the beach will continue during cable installation, with only the works area temporarily restricted from access. Once the cable has been installed it will be imperceptible due to the nature of the cable installation. Traffic management safety measures will be briefly in place between the beach and the car park, as the excavators cross from one location to the other at the start and end of the workday.

Impact and Significance of Effects

Due to the temporary and small-scale nature of the works, there will be a temporary slight negative impact, localised to the immediate works area only, on the 1-2 days that the trench excavation works take place on the beach. There will be no significant effect on tourism or recreation.

4.5.2.5 Noise

There will be a temporary increase in noise levels in the vicinity of Fallduff Strand, Old Head during the cable installation, as a result of machinery used for the works. This has the potential to cause a temporary nuisance to occupants of the dwellings located closest to the proposed works location. Construction noise at any given location near the site will be variable throughout the cable installation works, depending on the activities underway and the distance from the main cable installation activities to the receiving

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properties. Further details on noise are presented in Sections 8.4 and Section 8.5.2.3 of Chapter 8 of this report.

Impact and Significance of Effects

The proposed works at Fallduff Strand, Old Head will have a temporary, moderate negative impact at the dwellings located closest to the works location, during the cable installation stage. However, given that the works will last just 1-2 days, there will be no significant effects on the area with regard to noise. SubCom will notify local residents of the cable installation works prior to them taking place, by means of newsletter. Further details on local consultation are presented in Section 3.6.7 in Chapter 3.

4.5.2.6 Dust

There is potential for dust emission during the cable installation and trenching at Fallduff Strand, Old Head. An increase in dust emissions has the potential to cause a nuisance to sensitive receptors in the immediate vicinity of the site. The entry and exit of works vehicles from the site may result in the transfer of mud and sand to the public road, particularly if the weather is wet. This may cause nuisance to local residents and other road users. The following measures will be in place to limit any dust emissions from the site:

The beach trench will be backfilled with the excavated sand once cable installation is complete; therefore reducing the need to transport material to the site. All plant and materials vehicles shall be stored in dedicated areas. The access roads to the site will be regularly inspected for cleanliness and cleaned as necessary.

Impact and Significance of Effects

There will be a temporary imperceptible negative impact associated with dust emissions. There will be no significant effects on local receptors. Potential dust impacts are further described in Chapter 8: Air, Climate and Noise.

4.5.2.7 Traffic

The cable installation works at Fallduff Strand, Old Head are anticipated to last for approximately 1-2 days. During this time there is some potential for increased traffic associated with the movements of the beach works team and associated machinery and plant equipment to and from the works area, between the beach and its associated car park. Further detail on traffic associated with the proposed development can be found in Chapter 11: Material Assets.

Temporary traffic management safety measures will be implemented to ensure there are no negative impacts on traffic during the cable installation and associated beach works. These measures will be in place momentarily as the excavators cross from the beach car park to the beach. Prior to commencement of any works, the occupants of dwellings in the vicinity of the proposed works will be contacted and the scheduling of works will be made clear. No roads will be closed; access to all local properties and Fallduff Strand will be maintained throughout the works and local residents will also be supplied with the number of the works supervisor in order to ensure that disruption will be kept to a minimum.

Impact and Significance of Effects

The proposed works will have a brief to temporary slight negative impact on existing road users in the immediate vicinity of the works. There will be no significant effects in terms of traffic.

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4.5.3 Operational Phase

Once the cable installation works have been completed there will be no potential impacts on the receiving environment. The cable will be laid along the sea floor in the marine environment and trenched to a depth of up to 2m deep along the beach. It will therefore not be visible or noticeable to the public and there will be no associated impacts once installed.

Should Old Head Pier be developed in the future, AEC2 have provided assurances to Mayo County Council that, in such an event, the in-situ cable can be re-routed in agreement with Mayo County Council to accommodate the final design.

Impact and Significance of Effects

There will be no impacts on population (including recreation and amenity facilities) or human health during the operational stage of the proposed development.

4.5.4 Decommissioning Phase

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning, the associated excavation works and cable removal will be of similar scale and duration to the cable installation works. There is no significant impact on population or human health associated with these works.

4.5.5 Cumulative Effects

The potential cumulative impacts between the proposed development and the other projects described in Section 2.4 in Chapter 2 of this report have been considered in terms of impacts on human beings. Given the nature and size of the developments, as described in Section 2.4, the potential for cumulative impacts with the proposed development is low, as further described below.

4.5.5.1 Health and Safety

Any potential health and safety cumulative impacts between the proposed development and the other projects, in the event that the construction phases of each are concurrent, will be avoided by the requirement for all construction projects to adhere to Health & Safety legislation. There will be no cumulative health and safety impacts.

4.5.5.2 Population

The proposed development will not have any impacts on local population either in isolation or cumulatively with the other projects in the area.

4.5.5.3 Land Use

The impact of the proposed development is imperceptible as the land-use for the cable route will not be affected once the cable has been installed. Therefore, there will not be any impacts on land use either in isolation or cumulatively with the other projects in the area.

4.5.5.4 Tourism and Amenity

As outlined above, public access to the beach will continue where possible during cable installation. Once the cable has been installed it will not be noticeable or perceptible due to the nature of the cable installation. Any impact to Tourism and Amenity will therefore be only temporary in nature during the period of cable installation at Fallduff Strand, Old Head. Therefore, there will not be any impacts on tourism and amenity either in isolation or cumulatively with the other projects in the area.

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4.5.5.5 Noise

Potential cumulative impacts associated with noise are addressed in in Chapter 8 of this ER and conclude that there will be a temporary imperceptible negative impact.

4.5.5.6 Dust

Potential cumulative impacts associated with dust are addressed in in Chapter 8 of this ER and conclude that there will be a temporary imperceptible negative impact.

4.5.5.7 Traffic

Potential cumulative impacts associated with traffic are addressed in in Chapter 11 of this ER and conclude that there will be a temporary slight negative impact.

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5. BIODIVERSITY

This section of the Environmental Report (ER) identifies, describes and assesses the potential impacts and effects of the proposed development on biodiversity and has been completed in accordance with the guidance set out in Section 1.3.3 of Chapter 1: Introduction. The topics addressed in this chapter include benthic ecology, marine mammals and birds.

A Natura Impact Statement (NIS) has been prepared and accompanies this application. The NIS concludes that the proposed development is not likely to have any adverse effect on the integrity of any European site, i.e. Special Area of Conservation (SAC) or Special Protection Area (SPA). Designated sites in the area surrounding the proposed development site are shown in Figure 5-1.

5.1 Benthic Ecology

5.1.1 Approach and Methodology

Baseline ecological assessments and the consideration of potential impacts of the development of the proposed development were conducted through a literature review of the benthic habitats and species at the location of the proposed subsea cable, intertidal landfall location and its environs.

To fully understand the receiving environment, relative to project related effects, the literature consulted included:

EUSeaMap (2019). Predominant Habitat types (PHT). Infomar (2019). Seabed and sediment data for Clew Bay and environs National Parks and Wildlife Service (2019) data sources for the benthic habitats. EU Article 17 (2019) Marine monitoring reports.

A walkover survey of the intertidal area at Fallduff Strand (the cable landfall location) was undertaken in September 2020. During this survey, the sediment and reef habitats were characterised based on observations made and records of any obvious anthropogenic impacts were noted.

5.1.2 Receiving Environment

5.1.2.1 Zone of Influence

Following a review of the project scope of works, construction methods and post-construction operation the zone of influence of the proposed project is considered to be:

All benthic habitats and their associated species within the direct footprint of the construction site including a buffer zone 100m either side of the centre line of the cable route to account for the pre-grapnel run. The beach landing area at Fallduff Strand to include a buffer zone covering the intertidal zone extending from Old Head pier to 200m east of the landfall location.

5.1.2.2 Sublittoral Benthic Habitats

The predominant habitat types along the cable route are shallow sublittoral mixed sediment and shallow sublittoral sand with smaller areas of shallow sublittoral coarse sediment (DEHLG, 2020), (Figure 5-2). These habitat types are common to many of the exposed coasts of the west of Ireland. Infomar data collected during 2019 confirms this habitat assessment from Shipek grab samples taken from a number of locations within the outer sections of Clew Bay (Figure 5-3).

SEA002-0023-5747182-2 5-1 Map Legend

Fibre Optic Cable Route

Special Area of Converation

Special Protection Areas Ordnance Survey Ireland Ordnance Licence AR No. Survey 0021820© Ireland/Government of Ireland Drawing Title Microsoft product screen reprinted shots with permission from Microsoft Corporation Designated Sites Project Title TE Subcom Foreshore Licence Application Drawn By Checked By DN LM Project No. Drawing No. 200630 5-1 Scale Date 19.10.2020

MKO Planning and Environmental Consultants Tuam Road, Galway Ireland, H91 VW84 +353 (0) 91 735611 email:[email protected] Website: ww.mkoireland.ie 5-2 5-2

Foreshore Licence - ER F - 2020.11.2723

tive Irelands Marine Atlas V1 V1 Atlas Marine Irelands tive SEA002-0023-5747182-2

Figure 5-2 Predominant habitats alone the cable route corridor within the Irish segment. Source Marine Strategy Framework Direc Framework Strategy Source Marine segment. the Irish within route corridor the cable alone habitats Predominant 5-2 Figure 5-3 5-3

Foreshore Licence - ER F - 2020.11.2723 SEA002-0023-5747182-2

Figure 5-3 Grab sample locations. Infomar survey of Clew Bay 2019. ER D1 – 2020.10.20 – 200630

Sublittoral sand (EUNIS habitat code: A5.2)

This habitat occurs at the outer limits of the cable route and also between Achill Island and Clare Island and within the more westerly limits of Clew Bay. It is characterised by clean medium to fine sands or non- cohesive slightly muddy sands on open coasts, offshore or in estuaries and marine inlets. Such habitats are often subject to a degree of wave action or tidal currents which restrict the silt and clay content to less than 15%. This habitat is characterised by a range of taxa including polychaetes, bivalve molluscs and amphipod crustacea.

Sublittoral mixed sediment (EUNIS habitat code: A5.4)

This habitat occurs in the area around Achill Island, west of Clare Island and also within a section of the inner part of Clew bay including at the landfall location. It is characterised by sediments found from the extreme low water mark to deep offshore circalittoral habitats. These habitats incorporate a range of sediments including heterogeneous muddy gravelly sands and also mosaics of cobbles and pebbles embedded in or lying upon sand, gravel or mud. Depending on the particular mosaic, these habitats may support a wide range of infauna and epibiota including polychaetes, bivalves, echinoderms, anemones, hydroids and Bryozoa.

Sublittoral coarse sediment (EUNIS habitat code: A5.1)

This habitat is present across a relatively small area of the cable route to the south of Achill Head. It is characterised by coarse sediments including coarse sand, gravel, pebbles, shingle and cobbles which are often unstable due to tidal currents and/or wave action. These habitats are generally found on the open coast or in tide-swept channels of marine inlets. They typically have a low silt content and a lack of a significant seaweed component. They are characterised by a robust fauna including venerid bivalves.

Details of the sediment type recorded at each grab sample location are provided in Table 5-1.

Table 5-1 Infomar station data for Shipek grab samples collected in 2019 Depth Survey Sediment description Latitude Longitude Sample ID (m) date Muddy Sand: Sample is very well sorted in terms of size. Composition - some muds with 53.84 9.79 29 CV19011_CB_01 29/3/2019 mostly sand and finely fragmented shell. Muddy Sand: Retrieved large sample- mostly sand sized with some coarse shell fragment and very little mud. ~ 10 - 15% shell 53.83 9.82 30 CV19011_CB_02 29/3/2019 fragments. Sand mostly quartz and shell particles with some F.spars - sub sample bagged. Moderately sorted Gravel: Sample very coarse -shell hash and gravel. Lithoclasts sub rounded to rounded. Av 5cm - 0.2cm. Mineralogy Sst, mst, no 53.84 9.84 30 CV19011_CB_03 29/3/2019 small particles of sand or very little. Biogenics - worms, crabs etc. Poorly sorted. Muddy Sand: Sample was subsampled. Mostly sand, not 53.84 9.84 31 CV19011_CB_04 29/3/2019 much mud. Some fine shell fragments throughout sample -~10

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Depth Survey Sediment description Latitude Longitude Sample ID (m) date - 15%. Some atz, mica, fspar and dark minerals. Well Sorted. Sand: Fine grained sand, 10 -20% bioclasts. Some shell fragments. Mollusc. Mostly sand sized 53.85 9.82 25 CV19011_CB_05 29/3/2019 particles - very little to no mud. Qtz, fspars, shell fragments. Well sorted Gravel: Sample is coarse gravel ranging from 2.0 cm -4.0 cm. ~30%shell fragments. Lithic clasts are sub rounded to sub angular. 53.85 9.84 25 CV19011_CB_06 29/3/2019 Different host litholgies - mudsts, ssts, siltsts, and lmsts. Mod to poorly sorted Sand: Very well sorted sand sample, some dark laminations 53.86 9.85 19 CV19011_CB_07 29/3/2019 within sample. Sand: Very well sorted sand -little to no shell frags. Darker 53.86 9.82 23 CV19011_CB_08 29/3/2019 laminations within - anoxic layer. Qtz, Fspars, small lithics and HMs Sand: Very well sorted sand. No mud, small amount of bioclasts. 53.88 9.82 - CV19011_CB_09 29/3/2019 Qtz rich, Fspars, HMS and small shell frags (<5%) Sand: Well sorted medium sand, some anoxic layers. Sand particles 53.85 9.87 25 CV19011_CB_10 29/3/2019 are sub rounded to rounded Sand: Well sorted fine-grained sand. Mostly qtz, lithics some shell 53.86 9.92 11 CV19011_CB_11 29/3/2019 frags. Micas, HMS, no anoxic layers Sand: Very coarse to coarse sand, mostly comprised of shell hash. 53.86 9.92 20 CV19011_CB_12 29/3/2019 Some lithic grains mostly Qtz. Moderately sorted. Muddy Sand: Well sorted fine grained sample with laminations of anoxic sand. Samples has minor 53.85 9.96 43 CV19011_CB_13 29/3/2019 amount of mud.<5% bioclastic material, qtz, fspars Sand: Dark grey coarse shelly sand. Hit hard ground - small sample 53.84 9.95 46 CV19011_CB_14 29/3/2019 size, some lithic grains too. Moderately sorted. Muddy Sand: Well sorted, coarse- grained sample with lithic grains 53.84 9.91 36 CV19011_CB_15 29/3/2019 and shell hash. Little or no mud. Sand: Well sorted, fine-grained sand with fragment shell clasts. 53.84 9.89 35 CV19011_CB_16 29/3/2019 Some lithic grains likely, SSt, Siltstone, Limestone origin. Muddy Sand: Well sorted fine grained sand - muddy. Dark grey, 53.83 9.87 37 CV19011_CB_17 29/3/2019 HMS Amphiboles, etc

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Depth Survey Sediment description Latitude Longitude Sample ID (m) date Muddy Sand: Well sorted, very fine grained, muddy sand. Qtz, 53.83 9.90 34 CV19011_CB_18 29/3/2019 micas and some HMS. Muddy Sand: Well sorted, fine - medium grained muddy sand. Sample had laminations of anoxic 53.83 9.93 36 CV19011_CB_19 29/3/2019 mud/sand. Micaceous, Qtz rich and HMS Muddy Sand: Well sorted fine grained muddy sand. Very little 53.82 9.89 34 CV19011_CB_20 29/3/2019 shell fragments. Mostly siliciclastic grains, Qtz, Micas HMS Muddy Sand: Well sorted, fine grained, greenish brown muddy 53.81 9.87 33 CV19011_CB_21 29/3/2019 sand. Patches of dark grey anoxic layers. Qtz, micas, HMS Shells: Very coarse brown shelly sand. Very poorly sorted, no HMS, 53.82 9.82 35 CV19011_CB_22 29/3/2019 very little sand, not a place for a deposit Shells: Brown, moderately sorted, coarse shelly sand. Contains lithic grains from 2cm to 1mm. Sst, ss lst, 53.82 9.82 30 CV19011_CB_23 29/3/2019 gravel grade to sand grade siliciclastic. Mostly shell 20% sand. Muddy Sand: Well sorted, greenish brown, fine grained muddy sand. 53.81 9.78 31 CV19011_CB_24 29/3/2019 Qtz, micas, shell fragments and some HMS. Some anoxic layers. Muddy Sand: Nice sample, smooth. Well sorted greenish brown fine-grained muddy sand. 53.81 9.80 32 CV19011_CB_25 29/3/2019 siliciclastic, qtz, micas, HMS present Muddy Sand: Well sorted. Fine grained, muddy sand. More sand to mud in this sample compared to other areas. No bioclasts or shell 53.80 9.79 29 CV19011_CB_26 29/3/2019 fragments. Qtz ric, HMS, black anoxic layer. Probably amphiboles etc. Sand: Medium grained, well sorted brown sand, with dark grey anoxic patches. Comprised of small shell 53.79 9.81 21 CV19011_CB_27 29/3/2019 fragments, some quartz, feldspars. No apparent HMS Muddy Sand: Fine grained, well sorted brownish green sandy mud 53.79 9.75 25 CV19011_CB_29 29/3/2019 with grey patches. No bioclasts present. Sandy Mud: Well sorted, med to fine grained sand with some mud. 53.81 9.86 29 CV19011_CB_30 29/3/2019 No bioclasts, qtz, micas, amphiboles, fspars. Muddy Sand: Well sorted, med grained muddy sand. Qtz, amp, 53.8 9.87 28 CV19011_CB_31 29/3/2019 fspars.

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Depth Survey Sediment description Latitude Longitude Sample ID (m) date Shell Hash: Well sorted, coarse grained shell hash. All uniform in 53.79 9.89 18 CV19011_CB_32 29/3/2019 size (well sorted). Some lithic grains within. Shelly Sand: Well sorted, coarse grained shelly sand. Majority of the 53.79 9.90 17 CV19011_CB_33 29/3/2019 composition is comprised of fragmented shell.

5.1.2.3 Littoral Benthic Habitats

Littoral sand and muddy sand (EUNIS habitat code: A2.2)

A Littoral benthic habitat is present at Fallduff Strand, where an exposed north-northeast facing sandy beach is present. The beach is characterised by an exposed mobile sand shore (A2.22) with a shifting strandline (A2.21). A narrow boulder line is present in sections along the upper shore. A drain, which appears to carry wastewater and/or road run-off enters Fallduff strand approximately 14m west of the proposed landfall location

Moderate energy littoral rock (EUNIS habitat code: A1.2)

Small areas of littoral reef occur to the east and west of the pier at Old Head, and also further along Fallduff Strand. The littoral reef habitat is characterised by rock ridges/outcrops with basic rock pools present. The biota is dominated by fucoids and Ascophyllum nodosum indicating the moderate degree of shelter afforded by Old Head and the pier structure itself. The characterising macro algal species present are shown in Table 5-2. The Invasive Alien Species (IAS), Sargassum muticum (wireweed) was recorded in the reef habitat to the east of the pier. Sargassum muticum was also noted during a survey of the site in 2017 conducted as part of NPWS marine monitoring surveys. The littoral reef habitat is typical of the EUNIS habitat A1.2: Moderate energy littoral rock.

Plate 5-1 Fucoid dominated intertidal reef at Old Head Pier (September 2020)

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Table 5-2 Macro algal species recorded (30/9/2020)

Species recorded

Enteromorpha sp. Fucus spiralis Calcareous encrusters

Ulva lactuca Fucus vesiculosus Chondrus crispus

Ascophyllum nodosum Leathesia difformis Corallina officinalis

Chorda filum Pelvetia canaliculata Furcellaria lumbricalis

Dictyota dichotoma Saccorhiza polyschides Hypoglossum hypoglossoides

Laminaria digitata Ceramium sp. Mastocarpus stellatus

Membranoptera alata Nemalion helminthoides Osmundea hybrida

Osmundea pinnatifida Polysiphonia lanosa Sargassum muticum

5.1.3 Assessment of Likely Significant Effects

Sediment mobilisation and disturbance due to trenching in benthic habitats (subtidal and intertidal) during construction and/or decommissioning.

Sediment mobilisation during construction works in subtidal and intertidal benthic habitats has the potential to lead to adverse effects on a range of benthic habitats and species. The extent to which sediments will mobilise is dependent on the nature of the sediment (coarse sediments settle out rapidly following disturbance), the exposure of the site (sediments in exposed sites will frequently be subject to disturbance due to wave action), the tidal regime of the area (tide swept sediments are generally devoid of “fines”). The impact of sediment mobilisation on benthic habitats and their constituent species is dependent on the sensitivity of those species to burial and smothering resulting from sediment mobilisation and transport. The species found in exposed sediments are generally robust specialists capable of withstanding disturbance and smothering. The impacts of physical disturbance on highly exposed coarse sediments are generally low and greatest in areas of low natural disturbance where the species present are less well adapted to withstand physical stress. In such cases physical pressure as a result of traffic and personnel can lead to sediment compaction (Tyler-Walters & Arnold, 2008) or liquefaction/fluidisation (Hall & Harding, 1997).

The benthic sediment habitat in the area at, and adjacent to, the cable route and landfall site is comprised of a mosaic of sand, mixed sediment and coarse sediment in an exposed or moderately exposed environment. These sediments would be frequently mobilised due to wave action in such an exposed location. The coarse nature of these sediments will result in only very localised sediment mobilisation and transport which would quickly settle out again. The benthic species present in such sediments would be specialists favouring this habitat and exposure and not sensitive to localised short term disturbance where the effects of the disturbance would be unnoticeable within a short time period (weeks).

Sediment compaction can result from construction traffic and personnel working in intertidal areas. However, the highly mobile nature of the sand habitat at the landfall location would result in no significant adverse effects as compaction of this sediment type at this location would be minor and the habitat would return to its pre-construction state within a few tidal cycles.

Pollution risk related to accidental spillage of hydrocarbons from construction vessels, plant and equipment

Accidental spillage or leakage of hydrocarbons emanating from construction plant and equipment has the potential for adverse effects on benthic habitats including their associated macrofaunal and algal species. The effects of such spillage on marine ecosystems are dependent on the location, exposure and nature of the area in which the spill occurs in addition to the scale of the spill. Effects can range from catastrophic

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effects to almost negligible effects which is not always relative to the scale of any such spill. Hydrocarbon spills/leakage can result from poorly maintained vessels, plant and equipment in addition to vessel hull damage and wrecking. Other potential pollution events can result as a consequence of poor waste management, both on-board vessels and for construction on intertidal areas.

The main-lay vessel operates within the regulations of the International Convention for the Prevention of Pollution from Ships (MARPOL). In this respect Annex I and IV and V of the MARPOL convention, which contains the Regulations for the prevention of pollution by oil, the prevention of pollution by sewage from ships and the prevention of pollution by garbage from ships, are implemented by the vessel operators. Therefore, impacts as a result of oil pollution, sewage and waste from the main-lay vessel are not considered a risk to benthic habitats and species.

Risks benthic habitats and species are vulnerable to accidental hydrocarbon spillage resulting from plant and equipment operating in the intertidal area. However, such effects, should they occur, are likely to be localised to the immediate area of the intertidal and nearshore waters. For this reason, it is imperative that appropriate mitigation is prepared to address the potential for, and mitigate the effects of, any such pollution incidents in the intertidal area. These measures are set out in Section 5.1.4 below and will be in place during the works.

Introduction and or spread risk from Invasive Alien Species (IAS) emanating from construction vessels, plant and equipment

Invasive species have been identified as one of the four greatest threats to marine and coastal ecosystems. Vessel ballast water and hull fouling are known to be key vectors for the introduction of IAS. The emptying of ballast water is estimated to account for the uptake and trans-global transfer of tens of thousands of species of marine organisms at any given time (Bax et al, 2003). While many of these organisms will not survive in the ships ballast water or may not become invasive some may. Most marine plants and animals have a planktonic stage in their lifecycle, and can easily be taken up with ballast water. The sediments commonly contain dinoflagellate cysts that can remain in a state of dormancy until they are deposited in a suitable environment, where they divide and multiply to form harmful algal blooms.

Biofouling algae and invertebrates may attach themselves to any boat surface such as hulls, propellers, anchors and water pipes. Wharf pilings, breakwaters and adject hard substrate (e.g. geogenic and biogenic reef) may then provide suitable substrate for colonisation. While the fouling of hulls on larger vessels is generally well controlled, as such fouling causes drag thereby reducing speed, potentially invasive organisms can occupy niches on hulls which anti-fouling measures do not address. Similarly, biofouling organisms may colonise plant and equipment associated with marine construction sites if such equipment is not appropriately decontaminated after demobilisation.

The main-lay vessel is compliant with the International Convention for the Control and Management of Ship’s Ballast water and Sediments and holds the relevant certificate of compliance in this regard. This compliance covers the measures for the control and management of this vessel’s biofouling to minimise the transfer of invasive aquatic species. Furthermore, there will be no requirement for the vessel to empty ballast water. For this reason, the risk of the introduction of IAS resulting from the main-lay vessel are considered insignificant.

The IAS, Japanese wire weed is known to occur at Fallduff Strand. The potential for the spread of this species could occur if appropriate biosecurity measures are not taken to clean the plant and equipment being used at the site on completion of works. The appropriate measures will be in place, as set out below.

5.1.4 Mitigation of Likely Risks

Pollution derived from accidental spillage of hydrocarbons

There will be a requirement for vessels, plant and machinery to operate in the intertidal area at the landfall location. Risk associated with hydrocarbon spills and leakage has the potential to impact on benthic habitats and species within the intertidal area, leading to direct and indirect adverse effects on localised benthic habitats and species.

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To avoid the possibility for accidental spillage of any hydrocarbons associated with the use of plant, machinery or vessels the proper use and storage of oils and fuels the mitigation measures set out below will be implemented by the developer as a condition of any foreshore licence granted.

The cable main-lay vessel will maintain an up to-date programme for implementing the International Convention for the Prevention of Pollution from Ships (MARPOL) regulations for the duration of the project. A site compound (associated with the landfall location at Fallduff Strand) shall be established at a location at least 50 meters away from the beach area and any watercourses or drains. All fuel/ oil storage areas within the site compound shall be covered and bunded to 110% of storage capacity. All plant and machinery will be refuelled at the aforementioned site compound at the start of each working day. Drip-trays will be employed at the refuelling location within the compound, and a spill kit will be kept there for the duration of the project and be checked daily as to its suitability as fit-for-purpose. Vessels will be filled by a licensed operator prior to arriving on-site and no on-site refueling will take place. The Contractor and site-foreman will inspect the refuelling area at the compound at least daily during the operation of the compound to verify that drip-trays are being used consistently by site staff and are regularly emptied to a bowser. All plant and machinery and vessels will be regularly checked for leaks (fuel, oil and coolant). Drip trays will be used underneath mobile plant and drums whilst in use on site. All machinery and vessels to have an on-board spill kit. A hydrocarbon oil boom to be available at all times onsite in the event of it needing to be deployed. If required, generators to be on a hydrocarbon mat at all times during the construction works. Plant and machinery will not be left on intertidal areas overnight. The developer will prepare a waste management plan to deal with any waste (domestic and industrial) generated from working at the landfall location. This will include methods for the safe disposal of all such waste.

Introduction and spread of Invasive Alien Species

An IAS management plan will be prepared to avoid the potential for the introduction and spread of marine Alien Invasive species. This will include systems to ensure:

Boats, barges and marine equipment free of fouling by the use of appropriate application of antifouling paints and or washdowns for smaller boats and plant. Wash down all machines entering the intertidal and subtidal area at a designated location prior to mobilising. Remove any visible hitchhikers from any tracked plant and equipment entering the intertidal area.

5.2 Marine Mammals

5.2.1 Approach and Methodology

Baseline ecological assessments and the consideration of potential impacts of the development of the proposed project were conducted through a literature review of marine mammals recorded along the route of the proposed subsea cable and its environs. The literature consulted included:

Irish Whale and Dolphin Group (IWDG) Sightings database. NPWS Seal Database.

5.2.2 Receiving Environment

The IWDG database of sightings shows frequent records for Bottle-nosed Dolphin (Tursiops truncatus) within the area along and adjacent to the proposed cable route from south of Achill Head to inner Clew

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Bay. This database also shows records for Common dolphin (Delphinus delphis) and Harbour Porpoise (Phocoena phocoena) in this area. The NPWS cetacean distribution database indicates the area is within the range of the majority of marine mammals and within the known distribution of Bottle-nosed Dolphin, Common Dolphin, Harbour Porpoise, White-sided Dolphin (Lagenorhynchus acutus) and Minke whale (Balaenoptera acutorostrata).

Grey seal (Halichoerus grypus) and Harbour Seal (Phoca vitulina) are both recorded from the area along and surrounding the cable route from south of Achill Head to Clare Island and within inner Clew Bay (NPWS, 2020). While Grey seal occurs in greatest numbers on the western seaboard of Ireland significant numbers also occur on the east and southeast coasts. The Grey Seal generally breed between September and December on remote and generally undisturbed areas, in particular offshore islands. Harbour seals are found along the western seaboard predominantly in relatively sheltered areas (often estuaries and sand or mudflats) that are not subject to much human disturbance. Harbour seals come ashore during June to give birth. Harbour Seals also come ashore to moult during July and August often forming large groups on sheltered shores.

Harbour Seal population surveys are carried out during their annual moulting period which occurs between July and September (Thompson & Rothery, 1987). Grey Seals hauled ashore are also counted during these surveys, providing additional information on their summer distribution. In August 2017 and August 2018, the Sea Mammal Research Unit (SMRU) of the University of St Andrews, Scotland carried out a comprehensive aerial survey of Harbour Seals and Grey Seals on behalf of NPWS. These data comprised the entire coastline and offshore islands of Ireland.

The data from this survey indicates a widespread distribution of Harbour Seal in the area to the east of a line drawn between from Achill sound and Clare island where suitable haul out habitat occurs but with the largest density occurring within Clew Bay Complex SAC where 248 individuals were recorded in 2017/18. The survey data indicates that Grey seals, while also present within this area, have a more restricted distribution at a lower density.

5.2.3 Assessment of Likely Significant Effects

Disturbance, harm or injury to marine mammals as a result of underwater noise related to construction vessels and their associated operations (e.g. trenching).

Marine mammal sensory systems are adapted to life in the water or, in the case of seals, both in water and on land. Marine mammals rely on sound to navigate, to communicate with one another and to sense and interpret their surroundings. Behavioural responses of marine mammals to a sound are known to be strongly influenced by the context of the event and individual factors such as the animal’s experience, motivation, conditioning and activity (Nowacek et al, 2007, Southall et al, 2007 and Wartzok, et al 2004). Healthy new-born and younger animals may have the greatest hearing sensitivity while individual hearing ability declines progressively with age and prior exposure to harmful sound levels, disease, etc. Such features and variability may also require consideration in the case-specific assessment of impact on marine mammals from introduced sound sources (NPWS 2014). Sound waves dissipate through the water with distance from the source. While local oceanographic conditions affect the path of the sound and its transmission.

Vessels produce what is referred to as non-pulse (non-impulsive) sounds with acoustic characteristics represented by single or multiple discrete sound events within 24 hrs with a continuous sound event without a rapid pulse rise time. The cable installation includes trenching, rock placement, the pre-grapnel run and the use of thrusters for dynamically positioning. Similarly, these operations produce non-pulse continuous sound.

An assessment of the threshold for the onset of temporary threshold shifts (TTS) and permanent threshold shifts (PTS) derived from the scientific of literature is given in the guidelines for assessing the effects of anthropogenic sound on marine mammal hearing (NMTS, 2018). Table 5-3 below provides a summary of these data relative to non-pulse/continuous sound sources such as those that will emanate from the vessel and associated cable laying operations for the proposed project. While large ships may exceed 190 dB noise source levels when moving at high speeds, the proposed construction vessel will be

SEA002-0023-5747182-2 5-11 ER D1 – 2020.10.20 – 200630 operating at speeds in the region of 1-5 knots and noise levels will not exceed 70Hz which is below the documented level for TTS in Bottlenose dolphin and seals.

Table 5-3 Auditory bandwidth for species within the zone of influence

Species Bottlenose dolphin Grey seal and Harbour seal

Generalised hearing range 150hz – 160kHz 50Hz – 86kHz (NMFS 2018)

PTS (dB re 1 μPa2 s) 198 201

TTS (dB re 1 μPa2 s) 178 81

Disturbance due to construction vessels operating in the offshore and nearshore areas

Bottlenose dolphins are one of the most frequently recorded and familiar cetaceans occurring in Ireland. Bottle-nosed Dolphin occurs within the site in all seasons and the area comprises a key habitat for the species both regionally and within Irish waters as a whole. Local population estimates off south-west Co. Mayo and Connemara, Co. Galway describe a minimum of 123 dolphins, with possibly up to 150-200 individuals (NPWS, 2014). Bottlenose dolphin generally calve during the months of May to September, which is also considered the likely mating period in Irish water, and calves stay with their mothers for up to 5 years.

The main pressures thought to be acting on this species in Irish waters are considered to be geotechnical surveying and Marine fish and shellfish harvesting (professional, recreational) causing reduction of species/prey populations and disturbance of species (NPWS, 2019)

In both near offshore and nearshore waters bottlenose dolphin commonly approach vessels (ranging from large ships, to smaller fishing vessels and recreational craft). There are many reasons for this including curiosity, foraging opportunities and playfulness. Almost all bottlenose dolphins will follow boats off the coast of Ireland when the opportunity presents itself and the dolphins are not otherwise engaged in other activities e.g. foraging. In many cases e.g. the River Shannon Estuary, where high levels of shipping occur, dolphins have become habituated to shipping and coexist with shipping traffic in this area. Young dolphins are frequently seen alongside their mothers engaging in bow riding with vessels. A resident population of bottlenose dolphin has occupied the Lower River Shannon for several hundred years within the region of 140 individuals present at the site. The most recent and previous studies show a trend of increasing numbers using the Lower River Shannon over the last decade (NPWS, 2019). This is despite an increase in shipping associated with Foynes Port on the Lower River Shannon over the same period.

Disturbance to marine mammals utilising the area in and surrounding the proposed cable construction site is considered highly unlikely as the duration of cable laying operation is too short and temporary to lead to any significant effects to such species.

While seals are known to use the area in the vicinity of the proposed cable route the risk of disturbance to any Harbour or grey seal is considered to be insignificant. Noise generated from the vessel itself and its associated operations are below the levels known to cause TTS to seals.

Collision risk due to vessel operations

Collisions involving marine mammals are known to occur. However, the available research indicates that that collision risk is significantly higher with increased vessel speed, specifically at speeds of greater than 20 knots, but also, albeit far less frequently, at slower speeds in the range of 13-15 knots. Most fatal or serious injuries are to larger marine mammals (whales) and involve strikes from larger vessels (>100 tonne) which also generally move at high speed (> 20 knots) (Dolman et al, 2006). While the risk of collision with dolphins and seals is less well documented, it is considered that a risk exists in the absence of information to the contrary.

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Throughout the majority of the cable installation activities, while the vessel is underway, it will be travelling at speeds of 1-5 knots in open water. During ploughing activities, the vessel speed will be operating at speeds of between 0.5 and 1 knot and during cable-lay at 1 knot. At this speed the risk of collision with any marine mammal is highly unlikely. Furthermore, no risk associated with marine mammals coming into contact with the vessel propellers is possible as the vessel employs propeller guards. However, in line with the precautionary principle it is considered prudent to mitigate any risk of collision with Bottlenose Dolphins which may be present in the area.

To avoid the potential for disturbance to bottlenose dolphin the mitigation measures set out below will be implemented by the developer as a condition of any foreshore licence granted. Disturbance to bottlenose dolphin as a result of the proposed project is considered unlikely but uncertain. Therefore, with due consideration of the precautionary principle, the function of the MMO is to remove any uncertainty related to disturbance or collision risk as a result of the cable main-lay vessel operations.

5.2.4 Mitigation of Likely Risks

A qualified and experienced marine mammal observer (MMO) will be present during all works in Irish water and the Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters (NPWS, 2014) will be followed at all times.

The MMO will monitor for bottlenose dolphin and log all relevant events using standardised data forms (Appendix 6, DAHG, 2014). Cable-laying and trenching shall not commence if bottlenose dolphin are detected within a 500m radial distance of the vessel. The MMO will have the authority to halt vessel operations should bottlenose dolphin be detected within a 500m radial distance of the vessel. The MMO will be familiar with the Irish regulatory procedures and be provided with full details of all licence/consent conditions relevant to the performance of their role in advance of activity commencement, in order to ensure compliance. The MMO will be dedicated to and engaged solely in monitoring the operator’s implementation of the technical guidance set out below and in conducting survey effort for Bottlenose dolphin in accordance with the guidance. The use of a crew member or team member with other responsibilities is not considered to be a satisfactory substitute for a dedicated MMO. A sufficient number of MMO personnel will be assigned to ensure that the role is performed effectively. Avoidance of observer fatigue is essential. General conditions for effective visual monitoring by MMOs are: (1) during daylight hours and (2) in good visibility extending 1km or more beyond the limits of the assigned Monitored while (3) sea conditions for effective visual monitoring by MMOs are WMO Sea State 4 (≈Beaufort Force 4 conditions) or less. MMOs will be located on an appropriate elevated platform from which the entire monitored zone can be effectively covered without any obstruction of view. The MMO will have appropriate equipment for observation. They will use a distance measuring (i.e., range-finding) stick, reticle binoculars or other accurate range-finding mechanism to determine the distance to any bottlenose dolphin seen. Full reporting on MMO operations and mitigation undertaken will be provided to the Regulatory Authority as outlined in Appendix 6 of DAHG (2014).

5.3 Birds

5.3.1 Approach and Methodology

Bird surveys at Fallduff Strand were not deemed a requirement for the project, due to the nature and scale of the proposed development (i.e. beach works are not expected to last more than 1-2 days). Once installed there will be no loss of habitat for avian populations, as the cable will be trenched onFallduff Strand and laid upon the sea floor in the marine environment. The only potential for impacts to occur are therefore during the cable installation period through displacement or disturbance of bird populations from the active works areas.

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In the absence of dedicated ornithological survey data, IWeBS site summary data for Clew Bay has been consulted to provide information on local wintering bird populations in the area. IWeBS data for Clew Bay has been provided in Table 5-4 below. The mean is based only on the most recent 5-season period, i.e. for the period 2013/14 - 2017/18.

SEA002-0023-5747182-2 5-14 5-15 Mean 12 1 0 0 0 104 255 42 238 1 231 158 0 3 0 15 0 81 1 7 34 30

2017/18 9 1 77 259 41 317 2 218 106 62 46 10 44 25

ER– D1 2020.10.20 – 200630

2016/17 6 1 359 55 271 5 325 160 15 77 8 21 29

2015/16 12 11 294 43 184 242 201 1 105 6 3 28 34

2014/15 14 3 160 196 38 173 200 146 15 112 5 39 30

2013/14 18 270 169 31 246 169 179 63 9 36 30

2012/13 12 245 446 56 298 267 151 1 107 1 26 34

2011/12 9 160 267 54 178 179 164 2 103 4 44 23

2010/11 8 1 370 42 408 1 227 169 81 6 18 41

2009/10 26 423 40 241 304 136 8 64 8 38 32 SEA002-0023-5747182-2

2008/09 21 310 250 48 218 181 133 2 66 6 17 24

1% international population threshold 100 340 190 980 810 400 2500 14000 1200 5000 53000 600 650 7500 11400 860 3000 50 4700

1% national population threshold 90 150 100 35 160 350 100 560 20 360 280 20 20 110 40 25 20 20 20 Species Mute Swan Whooper Swan Greenland White-fronted Goose Greylag Goose Canada Goose Barnacle Goose Light-bellied Brent Goose Shelduck Wigeon Gadwall Teal Mallard Pintail Garganey Shoveler Common Scoter Goldeneye Red-breasted Merganser Goosander Red-throated Diver Great Northern Diver Little Grebe

Table 5-4 IWeBS site summary data for Clew Bay in County Mayo 5-16 Mean 0 72 47 21 43 0 0 534 203 125 1 68 3 76 3 218 0 2 51 131 1 371 0 44

2017/18 53 64 26 23 2 476 189 202 43 1 202 2 145 1 344 31

ER– D1 2020.10.20 – 200630

2016/17 80 26 19 46 772 150 340 49 172 428 2 152 106 3 407 2 52

2015/16 72 31 25 77 549 259 55 71 125 4 159 105 135 1 423 44

2014/15 70 75 17 34 444 107 29 7 95 84 11 200 2 181 1 317 42

2013/14 83 37 18 36 431 309 1 83 14 1 100 2 90 363 53

2012/13 182 17 12 51 566 342 43 82 17 450 360 3 41 120 9 585 1 44

2011/12 1 220 6 11 36 1 2 673 142 30 11 159 10 148 360 1 28 107 4 600 1 35

2010/11 1 249 18 9 57 1 2 552 375 144 6 186 4 79 16 358 4 52 512 1 39

2009/10 2 34 16 5 27 2 351 267 205 1 89 1 66 603 1 12 17 69 488 35 SEA002-0023-5747182-2

2008/09 1 119 6 4 39 2 3 448 403 351 76 6 414 27 202 1 1 52 86 1 585 47

1% international population threshold 6300 1200 1100 5000 15500 8200 540 9300 2000 72300 5300 2000 110 13300 1100 1500 7600 3300

1% national population threshold 30 110 20 25 190 610 120 920 30 850 160 85 20 460 200 170 350 20 Species Grebe Great Crested Cormorant Shag Little Egret Grey Heron Moorhen Coot Oystercatcher Ringed Plover Golden Plover Grey Plover Lapwing Knot Sanderling Sandpiper Purple Dunlin Jack Snipe Snipe Godwit Black-tailed Bar-tailed Godwit Whimbrel Curlew Redshank Spotted Greenshank 5-17 Mean 299 64 0 0 231 0 730 13 103 0 0 21 1 1

2017/18 244 58 80 677 8 71 16 1

ER– D1 2020.10.20 – 200630

2016/17 427 17 286 1029 9 78 1 34 1

2015/16 310 91 291 435 22 154 21

2014/15 257 77 1 272 785 20 80 17 1

2013/14 258 75 226 723 7 134 15 7 1

2012/13 296 162 184 370 12 259 42

2011/12 345 177 1 191 621 31 96 2 30 2 4

2010/11 477 122 255 1067 12 123 14 8 1

2009/10 314 99 2300 205 4 35 8 SEA002-0023-5747182-2

2008/09 413 145 736 1 930 35 88 3 26 1

1% international population threshold 2400 1400

1% national population threshold 240 95 Species Redshank Turnstone Mediterranean Gull Little Gull Gull Black-headed Ring-billed Gull Common Gull Gull Lesser Black-backed Herring Gull Iceland Gull Gull Glaucous Gull Great Black-backed Tern Sandwich Kingfisher ER D1 – 2020.10.20 – 200630

5.3.2 Results

As can be seen in Table 5-4 above, the most recent 5-year mean wintering population data shows a number of different wintering waterbird species at Clew Bay as described in further detail below.

Nationally Important Populations

The following species have been recorded at Clew Bay over the most recent 5-season period, i.e. for the period 2013/14 - 2017/18 in nationally important numbers (i.e. greater than 1% of the total national wintering population of that species recorded at Clew Bay):

Red-breasted Merganser Great Northern Diver Little Grebe Little Egret Grey Heron Ringed Plover Curlew Redshank

Other species such as Common Gull (730), Black-headed Gull (231), Dunlin (218), Oystercatcher (534), Teal (231), Light-bellied Brent Goose (255) and Barnacle Goose (104) are all deemed to have populations of Local or County Importance, based on the most recent IWeBS 5-year averages at Clew Bay.

5.3.3 Potential Impacts and Associated Mitigation Measures

5.3.3.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment. There would be no potential impacts to the local bird populations.

5.3.3.2 Cable Installation Phase

There will be an increase in noise levels in the vicinity of Old Head beach and in the marine environment during the cable installation, as a result of machinery which has the potential to cause disturbance or displacement of local bird populations which are dependent on habitat in proximity of the proposed development. These impacts will be temporary in duration. Cable installation and associated works at Old Head Beach are expected to be completed within 1-2 days. Best practice measures for noise control will be adhered to onsite (see Chapter 8 for further details) during the cable installation in order to mitigate the slight temporary negative impact associated with this phase of the development. Further information on noise mitigation measures can be found in Chapter 8: Air, Climate & Noise.

Impact and Significance of Effects

There will be a temporary imperceptible negative residual impact on local wintering bird populations due to an increase in noise levels during the cable installation.

Based on the assessment above there will be no significant direct or indirect effects.

5.3.3.3 Operational Phase

Once the cable installation works have been completed there will be no potential impacts of any nature to avian populations. The cable will be laid along the sea floor in the marine environment and trenched up

SEA002-0023-5747182-2 5-18 ER D1 – 2020.10.20 – 200630

to 2m deep along the beach. There will therefore be no associated habitat loss for birds and no potential for disturbance or displacement from the proposed development.

5.3.3.4 Cumulative Effects

There are no other projects within the marine environment that have the potential to cause cumulative or in combination effects with the proposed development.

Due to the small scale of the proposed development and the lack of significant residual impacts from the development that would affect the wider environment, there will be no significant cumulative impacts to birds resulting from this project, and other local existing developments, projects and plans.

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6. LAND, SOILS AND GEOLOGY

6.1 Introduction

This section of the Environmental Report (ER) identifies, describes and assesses the potential impacts and effects of the proposed development on land, soils and geology and has been completed in accordance with the guidance set out in Section 1.3.3 in Chapter 1: Introduction.

The full description of the proposed development is provided in Chapter 3 of this ER.

6.2 Methodology

6.2.1 Relevant Guidance

The land, soils and geology section of this ER is carried out in accordance with the EPA guidance referred to in Chapter 1, in addition to the following documents:

Institute of Geologists Ireland (2013): Guidelines for Preparation of Soils, Geology & Hydrogeology Chapters in Environmental Impact Statements; National Roads Authority (2008): Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes;

6.2.2 Desk Study

A desk study of the proposed site and the surrounding study area was completed. The desk study involved collecting the relevant geological data for the proposed development study area. This included consultation of the following:

Environmental Protection Agency database (www.epa.ie); Geological Survey of Ireland - National Draft Bedrock Aquifer map; Geological Survey of Ireland - Groundwater Database (www.gsi.ie); Bedrock Geology 1:100,000 Scale Map Series, Sheet 17 (Geology of Shannon Estuary), Geological Survey of Ireland (GSI, 1999); Geological Survey of Ireland – 1:25,000 Field Mapping Sheets; and, General Soil Map of Ireland 2nd edition (www.epa.ie);

6.2.3 Impact Assessment Methodology

Using information from the desk study, an estimation of the importance of the soil and geological environment within the study area is assessed using the criteria set out in Table 6-1 (NRA, 2008).

Table 6-1 Estimation of Importance of Soil and Geology Criteria (NRA, 2008).

Importance Criteria Typical Example Attribute has a high quality, Geological feature rare on a regional or significance or value on a regional national scale (NHA). or national scale. Large existing quarry or pit. Degree or extent of soil Proven economically extractable mineral Very High contamination is significant on a resource national or regional scale. Volume of peat and/or soft organic soil underlying route is significant on a national or regional scale.

SEA002-0023-5747182-2 6-1 ER D1 – 2020.10.20 – 200630

Importance Criteria Typical Example Attribute has a high quality, Contaminated soil on site with previous significance or value on a local heavy industrial usage. scale. Large recent landfill site for mixed Degree or extent of soil wastes Geological feature of high value High contamination is significant on a on a local scale (County Geological Site). local scale. Well drained and/or highly fertility soils. Volume of peat and/or soft organic Moderately sized existing quarry or pit soil underlying site is significant on Marginally economic extractable mineral a local scale. resource. Attribute has a medium quality, Contaminated soil on site with previous significance or value on a local light industrial usage. scale. Small recent landfill site for mixed Degree or extent of soil Wastes. Medium contamination is moderate on a Moderately drained and/or moderate local scale. fertility soils. Small existing quarry or pit. Volume of peat and/or soft organic Sub-economic extractable mineral soil underlying site is moderate on Resource. a local scale. Attribute has a low quality, Large historical and/or recent site for significance or value on a local construction and demolition wastes. scale. Small historical and/or recent landfill site Degree or extent of soil for construction and demolition wastes. Low contamination is minor on a local Poorly drained and/or low fertility soils. scale. Uneconomically extractable mineral Volume of peat and/or soft organic Resource. soil underlying site is small on a local scale.

Impacts are described in terms of magnitude, duration, consequences and significance, where relevant. In addition, the two impact characteristics proximity and probability are described for each impact where relevant and these are defined in Table 6-2.

In order to provide an understanding of this descriptive system in terms of the geological/hydrological environment, elements of this system of description of effects are related to examples of potential likely significant effects on the geology and morphology of the existing environment, as listed in Table 6-3

Table 6-2 Additional Impact Characteristics.

Impact Degree/ Description Characteristic Nature Proximity Direct An impact which occurs within the area of the proposed project, as a direct result of the proposed project. Indirect An impact which is caused by the interaction of effects, or by off-site developments. Probability Low A low likelihood of occurrence of the impact. Medium A medium likelihood of occurrence of the impact. High A high likelihood of occurrence of the impact.

SEA002-0023-5747182-2 6-2 ER D1 – 2020.10.20 – 200630

Table 6-3 Impact descriptors related to the receiving environment.

Impact Characteristics Potential Hydrological Impacts

Quality Significance

Negative only Profound Widespread permanent impact on: The extent or morphology of a cSAC. Regionally important aquifers. Extents of floodplains. Mitigation measures are unlikely to remove such impacts. Positive or Significant Local or widespread time-dependent impacts on: Negative The extent or morphology of a cSAC / ecologically important area. A regionally important hydrogeological feature (or widespread effects to minor hydrogeological features). Extent of floodplains. Widespread permanent impacts on the extent or morphology of an NHA/ecologically important area. Mitigation measures (to design) will reduce but not completely remove the impact – residual impacts will occur. Positive or Moderate Local time-dependent impacts on: Negative The extent or morphology of a cSAC / NHA / ecologically important area. A minor hydrogeological feature. Extent of floodplains. Mitigation measures can mitigate the impact OR residual impacts occur, but these are consistent with existing or emerging trends Positive, Negative Slight Local perceptible time-dependent impacts not requiring or Neutral mitigation. Neutral Imperceptible No impacts, or impacts which are beneath levels of perception, within normal bounds of variation, or within the bounds of measurement or forecasting error.

6.3 Existing Environment

6.3.1 Site Description

The elevation (i.e. ocean depth) of the proposed cable route ranges from 0-50m below sea level in Clew Bay, from the c. 32km length of cable route from the landfall area. As the cable route continues northwest from the landfall site, away from Clew Bay, the ocean depth then ranges from 50-200m below sea level for the next c. 52km. The cable route continues northwest along the sea floor for the remaining c. 206km of the Irish Branch of the cable route ranging from 200-500m below sea level.

The marine survey report is provided in Appendix 6-1 to this Environmental Report, which includes further detail on elevation data and topographical information for the marine floor.

There is a very gradual slope from the terrestrial environment towards the cable landfall location at Fallduff Strand, Old Head. A view of Fallduff Strand is shown in Plate 6-1.

SEA002-0023-5747182-2 6-3 ER D1 – 2020.10.20 – 200630

Plate 6-1 Fallduff Strand, looking out to Clew Bay

6.3.2 Soils and Subsoils

Fallduff Strand, Old Head is classified as Beach/Raised Beach Sand (Mbs). The soils at Fallduff Strand are classified as well drained. The lands to the south of Fallduff Strand, around the existing landing station, are mapped as clay derived from mainly acidic parent materials (AminPD) overlain on sandstone and shale till (lower palaeozoic) (TLPSsS). The soils in this area are classified as poorly drained. A local subsoil geology map is shown as Figure 6-1.

The marine survey report, provided in Appendix 6-1, states that the marine substrate along the proposed cable route comprises of very soft to firm clays, rocky scarps, glacial till and rocky outcrops. Further details on benthic substrates are provided in Chapter 5 of this report.

6.3.3 Bedrock Geology

The underlying bedrock strata at Fallduff Strand, Old Head is Silurian. This bedrock type comprises mostly sandstones, but some siltstone and mudstone are also incorporated. The main underlying bedrock strata at Clew Bay is classified as Mississippian. This bedrock type comprises mostly limestone with some calcareous carbonate sedimentary rock. The underlying bedrock strata for the remainder of the Cable Route in the marine environment, includes Devonian (metamorphic rock), Neogene (sand), Paleozoic (metamorphic rock) and Miocene (sandstone).

The underlying bedrock at the existing landing station to the south of Fallduff Strand, Old Head is classified as Glen Pebbly Arkose Formation. This is described as conglomerate & pebbly sandstone.

A local bedrock geology map is shown as Figure 6-2.

A probing survey was carried out along the proposed cable corridor at the beach during the route design stage, to investigate the depth of sand deposits. The survey found that there was between 1.5 and 2m of

SEA002-0023-5747182-2 6-4 ER D1 – 2020.10.20 – 200630

sand overlying the bedrock. In the event that shallow bedrock is encountered during the cable installation works, the cable will simply be laid on top.

6.3.4 Geological Resource Importance

The bedrock at the site is classified by the GSI as “Low” importance.

6.3.5 Geological Heritage and Designated Sites

The proposed development site is not located within or adjacent to any designated site (i.e. Special Area of Conservation, NHA etc). The nearest designated site to the proposed development is Oldhead Wood Special Area of Conservation (SAC), located approximately 0.26 km west of the proposed cable route. A local designated sites map is shown in Figure 5-1 of Chapter 5 of this report.

No geological heritage sites are mapped within 1km of the proposed development site.

SEA002-0023-5747182-2 6-5 Map Legend

Fibre Optic Cable Route

Existing Landing Station and Infrastructure

Subsoils

Beach/Raised Beach Sand

Clay derived from mainly acidic parent material on sandstone and shale till Ordnance Survey Ireland Ordnance Licence AR No. Survey 0021820© Ireland/Government of Ireland Drawing Title Microsoft product screen reprinted shots with permission from Microsoft Corporation Subsoil Geology

Project Title TE Subcom Foreshore Licence Application Drawn By Checked By DN LM Project No. Drawing No. 200630 6-1 Scale Date 28.10.2020

MKO Planning and Environmental Consultants Tuam Road, Galway Ireland, H91 VW84 +353 (0) 91 735611 email:[email protected] Website: ww.mkoireland.ie Map Legend

Fibre Optic Cable Route

Existing Landing Station and Infrastructure

Subsoils

Beach/Raised Beach Sand

Clay derived from mainly acidic parent material on sandstone and shale till Ordnance Survey Ireland Ordnance Licence AR No. Survey 0021820© Ireland/Government of Ireland Drawing Title Microsoft product screen reprinted shots with permission from Microsoft Corporation Bedrock Geology

Project Title TE Subcom Foreshore Licence Application Drawn By Checked By DN LM Project No. Drawing No. 200630 6-2 Scale Date 28.10.2020

MKO Planning and Environmental Consultants Tuam Road, Galway Ireland, H91 VW84 +353 (0) 91 735611 email:[email protected] Website: ww.mkoireland.ie ER D1 – 2020.10.20 – 200630

6.4 Potential Impacts

6.4.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment and no potential for impacts on the land, soils and geological environment.

6.4.2 Cable Installation Phase

6.4.2.1 Excavation

As previously discussed, the beach works will comprise of excavation works of up to 2m depth and 2m width. The excavated trench will be backfilled again with the excavated material once the cable is installed. No bedrock will be removed. There will be no requirement to break rock or reduce the bedrock level to facilitate cable installation; the cable will be laid on top of bedrock, if encountered. It should be noted that across the beach, the cable will have the additional protection of articulated pipe.

The excavation activities will be temporary, and no material will be permanently removed from the area. There is no potential for subsidence. As per industry best practice, the beach will be reinstated in a manner such that the base of the trench is reinstated with the material excavated from the base of the trench and the material excavated the middle area of the trench is reinstated with the material excavated from the middle of the trench, etc. When the trench is fully reinstated, it is compacted to ensure that there are no soft spots.

Impact and Significance of Effects

There will therefore be no impact or significant effects to soils or bedrock as a result of excavation works.

6.4.2.2 Contamination of Soils and Bedrock by Accidental Spills and Leaks

Excavation during beach trenching and cable laying will be completed using machinery, while the main lay operation will be undertaken by a cable ship. Such machinery is powered by diesel engines and operated using hydraulics. In the absence of careful management and best practice, such plant and machinery have the potential to leak hydraulic oils or cause fuel leaks during refuelling operations. The proposed development will have carefully designed management plans to ensure that there will be no spill or leaks of hydrocarbons, while all marine vessels will comply fully with The International Convention for the Prevention of Pollution from Ships (MARPOL). The following measures are standard practice to be applied, ensuring there will be no spills or leaks of pollutants:

All plant and machinery will be serviced before being mobilised to site; No refuelling will be carried out onsite; Drip-trays will be used for fixed or mobile plant such as pumps and generators in order to retain oil leaks and spills; Procedures and contingency plans will be set up to deal with emergency accidents or spills; and, An emergency spill kit with oil boom, absorbers etc. will be kept on-site for use in the event of an accidental spill.

Impact and Significance of Effects

There will therefore be no impact or significant effects to soils or bedrock as a result of spills or leaks.

SEA002-0023-5747182-2 6-8 ER D1 – 2020.10.20 – 200630

6.4.3 Human Health

Potential health effects in relation to soils and geology mainly occur due to direct and indirect (dust) contact with contaminated soil. However, as stated in Section 6.4.2.2 there will be best practice controls in place to ensure any potential sources of contamination on the site will be managed appropriately. Also, the active works areas will not be open to the public while works are ongoing and therefore direct contact is unlikely.

Hydrocarbons, in the form of fuels and oils, will be used on-site during cable installation. However, the volumes will be small in the context of the scale of the project and will be handled in accordance with best practice measures as outline in Section 6.4.2.2 above.

Impact and Significance of Effects

There will therefore be no impact or significant effects on human health associated with spills or leaks to soils or bedrock.

6.4.4 Operational Phase

Once the cable installation works have been completed there will be no impacts to Land, Soil or Geology in the receiving environment due to the development. In the event of maintenance works being required, the cable can be accessed via the existing beach manhole and landing station. The potential intermittent maintenance work will not require excavation or disturbance to land, soils or geology and therefore there will be no impacts on same.

Impact and Significance of Effects

There will be no impacts or significant effects on soils and geology during the operational stage of the proposed development.

6.4.5 Decommissioning Phase

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning the associated excavation works and cable removal are likely to be of similar scale and duration to the cable installation works.

Impact and Significance of Effects

There will be no impact or significant effects on land, soils or geology associated with the decommissioning phase.

6.4.6 Cumulative Effects

There are no other projects within the marine environment that have the potential to cause cumulative or in combination effects with the proposed development.

Due to the small scale of the proposed development and the lack of significant residual impacts from the development that would affect the wider environment, there will be no cumulative impacts to soil and geology resulting from this project in combination with other local developments.

SEA002-0023-5747182-2 6-9 ER D1 – 2020.10.20 – 200630

7. WATER

7.1 Introduction

This section of the Environmental Report (ER) identifies, describes and assesses the potential impacts and effects of the proposed development on water aspects (hydrology and hydrogeology) of the receiving environment, and has been completed in accordance with the guidance set out in Section 1.3.3 in Chapter 1: Introduction. The full description of the proposed development is provided in Chapter 3 of this ER.

The objectives of this assessment are:

Produce a baseline desk study of the existing water environment (surface water and groundwater) in the area of the proposed development; Identify any likely significant effects of the proposed development on surface water and groundwater during the construction phase, operational phase and decommissioning phase; Identify mitigation measures to avoid, remediate or reduce likely significant negative effects and, Assess whether there are any likely significant residual effects and cumulative effects of the proposed development and other local developments.

7.2 Methodology

7.2.1 Relevant Guidance

The Water Chapter of the ER is carried out in accordance with the EPA guidance referred to in Chapter 1, in addition to the following documents:

National Roads Authority (2008): Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes; CIRIA 2006: Control of Water Pollution from Construction Sites - Guidance for Consultants and Contractors. CIRIA C532. London, 2006;

7.2.2 Desk Study

A desk study of the proposed cable landfall site and the surrounding study area was completed. The desk study involved collecting all relevant geological, hydrological, hydrogeological and meteorological data for the study area. This included consultation of the following:

Environmental Protection Agency database (www.epa.ie); Geological Survey of Ireland - National Draft Bedrock Aquifer map; Geological Survey of Ireland - Groundwater Database (www.gsi.ie); Met Eireann Meteorological Databases (www.met.ie); National Parks & Wildlife Services Public Map Viewer (www.npws.ie); Water Framework Directive “WaterMaps” Map Viewer (www.wfdireland.ie); Bedrock Geology 1:100,000 Scale Map Series, Sheet 17 (Geology of Shannon Estuary); Geological Survey of Ireland (GSI, 1999); Geological Survey of Ireland - Groundwater Body Characterisation Reports; OPW Indicative Flood Maps (www.floodmaps.ie); Environmental Protection Agency – “Hydrotool” Map Viewer (www.epa.ie); CFRAM Preliminary Flood Risk Assessment (PFRA) maps (www.cfram.ie); and, Department of Environment, Community and Local Government on-line mapping viewer (www.myplan.ie).

SEA002-0023-5747182-2 7-1 ER D1 – 2020.10.20 – 200630

7.2.3 Impact Assessment Methodology

Impacts are described in terms of magnitude, duration, consequences and significance, where relevant. In addition, levels of sensitivity which are defined in Table 7-1, are then used to assess the potential effects that the proposed development may have on the local baseline water environment (i.e. water receptors).

Table 7-1 Receptor Sensitivity Criteria (Adapted from www.sepa.org.uk)

Sensitivity of Receptor Receptor is of low environmental importance (e.g. surface water quality classified by EPA as A3 waters or seriously polluted), fish sporadically present or restricted). Heavily engineered or artificially modified and may dry up during summer Not sensitive months. Environmental equilibrium is stable and is resilient to changes which are considerably greater than natural fluctuations, without detriment to its present character. No abstractions for public or private water supplies. GSI groundwater vulnerability “Low” – “Medium” classification and “Poor” aquifer importance. Receptor is of medium environmental importance or of regional value. Surface water quality classified by EPA as A2. Salmonid species may be present and may be locally important for fisheries. Abstractions for private water supplies. Sensitive Environmental equilibrium copes well with all-natural fluctuations but cannot absorb some changes greater than this without altering part of its present character. GSI groundwater vulnerability “High” classification and “Locally” important aquifer. Receptor is of high environmental importance or of national or international value i.e. NHA or SAC. Surface water quality classified by EPA as A1 and Very sensitive salmonid spawning grounds present. Abstractions for public drinking water supply. GSI groundwater vulnerability “Extreme” classification and “Regionally” important aquifer

7.3 Existing Environment

7.3.1 Local Hydrology and Site Drainage

Fallduff Strand including the existing landing station and associated infrastructure, is located in the Owenwee Sub-Catchment. The area in which the existing infrastructure and Fallduff Strand are located both drain in a northerly direction into Clew Bay. A view of Fallduff Strand looking out to Clew Bay is shown in Plate 7-1 below. There are no surface water features within proximity of the proposed cable route or the existing landing station or associated infrastructure. A local hydrology map is shown as Figure 7-1.

SEA002-0023-5747182-2 7-2 Map Legend

Fibre Optic Cable Route

Existing Landing Station and Infrastructure

WFD Subcatchment

WFD Streams and Rivers Ordnance Survey Ireland Ordnance Licence AR No. Survey 0021820© Ireland/Government of Ireland Drawing Title Microsoft product screen reprinted shots with permission from Microsoft Corporation Local Hydrology Project Title TE Subcom Foreshore Licence Application Drawn By Checked By DN LM Project No. Drawing No. 200630 7-1 Scale Date 28.10.2020

MKO Planning and Environmental Consultants Tuam Road, Galway Ireland, H91 VW84 +353 (0) 91 735611 email:[email protected] Website: ww.mkoireland.ie ER D1 – 2020.10.20 – 200630

Plate 7-1 View of Fallduff Strand cable landing location

7.3.2 Flood Risk Identification

OPW’s indicative river and coastal flood map (www.floodmaps.ie), Preliminary Flood Risk Assessment (PFRA) maps (www.cfram.ie), Department of Environment, Community and Local Government on-line planning mapping (www.myplan.ie) and historical mapping (i.e. 6” & 25” base maps) were consulted to identify those local areas as being at risk of flooding.

The PFRA mapping shows the extents of the indicative 100-year flood zone which relates to fluvial (i.e. river) and pluvial (i.e. rainfall) flood events. There are no mapped pluvial or fluvial flood zones at Fallduff Strand, Old Head or the existing Landing Station to the south.

There is no flood mapping data shown for the development area on the Department of Environment, Community and Local Government on-line mapping viewer - www.myplan.ie.

OPW’s Flood Hazard map was consulted to identify those areas as being at risk of flooding. There were no reports of flooding in any stream immediately downstream of site.

There is no text on local available historical 6” or 25” mapping for the proposed site that identify areas that are “prone to flooding”. The nearest flood risk area mapped on any of the flood mapping web portals is within the village of Louisburgh approximately 3km southwest of Fallduff Strand, Old Head.

7.3.3 Marine Water Quality

The waters at Clew Bay are important amenity and recreational resources. The beach and the adjacent waters are regularly used for swimming, water sports and recreation and also form part of the Old Head Blueway. The Blueway is a network of water trails at which water-based activities, including kayaking and snorkelling, can be carried out in a safe controlled environment.

SEA002-0023-5747182-2 7-4 ER D1 – 2020.10.20 – 200630

As outlined in the latest Bathing Water Quality report by the EPA (‘Bathing Water Quality in Ireland’, 2019), Fallduff Strand, Old Head has retained a standard of ‘Good’ water quality for the previous four years between 2016 and 2019. This status is just one level below the requirement for a Blue Flag (i.e. Excellent).

In accordance with the Bathing Water Quality Regulations, SubCom will liaise with the Environment section of Mayo County Council to ensure that all necessary approvals from the Council and the EPA, including if necessary for the suspension of the monitoring calendar, are obtained prior to installation.

7.3.4 Hydrogeology

The underlying bedrock at Old Head is classified by the GSI (www.gsi.ie) as a Poor Aquifer, having bedrock which is generally unproductive except for local zones (PI).

The underlying bedrock strata at Fallduff Strand, Old Head is Silurian. This bedrock type comprises mostly sandstones, but some siltstone and mudstone are also incorporated. The soils and bedrock at Fallduff Strand are highly permeable, while the subsoil at the existing landing station are moderately permeable, overlain with poorly drained gley soils.

7.3.5 Groundwater Vulnerability

The vulnerability of the aquifer underlying Fallduff Strand, Old Head is classified as “High - H” by the GSI (www.gsi.ie). This is likely due to the very high permeability of the soils and subsoils at the beach. The vulnerability of the aquifer underlying the existing landing station is classified as “Moderate – M” by the GSI (www.gsi.ie).

7.3.6 Water Framework Directive Status and Risk Result

Local Groundwater Body (GWB) and Surface water Body (SWB) status and risk result information is available for view from (www.catchments.ie).

The WFD Status and Risk Result for the Owenwee Sub-Catchment, in which Old Head is located, is reported to be Good and Not at Risk respectively.

7.3.7 Designated Sites

The proposed development site is not located within or adjacent to any designated site (i.e. Special Area of Conservation, NHA etc). The nearest designated site to the proposed development is Old Head Wood Special Area of Conservation (SAC), located approximately 277 metres west of the proposed cable route. A local designated site map is shown in Chapter 5 of this report as Figure 5-1.

7.3.8 Local Water Supplies

A search of the Geological Survey of Ireland (GSI) well database (www.gsi.ie) indicated that there are no wells within proximity of Fallduff Strand. The nearest well is located approximately 3.4km southeast of the development in Kilsallagh Upper and is located in a different water catchment to the proposed works.

7.3.9 Receptor Sensitivity

Due to the small-scale nature of the proposed development, which will involve installation of fibre optic cable in the marine environment, no impacts on local groundwater levels are expected. Surface water in the marine environment will be the main sensitive receptor in respect of sediments generated during beach trenching/excavation and from oil/fuel potential leaks and spills. Further details are provided in Chapter 5 of this report on Biodiversity.

The primary risk to groundwater at Fallduff Strand, Old Head would be from hydrocarbon spillage. This is a common potential impact on all construction sites. These potential contamination sources will

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present on site for a temporary period only, due to the timeline of the works, and will be carefully managed at the site, as described in Section 7.4 below on Potential Impacts.

Based on criteria set out in Table 7-1, groundwater at the site can be classed as not sensitive to pollution because the underlying bedrock is classified as a Poor Aquifer (PI). However, as outlined above bathing water at Fallduff Strand is an important amenity and has retained a standard of ‘Good’ water quality for the previous four years between 2016 and 2019 (EPA 2019). Therefore, it is important that the marine water quality at Fallduff Strand will not be impacted due to the proposed development.

Mitigation measures will ensure that any surface runoff from the Beach works area will be of a high quality and will therefore not impact on the water quality at Clew Bay or marine flora and fauna. Further details are provided in Section 7.4 below.

7.4 Potential Impacts

7.4.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment and no potential for any impacts on the receiving environment.

7.4.2 Cable Installation Phase

7.4.2.1 Excavation

The excavated trench will be backfilled with the excavated material once the cable is installed. The excavation activities will be temporary, although it will have the potential to generate sediments which could be transported off-site by surface water runoff. However, due to the relatively small-scale of the proposed development and temporary nature of the installation works, significant effects will not occur.

Impact and Significance of Effects

There will be no impact or significant effects on the water environment due to the excavation works.

7.4.2.2 Contamination of Groundwater and Marine by Accidental Spills and Leaks

Excavation during beach trenching and cable laying will be completed using machinery, while the main lay operation will be undertaken by a cable ship. Such machinery are powered by diesel engines and operated using hydraulics. Unless managed carefully such plant and machinery have the potential to leak hydraulic oils or cause fuel leaks during refuelling operations. The proposed development will have carefully designed management plans to ensure that there will be no spill or leaks of hydrocarbons, while all marine vessels will comply fully with The International Convention for the Prevention of Pollution from Ships (MARPOL). The following measures will be applied, ensuring there will be no spills or leaks of pollutants:

All plant and machinery will be serviced before being mobilised to site; No refuelling will be carried out onsite; Drip-trays will be used for fixed or mobile plant such as pumps and generators in order to retain oil leaks and spills; Procedures and contingency plans will be set up to deal with emergency accidents or spills; and, An emergency spill kit with oil boom, absorbers etc. will be kept on-site for use in the event of an accidental spill.

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Impact and Significance of Effects

There will be no impacts or significant effects on the water environment associated with spills or leaks.

7.4.2.3 Hydrological Impacts on Designated Sites

An NIS has been prepared for the proposed development which considers the potential effects of the proposed development on the features of interest and conservation objectives of European sites within the zone of influence of the proposed project.

The NIS concludes that, provided the measures described in the Environmental Report and the NIS are fully implemented so as to ensure no potential effects arise as a result of pollution or the introduction of Invasive Alien Species (IAS), no significant adverse effects are expected on the features of interest or Conservation objectives of any European site i.e. the integrity of the sites will not be adversely affected.

Impact and Significance of Effects

There will be no impacts or significant effects on designated sites due to the installation of the proposed development.

7.4.3 Human Health Effects

Potential health effects in relation to water would arise mainly through the potential for hydrocarbon release into the marine environment. Fallduff Strand, Old Head is an important amenity for residents and tourists with swimming and water sports a regular feature in this area. However, as stated above there will be best practice controls in place to ensure any potential sources of contamination on the site will be managed appropriately and the volumes present will be small in the context of the scale of the works.

Impact and Significance of Effects

The potential impacts associated with groundwater and marine contamination and subsequent health effects are therefore negligible.

7.4.4 Operational Phase

Once the cable installation works have been completed there will be no impacts to Water in the receiving environment due to the development. In the event of maintenance works being required, the cable can be accessed via the existing beach manhole and landing station. The potential intermittent maintenance work will not require excavation or disturbance to land, soils or geology with a potential to impact water in the receiving environment.

Impact and Significance of Effects

Therefore, there will be no impacts on water in the receiving environment due to the operation of the proposed development.

7.4.5 Decommissioning Phase

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning the associated excavation works and cable removal are likely to be of similar scale and duration to the cable installation works.

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Impact and Significance of Effects

There will be no impact or significant effects on the water environment associated with the decommissioning phase.

7.4.6 Cumulative Hydrological Effects

There are no other projects within the marine environment that have the potential to cause cumulative or in combination effects with the proposed development. There are a number of active licensed sites for aquaculture (Oysters) within Clew Bay and in the waters off Clare island (Fin fish). The proposed cable route does not cross any of these aquaculture sites. Given the nature and scale of the proposed cable works, there is no potential for any impacts arising from the proposed project that could combine with these activities to cause a cumulative impact.

Due to the small scale of the proposed development and the lack of significant impacts from the development that would affect the wider environment, there will be no significant cumulative impacts to water resulting from this project, and other local developments.

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8. AIR, CLIMATE AND NOISE

8.1 Introduction

This section of the Environmental Report (ER) identifies, describes and assesses the potential impacts and effects of the proposed development on air, climate and noise in the receiving environment.

The full description of the proposed development is provided in Chapter 3 of this ER.

8.2 Air Quality – Existing Environment

Due to the nature of the proposed development, i.e. it is not a project type that gives rise to air pollution sources or falls within the remit of Integrated Pollution Control (IPC) Licensing by the EPA, air quality sampling was deemed to be unnecessary for this assessment. In addition, the proposed cable landing site is located in Zone D of the EPA Air Quality Zones (see Section 8.2.1 below for further detail), which comprises rural areas located away from large population centres, and is not located near any existing sources of significant air pollution.

8.2.1 Air Quality Zones

Air quality legislation in Ireland is derived from the Clean Air for Europe (CAFE) Directive (2008/50/EC on ambient air quality) (as amended by Directive EU 2015/1480). The CAFE Directive is transposed by the Air Quality Standards Regulations 2011 (S.I. No. 180 of 2011) as amended by the Air Quality Standards (Amendments) and Arsenic, Cadmium, Mercury, Nickel and Polycyclic Aromatic Hydrocarbons in Ambient Air Regulations, 2016 (S.I. 659 2016).

The Environmental Protection Agency (EPA) has designated four Air Quality Zones for Ireland, as required by air quality legislation:

Zone A: Dublin City and environs Zone B: Cork City and environs Zone C: 16 urban areas with population greater than 15,000 Zone D: Remainder of the country.

These zones were defined to meet the criteria for air quality monitoring, assessment and management described in the Framework Directive and Daughter Directives. The site of the proposed cable and existing Landing Station lie within Zone D, which represents rural areas located away from large population centres.

8.2.2 Existing Air Quality

The EPA publishes Air Monitoring Station Reports for monitoring locations in all four Air Quality Zones. The ambient air quality monitoring carried out closest to the proposed development site is at the EPA offices on the outskirts of Castlebar town, approximately 32 km east of Fallduff Strand, Old Head. EPA air quality data is available for Castlebar in the report ‘Air Quality in Ireland 2015’, as detailed below in Tables 8-1 to 8-5.

Data for Sulphur Dioxide (SO2 and Carbon Monoxide (CO) are not available for Castlebar monitoring station. This data has been therefore sourced from the nearest monitoring station with available data, which is Galway City, approximately 73 km southeast of Fallduff Strand, Old Head. EPA air quality data is available for Galway City in the report ‘Ambient Air Monitoring in Galway City March 13th 2001 – 23rd October 2001’.

The monitoring stations referred to above are both located in Air Quality Zone C, which encompasses cities and large towns. It is a reasonable assumption therefore that lower measurement values would be obtained at the proposed development site at Old Head and within the marine environment.

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8.2.2.1 Sulphur Dioxide (SO2)

Sulphur Dioxide data for the period March 2001 – October 2001 recorded at Galway City monitoring station is presented in Table 8-1. Neither the hourly limit value (350 µg/m3) nor lower assessment threshold (50 µg/m3Daily Limit) set out in the CAFE Directive were exceeded during the monitoring period.

Table 8-1 Sulphur Dioxide Data for Galway City in 2001

Parameter Measurement

No. of hours 5,356

No. of measured values 3,672

Percentage Coverage 68.6%

Maximum hourly value 87.8 µg/m3

98 percentile for hourly values 42.3 µg/m3

Mean hourly value 10.0 µg/m3

Maximum 24-hour mean 31.1 µg/m3

98 percentile for 24-hour mean 27.7 µg/m3

8.2.2.2 Particulate Matter (PM10)

The notation PM10 is used to describe particulate matter or particles of ten micrometres or less in aerodynamic diameter. PM10 data for the 2015 monitoring period at Castlebar is presented in Table 8-2. The 24-hour limit value for the protection of human health (50 μg/m3) was exceeded on only two days during the measurement period. The CAFE Directive stipulates that this assessment threshold should not be exceeded more than 35 times in a calendar year. The mean of the daily values during the measurement period is below the annual limit value for the protection of human health (40 µg/m3).

Table 8-2 Particulate Matter (PM10) Data for Castlebar in 2015

Parameter Measurement

Mean daily value 13 µg/m3

Median daily value 10 µg/m3

Percentage Coverage 98%

No of Days >50 µg/m3 2

Maximum daily value 57 µg/m3

8.2.2.3 Nitrogen Dioxide (NO2)

Nitrogen dioxide and oxides of nitrogen data for the 2015 monitoring period at Castlebar is presented in 3 Table 8-3. No hourly mean NO2 value was above the lower assessment threshold (140 µg/m ). The CAFE Directive stipulates that this threshold should not be exceeded more than 18 times in a calendar

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year. The mean hourly NO2 value during the measurement period was below the annual lower assessment threshold for the protection of human health, which is 26 µg/m3.

Table 8-3 Nitrogen Dioxide and Oxides of Nitrogen Data for Castlebar in 2015

Parameter Measurement

Percentage Coverage 100%

Annual Mean (NO2) 8 µg/m3

Median Value (NO2) 5 µg/m3

Hourly Max Value (NO2) 96 µg/m3

3 Values > 100 ug/m (NO2) 0

Annual Mean (NOX) 11 µg/m3

Median Value (NOX) 7 µg/m3

Hourly Max Value (NOX) 254 µg/m3

8.2.2.4 Carbon Monoxide (CO)

Carbon Monoxide data for the 2001 monitoring period at Galway City is presented in Table 8-4. The mean hourly concentration of carbon monoxide recorded was 0.5 mg/m3. The carbon monoxide limit value for the protection of human health is 10 mg/m3. The lower Assessment Threshold is 5 mg/m3. On no occasions were values in excess of the 10 or 5 mg3 limit value set out in the CAFE Directive/ Air Quality Standards Regulations 2011 (as amended) recorded.

Table 8-4 Carbon Monoxide Data for Galway City in 2001

Parameter Measurement

No. of hours 5,356

No. of measured values 4,533

Percentage Coverage 84.6%

Maximum hourly value 2.8 mg/m3

98 percentile for hourly values 1.3 mg/m3

Mean hourly value 0.5 mg/m3

Maximum 8-hour mean 1.6 mg/m3

98 percentile for 8-hour mean 1.1 mg/m3

8.2.2.5 Ozone (O3)

Ozone data for Castlebar Monitoring Station in County Mayo from 2015 is presented in Table 8-5. The legislation stipulates that a daily limit of 120 mg/m3 should not be exceeded on more than 25 days for ozone. On no occasions were mean daily values in excess of the limit value.

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Table 8-5 Summary statistics for O3 concentrations for 2015: Castlebar

Parameter Measurement

Mean hourly value 58 mg/m3

Median hourly value 59 mg/m3

Percentage Coverage 100%

No. of Days > 120 mg/m3 0

Maximum 8-hour mean value 115 mg/m3

8.2.2.6 Dust

There are no statutory limits for dust deposition in Ireland. However, EPA guidance suggests that a deposition of 10 mg/m2/hour can generally be considered as posing a soiling nuisance. This equates to 240 mg/m2/day. The EPA recommends a maximum daily deposition level of 350 mg/m2/day when measured according to the TA Luft Standard 2002.

8.3 Climate – Existing Environment

Ireland has a temperate oceanic climate, resulting in mild winters and cool summers. The Met Éireann weather station at Belmullet, Co Mayo is the nearest weather and climate monitoring station to the proposed development site, located approximately 38 km to the northeast of the proposed cable route at its nearest point and approximately 52km north of Fallduff Strand, Old Head.

Meteorological data recorded at Belmullet over the 30-year period from 1981-2010 is available on the Met Éireann website, www.met.ie. The data shows that on average the wettest months recorded during this period were October and December, with April and May being the driest. The warmest month on average is August (mean temperature 15.0° Celsius), and the coldest month is January (mean temperature 6.3° Celsius).

8.4 Noise – Existing Environment

The proposed cable landfall location at Old Head is located in an area that is not subject to any significant noise sources. Sources of noise in this area are related primarily to low levels of road traffic, and recreational use of the beach and adjoining areas. As referred to in Section 8.2 above, the proposed development is not a project type that gives rise to noise pollution sources or falls within the remit of Integrated Pollution Control (IPC) Licensing by the EPA. The beach works associated with the proposed cable installation will have a duration of 1-2 days. Therefore, due to the nature of the proposed works and the general character of the surrounding environment, background noise monitoring was deemed to be unnecessary for this assessment.

Noise in the marine environment is addressed in Chapter 5: Biodiversity.

8.4.1 Acoustic Terminology

To take account of the vast range of pressure levels that can be detected by the ear, it is convenient to measure sound in terms of a logarithmic ratio of sound pressures. These values are expressed as Sound Pressure Levels (SPL) in decibels (dB).

The audible range of sounds expressed in terms of Sound Pressure Levels is 0 dB (for the threshold of hearing) to 120 dB (for the threshold of pain). In general, a subjective impression of doubling of loudness corresponds to a 10 dB increase in SPL. A doubling in sound energy (e.g. as may be caused by a doubling of traffic flows) increases the SPL by 3 dB.

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The sensitivity of the human ear to different frequencies in the audible range is not uniform. In order to rank the SPL of various noise sources, the measured level has to be adjusted to give comparatively more weight to the frequencies that are readily detected by the human ear. The ‘A-weighting’ system defined in the international standard, BS ISO 226:2003 Acoustics Normal Equal-loudness Level Contours has been found to provide the best correlations with human response to perceived loudness. SPL’s measured using ‘A-weighting’ are expressed in terms of dB(A).

An indication of the level of some common sounds on the dB(A) scale is presented in Plate 8-1.

Plate 8-1 The level of typical common sounds on the dB(A) scale (NRA Guidelines for the Treatment of Noise and Vibration in National Road Schemes, 2004)

8.4.2 Construction Noise

There is no published statutory Irish guidance relating to the maximum permissible noise level that may be generated during the construction phase of a project. Local authorities may consider noise limits for construction works at their discretion. The equipment to be used at the beach during the proposed cable installation works is listed in Section 3.5.6 of Chapter 3 of this report. The 2 no. tracked excavators that will be in use on the beach over a period of 1-2 days have the potential to give rise to local noise emissions. Table 8-6 below outlines the typical noise levels associated with this type of machinery, as per British Standard BS 5228 – 1: 2009 ‘Code of practice for noise and vibration control on construction and open sites’.

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Table 8-6 Typical Construction Noise Emission Levels

Plant Noise Level (dB LAeq,T) * Item Activity At 10m Distance At 150m Distance At 500m Distance

Tracked Trench Excavator excavation 77 52 41 (C.4.64) on beach Source: BS 5228 – 1: 2009

* LAeqT is the equivalent continuous sound level. It is a type of average and is used to describe a fluctuating noise in terms of a single noise level over the sample period (T).

As per the data above, the expected plant noise level from an excavator at 10m distance would be 77 db(A). A doubling in sound energy (e.g. as may be caused by a doubling of traffic flows or the use of two

pieces of plant) increases the SPL by 3 dB, which in this case would equate to 80 dB LAeqT.

There are no dwellings or immediate receptors located within 10m of the proposed works location at Fallduff Strand, Old Head. For every doubling of distance, sound level reduces by 6 decibels (dB). Therefore at 20 metres from the works if both excavators are operating at the same location, the

equivalent continuous sound level would be 74 dB LAeqT. At 80 metres, the equivalent continuous sound

level would be 62 dB LAeqT.

The nearest dwellings to the proposed cable installation location comprise holiday apartments located within 20 metres of the proposed works, at their nearest point. Figure 4-1 in Chapter 4 of this report presents all dwellings located within 1 km of the proposed works.

8.5 Potential Impacts

8.5.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment, and no potential for any impacts in relation to the air, climate or noise receiving environment.

8.5.2 Cable Installation Phase

8.5.2.1 Air Quality

The cable installation and associated beach works will require the use of machinery, plant and the main lay vessel, which could give rise to emissions. The excavated beach trench will be backfilled again with the excavated sand once the cable is installed, which could give rise to localised dust or sand emissions. The beach works associated with trenching of the cable will be 1-2 days in duration.

The following measures will be incorporated into the works to minimise emissions to air:

All construction vehicles and plant will be maintained in good operational order while onsite, thereby minimising any emissions that arise. Construction vehicles and plant will be located on site for the duration of the cable installation works. This will reduce the number of vehicles accessing the site from longer distances, thereby reducing the amount of emissions associated with vehicle movements. Machinery that is used intermittently will be shut down or throttled back to a minimum during periods when not in use. The access road to the site will be regularly inspected for cleanliness and cleaned as necessary.

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Impact and Significance of Effects

Whilst the construction phase of the proposed works is likely to lead to minor increases in dust and vehicle emissions, the implementation of the measures presented above and good management practices will prevent or minimise potential emissions. Good management practice consists adopting appropriate working methods, choosing the right equipment and ensuring that the workforce understands the company’s responsibilities and is familiar with good working practice and dust suppression techniques.

The proposed cable installation works will have a temporary, imperceptible negative impact on air quality in the immediate vicinity of the works. Given the nature and duration of the works however, there will be no significant effects on air quality.

8.5.2.2 Climate

The use of machinery during the cable installation will result in the emission of greenhouse gases associated with fossil fuel use. Operations such as the transport of people, equipment and materials are typical examples of machinery use.

Impact and Significance of Effects

The proposed works will have no impact on climate, given the nature of the works and the insignificant quantity of greenhouse gases that will be emitted.

8.5.2.3 Noise

There will be an increase in noise levels in the vicinity of Fallduff Strand during the 1-2 days that cable installation is taking place, as a result of machinery used for the works. This has the potential to cause a nuisance to dwellings located closest the proposed development site (see Section 8.4.2 above). Construction noise at any given noise sensitive location will be variable during the cable installation works, depending on the activities underway and the distance from the main cable installation activities to the receiving properties.

As described in Section 8.4.2 above, there is no published statutory Irish guidance relating to the maximum permissible noise level that may be generated during the construction phase of a project. Best practice measures for noise control will be adhered to onsite, including:

The best means practicable, including proper maintenance of plant, will be employed to minimise the noise produced by on site operations. All vehicles and mechanical plant will be fitted with effective exhaust silencers and maintained in good working order. Compressors will be attenuated models fitted with properly lined and sealed acoustic covers which will be kept closed whenever the machines are in use. Machinery that is used intermittently will be shut down or throttled back to a minimum during periods when not in use.

Noise impacts within the marine environment are addressed in Chapter 5: Biodiversity.

Impact and Significance of Effects

The proposed works at Fallduff Strand, Old Head will have a temporary, moderate negative impact at the dwellings located closest to the works location, during the cable installation stage. However, given that the works will last just 1-2 days, there will be no significant effects on the area with regard to noise. SubCom will notify local residents of the cable installation works prior to them taking place, by means of newsletter. Further details on local consultation are presented in Section 3.6.7 in Chapter 3.

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8.5.3 Operational Phase

The proposed cable will be laid along the sea floor in the marine environment and trenched up to 2m deep along the beach. It will therefore not be visible or noticeable to the public.

Impact and Significance of Effects

The operational stage of the proposed development will have no impacts or significant effects with regard air, climate or noise.

8.5.4 Decommissioning Phase

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning the associated excavation works and cable removal are likely to be of similar scale and duration to the cable installation works, resulting in similar predicted levels of impact.

8.5.5 Cumulative Effects

The potential cumulative impacts between the proposed development and the projects described in Section 2.4 in Chapter 2 of this report, hereafter referred to as the other projects, have been considered in terms of impacts on human beings.

Given the nature and size of the other projects, the potential for cumulative effects with the currently proposed development is low.

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9. LANDSCAPE AND VISUAL

9.1 Introduction

This section of the Environmental Report (ER) identifies, describes and assesses the potential landscape and visual impacts and effects of the proposed development on the receiving environment. The full description of the proposed development is provided in Chapter 3 of this ER.

The chapter includes a visual impact assessment of the proposed development, based on a desk study, field surveys of the site and surrounds which were undertaken in 2018 as part of the planning permission application for the existing landing station and associated infrastructure (Mayo County Council Pl. Ref. 18/833), and a site visit in October 2020.

9.2 Methodology

9.2.1 Guidance Documents

In 2000, the Department of the Environment and Local Government (DoEHLG) published ‘Landscape Assessment: Consultation Draft of Guidelines for Planning Authorities’, which recommended that all local authorities adopt a standardised approach to landscape assessment for incorporation into development plans and consideration as part of the planning process. This section of the assessment has been informed by the landscape assessment guidelines presented in the DoEHLG document as well as a range of other documents, which include:

Guidelines for Landscape and Visual Impact Assessment (The Landscape Institute/Institute of Environmental Management and Assessment (LI/IEMA), UK, 2013). Regional Seascape Character Assessment for Ireland 2020. Draft Consultation Report. (The Marine Institute. 2020. Definition and Classification of Ireland’s Seascapes) Mayo County Development Plan 2014 -2020 EPA guidance documents, as listed in Chapter 1 of this report.

9.2.2 Study Area

The Landscape Institute/Institute of Environmental Management and Assessment Guidelines on Landscape and Visual Impact Assessment (GLVIA) refer to the identification of the study area that is to be covered while assessing landscape effects. The Guidelines state:

“The study area should include the site itself and the full extent of the wider landscape around it which the proposed development may influence in a significant manner.”

The study area in this case consists of the site and immediate surroundings, accessible to the public, along the Oldhead Close Road, the site entrance as well as Fallduff Strand and Old Head Pier, the L1827 local from the R335 Regional road to Old Head Pier and another local access road leading off the R335 further west and connecting to the L1827. It also includes the public lands adjacent to the site. The relevant areas, therefore, are those which lie immediately to east and south of the site. There are no roads to the west of the site. The baseline landscape assessment was refined following the site visit and review of the proposal. This follows the LI/IEMA guidance, which proposes that the level of detail in the landscape baseline studies should be “appropriate and proportionate to the scale and development”.

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9.2.3 Assessing Landscape Effects

Landscape Effects

Landscape effects can be described as changes which affect the landscape as a resource. This includes how a proposal will affect the elements that make up the landscape, the aesthetic and perceptual aspects and its landscape character. Landscape effects also relate to changes in the structure of the landscape. Under the GLVIA (2013), the assessment of likely significant effects on landscape receptors includes a judgement on both the sensitivity of the receptor as well as the magnitude of change.

Landscape Sensitivity

Landscape sensitivity is described in the GLVIA (2013) as a combination of the landscape’s susceptibility to change, as well as the value attached to the landscape.

Magnitude of Change

The magnitude of change within a landscape is a combination of the size and scale of the change, the extent of the area affected (e.g. how much of a feature is lost or the extent of the feature to be added) and the degree to which aesthetic or perceptual aspects are altered. The duration and reversibility of the effect. Significance is then arrived at by combining the magnitude and sensitivity judgements.

9.2.4 Visual Receptors - Assessing Magnitude and Sensitivity

Visual Receptor Sensitivity depends on the occupation or activity of the people as well the extent to which the attention is focused on views and visual amenity, according to the GLVIA Guidelines (2013). It is also based on the value attached to the view.

9.3 Landscape Policy Context

9.3.1 Mayo County Development Plan 2014-2020

9.3.1.1 Landscape Character Areas

The Landscape and Landscape Character Assessment for County Mayo, published by Mayo County Council in 2014, divides the county into 16 distinct Landscape Character Areas (LCAs). The subject site is located in the Landscape Character Area O: Croagh Patrick Association. It runs from Roonah Point to Murrisk Pier and inland to the N59 road, south of Westport. This LCA is described as:

“The vista of Croagh Patrick from the Clew bay and the north-west is a highly distinctive vista within County Mayo. It is a steep and smooth, mountain landscape ascending from moorland foothills to the south west of the town of Westport to the focal point of the peaked ridgeline of Croagh Patrick. Such views continue around to the west above Clew Bay as the dominating ridgeline descends toward the sea. The primary landcover consists of mountain grasses, thinning in places to expose upland gravels. “

9.3.1.2 Landscape Sensitivity Rating

The sensitivity of a landscape to development and therefore to change varies according to its character and to the importance which is attached to any combination of landscape values. Landscape sensitivity is outlined within the Co. Mayo Landscape Appraisal document and is broken down into policy areas which then in turn have sensitivities attached relevant to different types of development.

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The study area is within Policy Area 3 - Uplands, moors, heath or bogs. While Policy Area 3 is designated as being of Medium sensitivity with regard to ‘Industrial/Commercial’ developments, given that the proposed cable will be located underground, it will have no impact on landscape values or character.

9.3.1.3 Focal Points and Views

The Mayo County Development Plan divides the mapping of views and prospects into 4 categories: Scenic routes, Scenic Views, High Scenic Views and Viewing Points. There are several High Scenic Views located along the R335 Regional road, however this road is located approximately 800m from the cable landing station at its nearest point. The location of the R335 road in relation to the cable landing station and beach landfall location is shown in Figure 2-2 in Chapter 2 of this report.

9.3.2 Regional Seascape Character Assessment for Ireland 2020

The ‘Regional Seascape Character Assessment for Ireland 2020: Draft Consultation Report’ was published in October 2020 by The Marine Institute. The report identifies Seascape Character Types, i.e. distinct types of seascape that are relatively homogeneous in character.

Fallduff Strand, Old Head and Clew Bay are located within Seascape Character Type (SCT) 1: Large Limestone Bay with low-lying/undulating hinterland and coastal wetlands. The key characteristics of this SCT include: Large, open sweeping bays. Low-lying hinterland terrain hosting subglacial landforms (e.g. drumlins, moraines) that indicate ice flow direction seaward towards large bay. Can include extensive sandy beaches. Sand dunes also present. The islands of Clew Bay are a renowned feature of this bay – often called drumlins, but more correctly drowned ribbed moraines. Long sweeping views along and across bays a feature. Macro tidal ranges (>4m) present at all Atlantic Sea limestone bays: Clew Bay, Galway to Tralee Bay, Dingle Bay.

This draft report is currently under public consultation.

9.4 Landscape Character

Landscape character refers to the distinct and recognisable pattern of elements that occurs consistently in a landscape, and how people perceive this. It reflects combinations of geology, landform, soils, vegetation, land-use and human settlement. It creates the sense of place found in different areas. The identification of landscape character comprises the identification of the physical, visual and image units.

9.4.1 Physical Unit

Landform and landcover in an area combine to physically distinguish one landscape from another. These physical characteristics form individual areas or units, known as physical units, whose character can be defined by aspect, slope, scale and size. A physical unit is generally delineated by topographical boundaries and is defined by landform and landcover. Landform is the term used to describe the spatial and formal arrangement of landscape components as natural products of past geological and geomorphologic processes and refers primarily to topography and to some extent drainage.

The physical unit in which the subject site is located consists of a relatively large physical unit although this is mostly in the marine environment, with views available to the surrounding coastline and inlets available to the north, with views of Crough Patrick to the east which dominates the view as seen in Plate 9-1.

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Plate 9-1 View from Fallduff Strand looking east across the bay towards Croagh Patrick

Plate 9-2 View from Old Head pier looking back towards the Beach and Cable Landing Station

Old Head woodland, to the west of the study area as seen in Plate 9-2 above, overlooks the entire study area. There are high levels of mature broadleaf native trees across the study area, as evident in this image.

9.4.1.1 Topography

The landscape of the study area is coastal and characterised by a series of beaches all along Clew Bay. Overall, the topography within the area slopes gradually down to the sea, with small cliffs in some areas.

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In the surrounding landscape the land rises more steeply to the local summit of Old Head, as seen above in Plate 9-2.

Plate 9-3 View from higher ground looking over the Old Head public car park down to Fallduff Strand

9.4.1.2 Land Cover

Land-cover is the term used to describe the combination of vegetation and land-use that cover the land surface. It comprises the more detailed constituent parts of the landscape and encompasses both natural and man-made features.

In the wider landscape, the land cover consists of agricultural fields, interspersed with small clusters of dwellings. A number of holiday homes and mobile homes are situated along the ‘Oldhead Holiday Village’ road, leading up to the beach, there is also an apartment block closer to the shore line, which is assumed are additional apartments attached to the holiday village development. The front of the apartment block building is shown in Plate 9-4 below.

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Plate 9-4 View looking toward the holiday apartments on the coastline

There is strong level of mature broadleaf trees across the study area. The access road from the R335 towards Fallduff Strand is also heavily vegetated, as shown in Plate 9-5.

Plate 9-5 View looking from the R335 toward the Oldhead Holiday Village road

Plate 9-6 below is taken from the junction of Oldhead Holiday Village and Oldhead Woods Roads. This view is looking directly towards the proposed development site, located 150m from this point.

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Plate 9-6 View from the junction of Oldhead Holiday Village and Oldhead Woods Road, looking towards Fallduff Strand.

9.4.1.3 Land-use

The proposed cable will be laid upon the ocean floor predominantly while a small section of the cable will be located along Fallduff Strand. The land-use will therefore be unaltered after the cable has been installed and will not be perceived in the marine environment or at Fallduff Strand. The proposed cable will connect to the existing landing station at Old Head, see Plate 9-7 below. The cable installation location on the beach is screened from the wider area by mature broadleaf trees as can be seen in Plate 9- 4.

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Plate 9-7 Existing Cable Landing Station

Plate 9-8 Existing Cable Route Connecting the Beach Manhole to the Landing Station, trenched through road and carpark area

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Plate 9-9 Beach Boundary Wall

9.4.2 Visual Unit

When describing landscape character, physical units can be restricted in terms of visibility due to landform or land cover and may be made up of smaller visual units. Long-range views are available from Fallduff Strand, Old Head and the marine environment.

9.4.2.1 Landscape Value

Landscape sensitivity and ultimately the significance of the impact are determined by assessing the landscape value of the proposed development site and wider study area. Table 9-1 below has been compiled with reference to the GLVIA (2013) as well as the Draft Guidelines on Landscape and Landscape Assessment (2000). Overall, the study area is considered to be of high landscape value.

Table 9-1 Features of Landscape Value

Feature Description

Landscape There are a number of scenic views in the vicinity of the site, as Designations discussed in Section 9.3.1 of this report. The site lies within a wider area designated by the County Mayo Landscape Appraisal as Policy Area 3 – Uplands, Moors, Heath or Bogs.

Landscape This refers to the physical state of the landscape, and the condition of Quality/Condition individual elements. The landscape in this area is in relatively good condition, having been partly modified by agriculture and some housing development. Mature broadleaf trees and hedgerows are features of this landscape.

Aesthetic Qualities Fallduff Strand, Old Head has a clear view of Clew Bay and Croagh Patrick to the east, which give high aesthetic qualities to the area.

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Feature Description

Wildness/naturalness There is a relatively high proportion of scattered built development and there is not a sense of wildness in the terrestrial environment. However, Fallduff Strand, Old Head and the marine environment in Clew Bay provide a sense of naturalness.

Rarity/Conservation Oldhead Wood Special Area of Conservation (SAC) is located to the Interests west of the proposed cable route.

Cultural Fallduff Strand, Old Head is associated with the wider area around Meaning/Associations Croagh Patrick, which is of high cultural significance.

Recreation Value The site of the proposed cable at Fallduff Strand, Old Head has a considerable recreational value. The beach and Pier are used for walking, bathing, water sports and fishing. Recreational uses are also evident along the Old Head Holiday Village Road.

9.4.3 Landscape Sensitivity

The susceptibility to change to a development of this type is low as a result of the nature of the development (i.e. a cable, which one installed will not be visible) and the character of the landscape, with high levels of vegetation, scattered dwellings and views of the coast. As the landscape value is generally deemed to be high, it is considered that, overall, landscape sensitivity is medium.

In terms of visual receptor sensitivity, although the site is in an area of high scenic value, the site itself has no designated views within or in close proximity. While Fallduff Strand has considerable recreational value, the proposed cable installation is expected to take no longer than 6-10 days and will not be visible once installed as it will be trenched under the beach. These recreational uses along with sparse nearby residential and holiday dwellings means that the visual receptor sensitivity is considered Medium to High.

9.5 Potential Impacts

9.5.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment.

9.5.2 Cable Installation Phase

The trenching of the cable at Fallduff Strand will last 1-2 days, with works localised to the immediate area. This will have a temporary, slight negative effect on landscape and visual receptors in the immediate vicinity of the site.

Impacts and Significance of Effects

The proposed cable installation works on the beach will be of small-scale and temporary in duration. There will be no significant effects to landscape or visual receptors as a result of the works.

9.5.3 Operational Phase

The proposed development will not be visible once installed. There will be no change to the physical landscape due to the proposed development. The proposed development will therefore have no impact on landscape character or value.

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Impacts and Significance of Effects

There will be no landscape or visual impacts or significant effects associated with the operational stage of the proposed development.

9.5.4 Decommissioning Phase

If the cable were to be removed from Fallduff Strand, the associated works would have a brief to temporary, slight negative effect on localised landscape and visual receptors, arising from the works associated with this phase of the project. This impact would be temporary and localised to the immediate area of the works, similar to the installation phase.

9.5.5 Cumulative Effects

Given the nature and scale of the proposed development, in combination with the other projects considered as part of this cumulative assessment (see Section 2.4 of Chapter 2), there is no potential for any cumulative effects on landscape or visual receptors.

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10. ARCHAEOLOGY AND CULTURAL HERITAGE

10.1 Introduction

This section of the Environmental Report identifies, describes and assesses the potential impacts and effects of the proposed development on archaeology and cultural heritage and has been completed in accordance with the guidance set out in Section 1.3.3 of Chapter 1: Introduction. The full description of the proposed development is provided in Chapter 3 of this ER.

This section of the Environmental Report is based on the following reports which have been completed for the America Europe Connect 2 (AEC2) project:

‘Marine Archaeological Assessment. Marine Survey and Site Investigation Works within the Havfrue Cable Route Corridor’ – Archaeological Monitoring Report prepared by Geomara (Subsea Survey Providers and Marine Archaeologists), July 2018. ‘Marine Archaeological Assessment of the Preferred Route within the Havfrue Cable Route Corridor’ – Archaeological Assessment of the Preferred Route prepared by Geomara, October 2018. ‘Archaeological Assessment (Field and Desk) at Old Head, Louisburgh, Co. Mayo’ – Report prepared by Anne Carey Archaeological Consultant, July 2018.

The above reports are provided as Appendices 10-1, 10-2 and 10-3 of this Environmental Report.

10.2 Receiving Environment

10.2.1 Marine Environment

10.2.1.1 Marine Survey and Site Investigation Works

The Geomara report in Appendix 10-1 of this Environmental Report describes the archaeological assessment that was carried out in conjunction with the bathymetric and geophysical survey works during identification of the optimum cable route corridor. The archaeological assessment comprised a description of the study area, and the identification of cultural heritage sites, features and deposits located along the proposed cable route corridor.

The key findings of the archaeological assessment include the following:

Beach probing was carried out at 19 locations along the proposed cable corridor at Fallduff Strand, Old Head. This probing was conducted to investigate the depth of sand deposits along the beach and was monitored by a licensed archaeologist. Nothing of archaeological significance was noted at any of the locations. During the course of data acquisition, one unknown wreck site was noted 126 metres (m) to the southwest of the centreline of the proposed cable route. Nothing of archaeological significance was noted during the examination of the bathymetric and geophysical data in advance of geotechnical work proceeding along the cable route corridor.

10.2.1.2 Marine Archaeological Assessment

Geomara carried out a marine archaeological assessment of the proposed AEC2 cable route within the marine environment and landfall location at Fallduff Strand, Old Head (please see Appendix 10-2 for full report).

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The assessment comprised a description of the study area, and the identification of cultural heritage sites, features and deposits located along the proposed cable route corridor. An extensive desk-based study of the route corridor was undertaken, which was then followed up by an extensive review of the geophysical data collected during site investigations. The archaeological monitoring of the beach probing at Old Head also formed part of the assessment.

Onshore Cultural Heritage Assets

The archaeological assessment identified four known archaeological sites in the vicinity of the cable route corridor at Old Head, which are included on the Sites and Monuments Record (SMR). These sites are listed below and shown on Plate 10-1.

The assessment found that none of these sites would be impacted by the proposed development.

Burnt mound (MA086-017) located 1km west of the proposed cable route Midden (MA086-12) located approximately 500m north of proposed cable route Midden (MA086-018) located approximately 300m north of proposed cable route Midden (MA086-013) located approximately 1km southeast of proposed cable route

Plate 10-1 Recorded Sites and Monuments at Old Head (Source: Geomara)

Known Possible Shipwreck Site

The desk study revealed one known cultural heritage asset located on the foreshore at Old Head: this comprised timbers that form part of the possible remains of a wreck (W11423) or the remains of the Coastguard Station or the Salt Pans which is recorded as in ruins on the 1st Ed. 6 inch OS map. The initial proposed cable route was modified so as to avoid this feature.

Unknown Shipwreck Site

As described above, one unknown shipwreck site was identified during the archaeological assessment, located 126m southwest of the centreline of the proposed cable route. Due to the distance from the centreline of the cable route corridor, it was not necessary to re-route the proposed route. The wreck was reported to the Underwater Archaeological Unit within the National Monuments Service. The possible wreck site is shown in Plate 10-1 above and outlined in Plate 10-2 below, around which the cable route is located so as to avoid it.

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Plate 10-2 Cable Route and Possible Wreck Site (Source: Geomara)

10.2.2 Terrestrial Environment

The cable landing station, beach manhole and associated cabling were constructed in 2019 under Mayo County Council Planning Reference No. 18/833. The planning permission application to Mayo County Council was accompanied by an Archaeological Assessment, prepared by Anne Carey, Archaeological and Historic Buildings Consultant (see Appendix 10-3 for full report).

The key findings of the archaeological assessment with regard to the then proposed development site included:

There are no extant archaeological sites within or close to the site boundary. The site is not within the Zone of Notification for any Recorded Monument. There are no protected structures on or near the site. The historic mapping does not record the presence of known but destroyed archaeological sites within the site boundary. The archaeological profile of the surrounding area suggests that the site has low archaeological potential.

10.3 Potential Impacts

10.3.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment. There would be no potential for impacts on unknown features of archaeological interest.

10.3.2 Cable Installation Phase

The archaeological assessment carried out for the cable landing station, beach manhole and associated infrastructure (now constructed) identified that the archaeological potential of the subject site was low and

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concluded that there would be no impacts on features of cultural heritage or archaeological significance. Similarly, there would be no impacts on Recorded Monuments arising from visual disturbance, given the nature of the development and the absence of such features in the vicinity of the site.

The marine archaeological assessment identified a possible wreck site at Fallduff Strand, Old Head. The cable route was moved to avoid this location. No further features of archaeological significance were identified during beach probing works or geophysical investigations along the proposed cable route. Notwithstanding this, there is a possibility that previously unidentified features could be disturbed during cable lay operations at the beach or within Clew Bay. This would result in a direct moderate negative impact on cultural heritage. The marine archaeological assessment identified that there was no potential for significant indirect impacts arising from the proposed development.

The cable installation works at Fallduff Strand will be subject to archaeological monitoring. Archaeological monitoring of the pre-lay grapnel run and plough trenching will also be undertaken (under archaeological licence) in order to identify any previously unrecorded features finds or deposits. Procedures will be in place to ensure that any previously unrecorded cultural heritage assets encountered during the cable installation works are assessed and recorded by a suitably qualified archaeologist. These procedures will be agreed during the licencing process with the Underwater Archaeology Unit (Department of Culture, Heritage and the Gaeltacht) prior to the works.

On completion of the cable installation a report will be produced summarising all archaeological aspects of the project and submitted to the Department of Culture, Heritage and the Gaeltacht and the National Museum of Ireland.

Impact and Significance of Effects

The cable installation works at sea and on the beach will be monitored by an archaeologist to ensure that no direct impacts occur on features of archaeological or cultural heritage. The proposed works will have no significant effects on archaeological or cultural heritage.

10.3.3 Operational Phase

Once the cable installation works have been completed there will be no potential for impacts on cultural heritage or archaeology.

Impact and Significance of Effects

There will be no impacts or significant effects on features of archaeological or cultural heritage during the operational stage of the proposed development.

10.3.4 Decommissioning Phase

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning the associated excavation works and cable removal are likely to be of similar scale and duration to the cable installation works.

Impact and Significance of Effects

There will be no impact or significant effects on features of archaeological or cultural heritage associated with the decommissioning phase.

10.3.5 Cumulative Effects

Given the nature and scale of the proposed development, in combination with the other projects considered as part of this cumulative assessment (see Section 2.4 of Chapter 2), there is no potential for cumulative effects on cultural heritage or archaeology.

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11. MATERIAL ASSESTS

11.1 Introduction

Material Assets are defined in the Environmental Protection Agency’s ‘Advice Notes for Preparing Environmental Impact Statements’ (EPA, draft 2015) as “resources that are valued and that are intrinsic to specific places”. The 2017 EPA guidelines ‘Guidelines on the Information to be Contained in Environmental Impact Assessment Reports’ (EPA, draft 2017) further clarifies that material assets can be taken to mean built services and infrastructure, including traffic. While this report is not an EIAR, this section of the Environmental Report describes and assesses the potential impacts of the proposed development on material assets.

Material assets may be either of human or natural origin. Economic assets of natural origin include non- renewable resources such as minerals or soils, and renewable resources such as water. These assets are addressed in Chapter 6: Land, Soils and Geology, and Chapter 7: Water of this Environmental Report (ER). The Population and Human Health chapter (Chapter 4) addresses existing land-uses and tourism, which are economic assets, and amenity resources. The cultural assets of Archaeology and Cultural Heritage are addressed in Chapter 10.

The full description of the proposed development is provided in Chapter 3 of this ER. Further information on the classification of impacts used in this assessment are presented Table 1-1 in Section 1.3.3 of Chapter 1.

11.2 Receiving Environment

11.2.1 Traffic and Transportation

From the public road network, Fallduff Strand is accessed via the Oldhead Holiday Village Road which in turn is accessed from the R335 Regional Road. From the Holiday Village Road, Fallduff Strand is accessible directly to the east, with the existing cable landing station accessed to the west via Oldhead Close road and the beach car park.

The local road network in the immediate vicinity of Fallduff Strand, Old Head permits one-lane traffic only on some sections. A default speed limit of 80 kph applies to the main local network, with 50 kph in some sections, although speeds on site were observed to be significantly lower, primarily due to geometric constraints.

11.2.1.1 Proposed Development and Traffic Generation

Section 3.5 in Chapter 3 of this ER describes the mobilisation process that will take place prior to installation of the cable at Fallduff Strand, including the movement of specialised equipment and excavators (2 no.) to the site. Appendix 3-2 of this report provides the list of vessel, equipment and material resources that will be utilised for installation of the cable.

As discussed in Chapter 3 (Section 3.2.2), the beach works associated with the proposed cable installation will last for 1-2 days. In advance of this works period, the excavation equipment, site vehicles and other equipment will be delivered to the site compound. Mayo County Council have requested that the site compound is located at the top of the existing beach car park. Use of the car park by beachgoers will not be affected.

The construction team will travel to the site by personal cars on each work morning, parking at the existing beach car park and leaving in the evenings. All site equipment will be removed from the site at the completion of works.

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While there will be no road closures, temporary traffic safety measures will be in place during beach works. The 2 no. excavators required for the beach works will cross from the site compound to the beach, and back again, at the start and end of the workday; this crossing will be managed so as to ensure health and safety for pedestrians and road users.

Within the marine environment, guard and safety boats will be in position on either side of the cable route to deter any oncoming marine traffic and guard for natural phenomena as required during the shore-end landing and cable installation stages. Guard boats will be used in the offshore section (1.2km from shore to 12 Nautical miles), whilst safety boats will be used from 1.2km to shore. They will be employed on a 24-hour basis.

11.2.2 Services and Utilities

11.2.2.1 Water Supply

As described in Chapter 7: Water, the search of the Geological Survey of Ireland (GSI) well database (www.gsi.ie) indicated that there are no wells within proximity of Fallduff Strand, Old Head. The nearest well is approximately 3.4km southeast of the development in Kilsallagh Upper and is located in a different water catchment to the proposed development.

11.2.2.2 Drainage

There are no surface water features within proximity of the proposed cable route or the existing landing station or associated infrastructure. A local hydrology map is shown as Figure 7-1, in Chapter 7. The area in which the existing infrastructure and Fallduff Strand, Old Head are located both naturally drain in a northerly direction into Clew Bay.

11.2.2.3 Utilities

The existing cable landing station is supplied with electricity by Energia, which will be available during the cable installation works.

A temporary site office (trailer-based) within the compound will provide welfare facilities for staff during the cable installation phase. Wastewater will be collected by an appropriately licenced contractor and disposed of offsite at a licenced facility. A water supply will not be required for the short duration of the beach works. Bottled water will be available for staff at the site office.

11.3 Potential Impacts

11.3.1 ‘Do-Nothing’ Scenario

If the proposed development were not to proceed, there would be no change to the existing environment and no additional traffic generated as a result.

11.3.2 Cable Installation Phase

11.3.2.1 Traffic and Transportation

The cable installation works at Fallduff Strand, Old Head will last 1-2 days. Traffic safety measures will be employed during the movement of two excavators from the beach car park to the beach, as described above.

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Impact and Significance of Effects

The traffic control measures will have a momentary slight negative impact on any pedestrians or vehicles that are currently using the car park or beach access road, in terms of disturbance. However, this impact will last minutes only and occur on 1-2 days. There will therefore be no significant effects with regard to traffic.

11.3.2.2 Services and Utilities

The proposed development will have no impact on existing services or utilities during the cable installation phase. The beach trenching operations will be performed with care that any previously located cables on the beach are not damaged. Any in service cables or metallic structures will be identified and located prior to trench excavation.

Within the marine environment, the pre-lay grapnel activity will not be conducted in hard bottom areas and will avoid existing buried cables, as described in Section 3.3 in Chapter 3 of this report.

Impact and Significance of Effects

The proposed works will have no impacts or significant effects on services and utilities.

11.3.3 Operational Phase

11.3.3.1 Traffic and Transportation

Once the cable installation works have been completed there will be no traffic impacts on the receiving environment. The existing cable landing station will be unmanned. In the event of maintenance works being required the cable can be accessed via the existing beach manhole and landing station. The potential intermittent maintenance work will not have any significant effect on traffic or transportation infrastructure in the area.

Impact and Significance of Effects

The operational stage of the proposed development will have no impacts or significant effects on traffic and transportation.

11.3.3.2 Services and Utilities

Impact and Significance of Effects

The proposed development will have a long-term positive impact in terms of providing telecommunications infrastructure. It will have no impact on existing services or utilities during the operational phase.

11.3.4 Decommissioning Phase

11.3.4.1 Traffic and Transportation

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning, the associated excavation works and cable removal are likely to be of similar scale and duration to the cable installation works, resulting in a momentary slight negative impact on traffic at the beach car park location.

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11.3.4.2 Services and Utilities

In the event that the buried cable at Fallduff Strand, Old Head is required to be removed during decommissioning the associated excavation works and cable removal are likely to be of similar scale and duration to the cable installation works. There would be no impact on existing services or utilities.

11.3.5 Cumulative Effects

11.3.5.1 Traffic and Transportation

Given the nature and scale of the proposed development, in combination with the other projects considered as part of this cumulative assessment (see Section 2.4 of Chapter 2), there is no potential for cumulative effects on traffic or transportation infrastructure.

11.3.5.2 Services and Utilities

Given the nature and scale of the proposed development, in combination with the other projects considered as part of this cumulative assessment (see Section 2.4 of Chapter 2), there is no potential for cumulative effects on existing services and utilities.

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APPENDICES

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