Appendix 3 Ecology Response

1. Avifauna

General comment The comments from Bird Watch Ireland and An Taisce are welcome. The Response has been prepared in a short period of time and a review of available literature on impacts is on‐going by the bird survey team. Since the Ecological Assessment of the EIA was prepared, a draft guidance document on survey and monitoring in relation to marine renewable deployments in Scotland was produced by Scottish Natural Heritage. Several reviews of the environmental impacts of marine renewable energy devices have been published (e.g. Grecian et al., 2010, Witt et al., 2011) and conferences on or including the theme of marine renewables have been held (e.g. ICES, 2011, EIMR, 2012). While the industry is developing quickly, data to describe the interactions between wave energy devices and birds is still limited. Within this context the following response has been prepared:

Bird Watch Ireland comment 1: Consideration of the interests of SPAs in the Appropriate Assessment screening process: Bird Watch Ireland notes that the Screening for Appropriate Assessment report identifies a number of Special Protection Areas and their distances from the proposal area. It does not identify the species concerned, their ecological needs or the potential for impacts as a result of the proposal. They appear to be screened out of the assessment process though the detailed rationale for this is not provided. The Ecological Assessment report (Annex 3: Ecological Assessment For The Proposed Atlantic Marine Energy Test Site) prepared for this proposal identifies potential impacts on Avifauna of Special Conservation Interest for nearby SPAs which are considered to be of “High” or “Unknown” significance which is a direct contradiction.

It is Bird Watch Ireland’s view that an assessment on the ecological needs of seabirds is required prior to decision‐making. While there are significant data gaps for the marine environment, existing information on the ecology of species needs could be used to inform an assessment along with more recent research on the interactions between species and renewable energy infrastructure. This is not included in the assessment process.

Response: To address the above concerns of Bird Watch Ireland the following steps were taken: i. “Qualifying” species (special conservation interests) for the coastal SPA’s which lie within 30km of the study site where listed (Table 1a and 1b below). ii. Migratory species or species which may be linked to more distant Irish or UK SPA’s and which were recorded in the study site, where listed (Table 2 below). iii. A Risk Assessment for the species listed in tables 1 and 2 based on the ecological needs of these species (considered in species groups), current risks, their use of the study site and their potential interactions with WEDs and AMETS was completed (Appendix 1). This Risk Assessment used standard reference texts (e.g. Mitchell et al.,2004), Birdwatch Ireland Action Plans (BWI, 2011), the SNH Draft Guidance document on marine renewable (Jackson & Whitfield, 2011) and the Strategic Environmental Assessment of Marine Renewable Energy Development in Scotland (Wilson et al.,2007). The Risk Assessment includes a number of additional species which commonly occur within the study site and which are part of the species groups being considered in the Risk Assessment. Conclusions from the Risk Assessment are presented below.

iv. The conclusions from the Risk Assessment were incorporated into a revised Appropriate Assessment Screening (Appendix 2). The conclusions of this Screening Assessment are presented below.

i. Qualifying species.

The qualifying species within the SPA’s identified in the Appropriate Assessment Screening (EIA, 2011) are listed in Table 1. (see also tables 3.1.1 and 3.1.2 of the Ecological Assessment: Annex 3 of the EIA).

Table 1a: Qualifying wintering species for coastal SPA’s lying within 20 km of the study site and which have used the study site. “*” indicates Annex I species. Wintering Species SPA Barnacle Geese* Inighlora Inishkeeragh Termoncarragh and Annagh Lake Machair Blacksod Broadhaven Bay Inishkea Islands Duvillaun Islands Light Bellied Brent Goose Blacksod Broadhaven Bay Great Northern Diver* Blacksod Broadhaven Bay Ringed Plover Blacksod Broadhaven Bay Inishkea Islands Sanderling Blacksod Broadhaven Bay Inishkea Islands Dunlin Blacksod Broadhaven Bay Curlew Blacksod Broadhaven Bay Purple Sandpiper Inishkea Islands Turnstone Inishkea Islands

Table 1b: Qualifying breeding species for coastal SPA’s lying within 20 km of the study site and which have used the study site. “*” Indicates Annex I species. Breeding Species SPA Storm Petrel* Inishglora and Inishkeeragh Duvillaun Islands Ilanmaster Stags of Broadhaven Leach’s Petrel* Stags of Broadhaven Arctic Tern* Inishglora and Inishkeeragh Inishkea Islands Sandwich Tern* Blacksod/Broadhaven Bay Little Tern* Inishkea Islands Cormorant Inishglora and Inishkeeragh Shag Inishglora and Inishkeeragh Inishkea Islands Lesser Black backed Gull Inishglora and Inishkeeragh Inishkea Islands Herring Gull Inishglora and Inishkeeragh Inishkea Islands Common Gull Inishkea Islands Puffin Illanmaster Stags of Broadhaven Fulmar Duvillaun Islands ii. Additional Species.

Additional species considered in the Risk Assessment given that they are migratory species and/or that they are likely part of the qualifying interest in distant Irish or UK SPAs are listed in Table 2. These species are taken from the list of more commonly occurring species recorded within the study site (Ecological Assessment, Annex 3 EIA).

Table 2: Migratory species and species which species which may be linked to distant Irish or UK SPA’s and which use the study site. Species Importance Gannet Distant SPA, foraging activity in study site Skuas Migratory – occurrence on passage Manx Shearwater Distant UK/Irish SPA (possibly) and migratory, large numbers in Spring, foraging. Great & Sooty Migratory – occurrence on passage Shearwater iii. Conclusions from the Risk Assessment

Appendix I of this Response provides summary information on the ecological needs of each of the qualifying species (considered in species groups), together with an assessment of the risk of a

negative interaction between the proposed development and the qualifying species. Conclusions from this assessment are as follows:

 The risk of negative interactions between cable laying activities within the Bay and the qualifying species is considered to be low, given the short duration and temporary nature of activities. Likely significant effects on the qualifying wintering and breeding birds which use the Bay are therefore considered unlikely. Monitoring of the Bay is recommended.  Displacement of foraging birds from the berth areas is considered to be of low impact for all species groups. The footprint of the berth areas is relatively small and alternative foraging habitat is available. There is also, so far, no indication that the berth areas provide favoured feeding habitat and are thus attractive to, any species group. Displacement is therefore unlikely to have significant effects on the qualifying species which use the AMETS. Monitoring is recommended.  For the protection of all species the active use of a comprehensive spill prevention and response plan is important.  The risk of collision for all species groups is considered to be low due to the small footprint of the development. Notwithstanding this assessment the risk of collision is higher for a number of species due to aspects of their behaviour (Table 3).

Table 3: Species groups at higher risk of collision with WEDs. Species Group Reason for higher collision risk Terns Plunge divers Petrels Nocturnal habits Shearwaters Low flying, nocturnal habits. Auks Pursuit divers, low fast flight.

 Monitoring is recommended at the wave energy test site to examine the interactions between birds and the wave energy devices. Without such data the impacts of wave energy devices on birds cannot be fully assessed. iv. Conclusions from the revised Appropriate Assessment Screening.

The AMETS is not likely to have a significant effect on the species of conservation interest within the SPAs identified in the Revised Appropriate Assessment. This conclusion is based on the information contained in the Ecological Assessment for the EIA, and the Risk Assessment completed as part of this Response. Given that the significance of some impacts are unknown and given the limited data with which to assess other impacts, monitoring is recommended.

Bird Watch Ireland comment 2: Data available for decision‐making in the marine environment:

Bird Watch Ireland recognises that there are serious data deficiencies for the marine environment in particular relating to the status and behaviour of seabirds and their ecological needs. Notwithstanding ongoing research relating to seabirds in other countries, it is important to build a knowledge base in an Irish context and to ensure informed decision‐making at both a sectoral and project level.

A series of unknowns need to be proactively addressed to assist decision‐making in this case:

Building a baseline: While significant work has been carried out by the applicant particularly in the last year, this provides a snapshot of usage of the location by certain species. This snapshot needs to become more applied. It is Bird Watch Ireland’s view that a single year of data is not sufficient in order to assess usage of the area by species, and that a more encompassing baseline assessment needs to be designed and rolled out. Specifically; surveys of off‐shore islands for terns and Eider for example, and the examination of foraging distances from nearby seabird colonies, and of species densities in the context of ecological needs is required.

Research & monitoring the test project: A coherent research and monitoring programme should be designed as part of the application process so as to ensure the proposed ‘test phase’ project contributes to better understanding the interactions of seabirds and energy infrastructure. Again the design of monitoring should ensure data gaps are addressed for Irish seabirds.

Response: One year of survey data is not sufficient to establish usage of the AMETS study site. Monitoring surveys have been on‐going since the surveys for the EIA and there is now a second year of data for the study site (see monitoring report) and a third year of surveys are currently underway. Analysis of three years of data will give a better picture of site use.

The Risk Assessment and Ecological Assessment for the EIA does not indicate that significant negative effects on birds are likely due to the wave energy test site. However precaution is necessary given the novelty of the development and the paucity of data from active wave energy installations. As such robust and focussed monitoring is essential, both to determine the actual effects of wave energy devices at the test site and to inform other wave energy developments in Ireland and elsewhere.

The pre‐development monitoring of the berth areas combines transect surveys with a BACI survey design to detect before and after impacts at regional and local scales. Should the wave energy devices be installed it will be recommended these surveys continue. Given the risk, albeit low, of collision and displacement interactions, between birds and WEDs, further monitoring elements will be recommended to address this risk, should the development proceed. The bird survey team have considered a number of survey elements which could be undertaken, pre – development. These have included tracking of targeted species and point count surveys at the berth areas. However, while a broader survey approach could be adopted, budgetary constraints demand that surveys are targeted. The current monitoring programme will continue and after WED installation monitoring of displacement, attraction and collision interactions within the berth areas will be undertaken.

Notwithstanding the above, the AMETS provides an ideal opportunity for research into the interactions of wave energy devices and birds. Such research is outside scope of an EIA, however it would allow greater scope for survey work and inform our understanding of impacts, useful at both AMETS and other wave energy sites. The Wave Hub development in England incorporates a strong research element (Witt et al., 2010) and this approach can only be recommended.

Bird Watch Ireland comment 3: Importance of the marine area in the zone identified in the proposal:

Current work under the EU funded FAME project (www.fameproject.eu) is identifying areas of particular importance for seabirds in Irish waters. A preliminary report of the projects findings will be published by the end of May 2012. This work has identified a number of ‘superclusters’ of

seabird activity. The project proposal lies within one of these ’supercluster’ areas. A summary of some of the findings related to this area from the FAME project are included below:

Two seabird colony SPAs are within 15 km of the AMETS site, and one (Inishglora & Inishkeeragh SPA), lies between the cabling landfall and the ‘array’ sites.

Inisglora/Inishkeeragh SPA supports nationally important number of breeding Storm Petrels, Shags, Lesser Black‐backed Gulls, Herring Gulls and Arctic Terns. Areas adjacent/surrounding breeding sites are used for foraging by these species and may require designation.

An extended boundary for Inisglora & Iniskeeragh SPA would also overlap considerably with foraging areas of seabirds nesting in Inishkea Island SPA (Shag, Common Gull, Herring Gull, Arcic Tern and Little Tern) and likewise for SPAs that are within 30 km of AMETS as outlined in the EIS.

It is Bird Watch Ireland’s view that as a result this is a key seabird area and is due to be put forward as a Marine Important Bird Area for this part of the Northwest Mayo coast.

Additionally, the area immediately off Annagh Head is considered a bottleneck site for passage (migratory) seabirds in autumn as it acts as an exit corridor for birds ‘drifted’ in to Donegal Bay by predominant north‐westerly winds. The important species using this bottleneck include Great and Sooty Shearwaters and four species of skuas.”

Response: Surveys of the AMETS study site have shown its importance for migratory seabirds, such as the large numbers of Great Shearwater recorded in 2010 and Manx Shearwater which arrive in late Spring. The study site is also important for foraging seabirds breeding both locally and possibly also at distant UK or Irish colonies. The results indicate that there are periods of increased foraging activity presumably linked to periods of higher productivity. The work of the FAME project will be a useful addition to the data being gathered at the study site. The monitoring currently underway, while constrained in scope to what is essential, is considered a rigorous approach which would also be appropriate should the study site be a marine protected area and as such a potential pre‐cursor to a Special Protection Area.

An Taisce Comment 1.

The effect that wave energy will have on Avifauna is largely hypothetical, unproven and based on a combination of comparison with other marine activities (shipping, oil, wind farms, etc.) and the perceived risks. As such, there is a limited knowledge concerning the effects of WECs on avifauna. There are many unknown possible outcomes to the effects of construction, operation and decommissioning of the wave energy test centre. The EIS states that the potential effects in the bay are perceived to be low both in the construction and the operational phases, however the EIS also states that onshore there is a possibility of disturbance to breeding waders and passerines, especially Ringed Plover which nests on shingle shores, if the construction phase is carried out during the breeding season.

Response:

Construction and operational impacts within the Bay are judged be of low impact due to their short duration and temporary nature together with their occurrence in the summer months. Ringed Plover are probably nesting at the south end of the shingle beach at Belderra during the summer months. Cable laying activity on the beach will be for a short period and will take place at the north end of the beach, approximately 400 metres from the probable nest site.

An Taisce Comment 2.

The AMETS site lies within 15km of two seabird colony SPAs, while one SPA (Inishglora & Inishkeeragh SPA) lies between the onshore cable landfall area and the WEC array sites. The Inishglora & Inishkeeragh SPA is used as a foraging area for nesting seabirds of Inishkea SPA and for other SPA within 30km of the AMETS site. BirdWatch Ireland has put this area forward as a Marine Important Bird Area as a result of its importance to seabird species. BirdWatch Ireland have also stated that the area immediately off Annagh Head is a bottleneck for migratory seabirds in autumn as it acts as an exit corridor for birds which have drifted in to Donegal Bay by predominant north‐ westerly winds.

Response: See response above in relation to BirdWatch Ireland submission.

An Taisce Comment 3.

The laying down of cabling will most likely result in habitat change or enhancement resulting from the introduction of an artificial reef. An artificial reef would benefit some species and disadvantage others. It is suggested that such a reef will provide shelter for fish and other animals and provide new surfaces for epibenthic colonisation. According to a paper by Grecian et al. (2010) “wave energy generating devices may indirectly impact marine birds by altering oceanographic processes and food availability, with implications for trophic cascades.....wave‐powered marine renewable installations offer the potential to enhance habitats. Direct positive effects may include provision of roosting sites, and indirect positive effects may include prey aggregation due to suitable substrates for sessile organisms or because they act as de facto protected areas”. As the potential benefits of such a project are unknown, an extensive monitoring programme should be put in place to monitor both the marine life communities that may be affected and the effects on the avifauna that utilize the area. The data which is collected from such monitoring should be shared with the general public and groups associated with monitoring marine mammal and bird taxa groups.

Response: Comments in relation to the bird monitoring programme are addressed above in the response to BirdWatch Ireland. In relation to sharing data, this is ideally how things should proceed. Their needs to be a discussion and exchange of information in relation to marine renewable energy developments, current research, research gaps and how to ensure that the industry develops in a way that is in fact sustainable.

An Taisce Comment 4.

In the Natura Impact Statement (NIS) submitted as part of the Appropriate Assessment screening for the proposed AMETS, the report identifies several SPAs that are within 15km of the proposed site. The NIS does not identify any of the species which inhabit the SPAs, their ecological requirements or the potential threats that the proposed AMETS site poses to these species. An Taisce submits that justification should be supplied for omitting this information and for the conclusions that were

researched. The proposed AMETS may effect populations of bird species that inhabit these SPAs therefore their inclusion in the NIS is essential.

Response: See response above in relation to BirdWatch Ireland submission.

References BirdWatch Ireland (2011) Action Plan for Marine & Sea Cliff Birds in Ireland 2011‐2020. BirdWatch Ireland’s Group Action Plans for Irish Birds. BirdWatch Ireland, Kilcoole, Co. Wicklow BirdWatch Ireland (2011) Action Plan for Shore and Lagoon Birds in Ireland 2011‐2020. BirdWatch Ireland’s Group Action Plans for Irish Birds. BirdWatch Ireland, Kilcoole, Co. Wicklow BirdLife International (2004) Birds in the European Union: a status assessment. Wageningen, The Netherlands: BirdLife International. Camphuysen, C.J. 1989. Beached bird surveys in the Netherlands 1915‐1988; Seabird mortality in the North Sea since the early days of Oil Pollution. Technical Repport Vogelbescherming 1. Werkgroep Noordzee, Amsterdam. Casement, M. 1966. Seabirds avoiding oil patches. Sea Swallow 18:79. Hatch, Scott A. and David N. Nettleship. 1998. Northern Fulmar (Fulmarus glacialis), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/361 Jackson, D., and Whitfield, P. 2011. Guidance on survey and monitoring in relation to marine renewable energy deployments in Scotland. Volume 4. Birds. Unpublished Draft Report to Scottish Natural Heritage and Marine Scotland. Lee, David S. and J. Christopher Haney. 1996. Manx Shearwater (Puffinus puffinus), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/257 Louzao, M., Arcos, J. M., Laneria, K., Beldae, E., Guallartf, J., Sánchez, A., Giménez, M., Maestre, R. and Oro, D. 2011. ["Evidence of the incidental capture of the Balearic Shearwater at sea"]. Proceedings of the 6 CONGRESS of GIAM and the International workshop on petrels and shearwaters ecology at southern Europe. 34: 165‐168. Lynas,P., Newton, S.F., Robinson, J.A. 2007 The status of birds in Ireland: an analysis of conservation concern 2008‐2013. Irish Birds, 8, No.2 Scottish Natural Heritage. 2011. Habitats Regulations Appraisal of Draft Plan for Offshore Wind Energy in Scottish Territorial Waters: Appropriate Assessment Information Review: Appendix D. Seabird Foraging and Migratory Baseline Review for the Draft OWE Plan HRA. http://www.scotland.gov.uk/Publications/2011/03/04165857/71 Wilson, B., Batty, R.S., Daunt, F. And Carter C. (2007) Collision risks between marine renewable energy devices and mammals, fish and diving birds. Report to the Scottish Executive. Scottish Association for Marine Science, Oban.

2. Marine Mammals

Three submissions relevant to the marine mammal component of the EIS were received; from the Department of Arts, Heritage and the Gaeltacht, the Marine Institute and An Taisce. We have addressed each submission independently addressing each issue sequentially.

The Irish Whale and Dolphin Group (IWDG) were contracted to carry out a baseline survey of marine mammals of the AMETS (formerly WETS) site in Co Mayo and adjacent waters. We were requested to identify species present in the area and thus may potentially be impacted by the development of the test site and to collect baseline data from which any changes in distribution and abundance may occur during the development and operation of the site. The information presented in the report on species occurrence, seasonal variability and some abundance estimates together with an extensive literature search has in our minds adequately described the species present and identified those species potentially affected. In addition extensive static acoustic monitoring should provide a robust baseline dataset with which to assess any short or long term impacts of Wave Energy Converters (WECs) on marine mammals.

1. An Taisce

An Taisce promote the precautionary principle given the lack of knowledge on the impact of WECs on marine mammals. We agree and also promote this principle. They also suggest impacts on cetaceans and basking sharks could be very serious and quote a report from Scotland which lists some potential impacts. It is likely that the number of individual devices deployed at the test site at one time will be small, usually one at each berth, of which there are two berths, thus there will be little or no cumulative effect such as that that may occur at a production site. Impacts would thus be limited spatially. At present pile‐driving is not proposed but if it was to used we would expect the draft National Parks and Wildlife Service document “Guidance to Manage the Risk to Marine Mammals from Man‐made Sound Sources in Irish Waters” to be fully implemented. These guidelines provide sufficient protection to marine mammals from pile‐driving and other acoustic sources. An Taisce express concerns over the impact of collisions with wave energy devices. The example from Faber et al. (2007) is not directly relevant as this is applied to tidal devices which have moving parts such as blades. Wave Energy Converters generally do not have moving blades etc and thus the collision risk, although there, is much less than from tidal devices. Any devices deployed at AMETS will be rigorously assessed against their potential environmental impacts prior to deployment. Finally we are lead to believe that a monitoring programme will remain in place during construction and operation and that the results from this monitoring will be available to the public.

2. Marine Institute

The Maine Institute did not raise any issues with regard to impact on the receiving environment, given the (small) scale of the operation.

3. Department of Arts, Heritage and the Gaeltacht

In relation to marine mammal species the Department of Arts, Heritage and the Gaeltacht made extensive comments and observations which are addressed chronologically below.

(1) Provides a list of potential impacts on marine mammals. These are speculative and listed in section 4, appendix 3 of the Environmental Impact Statement.

(2) The Department have listed areas in their opinion with uncertainty or gaps in knowledge with regards to the proposed WETS/AMETS site. Most of these (e.g. a, b, c, d and f) are beyond the role of marine mammal surveyors and these data will have to be provided by the developer. In e. they identify a data gap in the “specific levels of environmental noise associated with construction and decommissioning (and presumably operational) associated with such methods”. As outlined in Appendix 3, section 4.5 of the Environmental Impact Statement “The impact of wave energy devices on marine mammals is poorly understood. Without full size devices deployed at sea with which to monitor for any effects, impacts are at present speculative”.

Without additional detail being available on project design, scheduling, number and type of devices to be deployed and commissioning/decommissioning methods it is impossible to speculate on the potential impact of the AMETS development. Attenuation curves would be required to assess over what distance increased noise levels over ambient would be affected but it is likely to be in the order of tens of metres, especially when you consider this is a very high energy site with large waves and associated increased ambient noise levels. We recommend that this requirement should be included into an Environment Management Plan for the site with monitoring required following the deployment of a wave energy device. We cannot speculate on levels of environmental noise.

(4) The Department considers the “information provided concerning the marine mammal species occurring in the region and their ecology is not comprehensive and is inaccurate in places”. They cite grey seal breeding, moulting and resting sites occur throughout the site and telemetry studies show both UK and Irish seals use the site.

We have documented the high densities of grey, and to a lesser extent, common seals at the site but were not requested to carry out a breeding survey for either species. In the introduction to the section 4, appendix 3 of the Environmental Impact Statement we document all those available surveys of grey and common seals and acknowledge the importance of the site for both species. Extensive aerial surveys of breeding sites have been carried out in recent years and were referenced (Cronin et al. 2007a; 2007b). We make reference to recent published studies and also to tagging studies carried out by BIM in 1998 and 1999. A recent publication on the movements of grey seals in Ireland (Cronin et al. 2012) supports the conclusions of the Environmental Impact Statement that the site is very important for grey seals. Information on bottlenose dolphins has also been referenced and used, with fieldwork carried out during the present survey, to support the conclusion that the site is important for bottlenose dolphins and to a lesser extent other cetacean species.

It is unclear as to what information has been omitted and the level of detail required in a monitoring report. The baseline survey is still underway and continues to collect good quality information on the presence of marine mammals which was not available prior to this study.

(5) The Department suggest that information on “potential noise impacts on marine mammals arising from the development appears neither sufficiently detailed nor accurate for the wide range of marine mammal species concerned”. It was not part of our remit to collect acoustic data but on‐going ambient noise measurements are being carried out as part of this project. These data coupled with our data on species present can be used to produce a risk matrix. It would not be appropriate to speculate on acoustic impacts without good data on ambient noise (underway) and data on the sound characteristics (frequency band, intensity) generated by operational wave energy devices. The latter can only be recorded on deployed wave energy devices of which there are none deployed at present.

(6) While the Department acknowledge that “the prediction of impacts arising from the proposed development is speculative and research data is lacking to inform the likely impacts of wave energy devices on marine mammals” they require further detail on findings from similar projects elsewhere.

There is very little information outside review documents available on the impact of wave energy devices on marine mammals. The potential impacts have been well documented (see section 4.5, appendix 3 of the Environmental Impact Statement). Studies at similar test sites elsewhere are constrained by lack of information on the deployment and operation of wave energy devices, including any noise generated. Few studies have carried out such extensive baseline surveys and thus we are in a good position going forward to try and quantify any impacts if they occur.

The most advanced wave energy test site is the European Wave Energy Centre (EMEC) on Orkney, Scotland. The Scottish Government has commissioned a desk‐based review of the potential impacts of wave and tidal energy development on Scotland’s marine environment but is not yet completed. On‐site monitoring is limited to land‐based observations and does not include boat‐based or acoustic surveys (Ian Davies pers comm). Passive acoustic monitoring of cetaceans was carried out in addition to boat‐ based and aerial surveys as part of the environmental impact studies of WaveHub off southwest England. A new EU funded project called SOWFIA (Streaming of Ocean Wave Farms Impact Assessment) has been established to provide recommendations for streamlining of impact assessment processes, thereby helping to remove legal, environmental and socio‐economic barriers to the development of offshore power generation from waves. IWDG are partners in this project as sub‐contractors to UCC. One of the workpackages involves collating information on the extent and resolution of marine megafauna monitoring. This will assist in establishing standards and best practice for environmental monitoring of wave energy test and production sites going forward.

The Department state the methodologies for continued monitoring in advance of device deployments, identification of risks and monitoring of impacts post deployment are not well developed. We suggest, in section 4, appendix 3 of the Environmental Impact Statement, that continued monitoring of the site prior to deployment of wave energy devices should be carried out and that “acoustic monitoring provides high quality data and if enough devices are deployed over a good spatial scale”. The resolution and duration of monitoring is dependent on many factors but both visual and static acoustic monitoring has been on‐ going since the Environmental Impact Statement was published and will continue to the end of 2012 providing over three years of post‐deployment monitoring data.

We would recommend an Environmental Management Plan is developed drawing on the baseline data collected, to include construction of the site (deployment of berths, cable laying), pre and post wave energy device deployment and decommissioning. The development of such a plan was beyond the scope of the present baseline study.

(7) The Department refers to legal obligations to complete an Appropriate Assessment. Appropriate assessment was prepared for the Belderra Strand area. The issues raised by the Department will be addressed in an risk assessment and management plan for the species going forward. .

(8) The Department has referred to Regulation 51 of the EC Regulations 2011 and Article 12 of the Habitat Directive with reference to Articles 12 (1) a, b and d which prohibit deliberate killing, disturbance and deterioration of breeding sites. There is no evidence that any of the above will occur at present during the development of the AMETS. If during post‐deployment monitoring of a wave energy device, excessive disturbance or potential to kill (entanglement) is considered possible or likely then the wave energy device should be removed. This should be part of an Environmental Management Plan. There is also reference to the site being “situated within an area that is utilised for breeding and or parturition for bottlenose dolphins”. There is no evidence that the site is used for breeding or parturition for bottlenose dolphins. Neonates have been recorded among bottlenose dolphin groups at the site but as these are acknowledged as wide ranging breeding/parturition may have occurred elsewhere. However while adopting the precautionary principle we should assume that breeding/parturition of bottlenose dolphins does occur at the site.

In conclusion many of the comments can be addressed in an Environmental Management Plan prepared as part of a Build‐Monitor‐Mitigate philosophy while adopting the precautionary principle.

References

Cronin, M., Duck, C. and O´Cadhla, O. (2007a) Aerial surveying of grey seal breeding colonies on the Blasket Islands, Co. Kerry, the Inishkea Group, Co. Mayo and the Donegal Coast, Ireland. Journal for Nature Conservation 15, 73‐83.

Cronin, M., Duck, C., O´Cadhla, O., Nairn, R., Strong, D. and O’Keeffe, C. (2007b) An assessment of population size and distribution of harbour seals in the Republic of Ireland during the moult season in August 2003. Journal of Zoology 273, 131–139.

M. A. Cronin, H. D. Gerritsen, D. G. Reid (2012) Evidence of low spatial overlap between grey seals and a specific whitefish fishery off the west coast of Ireland Biological Conservation, Vol. 150, No. 1. (June 2012), pp. 136‐142, doi:10.1016/j.biocon.2012.02.013

Marine benthos The Marine Institute comment 1.

Re: Benthos Ecology Surveys were conducted of the seabed in the proposed lease areas and along the proposed cable route. These surveys consisted of video and diving assessments of hard substrate (reef) habitats and grab surveys of sedimentary habitats. Both surveying methods did not reveal habitats or species of any particular sensitivity. The Marine Institute agrees with the general conclusion that the majority of impact will be realised during the construction phase. This impact will result in disturbance of sediment along the cable route and direct occlusion of habitat by the use of rock armour, cable mattresses and/or grout bags. While the ability of sedimentary habitats to recover will be relatively quick, the direct occlusion of the hard substrate habitat types will result in loss of species over the affected footprint. However, the overall scale of this type of impact will be very small and the protective material will also provide substrate for subsequent epifaunal recruitment. One issue that should be clarified is the nature of the grout material to be included in the grout bags that might be used. In addition, what is the nature of the bags to be used (e.g. plastic)? It is important that any material to be used must be inert or non‐damaging to marine flora and fauna or non‐polluting (in the case of plastics). Information on the nature of this material appears to be lacking in the EIS and no reference is made in Chapter 18 on Summary of Impacts and Mitigations.

Response: Grout bags may typically consist of an outer polypropylene hessian and an inner polyethylene layer. Filling material is inert. SEAI will ensure that the requirement to bury the cables to a sufficient depth is conditioned in the cable laying contract with the cable laying contractor. Further detailed site investigation works to confirm sediment depth along the cable route to maximise cable burial will also be undertaken by the cable laying contractor, in advance of the cable laying operation. After installation, surveys will confirm the depth and further routine surveys will be undertaken to ensure the cables are not being exposed and to determine any required maintenance.

The Marine Institute comment 2.

RE: Monitoring: It is the Marine Institute’s view that as long as the construction phase (of cable laying) is quick then the impacts on the benthos will be short lived. Given this, the Marine Institute would be of the opinion that it would be necessary to monitor benthic habitat and species recovery along the cable route. Any monitoring of the cable route should focus upon the integrity of the cable to ensure it remains buried and does not present a hazard to other users.”

Response: We agree that monitoring of monitor benthic habitat and species recovery along the cable route should be conducted post installation of the Wave Energy Devices and associated cable route. Provision for the monitoring of this aspect will be made.

An Taisce Comment 1

The report admits that “effects of buried electrical cable laying on the macrobenthos is poorly understood” yet it suggests that “a recovery time in the order of one year is likely for this development” based on “some” studies. If the effects are poorly understood it is just as likely that the recovery time will take longer than a year.

Response: We disagree with the statement “….it is just as likely that the recovery time will take longer than a year”. The biotopes within the cable laying area are generally sandy in nature. Due to the dispersive nature of the high‐energy water movement, and general tolerance of the associated fauna to sediment resuspension, it is likely that the impacts of the development will lie within the natural variability of the area. While the effects of cable laying on the benthos in general may be poorly understood, the effect of disturbance in such a high energy environment, as the AMETS, can be assumed to be short lived.

The fact that effects of buried electrical cable on macrobenthos are poorly understood does not constitute a reason to assume recover would also take longer than one year by default.

Department of Arts, Heritage and the Gaeltacht comment 1. The necessary objective criteria and scientific evidence are not presented in the screening report to exclude the risk that the project, alone and in combination with other plans and projects, will have significant effects on the SAC in view of its conservation objectives. The following Annex I habitats and Annex II species are among the qualifying interests of the SAC:

. Otter (Lutra lutra) [1355] . Petalwort (Petalophyllum ralfsii) [1395] . Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] . Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130] . Atlantic decalcified fixed dunes (Calluno‐Ulicetea) [2150] . *Machairs [21A0]

Further assessment is required to address the likely significant effects on the above, most notably during site set up and construction, and taking in combination effects of other plans and projects into account. In particular, further evidence should be presented to confirm the type(s) of habitat present within the proposed site of the construction compound and access route to the beach. The location of this site, coupled with the presence of sand and certain plant species, and existing uses, are indicative of marginal or degraded machair or fixed dune.

Response: The exact boundaries of all habitats present within the construction compound and access route to the beach are clearly presented in figure 5.2 of Appendix 3 of the Environmental Impact Statement. A detailed description of each of these habitats is set out in section 2.3 of the EIS together with a detailed species list for each habitat. Surveys of the terrestrial areas of the site adjacent to the cable landfall were conducted over 3 days in July 2010 and backed up by information on the terrestrial habitats conducted as part of the scoping surveys conducted in June 2009. All surveys were conducted by two qualified and experienced botanists.

This information was used to make an informed decision on the type of habitats present both along the proposed cable route and the construction compound. As stated in appendix 3 of the EIS cables would reach land at the south‐western end of the beach where they would be trenched through the

beach (intertidal area) and through the car park area to a proposed substation on the land side of the coast road.

With due consideration to the habitats adjacent to the car park it has been decided that the cable route will be laid through the car park rather than any adjacent habitats, thereby avoiding any impact on adjacent habitats.

. Otter (Lutra lutra) [1355] Otters are widespread throughout Ireland in freshwater and coastal habitats (Lunnon and Reynolds, 1991) and while evidence of otters (i.e. spraints, footprints, digested remains, couches, etc) were not recorded during the survey, despite being looked for, it is accepted the area could provide a suitable habitat for otter.

Scottish National Heritage guidance on the avoidance of disturbance to otters states that, if otter shelters are recorded at the site “disturbance during the works should be minimised by declaring an area of at least 30 m radius from an otter shelter out‐of‐bounds to everyone at all times. Before any work starts on site, this protection zone should be fenced off to keep people out, whilst not affecting otter movements”. It is proposed that an additional otter survey within the area of the proposed cable trench and construction area is re‐surveyed prior to works commencing and should such shelters be identified that the area of the shelter be fenced off to avoid any disturbance.

. Petalwort (Petalophyllum ralfsii) [1395] Petalophyllum ralfsii was not recorded in the potentially suitable habitat adjacent to the construction area i.e. within the sand dune areas shown in figure 5.2 of Appendix 3 of the Environmental Impact Statement. While we are aware that this species can appear to be present at a site one season and absent the following season, we are of the opinion that even if Petalophyllum ralfsii were to be recorded, in the potentially suitable habitat immediately prior to construction, the habitat and hence the species would be unaffected as the potentially suitable habitat will not be impacted at any time during the construction phase. To ensure no disturbance occurs in habitats adjacent to the construction area the sand dune habitat will be fenced off prior to construction.

. Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] The dune systems present at the site are described in section 5.3 of Appendix 3 of the the Environmental Impact Statement. As stated in the Environmental Impact Statement “with the exception of the intertidal area at Belderra Strand all remaining areas of the site that will encompass the cable landfall, temporary construction area, cable joint transmission bay and substation location are outside any designated area (SAC, SPA or NHA). However, a number of habitats within the study area (dune slacks, marram dunes and machair) are listed under Annex 1 of the EU habitats Directive and their conservation status should not be negatively impacted by any aspect of the proposed development”

We concluded that the Annex I habitats adjacent to the construction area would not be impacted at any stage as mitigation to avoid these habitats has been considered and addressed in the following statement “All access to and egress from the substation should be via existing roads and the proposed new road across the field. Prior to entry to the site, all vehicle drivers should be instructed not to impinge on unfenced areas of calcareous grassland, dune slack or any other habitat for either the parking or turning of vehicles. Vehicles, machinery and construction materials should only be parked or housed in the designated area at Belderra car park and Area 9 (Figure 5.2) or within the site compound for the substation location which should be fenced in advance of any construction operations and these areas should be clearly marked”.

. Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130] See response for Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] above.

. Atlantic decalcified fixed dunes (Calluno‐Ulicetea) [2150] See response for Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] above.

. *Machairs [21A0] See response for Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] above.

Department of Arts, Heritage and the Gaeltacht comment 2 Marine Habitats:

The proposed development would predominantly occur outside of any current designated sites. However, it is proposed to bring electrical cables through the intertidal portion of Mullet/Blacksod Bay Complex cSAC (Site Code: 000470). This site is designated for amongst other things the following marine Annex I habitats Mudflats and sandflats not covered by seawater at low tide, Large shallow inlets and bays and Reefs.

The Department is of the view that the proposed development is unlikely to result in a significant long‐term impact to protected habitats at the Mullet/Blacksod Complex cSAC and, with the application of the mitigating measures described in the EIS, it is likely to reduce the potential impact to negligible levels beyond a very short‐term reduction in the number of species in a small area of the designated site.

Response: We agree, as already concluded in the EIS, that with the application of the mitigating measures described no long term impacts on the intertidal area will occur.

Appendix I: Risk Assessment for Qualifying Species

List of functional groups and associated species included in the risk assessment:

1. Geese and Swans: Barnacle, Light‐bellied Brent Goose (Whooper Swan) 2. Diving waterfowl: Great northern diver 3. Shorebirds: Ringed plover, ringed plover, sanderling, dunlin, curlew, purple sandpiper, turnstone 4. Terns: Arctic tern, sandwich, little, (common) 5. Gulls: Lesser black‐backed gull, herring gull, common gull, (greater black‐backed gull, kittiwake) 6. Petrels: Storm petrel, Leach’s petrel 7. Shearwaters: Manx, Great, Sooty, (Balearic) 8. Cormorants and Shags 9. Fulmar 10. Auks: Puffin, (Razorbill, Guillemot) 11. Skuas: great, (pomarine, arctic) 12. Gannets

1. Geese and Swans

Species included: Barnacle Goose (Branta leucopsis) Ireland: Amber; Europe: Secure Light Bellied Brent Goose (Branta Bernicla hrota) Ireland: Amber; Europe: Vulnerable Whooper Swan (Cygnus cygnus) Ireland: Amber; Europe: Secure

Ecological needs Geese and swans over winter in Ireland, taking advantage of the milder climate to feed on coastal grasslands, pastures, aquatic and marine vegetation. They require suitable habitat for both feeding and roosting and have established feeding and roosting sites and flight lines between these sites. Barnacle Geese, Light Bellied Brent Goose and Whooper Swan are largely site faithful returning to same wintering areas each year.

Current risks While numbers of the Barnacle Goose, Light Bellied Brent goose and Whooper Swan continue to increase (BWI, 2011) BirdWatch Ireland have identified a number of factors affecting shore [and lagoon] bird conservation in Ireland (see below). Specific factors of most relevance to Geese and Swans are likely to be habitat loss and degradation, coastal development and recreation and disturbance. Lack of awareness Recreation and disturbance Habitat loss, degradation and fragmentation Coastal developments Pollution and oil spills Climate Change Alien and invasive species and predation Mineral and resource use

Use of AMETS by Geese and Swans Barnacle Geese feed on Inishglora Island during the winter months. The AMETS study site is flown over by Barnacle Geese as they commute between roosting and feeding sites. Whooper Swans have been observed flying inland to Cross Lough, while established flight paths from the islands (Inishkea’s, Inishglora and Inishkeeragh) to the mainland (Termoncarragh Lake) are used by Barnacle Geese at dawn and dusk. Light Bellied Brent goose have been recorded at Annagh Beach and on the water within the inner Bay.

Potential interactions with WEDs and AMETS It is possible that flighting Geese and Swans during spring and/or Autumn migration will fly over the inshore berth area. Any within winter observations of flighting geese and swans have found that they do not fly over the proposed berth areas. Disturbance to Geese on Inishglora Island during construction and deployment at the inshore berth is a potential negative interaction. Construction activities are will be limited to the Spring and Summer months and should avoid Inishglora Island reducing any disturbance risk.

Summary risk of impact from AMETS and recommendations It is possible that swans and geese may pass over the WED’s during migration, however they tend to fly higher during migration flights and collision is considered unlikely. There is a low risk of disturbance to wintering geese on Inishglora Island due to the proximity of the inshore berth to this island and due to the Spring/Summer construction window.

It considered unlikely that AMETS will have a significant effect on this species group. Given that this is a novel development, monitoring of site use is recommended. Monitoring of wintering geese and swan populations in this region is on‐going through the I‐WeBs scheme and this data can be considered together with the study site data.

2. Diving Waterfowl

Species included: Great Northern Diver (Gavia immer) Ireland: Green; Europe: Secure

Ecological needs Great Northern Diver is a migratory species wintering in Irish coastal waters. They occur in highest numbers during the winter months, with small numbers of non breeding birds staying on through the summer months. Divers feed in waters of < 30 m depth, where they forage primarily for small fish but also crustaceans, cephalopods and molluscs. Divers dive through the water column to feed, propelling their bodies with their feet, to obtain food primarily by sight although tactile methods may also be used (Wilson et al.,2007).

Current risks Disturbance, oil spill, and broader threats such as outlined by BirdWatch Ireland and summarised below: Lack of awareness Recreation and disturbance Marine resource use Disease Alien invasive species and predation Climate change Pollution and oil spills

Use of AMETS by divers Great Northern Diver and small numbers of Red‐throated Diver are recorded in the inshore waters of the Bay. Great Northern Diver occur regularly within the Bay during winter and spring, with smaller numbers staying on into the summer months. Great Northern Diver forage within the shallow waters of the Bay.

Potential interactions with WEDs and AMETS An increase in boat activity within the Bay may cause disturbance to Great Northern Divers. Garthe and Huppop (2004) found that the related species, Black‐throated and Red‐throated Divers were sensitive to ship and helicopter traffic at marine wind farms sites. Wilson et al (2007) considered that collision risk with WEDs is likely to be higher than average for this group of birds. WEDs will not be located in the area used by Great Northern Diver, so interactions between foraging Divers and WED are not a concern. Disturbance by boat activity will be a temporary impact and will take place during the summer months. Any oil spill from associated activities and leakage from WEDs will have a negative impact on divers especially during moult.

Summary risk of impact from AMETS and recommendations Construction activities within the Bay may have a negative impact on Great Northern Diver, however as described in the Ecological Assessment, this disturbance should be of short duration and in the summer months when small numbers of divers are present. Biodegradable materials should be used and any leakage of oils or other substances should be prevented. There is a low risk of a negative interaction with the WEDs within the berth areas as the divers do not use the berth areas for feeding.

It considered unlikely that AMETS will have a significant effect on this species group. Given that this is a novel development, monitoring of site use is recommended. Monitoring of wintering Great Northern Diver populations in this region is on‐going through the I‐WeBs scheme and this data can be considered together with the study site data.

3. Shorebirds (wintering)

Species included: Ringed Plover (Charadrius hiaticula) Ireland: Amber; Europe: Secure Sanderling (Calidirs Alba) Ireland: Green; Europe: Secure Dunlin (Calidris alpina) Ireland: Amber; Europe: Declining Curlew (Numenis arquata) Ireland: Red; Europe: Declining Purple Sandpiper (Calidris maritima) Ireland: Green; Europe: Secure Turnstone (Arenaria interpres) Ireland: Green; Europe: Declining

Ecological needs Wintering shore birds arrive in Ireland during September/October and depart for their breeding grounds in March/April. During the winter months shore birds spend much of their time feeding, restoring their energy resources after migration and return migration and for breeding. Shore birds come to Ireland for the rich feeding resource held in the largely frost free coasts and wetlands. Feeding is a key part of the survival of wintering shore birds, both at their wintering grounds and as factor in breeding success at their breeding grounds. For some wintering species, which cannot habituate to disturbance, undisturbed feeding habitat is essential to their successful return migration and breeding success.

Current risks Crowe (2008) describes a decrease in the wintering population of Dunlin, Curlew, Purple Sandpiper and Turnstone, while there is a percentage increase for Ringed Plover. A number of factors affecting the shore [and lagoon] bird conservation in Ireland have been identified by BirdWatch Ireland (see Swans and Geese). Factors of particular importance to this species group are: Recreation and disturbance; Coastal developments; Habitat loss, degradation and fragmentation.

Use of AMETS by shore birds The shore habitats are used by feeding and roosting shorebirds as listed above. Belderra Strand the site of the proposed landfall is used by low numbers of shorebirds.

Potential interactions with WEDs and AMETS Wintering shorebirds will have no interactions with WEDs. There will be temporary disturbance at Belderra Strand during cable laying in the summer months.

Summary risk of impact from AMETS and recommendations It considered unlikely that AMETS will have a significant effect on this species group. Given that this is a novel development, monitoring of site use is recommended. Monitoring of wintering shorebird populations in this region is on‐going through the I‐WeBs scheme and this data can be considered together with the study site data.

4. Terns

Species included: Arctic (Sterna paradisaea) Ireland: Amber; Europe: Secure Sandwich (Sterna sandvicensis) Ireland: Amber; Europe: Declining Little (Sterna albifrons) Ireland: Amber; Europe: Declining Common (Sterna hirundo) Ireland: Amber; Europe: Secure

Ecological needs Terns are migratory moving south for the winter and returning to breed at coastal and mainland island sites during the summer. Terns are colonial nesters and feed mainly on small fish. During the breeding season terns forage extensively in inshore regions. Terns feed by plunge diving though they do not penetrate deeply into the water (Jackson & Whitfield, 2011).

Current risks Aside from Little Tern, the populations of Common, Arctic and Sandwich terns increased between 1969 and 1995 (BWI, 2011). The Little Tern population declined during this period. Pressures on breeding tern populations include: predation at nest sites, availability of food, quality of nesting habitat and survival in their wintering grounds (Mitchell et al.,2004).

Use of AMETS by Terns All tern species forage within the Bay. Arctic Tern is the only tern species recorded foraging outside of the Bay and within the study site. Terns forage within the study site between April and August, and are presumed to be part of the local breeding population. Foraging is likely to include gathering food for chick provisioning. Terns on migration have also been recorded within the study site.

Potential interactions with WEDs and AMETS As a plunge diving species terns are likely to be at higher collision risk than other seabirds (Wilson et al.,2007). However as they do not penetrate deep into the water this risk is considered to be low (Jackson & Whitfield, 2011). Availability of prey could be affected by changes to currents and wave action resulting from wave energy devices (Jackson & Whitfield, 2011). Terns foraging in the Bay may be temporarily disturbed from parts of the bay during cable laying activities. However, Garthe and Huppop (2004) found that Common Terns did not react strongly to disturbance by ships and helicopters. Other species of tern may be more sensitive, such as Little Tern. Some disturbance to terns nesting on Inishglora Island caused by deployment and operational activities at berth B is possible although considered unlikely given that berth B is 800 m from the western tip of the island.

Summary risk of impact from AMETS and recommendations Significant effects on the locally breeding terns species are not considered likely, owing to the relatively small area occupied by the berths and the lack of any obvious attraction to the berth areas. While the risk of collision is considered to be low any mortality due to collision could have a significant effect on the local breeding population. Monitoring interactions between foraging terns and WEDs is essential to examine collision risk.

5. Gulls

Species included: Common Gull (Larus Canus) Ireland: Amber; Europe: Depleted Herring Gull (Larus argentatus) Ireland: Red; Europe: Secure Great Black‐backed Gull (Larus marinus) Ireland: Amber; Europe: Secure Lesser Black‐backed Gull (Larus fuscus) Ireland: Amber; Europe: Secure Kittiwake (Rissa tridactyla) Ireland: Amber; Europe: Secure

Ecological needs The Kittiwake is the smallest and most oceanic of the above gull species nesting Ireland. Breeding in coastal colonies, Kittiwake feed mainly on small pelagic fish, invertebrates and discards from fishing boats. Outside of the breeding season Kittiwake are largely oceanic and range further offshore. Common, Herring, Great and Lesser Black‐backed gulls can breed at both inland and coastal sites, though winter foraging is mainly at coastal sites or further offshore. Like Kittiwake, Common, Herring, Great and Lesser Black‐backed gulls Gulls will feed on invertebrates, fish and fishing boat discards. Herring Gull and Great Black‐backed Gulls will also scavenge for food, predate off other birds and practice food piracy. Gulls feed mainly from the sea surface and are relatively tolerant of human disturbance. (BWI, 2011, Jackson & Whitfield, 2011, Mitchell et al.,2004)

Current risks BirdWatch Species Action for marine and sea cliff nesting species show an increase in the breeding population of Kittiwake, Common Gull and Lesser Black‐backed Gulls, though contractions in breeding range are also reported (BWI, 2011). The breeding populations of Great Black‐backed and Herring Gull have declined. BirdWatch Ireland list a number of factors affecting marine and sea cliff nesting species these are listed below:

Lack of awareness Recreation and disturbance Marine resource use Disease Alien invasive species and predation Climate change Pollution and oil spills

Factors of particular note in terms of breeding gulls are predation at nest sites, reduced food availability linked to changes in waste disposal and fisheries practice, habitat changes and botulism (Mitchell et al.,2004).

Use of AMETS by Gulls Gulls are present year round throughout the study site. Kittiwake, Great Black‐backed gull, Lesser black backed Gull and Herring Gull are recorded both inshore and offshore, while Common Gull and mainly recorded inshore. See EIA: Appendix 3.

Potential interactions with WEDs and AMETS Given that gulls are mainly surface feeders, SNH (2011) consider that they are unlikely to be exposed to collision risk from marine turbines. Wilson et al (2004) also consider this species group to be at lower risk of collision than other groups. Gulls make ready use of man made structures and SNH consider that WED’s protruding above the surface are likely to be used by perching gulls.

Summary risk of impact from AMETS and recommendations Gulls are considered to be at low risk of negative interaction from operational WED’s. Possible negative interactions such as collision, displacement and disturbance are unlikely to have an impact on this species group.

6. Storm Petrels

Species included: European Storm Petrel (Hydrobates pelagicus) Ireland: Amber; Europe: Secure Leach’s Storm Petrel (Oceanodroma leucorhoa) Ireland: Amber; Europe: Localised

Ecological needs Storm Petrels are a small pelagic seabird which only returns to land to breed on remote coastal island. Storm Petrels nest in burrows which they leave and enter only under cover of darkness. Storm Petrels are visual feeders and mainly peck food from the water surface feeding on small fish and zooplankton (Mitchell et al.,2004). While know to feed during the day, as for most seabird species, the extent of night time foraging is not known (Wilson et al.,2007). During the breeding season Storm Petrels are known to feed in deep water areas however recent evidence suggests they move inshore to feed at night (Mitchell et al.,2004).

Current risks Mammalian predators and availability of suitable habitat have been identified as factors affecting Storm Petrel breeding success (Mitchell, 2004). Other general factors identified by BirdWatch Ireland will also be relevant.

Use of AMETS by Storm Petrels European Storm Petrels nest on Inishglora Island and forage within the deeper waters of the study site. They are present between June and August and are recorded throughout the study site except within the Bay. Their distribution appears to be linked to waters beyond the 50 m isobaths.

Potential interactions with WEDs and AMETS WEDs are unlikely to present a collision risk to Storm Petrels due to their feeding behaviour. However, any risk of collision risk is likely to be higher where there are young birds are involved and at night time or in conditions of poor light. Given that Storm Petrels due not plunge dive or dive underwater this risk remains low. Storm Petrels may be displaced from foraging within the berth areas however alternative foraging habitat is available. Night time illumination of the vessels and berths may affect the nocturnal behaviour of Storm Petrels (Jackson & Whitfield, 2011). However the night time lighting will be the same as for navigational bouys. Inishglora Island lies 800 m from the berth B. There is a risk of collision due to birds moving between foraging areas and nesting sites on the island, especially under darkness or poor light.

Summary risk of impact from AMETS and recommendations There is a low risk of collision involving commuting birds, with a higher risk during poor light and/or when young birds are involved. Overall significant effects on the breeding population are considered unlikely, however adequate monitoring is essential.

7. Shearwaters

Species included: Manx shearwater (Puffinus puffinus) Ireland: Amber; Europe: Secure Great shearwater (Puffinus gravis) Ireland: Amber; Europe: Secure Sooty shearwater (Puffinus griseus) Ireland: Amber; Europe: Secure Cory’s shearwater (Calonectris diomedea) Ireland: Amber; Europe: Secure Balearic shearwater (Puffinus mauretanicus) Ireland: Red; Europe: Red

Ecological needs Shearwaters are part of the tubenose group of seabirds and use both scent and sight to help locate prey items. Shearwaters forage primarily on schooling fish and small pelagic crustaceans and molluscs, usually plucking prey from the water’s surface, though will also occasionally pursue prey underwater by swimming or via shallow plunge dives from 1‐2m altitude. Shearwaters generally fly within close proximity of the water as they make use of surface air currents for momentum. Foraging and flight frequently occur at night, which may make shearwaters more susceptible for collision events, particularly if there are bright white lights in operation (Jackson & Whitfield, 2011).

Shearwaters are highly pelagic birds and are mostly found in offshore environments. Of the shearwaters found in Irish waters, Manx shearwaters are the only confirmed shearwater species breeding in Ireland. Manx shearwaters nest in burrows, as part of large colonies and usually on islands less accessible to mammalian predators. Manx shearwaters visit colonies only on dark, moonless nights as their inability to walk on land makes them particularly susceptible to predation.

Shearwaters feed chicks on concentrated stomach oil derived from semi‐digested prey and forage over wide ranges from the colony (~400km). Specific foraging ranges from Irish colonies are not currently known.

As with other seabirds, shearwaters are long‐lived (30+ years) and their populations are particularly sensitive to adult mortality, though will also decline if recruitment is consistently poor.

Current risks Shearwaters generally have medium‐low susceptibility to oiling events, possibly being able to avoid oil through olfactory detection (Casement, 1966) but still occurring in oiled bird censuses (Camphuysen, 1989). They are incidentally taken in fishing gear and although rates are not well‐ characterised there is evidence of mass‐mortality in purse‐seining as well as mortality from long‐line fisheries (e.g. Balearic shearwaters ‐ Louzao et al. 2011). Balearic shearwaters are currently listed as critically‐endangered by the IUCN due to both fisheries‐related mortality (Louzao et al., 2011) and high predation due to mammalian predators at colonies. The more commonly‐occurring species of shearwater using the AMETS area are also subject to similar risks but their larger populations are currently stable.

Use of AMETS by shearwaters Manx Shearwater are the most commonly recorded shearwater in the study site. Manx Shearwater mainly occur between April and August. Large foraging rafts of Manx Shearwater have been recorded in Spring and these may be late arriving non breeding birds. Large numbers of foraging Great Shearwater have been recorded in the study site during Autumn passage, only small numbers of the other species have been recorded.

Potential interactions with WEDs and AMETS The nocturnal habits and low flight altitude of shearwaters result in a higher than average potential to collide with WEDs or service vessels, particularly if bright lights are employed during night time servicing or construction work. The potential for underwater entanglement is minimal given the shallow depths of shearwater dives. Shearwaters will also be low to moderately vulnerable to accidental fuel spills associated with AMETS activities.

Summary risk of impact from AMETS and recommendations Given the small footprint of the berth areas, the overall risk of harm to shearwaters is likely to be low. However, it is recommended that a comprehensive spill prevention and response plan be implemented and the use of bright lights and night time servicing be avoided. Although the footprint of AMETS creates a very small likelihood of collision risk, collisions are still possible, particularly for low‐flying nocturnal species like petrels. Monitoring is recommended to estimate collision events post‐installation.

8. Cormorant and Shag

Species included:

Cormorant (Phalacrocorax carbo) Ireland: Amber; Europe: Secure Shag (Phalacrocorax aristotelis) Ireland: Amber; Europe: Secure

Ecological needs The Cormorant is found in coastal waters, estuaries or freshwater lakes and reservoirs (Lloyd et al.,1991). The Shag is mainly found in coastal waters. Both species mainly forage inshore within a few km’s of the coast, where they surface dive, using foot propulsion and forage underwater for small fish. They are daytime feeders, using vision and tactile methods to search for prey. Shag and Cormorant dive from the surface to moderate depths of typically <30m (Jackson & Whitfield, 2011) to feed mostly on or close to the sea bottom. Colonial breeders, Shags nest on cliffs or offshore Islands, while Cormorant nest at both coastal and inland breeding sites. Man‐made objects are often used as perches by Shag and Cormorant.

Current risks The breeding populations of Cormorant and Shag have increased (BWI, 2011). However local declines have taken place. Factors leading to these declines include persecution, food availability and mortality due to oiling is a threat (Mitchell et al,2004).

Use of AMETS by Cormorant and Shag Cormorant and Shag forage and pass through the study site, though as expected their distribution is linked to the mainland and islands and they are found mainly within the Bay. Shag were not recorded during at sea surveys for the EIA, but were recorded in at sea surveys during the first year of monitoring. Further years of data will shed further light on their use of the study site.

Potential interactions with WEDs and AMETS Collision risk is considered to be higher than average for this group (Wilson et al.,2007). This risk is likely to be highest where WEDS are located within depths used by foraging Shag and Cormorant. The berths at the AMETs are both at depths of greater than 30m and collision during foraging is therefore unlikely. There is a risk of collision between WEDs and flighting Cormorant and Shag, especially given that they fly close to the water, this risk is likely to be greater during poor visibility. Any disturbance effects due to cable laying within the Bay will be of short duration and temporary.

Summary risk of impact from AMETS and recommendations It is unlikely that the WEDs and associated activities will have a significant effect of Shag and Cormorant.

9. Fulmar

Species included: Fulmar (Fulmarus glacialis) Ireland: Green; Europe: Secure

Ecological needs Fulmar are part of the tubenose family of seabirds and use both scent and sight to help locate prey items. Scent is particularly important for night‐time foraging. Fulmars forage primarily on pelagic prey including zooplankton, squid and schooling fish, though will also readily take fisheries discards and carrion. Prey are obtained primarily through surface feeding and occasionally through shallow plunge‐dives (<3m depth). As fulmars nest on the ground, they are vulnerable to land‐based predators and usually nest on offshore islands and inaccessible cliff faces. Fulmars feed chicks on concentrated stomach oil derived from semi‐digested prey. This allows fulmar to range more widely from their colonies while provisioning, covering ranges up to 664km, though this varies both with colony and seasonal oceanic conditions. Neither average nor maximum foraging ranges are known for breeding colonies local to AMETS. As with other seabirds, fulmars are long‐lived (30+ years) and their populations are particularly sensitive to adult mortality, though will also decline if recruitment is consistently poor. Fulmars generally fly within 4‐5 m of the water’s surface.

Current risks Fulmars do not appear to be as vulnerable to oiling as other species, possibly being able to use olfactory cues to avoid settling in oiled areas (Lorenstsen and Anker‐Nilssen, 1993). Likewise, fulmars do not seem to be as vulnerable to fishing mortality or anthropogenic disturbance at breeding colonies as other seabirds (Hatch et al.,1998). Their relative resiliency has resulted in populations that are stable or increasing in most areas.

Use of AMETS by fulmars Fulmar occur throughout the study site, with highest numbers recorded between January and August.

Potential interactions with WEDs and AMETS Being primarily diurnal in habit, fulmars are considered to have a low risk of collision with WEDs, though collision risk will increase in the event of reduced visibility (e.g. fog). The feeding habits of fulmars put them at minimal risk of underwater collision or entanglement with WED equipment.

Summary risk of impact from AMETS and recommendations Overall the risk of AMETS having a negative impact on fulmars is low due to the low risk of collision and low impact potential of oiling. Collision risk will likely increase in instances of reduced visibility. It is recommended a spill prevention and response plan be implemented to reduce risk of oiling events.

10. Auks

Species included: Razorbill (Alca torda) Ireland: Amber; Europe: Secure Common guillemot (Uria aalge) Ireland: Amber; Europe: Secure Puffin (Fratercula arctica), Ireland: Amber; Europe: Depleted

Ecological needs Auks are pursuit‐diving seabirds that feed primarily on small fish and crustaceans captured in the offshore environment. Birds will swim underwater in pursuit of prey, commonly descending to <60m deep and traveling through the water at speeds up to 1‐2m/s. While all species of auk tend to remain offshore during the wintertime, they must return to land to breed. As auks nest on the ground and in burrows, they are vulnerable to land‐based predators and usually nest on offshore islands or rugged cliff faces. Birds will flush from colonies if overly disturbed by humans, which can result in loss of eggs and chicks. Auks feed chicks on whole fish delivered to the chick at the colony. They thus require isolated breeding locations within commuting distance of adequate populations of small schooling fish. As auks are long lived, populations are very sensitive to adult mortality, but can also become depleted if recruitment is consistently poor. The adaptation of auk wings for underwater travel has resulted in high wing‐loaded and relatively poor maneuverability in the air. Auks frequently travel at high speeds within 10 m of the water’s surface, particularly when commuting from colonies to foraging areas.

Current risks The main current risks to auks in Ireland include depleted productivity due to introduced predators (e.g. rats), entanglement in fishing nets, and vulnerability to oiling. Auks spend a large amount of time in and on the water, which increases their likelihood of coming into contact with errant oil and other fluids spilled on the water’s surface. Oil‐related mortality results from the ingestion of oil while cleaning oiled feathers as well as from hypothermia due to compromised feather waterproofing. Entanglement and oiling frequently involve adult birds and can thus have significant impacts on breeding populations.

Use of AMETS by auks Auks were present in highest numbers during the Spring and summer months, and were present throughout the study site, both offshore and within the Bay.

Potential interactions with WEDs and AMETS Auks likely have a low‐moderate risk of aerial collision with WEDS. Although they amount of time auks spend underwater makes them more vulnerable to entanglement in WED cables or moving parts, the agility of auks underwater makes this unlikely. Auks are however more vulnerable to striking WEDs while in flight due to their relatively limited aerial agility and tendency to fly at high speeds and low altitudes. The fact that auks are used to avoiding waves during flight may make them effective at avoiding WEDs as well but overall the risk of collision is not well characterised. Auks are not commonly recorded as daytime bird strikes but there are documented cases of guillemots occasionally striking highly lit ships at night. These latter strikes are most‐likely caused by excess lighting but do indicate that strikes are possible.

Auks have a greater vulnerability to oiling (Camphuysen, 1989) than other species and although the likelihood of accidental exposure to oil or hydraulic fluid from AMETS activities is low, their vulnerability makes it particularly important that activities at AMETS follow rigorous fluid management protocols and that an effective spill response plan is in place.

The exclusion of fishing from the AMETs area may result in reduced adult mortality due to reduced incidence of entanglement in fishing nets.

Summary risk of impact from AMETS and recommendations The risk of a negative impact from AMETS activities is higher for auks than for most other species, primarily due to the low altitude of auk flight and their vulnerability to accidental spills. However, the risk is still estimated as low given the small footprint of the AMETS area. To ensure minimal impact, it is recommended that focal monitoring of WEDs be conducted following their installation to estimate the frequency of auk impacts.

11. Skuas

Species included: Great skua (Stercorarius skua) Ireland: Amber; Europe: Secure Arctic skua (Stercorarius parasiticus) Ireland: n/a; Europe: n/a Pomarine skua (Stercorarius pomarinus), Ireland: n/a; Europe: n/a Long‐tailed skua (Stercorarius longicaudus) Ireland: n/a; Europe: Secure

Ecological needs Skuas are primarily passage migrants in Ireland, visible between April and October en route to and from their main breeding colonies (Great skua –Scotland, Arctic skua – Iceland/Scandinavia, Pomarine skua – Russia). Only Great skuas nest in Ireland and of these there are only few nesting pairs, all on the West coast. Skuas nest in loose colonies or as lone pairs, frequently associated with nesting colonies of other birds from which they may take chicks and eggs. Great skuas are currently Amber listed in Ireland due to their limited breeding numbers. Pomarine and Arctic skuas are considered as rare and common visitors, respectively. The majority of skuas likely use Irish waters only for temporary feeding during migration. Skuas will plunge feed but generally remain within 1m of the water’s surface. They will also take prey from the surface while swimming. Skuas of all types associate readily with fishing vessels to feed on discards. As they are opportunistic feeders, they generally travel at medium altitudes over marine waters and are agile flyers.

Current risks There is only one known nesting site for Great Skua in Ireland. Factors affecting the Scottish Great Skua population are persecution and changes in food availability (Mitchell et al.,2004)

Use of AMETS by skuas Low numbers of Skua’s are found within the study site. Great Skua are the most commonly recorded species and these have been recorded during the Autumn.

Potential interactions with WEDs and AMETS The SNH identifies skuas as low risk for potential negative interactions with WEDs. Neither their foraging nor flying habits put them at risk for collision or entanglement and their general attraction to boats suggests that they will not be disturbed by installation and maintenance activities in the AMETS area. Given the brief presence of skuas in the AMETS area the exposure window for disturbance is also very short.

In this instance, the most probable negative impact of WEDs on skuas would be through altered prey availability. The low numbers of skua observed during surveys of the AMETS area suggest that the area is not a foraging hotspot for skuas but the limited duration of the surveys does not allow for definite conclusions in this regard. On going monitoring of skua activity in the AMETS area is suggested.

Summary risk of impact from AMETS and recommendations Based on the ecology of skuas and their temporary, low density presence in the AMETS area, it is unlikely that activities associated with AMETS pose a negative risk to skua populations of any species. Ongoing monitoring of the area for skua activity and interactions with WEDs once installed is recommended.

12. Gannet (Morus bassanus)

Species included: Gannet (Morus bassanus) Ireland: Amber; Europe: Secure

Ecological Needs The gannet is a large‐bodied, long‐lived seabird that nests on isolated islands and cliffs. As with most seabirds, populations are most sensitive to adult mortality and productivity fluctuates dramatically between years. Gannets require isolated nesting islands or cliffs to prevent disturbance from ground‐based predators and humans, within commuting distance of an adequate prey base for provisioning chicks. While gannets are known to forage up to 600 km from their breeding colonies (SNH 2011), this is a maximum range and average foraging ranges are not currently known for most Irish colonies. Average foraging ranges recorded at other European gannet colonies are usually in the area of 100‐155km (Grémillet et al., 2006, Hamer et al., 2009) and foraging ranges usually increase with colony size. Following the breeding season, gannets range widely in pursuit of prey, primarily into offshore areas. Gannets are plunge‐diving seabirds, meaning that they dive rapidly from heights of around 10‐30m, entering the water at high speeds and sometimes descending to depths of 10m‐20m in pursuit of prey. Because they search for prey from above, gannets tend to fly between 10‐30m altitude.

Current risks The main current threats to gannets in Ireland include nest predation and disturbance, potential for oiling, and potential entanglement in fishing nets. The gannet population is currently increasing in Ireland.

Use of AMETS by gannets Gannets were the most common bird observed within the AMETs area during the EIA surveys, though this was driven primarily by the presence of large feeding flocks in October of 2010 (see EIA document). These feeding flocks suggested high prey availability in the AMETS area during that time and it is likely that the gannets observed included young of year and adults from mixed colonies. The presence of gannets within the AMETS area was generally much lower but consistent throughout the remainder of the year (~3‐5 birds/km2).

Potential interactions with WEDs and AMETS The SNH Guidance (Jackson and Whitfield, 2011) ranks gannets as ‘low risk’ for negative interactions with WEDS. There is a risk of birds striking or entangling in underwater cables during foraging dives, but the small footprint of the cables makes the probability of such strikes unlikely, particularly given the gannet’s good eyesight. Above‐water collision risk is ranked as very low as gannets have keen eyesight and good maneuverability and generally fly at heights far above the maximum height of WEDs.

There is the risk that gannets will avoid WEDs and thus be displaced from potential feeding grounds. The impacts of such a displacement would likely be lower for gannets as they are able to range widely in search of food, unlike less mobile species like auks, though the exact impacts would depend on the importance of the AMETS area as a feeding site. The importance of AMETs as a feeding site for gannets is currently not well described.

Gannets generally show habituation to human activities at sea and readily feed of fisheries discards. As such they are unlikely to be disturbed by boat traffic associated with installation and maintenance of WEDs in the AMETS.

Gannets have a medium vulnerability to oiling events in general (Camphuysen, 1989) and are thus at medium risk of oiling in the event of a spill event in the AMETS area. The risk of accidental release of oil or hydraulic fluid into the marine environment is highest during the installation and servicing of WEDs but can be managed through proper maintenance of WEDs and the active use of a comprehensive spill prevention and response plan.

Reviews to date have suggested that WEDs may act as de facto MPAs due to the exclusion of fishing vessels and the introduction of novel shelter for potential prey in the form of WEDs (Grecian et al. 2009). It is possible that the AMETs area could have a positive effect on prey availability for gannets and thus attract rather than displace gannets, which could also in turn increase the likelihood of collision.

Summary risk of impact from AMETS and recommendations Based on gannet habits and ecology and the nature of WEDs, AMETS poses a low risk of a negative impact on gannets in Ireland. The main risk is potential displacement from the AMETs area. The footprint of the AMETS WED areas is very small within the ocean and the tendency of gannets to habituate to human presence at sea indicates that they are unlikely to be disturbed by installation and maintenance activities. However it is recommended that hydraulic fluids and oils be rigorously managed and that a spill prevention and response plan be put in place. Interactions between gannets and WEDs should also be monitored in the AMETS region.

Appendix 2: Revised Screening for Appropriate Assessment.

1. Description of the plan or project The proposed project is detailed in the Environmental Impact Statement. In summary the AMETS encompasses two berths, within which Wave Energy Devices (WEDs) will be deployed, and a submarine cable route. There is an offshore berth located at 100m depth, 15km from shore, and a near‐shore berth located at 50m depth and four km from shore. Each berth will have an array of up to 10 Wave Energy Devices (WEDs.) Underwater cabling will run from the berths to the shore at Belderra Strand on the Mullet Peninsula. A substation will be located inland from Belderra Strand.

2. Relevant Natura 2000 sites. Seven Special Protection areas lie within 30 km of the AMETS. Tables 1a and 1b lists each of these SPAs and the species of conservation interest (“qualifying” species) which they support. Only qualifying species relevant to the AMETS are listed.

The conservation objective for the SPAs in tables 1 a and 1 b is:  To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests.

Table 1a: Qualifying wintering species for coastal SPA’s lying within 20 km of the study site and which have used the study site. “*” indicates Annex I species. Wintering Special Protection Area Barnacle Geese* Inighlora Inishkeeragh Termoncarragh and Annagh Lake Machair Blacksod Broadhaven Bay Inishkea Islands Duvillaun Islands Light Bellied Brent Goose Blacksod Broadhaven Bay Great Northern Diver* Blacksod Broadhaven Bay Ringed Plover Blacksod Broadhaven Bay Inishkea Islands Sanderling Blacksod Broadhaven Bay Inishkea Islands Dunlin Blacksod Broadhaven Bay Curlew Blacksod Broadhaven Bay Purple Sandpiper Inishkea Islands Turnstone Inishkea Islands

Table 1b: Qualifying breeding species for coastal SPA’s lying within 20 km of the study site and which have used the study site. “*” Indicates Annex I species. Breeding SPA Storm Petrel* Inishglora and Inishkeeragh Duvillaun Islands Ilanmaster Stags of Broadhaven Leach’s Petrel* Stags of Broadhaven Arctic Tern* Inishglora and Inishkeeragh Inishkea Islands Sandwich Tern* Blacksod/Broadhaven Bay Little Tern* Inishkea Islands Cormorant Inishglora and Inishkeeragh Shag Inishglora and Inishkeeragh Inishkea Islands Lesser Black backed Gull Inishglora and Inishkeeragh Inishkea Islands Herring Gull Inishglora and Inishkeeragh Inishkea Islands Common Gull Inishkea Islands Puffin Illanmaster Stags of Broadhaven Fulmar Duvillaun Islands

3. Assessment of likely effects and significant of effects

The following assessment was completed for the EIA and has been revised in light of the Risk Assessment now completed.

Potential Impacts – To shore and open water SIGNIFICANCE OF IMPACT habitats of the Bay

CONSTRUCTION PHASE

Changes and disturbance to shore habitats Low and birds at Belderra Strand due to landfall activities on the shore.

Disturbance to wintering birds and breeding Low– if intertidal activities are limited to Ringed Plover at Belderra Beach due to noise two days in the summer months and from landfall and substation activities, consideration is given to breeding Ringed including increased road traffic and human Plover. activity. Low – if increased traffic and human activity associated with the substation construction does not extend onto the shore and dune habitats at Belderra

Strand.

Changes to subtidal habitats within the Bay Low – sediment disturbance will be due to cabling potentially disturbing the temporary. benthos with indirect effects on feeding birds.

Changes to subtidal habitat within the Bay Low – if activities take place in the summer where rock armouring is used with direct months and depending on benthic changes impacts on the benthos and potential indirect predicted due to presence of rock armour. effects on the feeding resource. Any change is likely to be localised.

Disturbance to birds due to activity of cable Low – due to short period of disturbing laying boat within the Bay. activity and if activity in the Bay is limited to the summer months. OPERATIONAL PHASE

Changes to the feeding resource due to any Low – if changes to the benthos are long term effects of cabling and the presence mimimised and are limited to the cabling of rock armour on the benthos and due to any and rock armour areas, avoiding Long changes in sediment patterns resulting from tailed duck feeding areas. the wave energy arrays. High – if there are wider changes to sediment patterns due to the wave energy arrays with potential indirect effects on the local feeding resource.

Potential Impacts – To open sea area SIGNIFICANCE OF IMPACT

CONSTRUCTION PHASE

Disturbance to birds due to cable laying and Low – for cable laying activities due to short WEC deployment. duration Unknown – for deployment activities due to lack of information on this potential impact.

OPERATIONAL PHASE

Noise disturbance due to operational WECs Unknown

Displacement and / or redirection of birds Unknown. due to wave energy arrays.

Disorientation due to night lighting Low – if lighting arrangement limited to one per berth and use of normal navigational lights

Collision with underwater cables between Low – at a population level, though this anchors and WECs. Above water collision interaction has not been studied and base

with WECs. line data on the study site is limited. Low – if locally breeding species are impacted. However monitoring is required to assess this risk.

Changes to sediment process resulting from Unknown wave energy arrays and indirectly affecting food web interactions and the feeding resource.

Impacts on water quality due to oil spillage, Low – if only appropriate materials used use of anti foulants and non use of anti and all steps taken to avoid spillages. foulants.

Creation of artificial reef, roosting habitat, de Unknown – potentially positive. facto marine protected area, fish aggregation area.

4. Screening Statement Conclusion The AMETS is not likely to have a significant effect on the species of conservation interest within the SPAs identified in this Appropriate Assessment. This conclusion is based on the information contained in the Ecological Assessment for the EIA, and the Risk Assessment completed as part of this Response. Given that the significance of some impacts are unknown and given the limited data with which to assess other impacts, monitoring is recommended.