Dublin Array Offshore Wind Farm

Environmental Impact Assessment Scoping Report

Date: September 2020 Revision: 1 Revision Prepared Checked Approved

0.1 (Internal) SLR/GoBe/RWE AJM/MB (SLR) PK (RWE)

GM/HM (RWE)

0.2 (Internal) SLR/GoBe/RWE AJM/MB (SLR) PK (RWE)

GM/HM (RWE)

0.3 (Internal) SLR/GoBe/RWE AJM/MB (SLR) PK (RWE)

GM/HM (RWE)

1 (External) SLR/GoBe/RWE AJM/MB (SLR) PK (RWE)

GM/HM (RWE) Contents

1 Introduction...... 1 1.2 Document Structure ...... 1 1.3 Project Background...... 2 1.4 Current Project Status ...... 4 2 Project Description ...... 5 2.1 Introduction...... 5 2.2 Design Envelope ...... 5 2.3 Offshore Infrastructure...... 6 2.4 Onshore Infrastructure...... 21 3 Environmental Impact Assessment Methodology...... 32 3.1 Overview...... 32 3.2 Guidance...... 34 3.3 EIA Screening ...... 35 3.4 EIA Scoping ...... 35 3.5 Consideration of Alternatives...... 35 3.6 Receiving Environment...... 36 3.7 Impact Assessment Process...... 36 3.8 Approach to Assessment of Project Design...... 41 3.9 Approach to Interactions of Environmental Factors...... 41 3.10 Approach to Cumulative Assessment ...... 42 3.11 Approach to Transboundary Assessment...... 43 3.12 Mitigation Measures and Monitoring...... 43 3.13 Residual effects...... 44 3.14 Appropriate Assessment...... 45 4 EIAR Structure...... 48 4.1 Introduction...... 48 5 Specialist Topics Offshore...... 54 5.1 Introduction...... 54 5.2 Physical Processes and Marine Water and Sediment Quality ...... 54 5.3 Underwater Noise...... 64 5.4 Benthic and Intertidal Ecology...... 65 5.5 Fish and Shellfish Ecology ...... 73 5.6 Offshore Ornithology...... 81 5.7 Marine Mammals ...... 89 5.8 Seascape, Landscape and Visual Amenity ...... 96 5.9 Shipping and Navigation...... 104 5.10 Aviation...... 113 5.11 Commercial Fisheries...... 118 5.12 Infrastructure and Other Uses...... 127 5.13 Marine Archaeology ...... 137 6 Onshore Specialist Topics ...... 144 6.1 Introduction...... 144 6.2 Biodiversity ...... 144 6.3 Land, Soils and Geology ...... 152 6.4 Water (Hydrology, Hydrogeology and Flood Risk)...... 159 6.5 Air Quality and Climate Change...... 164 6.6 Noise and Vibration ...... 168 6.7 Traffic and Transport ...... 172 6.8 Cultural Heritage (Archaeology and Monuments)...... 177 6.9 Landscape and Visual...... 184 6.10 Socio-economic, tourism, recreation and land use ...... 189 6.11 Other Issues...... 196 References Appendices

Appendix 1...... 199

Figures

Figure 1 - Proposed Dublin Array Site Boundary and Export Cable Search Area...... 3 Figure 2 - A typical wind turbine generator...... 7 Figure 3 - Sequential photographs of installation of turbine tower, nacelle and blades ...... 8 Figure 4 - Foundation Options...... 9 Figure 5 - Offshore substation at Gwynt y Mor Wind Farm in Wales...... 13 Figure 6 - Typical single armoured submarine cable – Source GGOWL (2009) ...... 16 Figure 7 - Onshore Grid Connection Points and Indicative Landfall Locations...... 22 Figure 8 - Overview of the onshore grid connection infrastructure...... 23 Figure 9 - TJB Construction...... 24 Figure 10 - TJB contruction site – RWE Renewables Gwynt y Mor Offshore Wind Farm in Wales ...... 25 Figure 11 - Typical HV Trench Excavation (Ducts laid in trefoil formation) – ESBI HV Cables – General Construction Methodology 2012...... 26 Figure 12 - Typical Joint bay under construction alongside a public road (HV Cables General Construction Methodology, ESBI 2012)...... 27 Figure 13 - Typical Substation Layout (RWE Renewables Galloper Offshore Wind Farm in UK)...... 30 Figure 14 The EIA Process and the position of the EIAR (EPA 2017) ...... 33 Figure 15 - Geographical overview of the bathymetry...... 58 Figure 16 - Geographical overview of the seabed sediment types...... 59 Figure 17 - Geographical Overview of Natura 2000 sites of relevance to benthic and intertidal ecology ...... 69 Figure 18 - Geographical overview of fish nursery grounds...... 75 Figure 19 – Geographical overview of fish spawning grounds ...... 76 Figure 20 – Geographical overview of fish spawning and nursing grounds (Marine Institute)...... 77 Figure 21 – Geographical overview of local Natura 2000 sites with ornithological features ...... 84 Figure 22 - Geographical overview of Rockabill and Dalkey Island SAC ...... 92 Figure 23 – Geographical overview of the SLVIA study area and proposed viewpoints for assessment ...... 100 Figure 24 - 14 Days Winter 2019 by Vessel Type, excluding Temporary Traffic...... 107 Figure 25 – Proposed extent of the projects to be considered in the NRA ...... 110 Figure 26 - Aviation receptors in the vicinity of Dublin Array...... 115 Figure 27 Geographical overview of ICES rectangles...... 120 Figure 28 Proportion of landings by vessel nationality (2012-2016, EU DCF, 2019) ...... 121 Figure 29 Average annual landings (tonnes) from 35E4 and 35E3 by country and species (based on data from 2012-2016, EU ECF, 2019) ...... 121 Figure 30 Distribution of whelk fisheries around Ireland ...... 123 Figure 31 Geographical overview of marine infrastructure and disposal sites ...... 131 Figure 32 Geographical overview of offshore wind farm developments ...... 132 Figure 33 – Identified ship wrecks within the proposed development ...... 140 Figure 34 - Key biodiversity receptors within the biodiversity study area ...... 149 Figure 35 - Superficial geology surrounding the study area ...... 155 Figure 36 - Bedrock geology surrounding the study area...... 156 Figure 37 - Key features within the water study area ...... 162 Figure 38 - Key traffic and transport features ...... 174 Figure 39 - Key features surrounding the cultural heritage inner study area ...... 181 Tables

Table 1 - Indicative Wind Turbine Numbers and Dimensions ...... 8 Table 2 - Maximum Dimensions of Piled Foundation Options ...... 11 Table 3 - Maximum Dimensions of Suction Bucket Foundation Options ...... 11 Table 4 – Typical mooring system parameters for buoys supporting meteorological sensing equipment ...... 15 Table 5 – Submarine cable parameters ...... 15 Table 6 - Proposed matrix for determining the significance of effect...... 40 Table 7 - Volume and Document Structure of the EIAR ...... 52 Table 8 – Potential impacts on physical processes arising from the proposed development...... 61 Table 9 - Potential impacts on marine water and sediment quality arising from the proposed development ...... 63 Table 10 – Potential impacts on benthic and intertidal ecology arising from the proposed development ...... 71 Table 11 – Potential impacts on fish and shellfish resources arising from the proposed development ...... 79 Table 12 - Summary of key species to be considered in the EIAR ...... 83 Table 13 – Potential impacts on offshore ornithology arising from the proposed development...... 88 Table 14 – Potential impacts on marine mammals arising from the proposed development...... 95 Table 15 – Potential impacts on SLVIA arising from the proposed development ...... 103 Table 16 – Potential impacts on shipping and navigation arising from the proposed development .112 Table 17 – Potential impacts on aviation arising from the proposed development ...... 118 Table 18 – Potential impacts on commercial fisheries arising from the proposed development ...... 126 Table 19 – Potential impacts on material assets arising from the proposed development ...... 136 Table 20 – Potential impacts on marine archaeology arising from the proposed development ...... 142 Table 21 - Potential impacts on biodiversity arising from the proposed development ...... 151 Table 22 - Potential impacts on land, soils and geology arising from the proposed development....158 Table 23 - Potential impacts on water arising from the proposed development...... 163 Table 24 - Potential impacts on air quality arising from the proposed development...... 167 Table 25 - Potential noise and vibration impacts arising from the proposed development ...... 171 Table 26 - Potential impacts on traffic and transport arising from the proposed development ...... 176 Table 27 - Potential impacts on cultural heritage arising from the proposed development ...... 183 Table 28 - Potential impacts on landscape and visual arising from the proposed development...... 188 Table 29 - Potential impacts on socio-economic, tourism, recreation and land use arising from the proposed development ...... 195 1 Introduction

1.1.1 This is an Environmental Impact Assessment (EIA) Scoping Report for the proposed Dublin Array Offshore Wind Farm (hereafter referred to as ‘Dublin Array’ or ‘the proposed development’), which is proposed off the east coast of Ireland on the Kish and Bray Banks off the coast of counties Dublin and Wicklow. An application for development consent is intended to be submitted to An Bord Pleanála under Marine Planning and Development Management legislation. As part of the application documentation it is intended to submit an Environmental Impact Assessment Report (EIAR). 1.1.2 This report sets out the proposed scope and methodology for the EIA intended to be undertaken for the proposed development. In addition, it provides the background to the proposed development, explaining its history since initial inception to the present day. The current proposals, whilst they are still subject to an iterative design process, will be informed by the environmental impact assessment and are described in this report. Finally, this report sets out the proposed structure of EIAR. 1.2 Document Structure

1.2.1 The Scoping Report is structured as follows:  Section 1 – Introduction – sets out a brief history of the project and its current status;

 Section 2 – Project Description – sets out a description of the proposed development, describing in detail the offshore wind farm and ancillary onshore works including grid connection options;

 Section 3 – Environmental Impact Assessment Methodology – sets out the general approach to the EIA, describing the impact assessment process including the approach to the cumulative and transboundary assessment;

 Section 4 – EIA Report Structure – sets out the proposed structure of the EIA Report (EIAR) which will present the findings of the EIA;

 Section 5– Offshore EIA Topics – sets out the proposed methodology for each offshore EIA topic to be assessed in the EIA; and

 Section 6 – Onshore EIA Topics – sets out the proposed methodology for each onshore EIA topic to be assessed in the EIA.

Page 1 of 220 1.3 Project Background

1.3.1 The Dublin Array Offshore Wind Farm is proposed on the Kish and Bray banks. The Kish and Bray banks are located approximately 10 kilometres (km) off the east coast of Ireland, immediately south of the city of Dublin off the coast of counties Dublin and Wicklow. The location of the proposed wind farm is shown in Figure 1 below. 1.3.2 The proposed wind turbines will be located within an area of approximately 54 kilometres squared (km2), in water depths ranging from 2 metres (m) to 30m lowest astronomical tide (LAT). The maximum export capacity of the proposed offshore windfarm is expected to be between 600 and 900MW (megawatts), however this figure will be refined during the design development and environmental assessment processes which are the subject matter of this Scoping Report. The proposed development also involves the export cables and onshore works which will facilitate connection to the national electricity grid. A detailed description of the proposed development is described in detail in Section 2. 1.3.3 Dublin Array is being developed by Kish Offshore Wind Limited and Bray Offshore Wind Limited (hereafter referred to as the 'Applicant’). The shareholders in both companies are RWE (RWE Renewables Ireland Limited) and Saorgus Energy Limited.

Page 2 of 220 700000 ¯

LEGEND Cable corridor and offshore fan Dublin Array site boundary 0 0 0 0 0 0 0 0 0 0 9 9 5 5 Data Source: Contains UKHO Law of the Sea data © Crown copyright and database right Ordnance Survey data © Ordnance Survey Ireland. All rights reserved. Licence number 25335584.

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Dublin Array Lease Areas and Offshore Cable Options VER DATE REMARKS Drawn Checked 1 16.04.2019 As Issued NW GM

DRAWING NUMBER: 00 30 77 880-01

SCALE 1:100.000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

0 1,25 2,5 5

Kilometres

700000 1.3.4 The project was initially developed by Saorgus Energy Ltd, a privately-owned Irish company specialising in the development of wind energy sites in Ireland. In March 2018 innogy Renewables Ireland Ltd (a wholly owned subsidiary of innogy SE) entered into a 50:50 partnership with Saorgus Energy to take the project forward. In July 2020 the global renewable energy portfolios of E.ON and innogy combined to from a new company called RWE Renewables. 1.3.5 RWE Renewables is wholly owned by RWE AG. It is one of four subsidiary companies which also include RWE Generation, RWE Power and RWE Supply and Trading. RWE Renewables is a leading global renewable energy company, with more than 3,500 employees and activities in 15 countries globally. RWE Renewables has considerable experience in developing, constructing and operating renewables assets both independently and together with project partners and investors. It invests in a broad range of technologies and has experience with onshore and offshore wind, hydro power, solar, battery storage and research and development (R&D) phase technologies. RWE Renewables is the second largest offshore wind developer in the world and the third largest renewable energy company in Europe. 1.3.6 RWE Renewables built and now operates the United Kingdom’s (UK) first ever commercial scale wind farm, North Hoyle which it completed in 2004. RWE Renewables currently has over 2.5GW of offshore wind projects in operation internationally . 1.4 Current Project Status

1.4.1 Dublin Array is the subject of two existing Foreshore Lease applications which were originally submitted to the Department of Communications, Marine and Natural Resources in 2006. Dublin Array has been identified by the Department of Housing, Planning and Local Government (DHPLG) and the Department of Communications, Climate Action and Environment (DCCAE) as a ‘Relevant Project’. 1.4.2 As a Relevant Project, Dublin Array is recognised by the DHPLG and DCCAE as being substantially advanced in its lease applications and therefore the applications are being transitioned to the new development consent process being introduced by the Marine Planning and Development Management Bill, 2020. The development consent application is being updated to take account of a design optimisation process and the latest available environmental data available for the location of the proposed development. 1.4.3 The Applicants and its consultants SLR Consulting Ireland (SLR) and GoBe Consultants Ltd (GoBe) are in the process of preparing an EIAR for the proposed development.

Page 4 of 220 2 Project Description 2.1 Introduction

2.1.1 The purpose of this chapter of the Scoping Report is to describe the proposed development during the construction, operation, maintenance and decommissioning stages of its lifecycle. The proposed development will consist of works and activities onshore and offshore. For the purposes of this report, the boundary between onshore and offshore is the high water point of mean or ordinary tides, which is shown as ‘HWM’ on Ordnance Survey Maps. 2.2 Design Envelope

2.2.1 The offshore wind industry is driving rapid developments in wind turbine technology and innovation in wind farm design and construction techniques. Given the anticipated future changes in the design and availability of wind farm components and uncertainty regarding future costs it is not appropriate to determine the optimum design solution for Dublin Array at the current time. The project description presented here, therefore, contains flexibility to allow for the adoption of the best available technology in an optimised detailed design which will be determined closer to the construction time. 2.2.2 This approach to development and associated consent application is often referred to as a ‘Rochdale Envelope’ approach and is based on identifying the worst case from within the realistic and likely options that might be developed. The development options with the potential for the worst case in terms of potential environmental impact are assessed. This is consistent with the assessment of ‘worst case effects’ as envisaged within the Draft Guidelines on Environmental Impact Assessment Reports as published by the Environmental Protection Agency in 2017. 2.2.3 The final layout of the proposed wind farm will be optimised to maximise the sustainable energy yield from the site within the constraints and limitations as set out in the development consent application, the EIAR and any development consent approval conditions. It should be carefully noted that the final layout, design and construction techniques will be selected to minimise the negative environmental effects and enhance the positive environmental effects. The nature and magnitude of these effects will not exceed those assessed and quantified in the EIAR. 2.2.4 Once a development consent is secured, there will be additional post consent verification surveys and investigations (onshore and offshore) undertaken. These surveys are likely to be environmental, archaeological and technical (for example geophysical or geotechnical) in nature. The outputs from these surveys will inform the final detailed design phases of the project prior to the commencement of construction 2.2.5 Offshore infrastructure proposed to be developed includes:  Up to 61 wind turbine generators (WTGs) and supporting tower structures; Page 5 of 220  WTG foundations with associated support and access structures;

 Up to three offshore platforms to support offshore substation(s);

 One meteorological mast and/or up to two meteorological measuring devices mounted on marine buoy(s);

 Subsea inter and intra-array electricity cables (between individual WTGs and the proposed offshore substations);

 Up to three electricity export cable circuits (from the offshore substations to land); and

 Up to two cable landfalls [at Shanganagh (near Shankill in County Dublin) and Poolbeg (near Dublin Port and city)].

2.2.6 A more detailed description of the proposed offshore infrastructure is included in Section 2.3. 2.2.7 Onshore infrastructure proposed to be developed includes;  Up to three transition joint bays located adjacent to the cable landfall points (where the subsea electricity export cables join with the on-land underground electricity cables);

 Up to two onshore substations (at Carrickmines in south west Dublin and Poolbeg near Dublin Port and city); and

 Up to three underground electricity cable circuits connecting the proposed onshore substations to the existing 220 kilovolt (kV) electricity substations at Carrickmines and Poolbeg.

2.2.8 A more detailed description of the proposed onshore infrastructure is included in Section 2.4. 2.3 Offshore Infrastructure

2.3.1 Wind turbine generators (WTGs) will be installed within the array area as shown in Figure 1. Wind turbines comprise a tower, nacelle and rotor, supported and fixed to the seabed by means of a foundation. A transition piece may be used, which acts as the interface between the turbine and the foundation. Figure 2 illustrates the main components of a WTG.

Page 6 of 220 Figure 2 - A typical wind turbine generator

Page 7 of 220 2.3.2 The turbine structures would typically be installed in sequence, commencing with the foundation. The transition piece (where required) is then installed, followed by tower, nacelle and rotor as shown in Figure 3 (moving in sequence from 1 to 6). Alternatively, sections of the structure may be prefabricated at a suitable shore side facility prior to being transferred to the offshore site.

Figure 3 - Sequential photographs of installation of turbine tower, nacelle and blades 2.3.3 The number of turbines proposed to be installed will not exceed 61. The largest turbines that are proposed will have a maximum tip height (when a rotor blade is in a vertical orientation) of 308m and an indicative hub height of 165.5m above mean high water springs (MHWS). Table 1 below provides the range of key sizes and dimensions which are proposed and will be assessed in the EIA.

Table 1 - Indicative Wind Turbine Numbers and Dimensions

Page 8 of 220 Indicative Indicative Hub Maximum Rotor Maximum Upper Maximum Individual Height (m above Diameter (m) Blade Top Height Number Capacity (MW) MHWS) (m above MHWS)

Up to 15 MW 61 133 220 240

Above 15 MW 45 165.5 285 308

Foundation Structures

2.3.5 Foundations are required to securely support the wind turbines, meteorological masts and offshore substation platforms which will be fixed to the sea bed. Foundations whilst providing this support also need to be capable of withstanding forces from the wind and the marine environment. They also provide safe access and a safe working environment for operational and maintenance activities. Installation of foundations for turbines, meteorological masts, and substations may result in the requirement for seabed preparation, including bed levelling and boulder clearance. Seabed levelling may result in the generation of surplus material which may be sidecast and subject to natural on-going erosion and dispersal, alternatively the surplus material may be used as backfill or ballast, or disposed of outside the array at a location for which a Dumping At Sea permit will be obtained. A range of foundation types are being considered as shown in Figure 4 including monopile, suction monopod and multi-leg.

Figure 4 - Foundation Options Monopile Foundation

2.3.6 A monopile foundation comprises a single pile which is typically driven into the seabed. Other piling installation methods include drilling, vibration piling and innovative techniques are being considered. Such innovative techniques include Hi-Lo piling or BLUE piling, which uses a column of water under pressure instead of a steel ram.

Page 9 of 220 2.3.7 Installed piles typically extend 5m to 10m above the sea surface, but termination of the monopile at access platform level, or below sea surface is also possible. To make the structural connection between the monopile foundation and the turbine tower, a transition piece is installed over or inside the monopile. The transition piece also supports external secondary steelwork such as J-tubes (structures which provide protection of the electricity cables as they transition from the wind turbine into the seabed), boat landings and working and intermediate access platforms. 2.3.8 A brief typical installation sequence for a monopile foundation would be as follows:  Transportation of monopiles to offshore site via vessel, barge or float-out (with the monopiles bunged to give positive buoyancy);

 Up-ending pile by crane vessel with buoyancy assistance if necessary;

 Monopiles lowered to seabed location, with pile weight providing initial seabed penetration;

 Installation of monopiles progressed by driving (piling), vibration, drilling or a combination, as required by site specific soil conditions and technical and economic viability;

 Installation of transition piece, alignment and fastening (grouting, bolting or welding);

 Installation of ancillary equipment, such as J-tubes and boat landings if not integral to transition piece; and

 Installation of scour protection as required, as discussed further from paragraph 2.3.13 onwards.

2.3.9 The sequence is repeated for each foundation, initiated by the installation vessel positioning itself at the pre-determined turbine location. Suction Monopod Foundation

2.3.10 Suction monopods utilise a single suction ’bucket’ to support a steel/concrete columnar structure. The weight of the water above the bucket and the soil strength provide the force required to hold the structure in place. This concept requires the presence of a suitably soft sediment and sufficient hydrostatic pressure to be effective and can be scaled for single column foundation designs (or multileg designs as discussed in paragraph 2.3.11 ).

Page 10 of 220 Multileg Foundation

2.3.11 Multileg foundations include tripod and jacket options. These typically consist of three or four main legs which are linked by a lattice of cross-braces. Each leg is secured to the sea floor using a driven or drilled pin-pile or may be held in place by a suction caisson (similar to an inverted bucket, the hydrostatic pressure and the seabed properties provide the force required to hold the structure in place). Foundation Dimensions

2.3.12 The dimensions of the pile or suction bucket depend on the size of the turbine, the hydrodynamic forces and the ground conditions at the turbine location. The maximum dimensions of each foundation type are presented in Table 2 and Table 3 below.

Table 2 - Maximum Dimensions of Piled Foundation Options

Maximum Width of Maximum Pile Diameter Maximum Pile Piled Foundation Foundation at Seabed (m) Penetration Depth (m) (m)

Wind Turbine Monopile 15 55 Not applicable

Wind Turbine Multipile 4.5 85 45

Offshore Substation 9 45 Not applicable Platform Monopile

Offshore Substation 3 55 50 Platform Multipile

Met Mast Monopile 7 40 Not applicable

Met Mast Multipile 4.5 55 35

Table 3 - Maximum Dimensions of Suction Bucket Foundation Options

Maximum Width of Suction Bucket Maximum Bucket Maximum Bucket Foundation at Seabed Foundation Diameter (m) Penetration Depth (m) (m)

Wind Turbine Monopod 28 30 Not applicable

Wind Turbine Suction 24 22 45 Multileg

Page 11 of 220 Maximum Width of Suction Bucket Maximum Bucket Maximum Bucket Foundation at Seabed Foundation Diameter (m) Penetration Depth (m) (m)

Offshore Substation Not applicable Monopod

Offshore Substation 15 8 50 Suction Multileg

Met Mast Monopod 15 12 Not applicable

Met Mast Suction 10 10 30 Multileg

Scour Protection

2.3.13 Scouring of soft surface sediments can occur around the base of foundations due to localised hydrodynamic effects, which can erode sediments causing scour pits to form. The formation of scour pits can impact on the stability of the structure. The presence of scour pits may increase the environmental impacts due to resulting changes in the hydrodynamic regime, and increased sediment load in the water column. As a precautionary assumption it is assumed that scour protection would be required at all foundation locations. 2.3.14 The final selection as to whether scour protection is required or otherwise is dependent upon the final project design and scour assessment but, if needed, would comprise a single or double layer of a wide-graded stone which functions as a filter and a protective armour layer. Offshore Substations

2.3.15 The proposed development will require up to three offshore substations depending on the capacity of the wind farm and the number of export circuits required. The location of the offshore substation platforms within the array area will be determined once the turbine layout has been confirmed. 2.3.16 The power from the turbines will be delivered to the offshore substations by subsea cables. Transformers housed in the substations will increase the voltage from 66 or 132kV to 220kV for delivery to the shore via the export cables.

Page 12 of 220 2.3.17 Each offshore substation platform will be supported by up to six legs and each leg will be secured to the seabed by a foundation structure. An example offshore substation is show in Figure 5. The range of different foundation types are the same as those described previously for the wind turbine foundations on page 9. The maximum dimensions of the foundation structures are provided in Table 2 and Table 3.

Figure 5 - Offshore substation at Gwynt y Mor Wind Farm in Wales 2.3.18 The substation topside structure is placed on top of the foundation and houses the electrical equipment and supporting functions. If a single offshore substation is constructed the top side may be up to 50m wide and 80m long. In the event that three substations are deployed these will be smaller, in the region of 40m by 40m. 2.3.19 The topsides are likely to be assembled at a construction port facility and loaded onto a heavy lift vessel for transport to site. The vessel will then lift the topside module onto the support structure. A number of options for a construction port facility are being considered by the Applicant. It is anticipated that a number of possible options will be included within the EIAR. Meteorological Stations

2.3.20 Meteorological stations are essential to provide meteorological and oceanographic data from the site. Up to three meteorological stations are proposed be installed at Dublin Array and may be mounted on a mast or on marine buoy, or a combination of these techniques.

Page 13 of 220 2.3.21 The maximum height of the meteorological masts will not exceed the upper blade tip height of the wind turbines, i.e. 308m (MHWS). The foundation options for meteorological masts will be the same range as presented for the turbines as presented in Table 2 and Table 3. The foundations will be fabricated, transported and installed in a manner similar to the process described for the turbine foundations. 2.3.22 The marine buoys will be moored using one the following mooring systems:  Anchor and chain mooring system. The anchor and chain slack mooring system will have a chain and/or wire, attached to the floating buoy and to an anchor at the seafloor. The mooring chain will terminate on the seabed and will be held in this position by means of a number of gravity anchor points, comprising steel, concrete or concrete and steel;

 Catenary mooring system. The catenary mooring system will comprise a chain and/or wire attached to a floating buoy and to an anchor at the seafloor. The mooring chain will terminate horizontally on the seabed and hang freely between the attached object and the touch down point, which will alter in accordance with the meteorological ocean conditions; or

 Clump weight mooring system. The clump weight mooring system will have a single weight comprising steel, steel and concrete or concrete to which multiple mooring chains and/ or wires or tension legs will be attached.

2.3.23 The choice of mooring and dimensions of the system components will be appropriate for the seabed characteristics, water depth, wave, tide and current profile. Mooring lines are typically three times the water depth. Table 4 includes maximum parameters for the range of possible mooring systems.

Page 14 of 220 Table 4 – Typical mooring system parameters for buoys supporting meteorological sensing equipment

Anchor and chain Catenary mooring Clump weight Mooring system parameter system system mooring system

Number of gravity anchor points 2 4 0

Number of clump weights 0 0 1

Height of gravity anchor points or 4 4 3 clump weights (m)

Width of gravity anchor points 4 4 10

Number of sinker weights 4 0 10

Subsea Inter-array, Intra-array and Export Cables

2.3.24 Submarine inter-array cables typically have a voltage of 66kV, expected developments in technology could enable 132kV cables to be installed at Dublin Array. Inter-array cables will be required to connect turbines together into groups or strings. Each string will then be connected to an offshore substation. 2.3.25 Up to three higher voltage (220 - 400kV) cables will then export electricity from the offshore substations towards the shore, where they will be joined to the onshore cables. Submarine intra-array cables may also be required to connect individual offshore substation platforms to each other. A typical single armoured submarine cable is shown in Figure 6.

Table 5 – Submarine cable parameters

Combined total length Submarine cable Voltage (kV) External diameter (mm) (km)

Inter-array cables 66 – 132 220 100

Intra-platform cables 220 - 400 310 24

Export cables 220 – 400 310 78

Page 15 of 220 Figure 6 - Typical single armoured submarine cable – Source GGOWL (2009) 2.3.26 The offshore cables will be buried, where it is feasible to do so, and protected as appropriate in order to:  Prevent movement of the cables over the life of the wind farm;

 Protect the cables from other activities such as fishing or the dragging of anchors;

 Protect against the additional small risk posed from dropped objects; and

 Limit the potential effects on environmental receptors from heat and electromagnetic fields.

2.3.27 Prior to cable installation the seabed will be cleared of surface boulders and debris along the route, which is usually achieved by passing a grapnel over the seabed. 2.3.28 In areas of the cable route where sand waves are present preparation works will include removal of the upper section of the sand waves (approximately 3m – 6m) to maximise the potential for achieving adequate burial of the cable and to prevent free spanning of the cable between sand waves, thus reducing the potential for secondary protection to be required. The upper section of the sand waves may be removed by jet trenching, multiple passes of a pre-lay plough, dredging or through the use of non-contact techniques such as mass flow excavation. 2.3.29 Cables will be installed using one, or a combination of techniques described as follows:  Ploughing: The cable is simultaneously laid and buried. The cable plough lifts a section of the seabed deposit and places the cable below. The seabed deposit is then returned to its original position. In areas of very hard substrate, modifications to this technique may be used, including use of a rock cutter plough or vibrating share plough;

Page 16 of 220  Trenching: A trenching tool comprising a remotely operated vehicle (ROV) fitted with high pressure water jets is used to fluidise the seabed in a narrow trench in which the cable will be laid. The fluidised sediments settle back onto the seabed giving a degree of back-fill. Where stiff clay or rock is present a cutting attachment may be used which will cut a trench into the seabed whilst the cable is simultaneously laid; and

 Jetting: The cable is first laid on the seafloor. An ROV equipped with high pressure water jets will proceed along the cable route, fluidising the seabed around the cable, allowing the cable to be lowered into the trench. The fluidised sediment subsequently settles back onto the seabed.

2.3.30 There is a single pipeline and a single telecommunications cable transecting the offshore export cable corridor on the approach to one of the landfall options being considered at Poolbeg which may have to be crossed by the cables. 2.3.31 Any of the techniques described for remedial cable protection may be used to achieve cable or pipeline crossings, but the common options include one or a combination of:  Pre-lay and post-lay concrete mattresses;

 Pre-lay and post-lay rock placement;

 Pre-lay steel or concrete structures; or

 Pre-constructed high density polyethylene (HDPE) castings.

2.3.32 The technique to be used will be agreed with the cable/pipeline operators prior to construction, and will be designed to provide adequate separation between pipelines and cables, protection for cables and stability through the lifetime of the wind farm. Landfalls

2.3.33 Three potential landfall locations are currently being considered at Shanganagh Cliffs, Shanganagh Park in South Dublin and Poolbeg, see Figure 1 in Section 1.3. 2.3.34 Dependent upon the location of the grid connection point or points a maximum of three cable circuits will be required. Up to two cable circuits may be required to come ashore at either Shanganagh Cliffs or at Shanganagh Park. An alternative configuration may include up to three cable circuits to Poolbeg with no cable circuits coming ashore at Shanganagh Cliffs or at Shanganagh Park. A combination of cable routing of one or two circuits to Poolbeg and one or two circuits to a Shanganagh area landfall may also be required. A maximum of three cable circuits will not be exceeded.

Page 17 of 220 2.3.35 Trenchless techniques, such as horizontal directional drilling (HDD), are likely to be used to install the cable ducts at the landfalls, if conditions are favourable, allowing the cable ducts and cables to be installed below the cliffs, where present, and sea defences without the need for open cut techniques to be used. If ground and seabed conditions are found to be unfavourable for trenchless techniques, then conventional open cut trenching will be required, followed by reinstatement of the trench and sea defences. In the case of a landfall at Poolbeg, it is likely that the cable will be installed by plough across the intertidal beach. 2.3.36 In the event of a trenchless installation technique being selected this will be undertaken from a compound on the top of the cliffs, or at Poolbeg behind the sea defences, and will drill beneath the cliffs and/or sea defences to exit in the sea bed in a depth of at least 5m of water (LAT), requiring a drill of approximately 1km in length. At Poolbeg the exit point may be within the intertidal area. 2.3.37 Typically a pilot hole will be drilled first and the bore progressively opened to its final size in a process known as forward reaming, where reamers of increasing size are progressed along the pilot holes. Because the seaward end of the hole remains sealed the drilling fluid and cuttings return to the rig onshore. The final ream will be of a diameter suitable to accommodate a cable duct of approximately 700 mm internal diameter. 2.3.38 Once ready for the cable ducts to be installed the drill bit will be steered through the prepared hole and upwards to punch-out at the seaward end. The cable duct is then attached to the drill string and pulled back towards the HDD rig. 2.3.39 Cables will be pullled through the installed cable ducts. This is usually achieved by passing a messenger line from the transition joint bay down the duct to be recovered at the seaward end onto the cable lay vessel. The messenger line is then attached to the export cable and a land based winch pulls the cable ashore through the duct. The submarine export cables, and the smaller onshore cables, will be joined at the onshore transtion joint bay. 2.3.40 With the export cable securely in position at the transition bays the export cable vessel will commence installation of the cable across the nearshore zone and progress along the export cable route towards the offshore substation. At the landfall, the duct will be plugged and reburied. 2.3.41 At the Poolbeg landfall, where the HDD may exit within the inter-tidal area, the cable laying vessel will be brought in as close as possible to the landfall at high water. Beach anchors will be connected to stabilise the vessel’s position. The vessel will most likely be of a flat bottom design and be able to ground at low tide on the seabed. Once the export cable has been secured on the landward side, the barge will be floated out on the next tide to commence cable laying. 2.3.42 It may be necessary to excavate a cable trench, approximately 2.5m in depth and 30m in length at the top of the beach. The cable will then be laid into the trench and reburied. Alternatively the cable may be installed across the intertidal area using a cable plough which may be pulled forward by tractor or by winch.

Page 18 of 220 Offshore Indicative Construction Sequence and Programme

2.3.43 The installation of the offshore infrastructure, excluding surveys and site preparation, is anticipated to take approximately 12 months and this activity may be spread across a two year period. 2.3.44 Offshore cable installation works are typically carried out under relatively calm ocean conditions which are normally experienced during the summer, although construction activities could take place throughout the year. 2.3.45 24-hour working will be required. Lighting will be provided by the installation vessels during night-time and low light conditions to illuminate construction activities to enable them to be conducted safely 2.3.46 Offshore infrastructure will typically be installed in the following sequence with some activities occurring simultaneously:  Seabed preparation;

 Cable duct installation at the landfall;

 Wind turbine and ancillary infrastructure foundation installation;

 Installation of scour protection;

 Installation of wind turbine generators;

 Installation of offshore substation topsides and met masts; and

 Cable laying. Offshore Operations and Maintenance

2.3.47 Once operational, Dublin Array will require regular maintenance throughout its lifetime which is expected to be approximately 35 years unless otherwise extendedi. 2.3.48 This will require a full time dedicated team of approximately 100 personnel including technicians and associated support staff who will be based at a dedicated Operations and Maintenance (O&M) base.

i If the operational lifetime of the project is extended beyond 35 years it is expected that this will be the subject of a new development consent application and be accompanied by a new EIAR at that time.

Page 19 of 220 2.3.49 The wind farm will be designed to operate with minimal day-to-day supervisory input and will be managed from an appropriately located control room in the O+M base. Each turbine will be controlled by local microprocessors, which in turn will be monitored by a centralised Supervisory Control and Data Acquisition (SCADA) system. The SCADA system and other communication requirements for Dublin Array will be linked to the onshore communication network via optical fibre cables which will form an integral part of HVAC subsea cables. Should a turbine develop a fault, this can usually be diagnosed remotely and the turbine shut down automatically as appropriate. 2.3.50 Factors governing the development of an O&M strategy include: health and safety issues in transferring crew members and O&M technicians to and from offshore structures; transit duration; O&M port location; weather downtime; turbine selection; and the associated cost- benefits of each option. Ultimately the final O&M approach can only be developed as part of the final project design process in consultation with the main component and service providers. 2.3.51 Due to the proximity of Dublin Array to the shoreline it is likely that the wind farm will be serviced by small crew transfer/work boats operating from a local port or habour where the O&M base will be located. In addition, there will be a requirement for heavy lift and cable laying vessels to visit the array site for periods of planned maintenance and remedial works. Offshore Decommissioning

2.3.52 At the end of the wind farm’s design life where it has been agreed that the infrastructure should be decommissioned, the decommissioning process is likely to follow a reverse programme of the construction process. The decommissioning process and techniques will adhere to all of the following requirements;  Any decommissioning specific conditions of the Development Consent and Maritime Area Consent;

 The latest development in technology available for decommissioning work at the time when the work is carried out;

 Legislative obligations in place at the time of decommissioning regarding method and scope;

 The results of environmental monitoring verification data which will be undertaken during the lifetime of Dublin Array; and

 Ensuring that the environmental impacts are consistent or less in scale and magnitude to those predicted in the EIAR associated with the development consent application or subsequent relevant consent. This process will utilise environmental data gathered during the construction and operational phase of the project as recommended in the EIAR and conditioned in the development consent.

Page 20 of 220 2.4 Onshore Infrastructure Electrical Connection Strategy

2.4.1 The power generated by the proposed development will need to be delivered to the existing electricity transmission network such that EirGrid, the national electricity transmission system operator, can effectively move the electricity to where it is needed. The proposed onshore infrastructure, which is part of the development being proposed, comprises the components of the project between the offshore export cables (from the Mean High Water Springs line), to the point of connection (i.e. an existing substation) on the existing national electricity transmission network. 2.4.2 An onshore substation (OSS) is required as part of the overall wind farm development proposal to regulate the power output to meet EirGrid’s requirements prior to connection into the existing national electricity transmission network at an existing substation. 2.4.3 Two potential grid connection points into the national electricity transmission network with three different scenarios are under consideration and are the subject of consultation with EirGrid. The first scenario is a connection into the existing Carrickmines 220kV substation (located in south-west Dublin). The second scenario is a connection into the existing Poolbeg 220kV substation (located adjacent to Dublin Port and the city). The third scenario is electrical connections to both the existing Carrickmines 220kV and existing Poolbeg 220kV substations. The geographical locations of the two grid connections points is shown in Figure 7 with potential landfall and cable corridor zones. The two potential landfall locations at Shanganagh, described in Section 2.3 are shown to the south of the map, whilst the potential Poolbeg landfall location is shown to the north, adjacent to Dublin Port. The cables and the whole electrical transmission system will be built to EirGrid specifications. 2.4.4 Each of the offshore substations (potentially up to three) will have a dedicated export cable, which will transition into an onshore cable circuit at a transition joint bay. It is anticipated that three export cables/onshore circuits will be required in the following configuration:  Carrickmines Grid Connection – up to two circuits;

 Poolbeg Grid Connection – up to three circuits; and

 Carrickmines one or two circuits, Poolbeg one or two circuits (up to three in total).

Page 21 of 220 ¯

Poolbeg Substation Grid Connection Point

LEGEND Potential Infrastructure Zones Potential Export Cable Landfall Zone

Carrickmines Substation Grid Connection Point Data Source: © OpenStreetMap (and) contributors, CC-BY-SA Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User

PROJECT TITLE

PotPeotenntiaila Exlp oErtxport CabCalbele LLanadfnall dZofnaesll Zones DUBLIN ARRAY

DRAWING TITLE Dublin Array Connection Point Options Potential Cable Route Corridor Zone VER DATE REMARKS Drawn Checked 1 8/25/2020 FIRST ISSUE AB RE

DRAWING NUMBER: FIGURE 7

SCALE 1:100,000 PLOT SIZE A3 DATUM D_TM65 PROJECTION TM65

0 1 2 4

Kilometers Onshore Grid Connection Infrastructure

2.4.5 The proposed onshore grid connection infrastructure is illustrated in Figure 8 and will comprise the following elements;  a) Transition Joint Bay;

 b) Onshore Electricity Export Cables (and associated infrastructure);

 c) Proposed Substation; and

 d) Connection to existing EirGrid/ESB Transmission Substation.

Figure 8 - Overview of the onshore grid connection infrastructure a) Transition Joint Bay (TJB)

2.4.6 A transition joint bay (TJB) is the location where the offshore cable(s) ends and the standard onshore cable will commence, with each circuit containing three separate cables. This means there could be a TJB at Shanganagh (general landfall location for a connection to Carrickmines 220kV substation), Poolbeg or both. The TJB will comprise a buried concrete chamber, typically 16m long, 4m wide and approximately 2.5m deep within which the offshore submarine cable divides and will be jointed to the onshore cables. One chamber will be required for each circuit. Figure 9 shows a TJB chamber under construction.

Page 23 of 220 Figure 9 - TJB Construction 2.4.7 TJB chambers are usually constructed within an excavated pit, supported by sheet piles. The chambers have removable lids and following construction and commissioning, the lids will be installed and the chambers buried. The TJB(s) will typically be completely buried and following construction, the surface of the land fully reinstated and returned to its previous use. 2.4.8 TJB construction areas are also typically used as the location for plant and equipment associated with trenchless installation techniques for subsea cables being pulled ashore. This plant and equipment can include drilling/boring equipment, storage, power generation plant and drilling fluid management infrastructure. A construction area of up to 60m x 60m is typically required at a TJB site such as that shown in Figure 10.

Page 24 of 220 Figure 10 - TJB contruction site – RWE Renewables Gwynt y Mor Offshore Wind Farm in Wales b) The Onshore Export Cables

2.4.9 At the TJB(s), each offshore electricity export cable will be joined with the onshore underground cables for each electricity circuit. Each offshore electricity cable connects with three onshore electricity cables. This means that if there are three offshore export electricity cables there will be nine onshore underground electricity cables. Each circuit of onshore underground electricity cables consists of three underground electricity cables which will be installed in ducts and are typically arranged in a ‘flat lay’ configuration. These cables will be installed in a trench approximately 1.1m wide for each circuit. An image of a typical onshore electrical trenching and duct laying work is included in Figure 11 below, which shows a narrower trench compared to that proposed for Dublin Array, with the ducts in a trefoil configuration. The arrangement of the cable ducts within the trench is shown in the photographs in Figure 11 below.

Page 25 of 220 Figure 11 - Typical HV Trench Excavation (Ducts laid in trefoil formation) – ESBI HV Cables – General Construction Methodology 2012 2.4.10 All of the onshore cables will be buried for their entire route and the land reinstated to its existing use. The proposed routes for cables will follow the hierarchy used by EirGrid for route selection of underground electricity cable infrastructure. This hierarchy is set out in the Eirgrid Functional Specifications for Underground HV Cables, under Route Selection, Design ans As- Built Records (CDS-HFS-01-001-R2) – Section 3, Policy on underground cables in third party lands and summarised below:  Public roads (first preference) – considered to be the preferred location for cables as the road provides access for construction and maintenance, protects the cables and works carried out in roads are controlled by the local roads authority;

 Public land (second preference) - generally considered to be the second choice due to the need for access to and along the cable corridor, the proximity of tree and restrictions on planting over the cable all need to be considered in the route selection; and

Page 26 of 220  Private land (last preference).

2.4.11 To connect to the existing Carrickmines 220 kV substation onshore cable routes in the range of 7km – 12km are likely to be required from the TJB. The potential cable routes under consideration are predominantly in public roads or public land. There may be a requirement for some of the route to be located within development sites which are currently privately owned, however the intention at these locations will be for the route to be located under roads, pathways or greenspaces. 2.4.12 The Poolbeg site is separated from the beach by a road and a connection into either of the existing substations at Poolbeg involves only a very short onshore cable. 2.4.13 For each cable circuit, three electricity cable ducts will be required, with two additional ducts for communications. Cables are manufactured and delivered on drums containing typically 650m to 800m of cable. Therefore, joint bays will be required at intervals within this range. Joint bays are concrete chambers which are installed below ground level, buried and the surface fully reinstated following construction and are typicaly installed either in roads, or in the verge alongside a road. Joint bays are typically 6-8m in length, 2-2.5m in width and 2.1m in depth. At joint bay locations, small inspection chambers with removable covers are also required, to allow inspection of the communications cables and the cable earthing arrangements. These have removable iron covers set flush with the ground level and are typical of other utility inspection chambers. These are normally set in the road verge or alongside a footpath to facilitate access. A typical joint bay under construction is shown in Figure 12.

Figure 12 - Typical Joint bay under construction alongside a public road (HV Cables General Construction Methodology, ESBI 2012)

Page 27 of 220 2.4.14 Where the onshore cable is proposed to be installed in roads, this will be carried out by cutting the road surface and the excavation of a trench, using an excavator and removing all of the excavated material. The ducts are surrounded by imported bedding material and the road base materials installed. It is likely that each circuit will be installed independently within one traffic lane, with traffic controlled by traffic lights or other means. It is likely that approximately 50m of duct will be installed in one day but this could be more or less depending upon the number of services or other obstructions encountered. It is likely that a temporary road surface reinstatement will be carried out for the area completed at the end of each day, with a permanent reinstatement being carried out at a later stage. 2.4.15 In the sections of the route in soft ground, such as through a public greenspace, a different methodology will be implemented in order to protect soil resources, which will be retained and used for reinstatement. Where the route crosses through land with public access, to protect members of the public, the works will be temporarily fenced. Additional working space will be required on either side of road or rail crossings and potentially where significant utilities infrastructure (gas, water, telecommunications) are encountered and where trenchless installation techniques may be required (such as horizontal directional drilling or pipe-jacking). These crossing locations are referred to as ‘special crossings’ and are addressed below. 2.4.16 Following the installation of the cable ducts for the entire route, cable installation and joining will take place as a separate operation. The works will take place at the joint bay locations, with a cable drum being located at one end of a section and a winch at the other end which will pull the cable through the duct. Final reinstatement of the joint bay sites will take place following cable installation, testing and commissioning. c) Special Crossings

2.4.17 Special sections or crossings are areas where there is an obstruction, standard construction methodologies are not practical and special methodologies need to be deployed. These sections are usually installed in advance of the main cable installation works, by specialist contractors. 2.4.18 For the Dublin Array onshore cable route, the obstructions which are likely to require special installation methodologies are:  Railway line (Dublin-Rosslare);

 Major roads (N11 and M50); and

 Rivers (Loughlinstown River).

2.4.19 For railway lines and motorways, it is essential that the cables are installed by trenchless means, not involving any surface excavation work, with work sites being established on either side of the obstruction. HDD is usually the preferred solution, although other technologies such as pipe-jacking are possible. For most roads there is the option of open cutting or trenchless.

Page 28 of 220 2.4.20 For a crossing installed by HDD, the working areas will typically be 45m x 45m on each side of the crossing subject to space availability. The HDD drilling rig will be located on the launch side, along with the power generator, control room, drill pipes and drilling mud supply. On the exit side, a pit will be excavated into which the drill will emerge. A drilling mud storage tank may be required and sufficient space to lay out the section of duct that will be pulled back by the drill pipe. 2.4.21 For crossings of the small rivers on the route(s), the crossing points are likely to be all of a size that could be crossed by open cutting, subject to the approval of the method statement by Inland Fisheries Ireland, thereby minimising the construction footprint of the associated works. d) The Onshore Substation (OSS)

2.4.22 The proposed development will include up to two new onshore substations, to provide voltage regulation, reactive power compensation and harmonic synchronisation. 2.4.23 A site with an area between 4 acres (1.62 hectares, ha) and 6 acres (2.42ha) is likely to be necessary for the construction of each of the onshore substations. The main components of the substations, that contribute to this land requirement are the switchgear building and outdoor plant and equipment. 2.4.24 A GIS building is typically a portal frame, steel clad building, similar in nature to other light industrial structures (and the existing GIS building at Carrickmines 220kV substation). It is likely to be in the range of 60m (l) x 20m (w) x 17m (h). A typical GIS building is included (green structure) in Figure 13 below. Other single storey control buildings include two STATCOM buildings which together will be in the range of 53m (l) x 25m (w) x 10m (h), although these details are still the subject of an on-going design process. Typical STATCOM buildings are included (yellow structures) in Figure 13 below.

Page 29 of 220 2.4.25 The outdoor plant and equipment typically includes a works power transformer (to provide the power to operate the substation), static compensation plant, shunt reactors and harmonic filters. These items of plant typically have the appearance of grey blocks or cylinders within internal fenced compounds. It is expected that a back-up generator will be included in the OSS.

Figure 13 - Typical Substation Layout (RWE Renewables Galloper Offshore Wind Farm in UK) Onshore Indicative Construction Sequence and Programme

2.4.26 The installation of the onshore infrastructure, excluding surveys and site preparation, is anticipated to take approximately 24 months and onshore construction is likely to commence in advance of the offshore construction programme. It is likely that the latter part of the onshore programme will be concurrent with offshore construction operations. 2.4.27 The most intense activity during the construction stage of the project will be at the OSS, albeit there will be significant activities occurring at the location of the TJB(s) and particularly at the special crossings for the onshore cable route(s). Construction of the OSS is likely to start very early in the overall construction programme and works will continue until the wind farm and complete electrical system has been commissioned. The largest concentration of construction staff will be at OSS site and this will peak at later stages of the construction programme when it is likely that there will be up to approximately 75 staff on site. 2.4.28 Construction will occur during normal construction working hours, with the exception of works associated with the entry and exit pits at the TJB(s) and special crossings associated with trenchless construction techniques which will typically occur 24 hours per day, seven days per week for defined periods within the construction programme. 2.4.29 The main construction activities and durations within the overall 24 month construction programme are described as follows:  Onshore substation groundworks, drainage and fencing 18 weeks;

 Onshore substation civil works, ducting and surfacing 34 weeks; Page 30 of 220  Special crossings works (per location) 16 weeks;

 Transition Joint Bay(s) 70 weeks;

 Cable trench and joint bay installation 70 weeks; and

 Substation energisation 16 weeks. Onshore Operations and Maintenance

2.4.30 Once operational, the proposed substation will generally be unmanned and remotely monitored/operated by EirGrid. Operations at the substation will involve six to eight visits per month by ESB personnel, quarterly inspection site visits and maintenance visits when required.

2.4.31 The substation will be serviced with an electricity, gas (SF6 ,sulphur hexafluoride) and water supply. Specialised utility and services maintenance procedures and training are incorporated into ESB management systems and will be implemented on-site. Onshore Decommissioning

2.4.32 At the end of the substation’s design life where it has been agreed that the infrastructure should be decommissioned, the decommissioning process is likely to follow a reverse programme of the construction process. The decommissioning process and techniques will adhere to all of the following requirements:  Any decommissioning specific conditions of the Development Consent;

 The latest development in technology available for decommissioning work at the time when the work is carried out;

 Legislative obligations in place at the time of decommissioning regarding method and scope; and

 Ensuring that the environmental impacts are consistent or less in scale and magnitude to those predicted in the EIAR associated with the development consent application or subsequent relevant consent. This process will utilise environmental data gathered during the construction and operational phase of the project as recommended in the EIAR and conditioned in the development consent.

Page 31 of 220 3 Environmental Impact Assessment Methodology 3.1 Overview

3.1.1 The following section sets out the general EIA methodology that will be implemented by the Applicant and its project team. This section should be read alongside topic specific methodology which is provided in Sections 5 and 6 of this Report. 3.1.2 The EIAR will comply with the requirements of the EU EIA Directive 2011/92/EU1 and EIA Directive 2014/52/EU2 and the European Union (Planning and Development) (Environmental Impact Assessment) Regulations 2018, and such revisions as may be made from time to time. 3.1.3 EIA provides a system of sharing information about the environment which enables effects to be foreseen and prevented during the design and consent stages (see Figure 14). This protects the environment and informs and improves decision-making. The EIAR presents an objective and concise record of the process and the determination of significant environmental effects.

Page 32 of 220 Figure 14 The EIA Process and the position of the EIAR (EPA 2017)ii

ii Source: Adapted from Draft Guidelines on the Information to be contained in Environmental Impact Assessment reports (Environmental Protection Agency, 2017)

Page 33 of 220 3.2 Guidance

3.2.1 The proposed EIA methodology will comply with the requirements of the European Union (EU) EIA Directive 2011/92/EU1 and EIA Directive 2014/52/EU2 and the European Union (Planning and Development) (Environmental Impact Assessment) Regulations 20183 (hereafter referred to as the EIA Regulations) and key Irish guidance relevant to EIA including:  Draft Guidelines on the Information to be contained in Environmental Impact Assessment reports (Environmental Protection Agency, 2017)4 (hereafter referred to as the draft Guidelines);

. Whilst it in noted that these are draft Guidelines, they are considered more appropriate than the current finalised version (published in 2002)5 as they transpose the current EIA Directives (2011/92/EU1 and 2014/52/EU2). Therefore, the draft Guidelines have been utilised to define the proposed methodology for the Dublin Array EIA.

 Advice Notes on Current Practice (in the preparation of Environmental Impact Statements) (Environmental Protection Agency, 2003)6 (as referenced in the draft Guidelines);

. Draft Advice Notes on Current Practice (in the preparation of Environmental Impact Statements) (Environmental Protection Agency, 2015)7 (which are to be finalised following the finalisation of the draft Guidelines).

 Guidelines for Planning Authorities and An Bord Pleanála on carrying out Environmental Impact Assessment (Department of Housing, Planning and Local Government, 2018)8 (hereafter referred to as the EIA Guidelines);

 Guidance on Environmental Impact Statement (EIS) and Natura Impact Statement (NIS) Preparation for Offshore Renewable Energy Projects (Environmental Working Group of the Offshore Renewable Energy Steering Group and the Department of Communications, Climate Action and Environment, 2017)9 (hereafter referred to as the DCCAE Guidance); and

 Guidance on Marine Baseline Ecological Assessments & Monitoring Activities for Offshore Renewable Energy Projects (DCCAE, 2018) (Parts 1 and 2)10,11.

Page 34 of 220 3.2.2 In addition to these overarching guidance documents, each environmental aspect (e.g. air quality) will be assessed in accordance with specific guidance and best practice for the environmental aspect. A number of other guidance documents specific to the consideration of specific topics are available for jurisdictions/countries with established offshore renewable energy sectors where significant monitoring data is available. These have been utilised as appropriate, along with European Commission Guidance. The proposed specific guidance is detailed under each environmental aspect in this Scoping Report. 3.3 EIA Screening

3.3.1 Screening is the first stage of the EIA process, whereby a decision is made on whether an EIA is required. In order to determine whether an EIA is required for the proposed development, it is necessary to determine whether it is a project listed in one of the Annexes to Directive 2011/92/EU1 (as amended by Directive 2014/52/EU)2. Dublin Array was screened in as a wind farm project (class 3 of Annex II) and requires an EIA to be undertaken. 3.4 EIA Scoping

3.4.1 This following section sets out general methodology and approach to be adopted for the EIA. This general methodology seeks to refine the scope of the EIA so that it is proportionate, concise and focuses on potential significant effects (in EIA terms). However, it is acknowledged that scoping is an on-going activity, and additional effects to be assessed in the EIAR where identified as being potentially significant through the EIA process. 3.4.2 The section should be read in conjunction with the methodologies which are presented in Section 5 and Section 6 which set out the detailed approach to be adopted for each EIA topic. 3.5 Consideration of Alternatives

3.5.1 A four stage site selection process has been used for the selection of the sites for the major elements of the project. Stage 1 involved defining the strategy for the siting. Stage 2 involved defining the essential criteria that any site has to meet, the identification of a ‘long list’ of sites that meet some of the criteria and the refinement of this to a ‘short list’ meeting all of the essential criteria. Stage 3 involves a multi-criteria assessment of the options and Stage 4 is a confirmation of the preferred option and an alternative. The options considered at Stage 3 and the reasons for their selection or rejection will be presented in the EIAR and accompanying documents.

Page 35 of 220 3.6 Receiving Environment Current Receiving Environment

3.6.1 In accordance with Section 3.6 of the draft Guidelines, a description of the baseline scenario will be provided in the EIAR of sufficient detail to accurately and reliably characterise the baseline for the purposes of EIA. The baseline scenario description will provide a reference against which the effects can be assessed (see Section 3.6). The baseline scenario for each aspect will be presented within the defined study area (and zones of influence). 3.6.2 Environmental information has been collected from publicly available data sources (such as those available from state agencies) and will be supplemented with information as agreed with relevant consultees. This Scoping Report seeks to outline the proposed methodology for establishing the baseline for each of the technical assessments. These methodologies are based on established good practice and specialist professional judgement. Baseline surveys will be undertaken to fill gaps in the available data, for example data already gathered from desk- based and field surveys already completed. 3.6.3 All methodologies for data analysis and survey will be recorded to ensure that they are replicable. The condition of the receiving environment will be used to inform whether or not an effect is significant and to understand its vulnerability and sensitivity (see Section 3.6) Likely Future Receiving Environment

3.6.4 As highlighted in Section 3.6 of the draft Guidelines and 4.6.3 of the DCCAE Guidance, an important consideration of the Dublin Array EIA is the need to include a description of the likely future receiving environment given the proposed operational life of the project. Where aspects of the baseline are anticipated to change, either through natural changes (such as seasons or climate change) or proposed plans or projects being constructed or delivered, these changes will be considered in the impact assessment – particularly for operation effects and the cumulative assessments. 3.7 Impact Assessment Process

3.7.1 The significance of an effect, either adverse or beneficial, will be determined using a combination of the sensitivity of the receptor and the magnitude of the impactiii. Where possible, a matrix approach will be used to ensure a consistent approach within the EIAR. Small variations on this approach may be necessary for some topics where topic specific guidance indicates an alternative approach is necessary, for example biodiversity. iii Unless best practice guidance recommends an alternative approach

Page 36 of 220 Receptor Sensitivity

3.7.2 The condition of the receiving environment, as defined in the baseline characterisation, will be used to inform the sensitivity of each receptor or group of receptors. The sensitivity of a receptor is a function of its capacity to accommodate change and reflects its ability to recover if it is affected. The sensitivity of the receptor is therefore quantified via the following factors:  Context – The degree to which the impacted receptor will alter from the established (baseline) conditions, i.e. how sensitive is the aspect to the environmental change. To define the context the following sub-factors will be considered:

. Adaptability – The degree to which a receptor can avoid or adapt to the environmental change;

. Tolerance – The ability of a receptor to accommodate temporary or permanent change without a significant adverse impact; and

. Recoverability – The temporal scale over and extent to which a receptor will recover following an impact.

 Value – A measure of the receptor’s importance, rarity and worth.

3.7.3 Each EIAR chapter will present a ‘Sensitivity/ importance of the environment’ table within the assessment chapter. This table will present how sensitivity is defined for the topic’s receptors based on the criteria above (i.e. context and value). 3.7.4 Where possible, four levels of sensitivity for receptors will be utilised – Negligible, Low, Medium and High. For each aspect a topic-specific definition of the levels of receptor sensitivity will be presented in the EIAR chapter, i.e. an international habitat designation could be equivalent to High whereas a local designation could be defined as Low. The sensitivity of each receptor to each impact will be determined to account for the context of the impact on the receptor. Any deviations to this approach, for example to reflect topic specific guidance will be explained in the topic EIAR chapter. The Magnitude of the Impact

3.7.5 The magnitude of an impact provides a useful initial measure of the likelihood of an environmental effect arising. Magnitude is defined for the purposes of assessment via five factors:  Extent – The area, the number of sites and/ or the proportion of a population affected over which an impact occurs;

 Duration – The time for which the impact occurs;

Page 37 of 220  Frequency – How often the impact occurs;

 Probability – How likely the impact is to occur; and

 Consequences – The degree of change relative to the baseline level and the change in character.

3.7.6 The EIA process will apply the definitions of duration of effects across topics as provided in Table 3.3 of the draft Guidelines. For instance, Momentary Effects (defined as from seconds to minutes) through to Permanent Effects (lasting over sixty years). 3.7.7 Each EIAR chapter will present a topic specific ‘Magnitude of Impact’ table which will explain how the magnitude of the identified impacts are defined based on the criteria (in the bullets) above. 3.7.8 Where possible four levels of magnitude will be utilised – Negligible, Low, Medium and High. For each aspect a definition for will be presented in the EIAR chapter which is topic specific based on the factors described above. Any deviations to this approach, for example to reflect topic specific guidance will be explained in the topic EIAR chapter. Determining the Significance of an Effect

3.7.9 The significance of an effect, either adverse, neutral or positive, will be determined using a combination of the magnitude of the impact and the sensitivity of the receptor. As indicated above, where possible a matrix approach is proposed to be used to ensure a consistent approach within the Dublin Array EIAR. Any deviations to this approach, for example to reflect topic specific guidance will be explained in the topic EIAR chapter. 3.7.10 Effects defined as Significant, Very Significant and Profound will be considered significant in EIA terms. Table 6 presents the proposed matrix for determining the significance of effect as it will be presented in the EIAR. The terminology and structure of the matrix has been informed by the draft Guidelines, in particular Figure 3.5. 3.7.11 Predictions of impact will be based on the best available data and using a combination of professional judgement, specialist knowledge and modelling where appropriate. This is especially true for the determination between whether an effect is Profound or Very Significant – see Table 6. The precautionary principleiv will be applied to ensure that potential effects are not ascribed unduly low probability of occurrence or low levels of significance.

iv Precautionary Principle: Principle adopted by the UN Conference on the Environment and Development (1992) states that in order to protect the environment, a precautionary approach should be widely applied, meaning that where there are threats of serious or irreversible damage to the environment, lack of full scientific certainty should not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

Page 38 of 220 3.7.12 Where significant effects are identified during the preparation of EIA process, it may be possible for these to be avoided or reduced during the iterative design process. The analysis of effects can also contribute to environmental protection by identifying mitigation measures. 3.7.13 This Scoping Report identifies the effects likely to be significant in EIA terms and this is proposed to be the focus of the EIA.

Page 39 of 220 Table 6 - Proposed matrix for determining the significance of effect

Existing Environment - Sensitivity

High Medium Low Negligible

Profound or Very High Significant Significant Moderate Imperceptible (significant) Adverse impact Medium Significant Moderate Slight Imperceptible

Low Moderate Slight Slight Imperceptible

Negligible Not significant Not significant Not significant Imperceptible Neutral impact Negligible Not significant Not significant Not significant Imperceptible

Low Moderate Slight Slight Imperceptible Description of Impact - Magnitude of Impact - Description Positive impact Medium Significant Moderate Slight Imperceptible Profound or Very High Significant Significant Moderate Imperceptible (significant)

Page 40 of 220 3.8 Approach to Assessment of Project Design

3.8.1 The Dublin Array EIA will be based on identifying the 'realistic worst case' design scenario for each effect considered. This ‘realistic worst case’ scenario will be referred to throughout the EIA as the 'maximum design scenario' (MDS). The MDS will be presented for each effect assessed within the EIAR. This approach ensures that the scenario that will have the greatest environmental impact (i.e. largest footprint, longest exposure, or tallest dimensions, depending on the topic) is assessed; it can then be assumed that any other (lesser) scenarios will have an impact that is no greater than that assessed. 3.8.2 The MDS approach is a resilient method for developments (particularly offshore wind where rapid technology development is optimising size, power output, construction and operational efficiency on a continuous basis), where it is not possible to identify the exact components to be used within the final development. This is because the MDS approach accommodates the necessary flexibility in design and construction whilst still ensuring that the maximum extents and ranges are assessed within the EIA. Therefore, the consent permits the use of any components so long as they are within the maximums assessed in the EIA, rather than limiting the development to existing offshore wind technology at the time of assessment, which may not be the optimum choice technically, environmentally or commercially when the project is progressed towards its procurement and construction stages. This is of particular relevance to offshore wind development, where the technology and construction practices are constantly improving. 3.8.3 This approach is considered to align with the guidance set out in Section 3.5.8 of the Environmental Protection Agency (EPA) draft Guidelines (2017)4 which state – “Where very detailed design parameters are not available, the project description for the consent process and the EIAR will need to specify the outermost (‘not to exceed’) environmental parameters of the characteristics of the proposed project. Such parameters, might include maximum dimensions, tolerance for variation, maximum emissions, range of technologies and processes to be employed etc. The EIAR thus examines the ‘worst case’ effects of the project. The detailed design can then vary within this envelope without rendering the EIA inadequate.” 3.9 Approach to Interactions of Environmental Factors

3.9.1 All environmental factors are inter-related to some extent. Interactions within the study area can be one-way interactions, two-way interactions and multiple-phase interactions may be influenced by the proposed development. An assessment of the interaction between environmental factors are required under Article 3(1)(e) of the EIA Regulations – 1. The environmental impact assessment shall identify, describe and assess in an appropriate manner, in the light of each individual case, the direct and indirect significant effects of a project on the following factors:

Page 41 of 220 a) population and human health;

b) biodiversity, with particular attention to species and habitats protected under Directive 92/43/EEC and Directive 2009/147/EC;

c) land, soil, water, air and climate;

d) material assets, cultural heritage and the landscape;

e) the interaction between the factors referred to in points (a) to (d).

3.9.2 The assessment of the Interactions of the Foregoing will consider impacts of the proposals on the same receptor. These occur where a number of separate impacts, e.g. noise and air quality, affect a single receptor such as fauna. 3.9.3 These inter-related effects are proposed to be assessed through consideration of all effects on a receptor by the proposed development. The assessment will consider the potential for all effects on that receptor to interact, whether that be spatially or temporally, resulting in the identification of inter-related effects on a receptor (for example all effects on human amenity - noise and air quality, access, and traffic - these might be short-term, temporary or transient effects or incorporate longer term effects). 3.10 Approach to Cumulative Assessment

3.10.1 A Cumulative Effects Assessment (CEA) will be undertaken as part of the Dublin Array EIA to ensure that any additive impacts arising from other developments are fully assessed, as required under Annex IV, point 5(e) of the EIA Directive (2014/52/EU)2 and Schedule 6(2)(e)(i)(V) of the EIA Regulations. The CEA will be undertaken in line with the principles outlined in the draft Guidelines and the EIA Guidelines. 3.10.2 The CEA will identify where there could be an accumulation of impacts on a sensitive receptor, which could result in the need for further mitigation (for instance a large number of minor effects may coincide to result in an adverse effect of greater severity/ harm overall). The CEA will consider other proposed development within the context of the site and any other reasonably foreseeable proposals in the vicinity. 3.10.3 'Proposed' are those projects and plans at early project stages may or may not actually be taken forward. All relevant projects/plans will be allocated into 'Tiers', reflecting their stage within the planning and development process and the associated certainty. This allows the cumulative impact assessment to present several future development scenarios, each with a differing potential for being ultimately built out.

Page 42 of 220 3.10.4 It is proposed that projects that are built and operational at the time that survey data are collected will be classified as part of the baseline conditions within the EIAR. However, consideration of the relevant application materials, including but not limited to the EIAR, will be reviewed to ensure no additional phases of work are proposed. Where there is the potential for further change in the baseline conditions from another project or where there is uncertainty then the other project will be included in the CEA also. 3.11 Approach to Transboundary Assessment

3.11.1 The Espoo Conventionv sets out the obligations of Parties to assess the environmental impact of certain activities that have the potential to have transboundary effects at an early stage of planning and to notify and consult other States in cases where there is likely to be significant adverse environmental impact on those States. This duty is encapsulated in the 2018 EIA Regulations. 3.11.2 The Dublin Array EIA will consider the following transboundary impacts:  Impacts that may occur in/on the environment of another State (i.e. their territory or territorial waters); and

 Impacts that may occur to interests of another State (for instance commercial fishing taking place within the Irish EEZ).

3.11.3 An assessment of mobile species, such as marine mammals and sea birds, where their rangesvi overlap with Natura 2000 sites for which they are qualifying features, will be undertaken in NIS both for Irish sites and those of other jurisdictions. 3.12 Mitigation Measures and Monitoring Mitigation Measures

3.12.1 Appropriate mitigation measures will be explored to avoid, prevent, reduce or offset identified potentially significant effects on the environment. Good practice strategies for mitigation are widely practiced and accepted within EIAR and will be followed when considering the methods of dealing with the environmental impacts of the proposed development.

v The Convention on EIA in a Transboundary Context. United Nations Economic Commission for Europe (UNECE), signed at Espoo, Finland, 1991 to which Ireland is a signatory. vi Foraging ranges will be applied for marine mammals and ornithology. Whereas, the ranges for fish will be taken from literature.

Page 43 of 220 3.12.2 Embedded mitigation measures are those which are inherently built into the design of the project. Where changes are required to be made to the design of the project, where a significant effect is predicted and could be reduced by design changes, these changes will be made as part of an iterative EIA process and will be clearly identified within the EIAR. The clear inclusion of these measures within the EIAR will demonstrate the commitment of Dublin Array to these design changes. By employing this method, the significance of effect presented for each identified impact may be presumed to be representative of the maximum residual effect (see Section 3.13) that the development will have, should it be approved and constructed without any additional specific mitigation. 3.12.3 In some instances, additional mitigation measures beyond the embedded mitigation measures described earlier will be outlined in the aspect EIAR chapters. The additional mitigation measures may be deemed necessary where:  An effect is significant in EIA terms, even with embedded mitigation, but additional mitigation measures are available to reduce the level of the residual effect (see Section 3.13).

3.12.4 Where relevant, these additional mitigation measures will be outlined in the aspect chapters, after the assessment of significance section. The assessment will be repeated to determine the significance of the effect with the additional mitigation measures in place. Monitoring

3.12.5 As outlined in Section 3.8.2 of the draft Guidelines, monitoring may be required (after consent is granted) to ensure that the effects from the proposed development conform with the predictions in the EIAR during operation. The monitoring, if required, will be designed to confirm EIA predictions where there may be key uncertainties. Monitoring will also seek to provides assurance that the project’s activities are compliant with the consent conditions and that mitigation is effective. 3.12.6 A list of mitigation and monitoring commitments will be included in the EIAR to provide a list of the relevant measures as per the recommendation in Section 3.8.4 of the draft Guidelines. 3.13 Residual effects

3.13.1 The residual effects are those that are the final effects after proposed mitigation measures (embedded and additional) have been implemented. The draft guidelines defined them as: “the remaining environmental ‘costs’ of a project that could not be reasonably avoided. These are a key consideration in deciding whether the project should be permitted or not.”

3.13.2 The residual effects will be clearly described in accordance with the approach to determining the significance of effect above. A summary of the residual effects will be provided for each aspect within the EIAR.

Page 44 of 220 3.14 Appropriate Assessment

3.14.1 The Habitats Directive (Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora)12 forms the basis for the designation of Special Areas of Conservation (SAC). Similarly, Special Protection Areas (SPA) are legislated for under the Birds Directive (Council Directive 2009/147/EEC on the Conservation of Wild Birds)13. The Habitats and Birds Directives are transposed into Irish law by the European Communities (Birds and Natural Habitats) Regulations 2011 (Statutory Instrument No. 477 / 2011)14. Collectively, SACs and SPA are referred to as the Natura 2000 network. These sites are important for rare, endangered or vulnerable habitats and species within the European Community. Natura 2000 sites are also referred to as European sites. 3.14.2 Under Article 6(3) of the Habitats Directive an ‘appropriate assessment’ must be undertaken for any plan or project that is likely to have a significant effect on the conservation objectives of a Natura 2000 site. An appropriate assessment is an evaluation of the potential impacts of a plan or project on the conservation objectives of a Natura 2000 site, and the development, where necessary, of mitigation or avoidance measures to preclude negative effects. 3.14.3 Article 6, paragraph 3 of the Habitats Directive states that: “Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public”. Appropriate Assessment Screening (Stage 1)

3.14.4 Screening for appropriate assessment (often referred to as AA screening or Stage 1 screening) is the first stage of a process that consists of up to four stages. The requirement to progress to the next stage is determined by the outcome of the preceding stage. Screening identifies the potential impacts and likelihood of significant effects of a project on Natura 2000 sites. To provide the required information to the competent authority (in this case An Bord Pleanála) a screening report is prepared, and this report is used by the competent authority to carry out a screening assessment. The report will include the approach and methodology, a summary of relevant legislation and reference documents including standard guidance. The approach that will be taken to preparing the AA screening report will be the same for both the onshore and offshore elements of the project. The approach that will be taken to preparing the screening report for the project is as follows:

Page 45 of 220  Identify Natura 2000 sites, within the potential zone of influence of the projects. The zone of influence will be established on a case-by-case basis for each project and different receptors (qualifying interests of the sites concerned);

 Review the features of interest and conservation objectives of the identified Natura 2000 sites;

 Review whether there is potential for the features of interest to be affected by the project, in the absence of mitigation, based on information such as the vulnerabilities of the Natura 2000 sites, location relative to the projects, the nature of the projects i.e. offshore wind turbines and onshore underground cable and the sensitivity of features of interest to typical effects of such projects. It is recognised that impacts to interest features could result via impacts to undesignated supporting habitat or resources present within the projects’ zone of influence (ZoI);

 Consider the likelihood of cumulative effects arising from the projects in- combination with other plans and projects;

 Consider the likelihood of significant effects, either alone or in-combination, using the information collated and professional scientific judgement; and

 Identify the Natura 2000 sites and pathways that should be examined at the next stage of the AA process i.e. those that are screened in on the basis that the likelihood of significant effects cannot be excluded at the preliminary stage, or in respect of which some reasonable doubt remains.

3.14.5 The requirement to progress to the next stage is determined by the outcome of the preceding stage. In other words, the outcome of the screening determines the requirement for progression to the next stage of the AA process. Natura Impact Statement (NIS)

3.14.6 The second stage of the AA process determines whether the project (either alone or in combination with other plans and projects) is likely to result in an adverse effect on the integrity of Natura 2000 sites with respect to their structure, function and conservation objectives. The report produced for ‘Appropriate Assessment’ of projects is known as a Natura Impact Statement (NIS) and documents the findings of this stage of the process.

Page 46 of 220 3.14.7 Where adverse effects are identified or where an adverse effect is uncertain, mitigation will be required. The mitigation measures will aspire to avoid impacts and effects at source insofar as possible. The mitigation measures proposed will be clearly set out and an explanation provided as to how the mitigation measures will avoid or reduce the adverse effects. In addition, details will be provided on how, and by whom, the mitigation measures will be implemented along with likelihood of their success, timescale for implementation and any proposed monitoring of their success. 3.14.8 The NIS will include a summary of the approach and methods for the second stage of the AA process and to identify the types of impacts anticipated to occur due to the projects. The NIS will consider if the integrity of Natura 2000 sites is likely to be adversely affected by the projects and proscribe appropriate mitigation measures to avoid, reduce or remedy effects. 3.14.9 The approach taken to preparing the NIS can be broadly summarised as follows:  Set out information on the Natura 2000 sites identified at screening stage as likely to be significantly affected by the project;

 Describe the elements of the project (alone or in combination with other projects or plans) that are likely to give rise to significant effects on the environment;

 Set out the conservation objectives of the site(s);

 Describe how the project or plan will affect key species and key habitats. Acknowledge uncertainties and gaps in information; and

 Describe how the integrity of the site (determined by structure and function and conservation objectives) is likely to be affected by the project or plan (e.g. loss of habitat, disturbance, disruption, chemical changes, hydrological changes and geological changes). Any uncertainties or gaps in information will be acknowledged.

3.14.10 The appropriate assessment is carried out by the competent authority and is informed by the NISvii. The requirement to proceed to next (third) stage of the AA process will be determined by the outcome of the appropriate assessment. The test to be applied by the competent authority prior to determining to grant consent is that the project “will not adversely affect the integrity of the site concerned”. A high degree of scientific certainty is required.

vii Page 28 https://www.npws.ie/sites/default/files/publications/pdf/NPWS_2009_AA_Guidance.pdf

Page 47 of 220 4 EIAR Structure 4.1 Introduction

4.1.1 As set out in Section 3 the proposed EIA methodology will comply with the requirements of the EU EIA Directive 2011/92/EU1 and EIA Directive 2014/52/EU2 and the European Union (Planning and Development) (Environmental Impact Assessment) Regulations 20183 together with the key guidance set out in this section. 4.1.2 Article 3 (1) of the amended EIA Directive (2014/52/EU)2 prescribes a range of environmental factors which are used to organise descriptions of the environment and it sets out that these factors must be addressed in the EIAR. “The environmental impact assessment shall identify, describe and assess in an appropriate manner, in the light of each individual case, the direct and indirect significant effects of a project on the following factors: a) population and human health; b) biodiversity, with particular attention to species and habitats protected under Directive 92/43/EEC and Directive 2009/147/EC; c) land, soil, water, air and climate; d) material assets, cultural heritage and the landscape; e) the interaction between the factors referred to in points (a) to (d)”.

4.1.3 Article 3(2) of the amended EIA Directive requires that the effects referred to in 3(1) shall include the expected effects deriving from “the vulnerability of the project to risks of major accidents and/or disasters that are relevant to the project concerned”. 4.1.4 Recital (12) of the EIA Directive 2014/52/EU2 provides specifically in relation to projects in the marine environment: "With a view to ensuring a high level of protection of the marine environment, especially species and habitats, environmental impact assessment and screening procedures for projects in the marine environment should take into account the characteristics of those projects with particular regard to the technologies used (for example seismic surveys using active sonars). For this purpose, the requirements of Directive 2013/30/EUviii of the European Parliament and of the Council could also facilitate the implementation of the requirements of this Directive.” 4.1.5 Article 5 (1) of the amended Directive sets out that the EIAR should contain at least the following ‘a) a description of the project comprising information on the site, design, size and other relevant features of the project;

b) a description of the likely significant effects of the project on the environment;

viii Directive 2013/30/EU of the European Parliament and of the Council of 12 June 2013 on safety of offshore oil and gas operations and amending Directive 2004/35/EC

Page 48 of 220 c) a description of the features of the project and/or measures envisaged in order to avoid, prevent or reduce and, if possible, offset likely significant adverse effects on the environment;

d) a description of the reasonable alternatives studied by the developer, which are relevant to the project and its specific characteristics, and an indication of the main reasons for the option chosen, taking into account the effects of the project on the environment;

e) a non-technical summary of the information referred to in points (a) to (d); and

f) any additional information specified in Annex IV relevant to the specific characteristics of a particular project or type of project and to the environmental features likely to be affected.’

4.1.6 It is proposed that the EIAR for the Dublin Array project will be presented in a series of six volumes, each one presenting the findings of the EIA process. The findings will be presented clearly, concisely and in a systematic way to make navigation through the document as easy to follow as possible. In order to provide clarity to the reader it is proposed to prepare a separate volume covering the environmental factors relevant to the offshore environment and a separate volume for those relating to onshore. Interactions between these two will be clearly stated in the relevant chapters. In some case, for example the chapter relating to socio- economics, tourism recreation and land use, the chapter will address both the onshore and offshore environment. Where this is the case it will be clearly stated in the chapter. 4.1.7 These volumes will be structured by specialist EIA topic on a topic-by-topic basis. This practice aligns with the guidance presented in the draft EPA guidelines and accompanying advice notes. The following section provides a brief summary of the proposed contents of each volume. Volume 1: Non-Technical Summary.

4.1.8 This will set out a non-technical summary of the EIA process and findings. In accordance with the draft EPA guidelines the non-technical summary will be short and easily followed and will contain an overview of all key likely significant effects. Volume 2: Introductory Chapters

4.1.9 Volume 2 will provide an introduction to the development and an explanation of the aims and format of the EIAR. It will identify the various competent expertsix who have contributed to the EIAR and the conclusions from consultation activities undertaken as part of the EIA process.

ix Details and affiliations of the organisations will be provided, which will have contributed to the development of the EIAR, demonstrating sufficient expertise and experience to qualify as ‘competent experts’.

Page 49 of 220 4.1.10 This volume will contain a description of the proposed development comprising information on the site, design, size and other relevant features of the project including the onshore electricity grid connection works. A description of the alternatives studied by the Applicant together with the main reasons for the option chosen will be included in this volume. 4.1.11 In addition, this volume will contain a detailed methodology of the EIA process for Dublin Array. It will include details of the cumulative and transboundary approaches and identified projects and plans to be considered in the cumulative assessment. This volume will also detail the relevant Policy and Legislation and demonstrate compliance of the project with Government Policy, EU obligations and global sustainability goals through the production of the EIA. Volumes 3 (offshore) and Volume 4 (onshore)

4.1.12 Each volume will contain the specialist topics relevant to that spatial area (i.e. onshore or offshore). Each section will provide detailed information on all aspects of the existing (baseline) environment and will identify, describe and present an assessment of the likely direct and indirect significant effects of the proposed project on the environment. Mitigation and monitoring measures to avoid, prevent, reduce or offset these significant effects will be described together with residual impacts arising following the implementation of these. The relevant sections are set out in Table 7. 4.1.13 To undertake a robust and proportionate EIA of the proposed development, the identified specialist topics, proposed in this Scoping Report and in Table 7 have been derived from a range of sources comprising:  The Applicant and its specialist advisor’s knowledge of the likely significant effects which may arise as a result of the construction, operation and decommissioning of the project;

 Consideration of the receiving environment and its potential sensitivity in respect of the proposed development, including extensive desk top research and associated field surveys;

 Advice and opinion provided by statutory and non-statutory consultees;

 A review of the Strategic Environmental Assessment (SEA) of the Offshore Renewable Energy Development Plan (OREDP) in the Republic of Ireland was undertaken and formed the primary scope of the offshore sensitivities proposed to be assessed within the Dublin Array EIA (see Section 5);

Page 50 of 220  A review and consideration of the potential sensitivities and impacts identified in National Marine Planning Framework (Consultation Draft) was undertaken during the formulation of the offshore EIA scope. For some potential impacts and sensitivities, it was concluded that there is not a source-receptor-pathway for the proposed development. Where this conclusion was reached details are provided in the Scoping Report Sections 5 and 6;

 Consideration of guidance and best practice including but not limited to:

. Environmental Impact Assessment of Projects. Guidance on Scoping (Directive 2011/92/EU as amended by 2014/52/EU). (European Commission, 2017)15;

. Environmental Impact Assessment of Projects, Guidance on the preparation of the Environmental Impact Assessment Report (Directive 2011/92/EU) as amended by 2014/52/EU) (European Commission, 2017)16; Guidance on Integrating Climate Change and Biodiversity into Environmental Impact Assessment (European Commission, 2013)17;

. The Guidance on EIS and NIS preparation for Offshore Renewable Energy Projects (DCCAE, 2017)9;

. Guidelines for Planning Authorities and An Bord Pleanála on carrying out Environmental Impact Assessment, (Department of the Environment Heritage and Local Government (Ireland) (DEHLG), 2018)8;

. Guidance on Marine Baseline Ecological Assessments & Monitoring Activities for Offshore Renewable Energy Projects (DCCAE, 2018) (Parts 1 and 2)10,11;

. Revised Guidelines on the Information to be Contained in Environmental Impact Statements (Environmental Protection Agency, 2017)4;

. Draft Advice Notes on Current Practice (in the preparation of Environmental Impact Statements) (Environmental Protection Agency, 2015)7; and

. The Applicant’s experience in the design, construction and operation of offshore wind farms and associated infrastructure.

4.1.14 One of the key conclusions by the SEA of OREDP, the marine environment and its living, and non-living, resources should not be adversely affected. Therefore, the scope of the topics in Section 5 have been developed in line with the findings of the SEA; to ensure that any effect to potentially to be significantly adversely to the environment (in EIA terms) have been scoped in.

Page 51 of 220 4.1.15 The scope of the EIAR also seeks to assess the interdependent nature of activities in the maritime area. Whilst consideration of the National Marine Planning Framework (NMPF) will be intrinsic to the offshore chapters in the EIAR, explicit references have been provided in this Scoping Report, where the scope has been refined by review of the draft NMPF. 4.1.16 Table 7 sets out each of the specialist topics proposed to be included in the Dublin Array EIAR and the corresponding environmental factor as prescribed in Article 3 (1) of the amended EIA Directive (2014/52/EU)2. 4.1.17 It also sets out the proposed volume and document structure of the EIAR. Volume 6 and 7 shall contain technical appendices relating Volumes 3 and 4.

Table 7 - Volume and Document Structure of the EIAR Corresponding environmental Chapter Chapter Title factor in Article 3(1) of the Number amended Directive Volume 1: Non-technical Summary 1.1 Non-technical Summary - Volume 2: Introductory Chapters 2.1 Introduction - 2.2 Consents, Policy and Legislation - 2.3 EIA Methodology - 2.4 Cumulative Impact Assessment Methodology - 2.5 Project Description - 2.6 Site Selection and Alternatives - 2.7 Consultation - Volume 3: Offshore Chapters 3. Land, soil, water, air and 3.1 Physical Processes climate 3. Land, soil, water, air and 3.2 Marine Water and Sediment climate 3.3 Benthic and Intertidal Ecology 2. Biodiversity 3.4 Fish and Shellfish Ecology 2. Biodiversity

Page 52 of 220 Corresponding environmental Chapter Chapter Title factor in Article 3(1) of the Number amended Directive 3.5 Marine Mammal Ecology 2. Biodiversity 3.6 Offshore Ornithology 2. Biodiversity 3.7 Offshore Designated Sites 2. Biodiversity 3.8 Commercial Fisheries 1. Population and human health 3.9 Shipping and Navigation 1. Population and human health 4. Material assets, cultural 3.10 Infrastructure and Other Uses heritage and the landscape 4. Material assets, cultural 3.11 Aviation heritage and the landscape 4. Material assets, cultural 3.12 Marine Archaeology heritage and the landscape 4. Material assets, cultural 3.13 Seascape, Landscape and Visual Amenity heritage and the landscape 3.14 Underwater noise 2. Biodiversity Volume 4: Onshore Chapters 4.1 Biodiversity 2. Biodiversity 3. Land, soil, water, air and 4.2 Land, Soils and Geology climate 3. Land, soil, water, air and 4.3 Water (Hydrology, Hydrogeology and Flood Risk) climate 3. Land, soil, water, air and 4.4 Air Quality climate Noise and Vibration *this chapter will also deal 1. Population and human health 4.5 with effects on onshore receptors arising from the offshore works. 4. Material assets, cultural 4.6 Traffic and Transport heritage and the landscape Cultural Heritage (Archaeology and Monuments) 4. Material assets, cultural *this chapter will also deal with the effects on heritage and the landscape 4.7 onshore receptors arising from the offshore works. 4. Material assets, cultural 4.8 Landscape and Visual heritage and the landscape Socio-economic, Tourism, Recreation and Land 1. Population and human health 4.9 Use *this chapter will also assess effects on offshore recreation e.g. sailing.

Page 53 of 220 Corresponding environmental Chapter Chapter Title factor in Article 3(1) of the Number amended Directive 3. Land, soil, water, air and 4.10 Climate climate Volume 5: Interaction of the Foregoing and Conclusions Volume 6: Technical Appendices (offshore) Environmental factors associated 6.1 Offshore Technical Appendices with Volume 3 Volume 7: Technical Appendices (onshore) Onshore Technical Appendices Environmental factors associated with Volume 4 7.1

Page 54 of 220 5 Specialist Topics Offshore 5.1 Introduction

5.1.1 The following section of the Scoping Report sets out the proposed scope and methodology to be adopted for the specialist offshore topics proposed to be included in the Dublin Array EIA. Each specialist topic includes the following contents:  Introduction – an introduction to the topic;

 Policy and Guidance – policy and guidance relevant to the topic;

 Receiving environment (baseline) – a summary description of the receiving environment relevant to the topic;

 Methodology – the proposed scope and methodology to be adopted; and

 Potential Impacts – a description of the potential impacts to be included in the EIA. 5.2 Physical Processes and Marine Water and Sediment Quality Introduction

5.2.1 This section of the Scoping Report sets out the approach to the characterisation of marine geology, oceanography and physical processes, hereafter referred to as physical processes, and the intended scope of and approach to the assessment of impacts on physical processes. For the purposes of scoping, this chapter also incorporates sediment and water quality, which will be provided as a separate chapter within the subsequent EIAR, as presented in Table 7. Policy and Guidance

5.2.2 The assessments will comply with the guidance relevant to the design and acquisition of data, standards in terms of data quality and coverage of the baseline and assessment for physical processes, and marine water and sediment quality, as presented in Section 3.2. 5.2.3 In addition, a number of other guidance documents are referenced in the DCAAE guidance specific to the consideration of physical processes and marine water quality where comprehensive guidance has been developed. This guidance will be used to inform the assessment of the potential impacts:

Page 55 of 220  Coastal Process Modelling for Offshore Wind Farm Environmental Impact Assessment: Best Practice Guidance (ABPmer and HR Wallingford, 2009)18;

 Potential Effects of Offshore Wind Developments on Coastal Processes (ABPmer and Metoc Plc, 2002)19;

5.2.4 In addition, a number of other guidance documents specific to the consideration of physical processes are available for jurisdictions/countries with established offshore renewable energy sectors where significant monitoring data is available to inform the assessment of the physical environment; examples of such guidance include:  Guidelines for Data Acquisition to Support Marine Environmental Assessments of Offshore Renewable Energy Projects. (Cefas, 2011)20;

 Environmental impact assessment for offshore renewable energy projects. (BSI, 2015)21;

 Further review of sediment monitoring data. (COWRIE ScourSed-09).’ (ABPmer, HR Wallingford and Cefas, 2010)22;

 Offshore Windfarms: Guidance note for Environmental Impact Assessment in Respect of FEPA and CPA requirements (Cefas, 2004)23;

 Water Framework Directive assessment: estuarine and coastal waters (Environment Agency, 2017)24; and

 European Commission’s Water Framework Directive (WFD) guidance documents as referred to by WFD Directive Irelands’ website.

5.2.5 Through email correspondence with Environmental Protection Agency and the Department of Housing, Local Government and Heritage it is understood that planning guidance for WFD assessments is anticipated to be released for public consultation by the end of 2020. This guidance will be reviewed, on publication, to ensure that the WFD assessment meets the requirements therein. Receiving Environment – Baseline

5.2.6 The baseline for the physical marine environment will be provided within the EIAR chapters and supplemented by a more detailed baseline report. Within the guidance (DCAAE, 2017) this topic of the EIAR is captured under two topic headings, namely Soils and Geology and Water, and incorporates the following:  Soils and geology:

. Coastal erosion;

. Sedimentation processes; and

Page 56 of 220 . Seabed geology and morphology.

 Water:

. Water quality;

. Bathymetry and hydrography; and

. Sediments. Seabed Morphology and Sediments

5.2.7 The proposed array is located on a raised area of the seafloor, known as the Kish and Bray Banks. The Kish and Bray Banks occur as part of a series of coast-parallel north-south trending offshore banks along the east coast of Ireland. Water depths on the Kish and Bray Banks vary between 2m to 26m (see Figure 15). Other morphological features likely to be found in the study area are mega ripples and sandwaves. These features will be characterised within the baseline to provide the understanding of indicative geomorphological change over time, for both the bank systems and the sand wave features. 5.2.8 The Dublin Array site is dominated by sediment classed as sand (see Figure 16). The offshore export cable corridor associated with the northerly landfall zone (see Figure 7, Figure 16), near Poolbeg, close to shore is dominated by mud to muddy sand deposits. Conversely the offshore export cable corridor associated with the southerly landfall zone, near Shanganagh has instances of coarse sediments and potential for rock exposure (see Figure 16). There is a general decreasing trend of suspended particulate matter with distance offshore with the highest concentrations in the study area observed in Dublin Port. Tidal Currents and Waves

5.2.9 Strong currents and tidal flows are experienced around the Kish and Bray Banks. The area experiences approximately southern flow during ebb tidex and a northern flow during the flood tide. The larger waves in the area originate predominantly from the south and south easterly directions. This is consistent with the concept that waves arriving from the south are a result of channelling from the Atlantic, whereas those from other orientations are a result of the relatively short fetchxi of the Irish Sea.

x Ebb is the tidal phase during which the tidal current is flowing seaward (ebb current) and the water level is decreasing. Whereas, the flood is the tidal phase during which the tidal current is flowing inland (flood current) and the water level is increasing. xi Distance over which a wind acts to produce waves.

Page 57 of 220 Geology

5.2.10 The current seabed landscape is dominated by glacial advance and retreat resulting in the deposition of glacial and post-glacial sediments on top of largely Palaeozoic sedimentary bedrock. The eastern coast of Ireland (including Dublin) is especially susceptible to coastal erosion, owing to the presence of unconsolidated sediments along the coastline. Water Quality

5.2.11 Dublin Bay has historically had issues with contamination though the levels of contaminants have reduced in the sediments over time due to reductions in shipbuilding, although concentrations of PAHs, metals and a range of pesticides are high in some areas. (Brooks et al., 2016)25. For example, levels of some metals exceeded either the upper level (Copper, Lead, Arsenic) or the lower level (Mercury) for the Irish action list guidelines for metals in sediment (Marine Institute, 2006)26. The Marine Institute (2014)27 also highlighted that some of the historical persistent organochlorine contaminants, such as PCBs and organochlorines (these chemicals are no longer produced) but noted a decline with time. The Marine Institute recommended that efforts to reduce the introduction of contaminants further upstream in the catchments should be made. 5.2.12 Sediment bound contaminants are likely to be low in the array and the majority of the export cable corridors. The highest concentrations are likely to be in the inshore parts of the northern export cable corridor where finer sediments are present and the cable route transverses through Dublin Port (through the Liffey Estuary) xii. 5.2.13 Other pollutants associated with run-off, shipping and industry have been a persistent problem in the bay and levels found in both sediment and water remain relatively high and above recommended quality standards (Marine Institute, 2014)27. 5.2.14 As well as pollution from contaminants, Dublin Bay has had historical (and recent) issues with excess nutrients (Brooks et al, 2014)25. The Lower Liffey and Tolka Estuaries were first designated as ‘sensitive’ areas under the Urban Waste Water Treatment Directive in 2001. Recent monitoring to support the WFD status, indicated that the water quality has improved with the chemical status of the estuary now being designated as having the potential to support Good chemical status.

xii The potential for contamination increases with the proportion of fine sediment present since it is these smaller particles which bind contaminants, due to their larger surface area to volume ratios and higher organic carbon content.

Page 58 of 220 690000 700000 710000 ¯

LEGEND Wind Farm Area and Offshore Cable Corridor Sediment Waves

5910000 5910000 Depth (m) 0 130

5900000 5900000 Data Source: Bathymetry data from Infomar

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of the bathymetry VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB SM

DRAWING NUMBER: 15

SCALE 1:125,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

0 5 10

5890000 Kilometres 5890000

Service Layer Credits: INFOMAR, Government of Ireland. Esri, HERE, Garmin, © OpenStreetMap contributors, and the GIS user community

690000 700000 710000 690000 700000 710000

LEGEND Wind Farm Area and Offshore Cable Corridor Seabed Substrate (INFOMAR)

5910000 5910000 Coarse Substrate Mixed Sediment Rock Sand Sandy Mud / Muddy Sand

5900000 5900000 Data Source: Bathymetry data from Infomar

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of the seabed sediment types VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB SM

DRAWING NUMBER: 16

SCALE 1:125,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

0 5 10

5890000 Kilometres 5890000

Service Layer Credits: Esri, HERE, Garmin, © OpenStreetMap contributors, and the GIS user community INFOMAR/INSS Project, a joint seabed mapping project between the Geological Survey Ireland and the Marine Institute.

690000 700000 710000 Methodology

5.2.15 A literature review of baseline information will be sourced from available site specific and regional data including outputs from Integrated Mapping for the sustainable development of Ireland’s Marine Resource (INFOMAR)xiii surveys. These data will include multibeam bathymetry, backscatter, single beam echosounder, sub-bottom profiling, magnetometer data and seabed sampling data used to inform the metocean conditions, bed mobility, and sediment pathways. 5.2.16 Where the data from previous site specific studies are still relevant, they will be used and supplemented by more contemporary studies undertaken to support site investigation of the project. A literature review will be undertaken to provide an understanding of the physical processes controlling the receptors, pathways and features within the study area. Broader context will also be provided by describing the regional baseline across the Irish Sea as appropriate, given the scale of the processes discussed. 5.2.17 The data collated through the literature review will be supplemented by the outputs of the site specific modelling, which will provide the primary source of tidal currents and wave climate data for the project. 5.2.18 The suite of numerical models developed to support the EIA are collectively termed the Dublin Array Physical Processes Modelling System (DAPPMS), and this includes a Hydrodynamic (HD) model (which quantifies the tidal regime) and a Spectral Wave (SW) model (which quantifies the wave climate). The DAPPMS was built using the MIKE21 Flexible Mesh (FM) modelling system. This software has international recognition as an appropriate platform for model development and is specifically identified in the COWRIE best practice guidance as being suitable for the purpose of EIA studies for Offshore Wind Farm developments (Lambkin et al., 2009)28 . 5.2.19 The physical environment study area will be defined by the zone of influence (ZoI), defined by the numerical modelling to quantify the worst case spatial extent of potential impacts. However, it should be noted that for the assessment of coastal erosion impacts the study area will extend beyond MHWS. 5.2.20 The EIAR chapter and assessment will be supported by the following appendices:  Model calibration and validation reports, one for each of the models developed, which will provide technical details of the underlying data utilised to construct the models, the data utilised to calibrate and validate the models; and the overall performance of the models;

xiii formerly Irish National Seabed Survey (or NSS), a joint seabed mapping project between the Geological Survey of Ireland (GSI) and the Marine Institute.

Page 61 of 220  Technical modelling report detailing the hydrodynamic and wave model simulations undertaken and the results. These simulations will provide quantification of the baseline environment (tidal levels, current speeds and waves) and the potential changes as a result of the proposed development; and

 A technical baseline report which will provide a robust and detailed characterisation of the physical environment to support the EIA. Potential Impacts

5.2.21 While marine physical processes can largely be considered as ‘pathways’ for indirect effects on other receptors, a small number of features have been identified as potentially sensitive physical processes receptors. The potential impacts for physical processes to be considered in the EIA are presented in Table 8. The cells shaded in grey indicate that there is no source- receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so will not be applicable to the construction and decommissioning phases of the proposed development.

Table 8 – Potential impacts on physical processes arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Increases in suspended sediment concentrations and underlying seabed levels. Increases may occur as a result of construction (such as sandwave    clearance) and operation and maintenance (such as cable maintenance or repair) activities, in turn, may result in variations in the underlying bed levels and changes to the seabed sediment type.

Potential changes to the wave and tidal regime. The interaction between the naturally present metocean regime (waves and currents) and the presence and installation of the wind farm  infrastructure may result in patterns of change in current speed, wave energy, and turbulence.

Potential change to coastal features and coastal erosion. This may occur as a result of changes in metocean regimes, due to the  presence of wind farm infrastructure.

Page 62 of 220 Project Phase Potential changes to the sediment transport regime This may occur as a result of the installation of wind farm infrastructure willPotential be primarily Impact assessed on the nature and magnitude of any impacts on the metocean regimes, which control the rates and patterns of  sediment transport both within the near and far field. Particular consideration will be given the sand bank receptors within the study area.

Localised scouring of the seabed. The wind farm infrastructure has the potential to cause localised scouring of seabed sediment, leaving a depression and localised  alterations to sediment transport patterns. The extent and depth of scour may vary over time and will be assessed within the context of the characterised baseline.

Potential impacts of the installation of export cables in the landfall and intertidal zones. The physical impact of cable installation at the landfall in terms of morphology and release of inert drilling mud will be assessed. The  modelling system will be used to simulate the release of drilling mud. Whereas the potential impacts on morphology will be assessed as a desktop analysis, considering available relevant coastal processes data (e.g. coastal monitoring reports).

5.2.22 The physical processes assessment will consider the potential impacts outlined above on features of adjacent NATURA 2000 sites, Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) located within the zone of influence. 5.2.23 The potential impacts for marine water and sediment quality to be considered in the EIA are presented in Table 9. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development.

Page 63 of 220 Table 9 - Potential impacts on marine water and sediment quality arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Potential deterioration in water quality as a result of proposed activities (seabed preparation, cable installation etc.) primarily with respect to    changes in suspended sediment concentrations, water clarity and nutrients as a result of the proposed development;

The potential release of contaminated sediments as a result of sediment disturbance during construction and operation and    maintenance (such as cable maintenance or repair) activities; and

Accidental releases and spills of construction materials or chemicals.   

5.2.24 The outputs from the physical processes assessments and the information on changes to marine physical processes pathways will be used to inform other EIA topic assessments, including benthic and intertidal ecology, fish and shellfish and archaeology and cultural heritage. The importance of any changes will be evaluated in the context of the wide range of natural variability, such as storm events. 5.2.25 An assessment of all coastal and transitional Water Framework Directive (WFD) water bodies, within 5km of the offshore proposed developmentxiv, will be undertaken to ensure there is no deterioration as a result of the project’s activities. 5.2.26 An assessment of cumulative and transboundary effects (as outlined in Sections 3.10 and 3.11 of this Scoping Report respectively) on physical processes and marine water and sediment quality will be undertaken as part of the impact assessment process (as appropriate).

xiv This distance was taken from the Water Framework Directive assessment: estuarine and coastal waters (Environment Agency, 2017);

Page 64 of 220 5.3 Underwater Noise Introduction

5.3.1 DCCAE 2017 guidelines identify the potential impacts of underwater noise on ecology as a result of offshore renewable energy projects. There are several ‘noisy’ activities associated with offshore wind farm developments, with the loudest source of noise during construction associated with the piling of foundations. 5.3.2 Increased levels of underwater noise in the marine environment may result in mortality, injury or disturbance and displacement of fish and marine mammals. Therefore, the potential impacts on these receptors are outlined in Sections 5.5 and 5.7 of this Scoping Report, respectively. This section seeks to outline the methodology proposed to assess the impacts of underwater noise in the EIAR. Methodology

Fish Ecology

5.3.3 The underwater noise modelling will determine the spatial extent of the impact area associated with subsea noise produced during percussive piling, and by reference to the thresholds described in Popper et al., (2014)29. The noise modelling will incorporate information on the likely source levelsxv for piling (dependent on a number of parameters including hammer energy, pile type and diameter) and the predicted propagation of the sound (dependent on bathymetry, substrate type etc.) to predict the area over which sound levels may be above the threshold criteria (which consider mortality, injury and disturbance effects). Noise assessments will be informed by topic specific guidance looking at the behavioural responses of fish and shellfish by a number of researchers including, for example, Hawkins 200630; Nedwell et al., 200731; Popper, and Hastings 200932.

xv The amount of sound radiated by a sound source. It is defined as the intensity of the radiated sound at a distance of 1 meter from the source, where intensity is the amount of sound power transmitted through a unit area in a specified direction. Source level is given as a relative intensity in units named decibels (dB). In underwater sound, decibels are referenced to a pressure of 1 micro Pascal (µPa). Therefore, source level is reported in units of dB re 1 µPa @ 1 m.

Page 65 of 220 Marine Mammals

5.3.4 Underwater noise modelling will be completed to determine the spatial extent of the impact area associated with subsea noise produced during percussive piling, and by reference to the most up to date guidance and criteria described in Southall et al., 201933. These criteria were designed as a tool to assess how much noise a marine mammal can be exposed to before it affects its hearing sensitivity (i.e. shifting up its hearing threshold) within certain frequency ranges. The noise modelling will incorporate information on the likely source levels for piling (dependent on a number of parameters including hammer energy, pile type and diameter) and the predicted propagation of the sound (dependent on bathymetry, substrate type etc.) to predict the area over which sound levels may be above the threshold criteria (which consider mortality, injury and disturbance effects). 5.3.5 The quantitative noise impact assessment will combine the most up to date spatially explicit density calculations for each species with quantification of the spatial and temporal extent of ‘impact footprints’ for each noise related impact in order to provide a quantitative prediction of the number of animals at risk. This information will also take into account the scientific evidence on the movement and behaviour of marine mammals, both under baseline conditions and in response to piling noise. Potential Impacts

5.3.6 For the potential impacts on noise sensitive receptors refer to Sections 5.5 and 5.7 of this Scoping Report respectively. 5.4 Benthic and Intertidal Ecology Introduction

5.4.1 This section of the Scoping Report sets out the approach to the characterisation of benthicxvi and intertidalxvii ecology, and the intended scope of and approach to the assessment of impacts on intertidal and benthic ecology including species of conversation interest.

xvi The benthic zone is below low tide and so is always covered by water. The benthic zone extends along the seafloor of the ocean basin encompassing the sediment surface and subsurface layers. xvii Denoting the area of a seashore which is covered at high tide and uncovered at low tide.

Page 66 of 220 Policy and Guidance

5.4.2 The assessments will comply with guidance relevant to the design and acquisition of data, standards in terms of data quality and coverage of the baseline and assessment for benthic and intertidal ecology, as presented in Section 3.2. 5.4.3 In addition, a number of other guidance documents specific to the consideration of benthic and intertidal ecology are available from jurisdictions/countries with established offshore renewable energy sectors where comprehensive guidance has been developed. This guidance will be used to inform the assessment of the potential impacts:  Guidance on Survey and Monitoring in Relation to Marine Renewables Deployments in Scotland Volume 5: Benthic Habitats (Scottish National Heritage, (SNH), 2011)34;

 Guidelines for EIA in Britain and Ireland. Marine and Coastal, Final Document (CIEEM, 2010)35;

 Guidance note for EIA in respect of FEPA and CPA requirements (Cefas et al., 2004)23;

 Guidelines for data acquisition to support marine environmental assessments of offshore renewable energy projects (Cefas, 2011)20; and

 Guidance on Environmental Considerations for Offshore Wind Farm Development (OSPAR, 2008)36. Receiving Environment – Baseline

5.4.4 The characterisation will provide a description of the species and habitats, including those of conservation importance, within the projects ‘ zone of influence’ (ZoI). A brief description of the baseline is provided below. 5.4.5 Data from existing studies confirms that the Kish and Bray Banks are two interconnected sandbanks characterised by sand, shell, gravel and cobble sediments. To the east of the sandbanks, the general area is characterised by a large expanse of sand and areas of sand and shell. The literature indicates that the benthic habitats of the Kish and Bray Banks are characterised with moderate faunal diversity and a range of biotopes depending on the sediment structure. None of the surveys of the area carried out to-date have indicated the presence of any rare or unusual species, or benthic species of conservation importance. Areas of intertidal sand and geogenic reefxviii are present in the nearshore areas where the proposed export cable route corridor reaches landfall at Shanganagh (Gavin and Doherty, 2019)37.

xviii Formed by non-biogenic substrate and is topographically distinct from the surrounding seafloor.

Page 67 of 220 5.4.6 The intertidal area at the Shanganagh Cliff and Park landfall zones has been characterised (Aquafact, 2017)38 and shows the upper shore consisting of a band of cobbles and pebbles with occasional boulders grading into a finer gravel and coarse sand down the shore. This zone was classified as barren littoral shinglexix. The infaunal analysis revealed low numbers of oligochaetes and talitrid amphipods similar to the talitrids on the upper shore and strand-line biotopexx. The mid shore at the landfall site consisted of boulders and cobbles covered with ephemeral green algae (Ulva intestinalis) with some Porphyra purporea, consistent with the Ephemeral green and red seaweeds on variable salinity and/or disturbed eulittoral mixed substrata biotopexxi. The lower shore along the transect length was consistent with the Polychaetes and Angulus tenuis in littoral fine sand biotopexxii. 5.4.7 Scally et al. (in prep)39 collected 11 subtidal day grabs in the subtidal area of Dublin Bay, through which the northern export cable corridor transects, as part of the 2015 to 2018 compliance programme for EU Article 17 monitoring of marine habitats. A single marine community complex was identified – Fine sands with Angulus tenuis community complex. This survey (collected by Scally et al) included granulometric and organic carbon analysis and indicated the sediment profile was typical of fine sands with low organic matter content. 5.4.8 There are a number of designated subtidal habitats that are associated with Natura 2000 sites within the study area (see Figure 17). The relevant important habitats will be described as part of the baseline characterisation. Relevant designated sites for benthic and intertidal ecology include:  Lambay Island SAC (reefs);

 Rockabill to Dalkey Island SAC (reefs);

 South Dublin Bay SAC (mudflats and sandflats not covered by seawater at low tide, salicornia and other annuals colonising mud and sand, Atlantic salt meadows and Mediterranean salt meadows);

 North Dublin Bay SAC (mudflats and sandflats not covered by seawater at low tide, salicornia and other annuals colonising mud and sand, Atlantic salt meadows and Mediterranean salt meadows);

 Wicklow Reef SAC (reefs);

xix The Marine Life Information Network (MarLIN) UK and Ireland classification - LS.LCS.Sh.BarSh xx MarLIN classification - (LS.LSa.St.Tal) xxi MarLIN classification - (LR.FLR.Eph.Eph.X) xxii MarLIN classification - (LS.LSa.FiSa.Po.Aten)

Page 68 of 220  Baldoyle Bay SAC (mudflats and sandflats not covered by seawater at low tide, salicornia and other annuals colonising mud and sand, Atlantic salt meadows and Mediterranean salt meadows);

 Malahide Estuary SAC (mudflats and sandflats not covered by seawater at low tide, salicornia and other annuals colonising mud and sand, Atlantic salt meadows and Mediterranean salt meadows);

 Rogerstown Estuary SAC (mudflats and sandflats not covered by seawater at low tide and estuaries, salicornia and other annuals colonising mud and sand, Atlantic salt meadows and Mediterranean salt meadows);

 Codling Fault Zone SAC (submarine structures made by leaking gas); and

 Transboundary impacts on Natura 2000 sites, within other jurisdictions, on benthic ecology qualifying features are not anticipated due to the lack of a source-receptor- pathway.

Page 69 of 220 675000 700000 725000

Rogerstown Estuary SAC Lambay Island SAC (reefs) Malahide LEGEND Estuary SAC Wind Farm Area and Offshore Cable Corridor

5925000 5925000 Special Area of Conservation

Baldoyle Bay SAC Rockabill North Dublin to Dalkey Bay SAC Island SAC Codling (reefs) Fault Zone SAC

South Dublin Bay SAC 5900000 5900000

Data Source:

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of Natura 2000 sites of relevance to benthic and intertidal ecology VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB LS

DRAWING NUMBER: 17

SCALE 1:300,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

0 10 20

5875000 Wicklow Kilometres 5875000

Reef SAC Service Layer Credits: Esri, Garmin, GEBCO, NOAA NGDC, and other contributors (reefs)

675000 700000 725000 Methodology

5.4.9 For the purposes of the benthic, subtidal and intertidal habitats, the study area for the EIA will encompass the project footprint for both the array and cable corridors up to MHWS and the wider ZoI of the proposed project. The ZoI of the project for benthic and subtidal habitats will be represented by the modelled tidal ellipse that describes the maximum distance over which suspended sediments resulting from the proposed activities may be carried over a single tidal cycle. 5.4.10 The baseline description of the receiving environment in the EIAR will include a comprehensive understanding within the study area. This robust characterisation will allow for the prediction of any likely significant effects arising from the development. The baseline description will establish the spatial distribution and abundance of species within subtidal reef, subtidal sediments and littoral habitats and the presence of:  Species and habitats of conservation importance protected under the relevant conservation legislation;

 The benthic communities characterising the intertidal and subtidal areas, including priority, rare, protected, invasive or endangered species; and

 Species or habitats sensitive to potential impacts associated with offshore wind development.

5.4.11 A desk based review will be undertaken to collate and analyse all existing datasets across the study area, including historic and contemporary data, including but not limited to:  Marine Institute Benthic Ecological Quality Element Sampling and analysis of Dublin Bay and the Tolka Estuary 2017 to 2019;

 Marine Monitoring of Annex I Habitats; and

 EU Seamap data.

5.4.12 Benthic sediment data for the nearshore portions of the study area is available from survey efforts focused on compliance with both the Water Framework Directive and the EU Habitats Directive. Key data sources include surveys and conservation assessments undertaken by NPWS as a part of a baseline mapping programme of the extent, distribution and broad community complexes of selected subtidal reef within Natura 2000 sites in Ireland. The baseline will incorporate data collected through the Marine Monitoring of six Annex I Habitats (Scally et al., 2020)39, which provides the most recent conservation assessment of relevant features in Irish marine SACs.

Page 71 of 220 5.4.13 To comply with the guidance (DCAAE, 2018)10,11 and in accordance with advice provided by the Development Applications Unit (DAU) /NPWS (meeting dated 09/05/19), the existing data sources will be supplemented through a site specific benthic ecology survey which will be undertaken across the array and offshore export cable corridor. Subtidal benthic habitats will then be sampled via a combination of targeted benthic infaunal grab sampling and drop-down video (DDV) surveys. Sediment samples will also be collected for contaminants and particle size analysis. 5.4.14 The Guidance (DCAAE, 2017)9 also requires the intertidal benthic habitats to be characterised by surveys which will be obtained by walkover surveys appropriately designed to assess the full zonation and species composition of the habitat. Potential Impacts

5.4.15 Consideration will be given to the following potential impacts on benthic (subtidal and intertidal) ecology arising from the development of the Project and within each phase of development are presented in Table 10. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so would not be applicable to the construction and decommissioning phases of the proposed development.

Table 10 – Potential impacts on benthic and intertidal ecology arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Increased suspended sediment and turbidity Sediment disturbance arising from construction activities, such as cable laying and foundation installation, operational activities (such as cable remedial works) and decommissioning may result in adverse effects on    benthic communities through smothering. The assessment will be informed by the findings of the physical processes modelling of the extent of any sediment plumes and subsequent sediment deposition.

Loss of habitat (damage and/or loss to habitats and non-mobile species)   

Page 72 of 220 Project Phase The proposed activities will be considered in terms of long term habitat loss and alteration. Consideration will be given to the sensitivity of key species within study area to habitat loss and habitat change. Potential Impact Habitat disturbance There is the potential for direct habitat disturbance during construction    and maintenance activities in the array area and along the export cable corridor, due to, for example, cable laying and foundation installation.

Changes in physical processes The presence of the subsea infrastructure can result in potential effects on benthic communities arising from scour effects, changes in sediment  transport and wave and tidal current regimes. The assessment will be informed by the findings of the physical processes modelling and assessment.

Reduction in water and sediment quality through release of contaminated sediments and/or accidental contamination The impacts of changes to water and sediment quality resulting from    development activities on benthic communities will be undertaken. The assessment will be informed by the findings of the physical processes modelling and the marine water quality and sediment assessment.

Colonisation of hard substrate Man-made substructures (foundations and associated scour/cable protection) on the seabed are expected to be colonised by a variety of  marine organisms. This can result in an increase in local biodiversity and alterations to the prevailing benthic habitats and communities.

Introduction of marine invasive non-native species Increased risk of introduction or spread of marine invasive non native species (MINNS) due to increased vessel movements during all phases    of the project (e.g. ballast water) which may facilitate the spread of non-native species and may subsequently impact biodiversity and benthic ecology of the area.

5.4.16 An assessment of cumulative and transboundary effects (as outlined in Sections 3.10 and 3.11 of this Scoping Report respectively) on the existing benthic ecology will also be undertaken as part of the impact assessment process. The NIS will include a full assessment of the potential impacts on Natura 2000 sites designated for benthic features within the study area.

Page 73 of 220 5.5 Fish and Shellfish Ecology Introduction

5.5.1 This section of the Scoping Report sets out the approach to the characterisation of fish (benthic, pelagic and elasmobranchxxiii species) and shellfish species of commercial and conservation importance within the study area. This section also presents the intended scope of and approach to the assessment of impacts on fish and shellfish ecology. Policy and Guidance

5.5.2 The assessment will comply with guidance relevant to the design and acquisition of data, standards in terms of data quality and coverage of the baseline and assessment for fish and shellfish ecology, as presented in Section 3.2. 5.5.3 In addition, guidance documents specific to the consideration of fish and shellfish ecology are available from jurisdictions/countries with established offshore renewable energy sectors including:  Guidelines for Data Acquisition to Support Marine Environmental Assessments of Offshore Renewable Energy Projects (Cefas, 2011)20. Receiving Environment – Baseline

5.5.4 The Irish Sea supports a variety of commercial fisheries for cod, plaice and sole, as well as significant fisheries for Nephrops, crabs, lobster, scallops, razor shells and whelks. Species identified in the Stock Book 2019 (Marine Institute, 2019)40 as being of commercial importance in the Irish Sea include cod, haddock, whiting, plaice, sole, Nephrops, ray species (Raya clavate, Raya montagui, Raya brachyiura) and herring. In the wider Irish Sea region, demersal trawling for Nephrops dominates the fishing effort, whilst vessels operating inshore typically target shellfish with pots, or dredge for scallop. More locally on the Kish and Bray Banks, key target species have been skates and rays and mixed demersal species, together with some dredging for scallop, but more recently whelk have been the dominant target species though they were not exploited 30 years ago. Across the export cable route corridors there are potting fisheries for whelk, brown crab, velvet crab and lobster.

xxiii Benthic species refer to all fish that inhabit the seabed, as opposed to pelagic who swim within the water column. Elasmobranch covers cartilaginous fishes that include sharks, rays and skates.

Page 74 of 220 5.5.5 Coull et al., (1998)41, Ellis et al., (2012)42 and Marine Institute provide broad scale overviews of the potential spatial extent of spawning and nursery grounds and the relative intensity and duration of spawning activity (see Figure 18 to Figure 20). Seven species of fish are known to spawn in the vicinity of the proposed development, namely lemon sole, sprat (Sprattus sprattus), plaice (Pleuronectes platessa), sole (Solea solea), whiting (Merlangius merlangus), cod (Gadus morhua) and the Norwegian lobster (Nephrops norvegicus) (Coull et al., 1998)41. 5.5.6 As presented in Figure 18, the nursery areas which occur in the vicinity of the proposed development include those for cod, haddock (Melanogrammus aeglefinus), herring, lemon sole, Nephrops, plaice, whiting (Coull et al., 1998)41 and sandeel (Ellis et al., 2012)42. 5.5.7 Key shellfish species that will be considered within the baseline include common whelk, European lobster, brown crab, velvet crab, scallop and Nephrops. 5.5.8 Migratory fish are known to be present within the study area. Atlantic Salmon are known to occur within the River Liffey. Two other rivers which flow through Dublin, the Dodder and Tolka, also have populations of salmon, although much smaller than the population of the Liffey. River systems flowing into Dublin Bay (Liffey, Tolka and Dodder) are also reported to support sea trout. European eel has been documented in Tolka and Liffey river systems flowing into Dublin Bay and the Lower Liffey is a migratory corridor for river and brook lamprey known to occur in the wider Liffey catchment.

Page 75 of 220 ¯ ¯

LEGEND Wind Farm Area and Offshore Cable Corridor Study Area (15km Buffer from Wind Farm Area) Nursery Grounds (Intensity) (Ellis et al., 2010) Anglerfish, Low Intensity Cod, High Intensity Plaice, Low Intensity Sandeel, Low Intensity Spotted ray, Low Intensity Thornback ray, Low Intensity Tope shark, Low Intensity Whiting, High Intensity ¯ ¯

0 10 20

Kilometres Data Source: Nursery Grounds data from CEFAS 2010

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of fish nursery grounds VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB AL

DRAWING NUMBER: 18

SCALE 1:400,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N LEGEND Wind Farm Area and Offshore Cable Corridor Study Area (15km Buffer from Wind Farm Area) Spawning Grounds (Intensity) (Ellis et al., 2010) Cod, Low Intensity Ling, Low Intensity Mackerel, Low Intensity Plaice, High Intensity Plaice, Low Intensity Sandeel, Low Intensity Sole, Low Intensity Whiting, Low Intensity

0 10 20

Kilometres Data Source: Spawning Grounds data from CEFAS 2010

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of fish spawning grounds VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB AL

DRAWING NUMBER: 19

SCALE 1:400,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N 650000 700000 750000 5950000 5950000

LEGEND Wind Farm Area and Offshore Cable Corridor Marine Institute Data Whiting Spawning Whiting Nursery Cod Spawning Cod Nursery Haddock Nursery Haddock Spawning Horse Mackerel and Mackerel Nursery 5900000 5900000

Data Source:

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of fish spawning and nursing grounds (Marine Institute)

VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB LS

DRAWING NUMBER: 20

SCALE 1:500,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

5850000 0 20 40 5850000

Kilometres

Service Layer Credits: Esri, Garmin, GEBCO, NOAA NGDC, and other contributors

650000 700000 750000 Methodology

5.5.9 The baseline presented in the EIAR for fish and shellfish resource will be described for the wind farm array and export cable route corridors and wider study area. The study area will be determined by the zone of influence of the proposed development, derived from numerical modelling (defined by the maximum tidal excursion over which indirect effects such as those from increases in suspended solids could occur (informed by the hydrodynamic modelling) and the area affected by increases in underwater noise (and applying the thresholds for noise effects on fish species set out in Popper et al., 2014)29 resulting from the percussive piling of foundations (informed by underwater noise modelling). 5.5.10 Baseline information for fish and shellfish will consist of a broad description of the species present in the array area and along the offshore export cable corridors and the relative importance of the project area compared to the wider study area. Baseline information across the study area in relation to fish and shellfish will be obtained mainly through desk study, incorporating biologically sensitive areas, fisheries stock and activity data. 5.5.11 In line with DCCAE 2017 Guidance Part 2 and consultation undertaken with Bord Iascaigh Mhara (BIM), Sea Fisheries Protection Agency (SFPA) and the Marine Institute, the baseline will also incorporate fisheries data and the data derived from a site specific trawl survey. A commercial fisheries survey was undertaken in July 2019 to further understand the function of the Kish and Bray Banks in relation to the local fisheries resource. The survey was undertaken in line with advice from SFPA using commercial gear and techniques, as well as utilising a local vessel to take advantage of local knowledge. The species recorded, as well as life-stage and abundance conclusions, will be used to inform the description of the baseline environment. 5.5.12 Fish and shellfish are identified within the guidance (DCCAE, 2017) as receptors under both biodiversity, flora and fauna and population and human health (for their commercial exploitation). The DCCAE Guidance requires a comprehensive understanding of the receiving environment to allow for a prediction of the likely significant effects of the development and as such the baseline will establish the following based on the available information:  Those species of fish and shellfish in the study area that are of commercial or recreational importance;

 Those species that are of conservation importance;

 The species of commercial or conservation interest known to have nursery and/or spawning grounds within the study area;

 Species of commercial or conservation interest known to migrate through the study area;

Page 79 of 220  Species of commercial or conservation interest known to be potentially sensitive to the specific impacts of offshore wind farm development; and

 Fish and shellfish species of commercial or conservation interest that have a generally restricted geographical distribution but are considered to be locally abundant.

5.5.13 A number of data sources are relevant to both the fish and shellfish ecology and commercial fisheries assessments and therefore, the EIAR baselines for these topics will be developed in parallel. The desk based sources will be supplemented through consultation with appropriate bodies including the Marine Institute, SFPA, BIM and through targeted consultation via the project team’s Fisheries Liaison Officer (FLO) directly with the fishing industry. 5.5.14 The assessment will be informed by the output of project specific modelling, primarily the hydrodynamic modelling to inform the spatial extent of the sediment plumes and subsequent deposition (but also the WFD assessment) and underwater noise modelling. Potential Impacts

5.5.15 The DCCAE Guidance and the Offshore Renewable Energy Development Plan (OREDP) Strategic Environmental Assessment (SEA) identify the potential impacts relevant to offshore renewable energy projects and have been used to inform the scope of the assessment for fish and shellfish ecology. Consideration will be given to the following potential impacts on fish and shellfish arising from the proposed development and within each phase of development, as presented in Table 11. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so would not be applicable to the construction and decommissioning phases of the proposed development.

Table 11 – Potential impacts on fish and shellfish resources arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Increased suspended sediment and turbidity arising from the installation of offshore wind infrastructure The extent of any sediment plumes and subsequent deposition will be    modelled and assessed for the proposed development. The results will be utilised to inform the assessment of impacts on fish and shellfish through consideration of the scale, both spatially and temporally to

Page 80 of 220 Project Phase determine any potential for smothering of habitats or impacts on demersal spawning fish.

PotentialLoss of habitat Impact (disturbance, displacement or exclusion of mobile species and loss of sessile species). Consideration will be given to the sensitivity of key fish and shellfish species within Dublin Array study area to habitat loss and habitat    change. Consideration will be given to any species known to use the area for a particular part of their life cycle where a change in habitat could limit the availability of suitable habitat.

Reduction in water and sediment quality through release of contaminated sediments and /or accidental contamination. The EIAR will include an assessment of water and sediment quality,    incorporating a WFD assessment. An assessment of potential impacts on stocks will be undertaken against background levels and the potential for re-suspension of contaminants present.

Introduction of additional underwater noise and vibrations through the installation of turbine foundations by piling in particular (but also noise from other construction activities and operational noise and vibration generated). Underwater noise has the potential to impact on fish and shellfish species ranging from behavioural effects to physical injury/mortality. Underwater noise modelling will be undertaken of the noise generated   by pile driving and other construction and maintenance activity to determine the magnitude of the impact. Given the commercial importance of shellfish to the area, a comprehensive desk top study will be undertaken of all information available relating to their sensitivity to noise but also particle motion effects). This will include reference to monitoring studies undertaken on wind farms across Europe where commercial shellfisheries are in operation.

Increased hard substrate and structural complexity. This may occur as a result of the introduction of turbine foundations,  scour protection and cable protection have the potential to create fish aggregating device and reef effects.

Potential barriers to movement through the presence of turbines and electromagnetic fields (EMF) from export cables and inter-array cables. This potential impact will be assessed taking into consideration natural  background levels, together with knowledge on the behavioural responses of fish and shellfish gained from monitoring studies of operational wind farms across Europe.

Page 81 of 220 5.5.16 An assessment of cumulative and transboundary effects (as outlined in Sections 3.10 and 3.11 of this Scoping Report respectively) on fish and shellfish species will also be undertaken as part of the impact assessment process. The NIS will include a full assessment of the potential impacts on sites designated for migratory fish species within the study area. 5.6 Offshore Ornithology Introduction

5.6.1 This section of the Scoping Report sets out the approach to the characterisation of seabird population and usage across the offshore and intertidal development area and within the wider context of the Irish Sea, incorporating any connectivity to designated conservation sites further afield as required. It also summarises the intended scope of, and approach to, the assessment of effects on offshore ornithology. Policy and Guidance

5.6.2 The assessment will comply with guidance relevant to the design and acquisition of datastandards in terms of data quality and coverage of the baseline and assessment for offshore and intertidal ornithology, as presented in Section 3.2. 5.6.3 The proposed method of assessment used to determine the significance of effects on important ornithological features (IOFs) will adhere to:  Guidelines for ecological impact assessment in the UK and Ireland (CIEEM, 2018)43. Receiving Environment – Baseline

5.6.4 Ireland is regionally important for breeding bird populations. When considering breeding birds in Ireland as a whole, for fifteen species more than 1% of the biogeographical populationxxiv breeds in Ireland. For two species, European Storm-petrel (Hydrobates pelagicus) and Roseate Tern (Sterna dougallii), more than 10% of the biogeographical populations are found breeding in Ireland, while significant numbers of Great Cormorant (Phalacrocorax carbo) and Manx Shearwater (Puffinus puffinus) also breed. 5.6.5 Based on numbers of birds presented in previous site survey reports, and applying knowledge of what species have been considered as key species for other offshore wind farm assessments elsewhere in Ireland and the UK due to their sensitivity to the potential effects, there are several seabird species that are likely to be the particular focus for the EIAR for Dublin Array. The key species are listed in Table 12 below, together with the relevant SPA.

xxiv A biograographic population is the distribution of species in a defined geographic space.

Page 82 of 220 5.6.6 The SPAs within the vicinity of the proposed development are presented in Figure 21. The cable search area associated with the Polbeg landfall zone transverses through Sandymount Strand/Tolka Estuary SPA which protects 20 species, including brent geese, terns, gulls and plover, under the Nature Directive, see Table 12.

Page 83 of 220 Table 12 - Summary of key species to be considered in the EIAR SPA colony within mean Key species Key season maximum foraging range Breeding season – birds leave Copeland Islands (Northern Manx shearwater (Puffinus the Irish Sea and migrate south Ireland) * puffinus) for non-breeding season. Lambay Island Breeding season – most Ireland’s Eye Gannet (Morus bassanus) Gannets move south in non- Saltee Islands breeding season. Ailsa Craig* Grassholm* Shag (Phalacrocorax Predominantly breeding Lambay Island aristotelis) season. Skerries Islands Lambay Island Herring gull (Larus All year. Ireland’s Eye argentatus) Skerries Islands Predominantly breeding Not Qualifying Interest for any SPA Great black-backed gull season, although some birds but nationally important numbers (Larus marinus) present all year. breed at Skerries Islands SPA Howth Head Coast Predominantly breeding season Lambay Island Kittiwake (Rissa tridactyla) for displacement, all year for Ireland’s Eye collision risk. Wicklow Head No SPAs currently in Ireland with Little gull (Hydrocoloeus Non-breeding season. this species defined as a feature of minutus) the site. Post-breeding season – birds Rockabill Common tern (Sterna leave the Irish Sea and migrate Dalkey Island. hirundo) south for non-breeding season. Post-breeding season – birds Rockabill Arctic tern (Sterna leave the Irish Sea and migrate Dalkey Island paradisaea) south for non-breeding season. Copeland Islands Breeding and post-breeding Rockabill Roseate tern (Sterna season – birds leave the Irish Dalkey Island dougallii) Sea and migrate south for non- breeding season. Predominantly breeding Lambay Island Guillemot (Uria aalge) season. Ireland’s Eye Predominantly breeding and Lambay Island Razorbill (Alca torda) post-breeding season. Ireland’s Eye * Transboundary site 5.6.7 In addition, there are a variety of migratory wildfowl, waders and passage migrant species that may be recorded within the Dublin Array area at certain times of the year and which might be sensitive to the impacts arising from the proposed development. Impacts on these species will also be considered.

Page 84 of 220 680000 700000 720000 Ireland's Baldoyle Eye SPA Bay SPA

5920000 North Bull 5920000 Island SPA

Howth Head Coast SPA

Sandymount Strand/Tolka LEGEND Estuary SPA Wind Farm Area and Offshore Cable Corridor Special Protection Area

Dalkey Islands SPA 5900000 5900000

Data Source:

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

Wicklow DRAWING TITLE Mountains Geographical overview of local Natura SPA 2000 sites with ornithological features

VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB SM

DRAWING NUMBER: 21

SCALE 1:150,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

The Murrough SPA 0 5 10 Kilometres

Service Layer Credits: Esri, Garmin, GEBCO, NOAA NGDC, and other contributors

680000 700000 720000 Methodology

5.6.8 For the purposes of the baseline characterisation, the offshore ornithology study area will be defined by the zone of influence, considered to represent a realistic maximum spatial extent of potential impacts on receptors. To account for any indirect effects on prey availability, the study area will also take account of the numerical modelling that informs the relevant receptor chapters (hydrodynamic modelling and underwater noise modelling) and the conclusions of the assessment of impacts on fish and shellfish ecology and benthic subtidal ecology. 5.6.9 The description of the baseline environment will provide characterisation of bird species, number, distribution, flight height, activity and behaviour for birds on the water and in flight. Given the high natural variability in seabird distribution, abundance and productivity between years, there is a need for the consideration of long term datasets with a robust sample size, in order to detect changes. 5.6.10 Information on designated conservation sites for bird species in close proximity to the Dublin Array (and therefore potentially most likely to be affected by activities associated with the proposed windfarm development) will be included, along with information on designated sites from further afield which may potentially have some interaction with the site based on the foraging ranges of species of qualifying interest. 5.6.11 A variety of sources of information will be considered as part of a desk-based survey to describe the baseline environment, including both peer reviewed scientific literature and the ‘grey literature’ such as other available development submissions and reports. A detailed review of all available grey literature will be undertaken during the characterisation of the baseline; however, it is anticipated to include other relevant offshore wind farm, ports and maritime developments within the vicinity of the proposed development. 5.6.12 Published literature on seabird ecology and distribution, and on the potential impacts of wind farms will also be considered. The data will provide context to the project area temporally and spatially within the Irish Sea and identify any connectivity with designated sites. Key datasets available to inform the baseline include previous site specific surveys of the development area, European Seabirds at Sea (ESAS) survey across the wider Irish Sea, ObSERVE survey data, Birdwatch Ireland seabird colony counts and seabird sensitivity mapping tool, JNCC Seabird monitoring programme and I-Webs data. Consultation with NPWS and BirdWatch Ireland has been undertaken to identify all relevant data available. 5.6.13 Breeding seabirds can travel considerable distances, as a result, it is necessary to consider designated sites beyond the array boundary. The extent of connectivity between seabird designated sites and offshore windfarms during the breeding season is largely a function of distance and species-specific foraging ranges. The EIAR will consider potential connectivity with statutory designated sites across Irish and other jurisdictions when assessing potential impacts on bird species as well as considering the impacts on the broader biogeographic populations.

Page 86 of 220 5.6.14 The DCCAE 2018 Guidance Part 1 outlines the requirement for data gathering to inform the baseline and the importance of any studies being able to detect any change that can be attributable to the development and distinguish these from natural levels or other developments. In order to ensure that two years of site specific data is used to support the assessment, as required in the DCCAE Guidance Part 1, the Applicant proposes to use site specific data collected during the 2016-17 and 2019-20 surveys. Relevant information from two further site specific surveys (undertaken in 2001/2 and 2010/11) will be utilised to provide additional context regarding flight height, whilst distribution patterns are likely to be useful in providing context on how seabirds use the study area over time. 5.6.15 The desk based study will be supplemented by at least 12 months of boat based site specific data collection which commenced in June 2019 and will continue into 2020. Part 2 of the Guidance on Marine Baseline Ecological Assessments and Monitoring Activities contains the most relevant information regarding baseline surveys for seabirds, in terms of offshore renewable energy projects. The guidance identifies the European Seabirds at Sea (ESAS) survey methodology as the standard method for surveying seabirds at sea. 5.6.16 The boat-based surveys are based on the standard ESAS survey method (which is fully described in Camphuysen et al., 2004)44. The main features of the boat based survey approach is summarised as follows:  12 monthly surveys encompassing the full study area (two surveys have been completed in each of the months of August 2019 and September 2019 to provide additional coverage of post breeding activity. Survey work is ongoing in 2020 to ensure at least 12 months of data are collected);

. Due to weather and Covid-19 the planned surveys between February and April 2020 were unable to be conducted. Therefore, the Applicant has undertaken two surveys in May 2020 rather than the originally planned one. The phenology of seabirds likely to be in the survey zone will be largely similar across the months of April and May. Therefore the survey undertaken in early May is considered representative of seabird abundance in April..

 The survey area includes the array area and a 4km buffer (to ensure that displacement impacts can be assessed as recommended in JNCC, 2017)45. Effects via displacement or disturbance will be determined within this buffer at spatial scales including either a 2km or 4km buffer depending on species vulnerability (JNCC et al., 2017)45;

 Species, number, distribution, flight height, activity and behaviour of birds on the water and in flight are recorded; and

 Surveys follow transects across the study area and utilise survey distance bands; A: 0- 50m, B: 50-100m, C: 100-200m, D: 200-300m, E: 300+m perpendicular to ship.

Page 87 of 220 5.6.17 Data for the intertidal birds will be supplemented by the intertidal bird surveys undertaken monthly throughout the winter season of 2019/2020 at the Shanganagh landfall, surveys were completed in line with the Irish Wetland Bird Survey (IWeBS) methodology . Data from surveys undertaken as part of IWeBS will be used to inform the numbers and distribution of waterbird populations at the Poolbeg landfall. 5.6.18 The boat based survey data will be analysed and modelled to inform the baseline reporting and feed into the ornithological impact assessment. The EIAR will include the following data analysis:  Distance analysis is required to produce monthly population estimates and bird density estimates for all species where there were more than 60 separate sightings over the survey period. It is currently anticipated this will likely involve 12 species (fulmar, Manx shearwater, gannet, cormorant, shag, lesser black-backed gull, herring gull, great black- backed gull, kittiwake, common tern, Arctic tern, guillemot, razorbill). This number of sightings was selected to ensure that there are sufficient data to ensure the analysis are statistically robust. Analysis will follow a standard methodology for assessment of birds based on the distance sampling technique (Buckland et al., 1993, 2001, 2004)46,47,48 . The outputs of distance analysis will be seasonal species distribution maps. In accordance with the guidance, the average density of flying birds as determined by the ESAS snapshot method will be presented along with a population estimate based on this density and the total surface cover of the study area;

 Collison risk modelling (CRM) will be undertaken to provide model outputs for key species accounting for worst case project design parameters and appropriate seabird biometric information. The species list required for CRM will be finalised after completion of surveys in 2020, the model will include the use of both site specific (where available) and generic flight heights as appropriate. Currently the Band (2012) model is proposed, although use of the new Marine Scotland CRM toolxxv will be considered at the time depending on its acceptance by relevant stakeholders;

 Collision risk modelling for migratory wildfowl, waders and passage migrant species will also be undertaken where numbers recorded during the boat based surveys are sufficiently high to allow robust abundance and density estimates to be obtained.

 Displacement analysis will be undertaken in line with relevant guidance (JNCC, 2017)45 using the matrix approach. Species included within the displacement analysis, along with the species-specific mortality rates and displacement rates will be based upon the best available evidence and will be finalised after completion of surveys in 2020; and

xxv The Marine Scotland CRM tool (stochastic collision risk model) is the updated collision risk model has been requested (and it the model of choice) in recent OWF development assessments in jurisdictions/countries with established offshore renewable energy sectors. The model incorporates parameter variability to allow quantifications of uncertainties in the parameterisation of the model.

Page 88 of 220  Population Viability Analysis (PVA) is considered best practice to understand the population-level consequences of predicted effects of offshore wind farms on seabirds. PVA provides a framework that uses estimated demographic rates for a population (typically survival and productivity information) in a mathematical model to forecast future levels of a population, either under currently prevailing circumstances or as a consequence of some impact applied to the population. The outputs of the PVA model will be used to compare baseline conditions with “impact” scenarios based on actual or predicted impacts from the project. Potential Impacts

5.6.19 DCCAE 2017 guidelines identify the potential impacts relevant to offshore renewable energy projects and have been used to inform the scope of the assessment for Dublin Array. Consideration will be given to the following potential impacts on birds arising from the proposed development and within each phase of development as presented in Table 13. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so would not be applicable to the construction and decommissioning phases of the proposed development. Table 13 – Potential impacts on offshore ornithology arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Disturbance from construction activities Construction activities such as increased vessel activity and installation    works may result in direct disturbance or displacement of birds from important habitats, feeding and roosting areas.

Operational disturbance and displacement from the array area The presence of the turbines and associated infrastructure has the potential to disturb and displace birds from within and around the  array. This would have the potential to reduce the area available to birds for feeding or loafing;

Collision risk  There is a risk of birds in flight colliding with rotating turbine blades. The susceptibility of species to collision risk depends upon physiological

Page 89 of 220 Project Phase and behavioural characteristics of the species, in addition to the project design specifications.

PotentialIndirect impacts Impact on prey species include those resulting from underwater noise (e.g. during piling) or the generation of suspended sediments (e.g. during preparation of the seabed for foundations) that may alter the distribution, physiology or behaviour of bird prey species    and thereby have an indirect effect. These mechanisms could potentially result in less prey being available in the area adjacent to active construction works to foraging seabirds.

5.6.20 An assessment of cumulative and transboundary effects (as outlined in Sections 3.10 and 3.11 of this Scoping Report respectively) on the offshore ornithology will also be undertaken as part of the impact assessment process. The NIS will include a full assessment of the potential impacts on SPA sites designated for bird features identified using foraging ranges for species present across the study area. 5.7 Marine Mammals Introduction

5.7.1 This section of the Scoping Report sets out the approach to the characterisation of marine mammal population and usage across the offshore development area and within the wider context of the Irish Sea, incorporating any connectivity to designated conservation sites further afield. It also summarises the intended scope of, and approach to, the assessment of impacts on marine mammals. Policy and Guidance

5.7.2 The assessment will comply with guidance relevant to the design and acquisition of data, standards in terms of data quality and coverage of the baseline and assessment for offshore ornithology, as presented in Section 3.2. In addition, the following guidance will be used to inform the assessment:  Guidance to manage the risk to mammals from manmade sound sources in Irish waters (NPWS, 2014)49; and

 Assessment and Monitoring of Ocean Noise in Irish Waters (EPA, 2011)50.

5.7.3 In addition, a number of other guidance documents specific to the consideration of marine mammals are available from jurisdictions/countries with established offshore renewable energy sectors where comprehensive guidance has been developed. This guidance will be used to inform the EIAR:

Page 90 of 220  Guidance on survey and Monitoring in Relation to Marine Renewables Deployments in Scotland. Volume 2. Cetaceans and Basking Sharks (SNH and Marine Scotland, 2011)51;

 Guidance on Survey and Monitoring in Relation to Marine Renewables Deployments in Scotland. Volume 3. Seals. (SNH and Marine Scotland, 2011)52;

 Methodologies for Measuring and Assessing Potential Changes in Marine Mammal Behaviour, Abundance or Distribution Arising from the Construction, Operation and Decommissioning of Offshore Windfarms. (Diederichs, A., G. Nehls, M. Dähne, S. Adler, S. Koschinski, U. Verfuß. for COWRIE Ltd, 2008)53;

 Statistical Modelling of Seabird and Cetacean Data: Guidance Document (Mackenzie et al., 2015)54;

 Recommendations for the Presentation and Content of Interim Marine Bird, Mammal and Basking Shark Survey Reports for Marine Renewable Energy Development (SNH, 2014)55; and

 Southall et al., 2019 (Southall B L, Finneran J J, Reichmuth C, Nachtigall P E, Ketten D R, Bowles A E, Ellison W T, Nowacek D P, Tyack P L (2019). Marine Mammal Noise Exposure Criteria: Updated Scientific Recommendations for Residual Hearing Effects. Aquatic Mammals 2019, 45(2), 125-232, DOI 10.1578/AM.45.2.2019.125)33. Receiving Environment – Baseline

5.7.4 A review of existing data sources indicates that the key species likely to be present within the proposed development and surrounding area are harbour porpoise (Phocoena phocoena), harbour seal (Phoca vitulina) and grey seal (Halichoerus grypus). Other species have been recorded in the area, including minke whales (Balaenoptera acutorostrata), bottlenose dolphins (Tursiops truncatus), Risso’s dolphins (Grampus griseus) and common dolphins (Delphinus delphis), however they are not commonly encountered, and density estimates are considered very low. 5.7.5 The cable search area zone overlaps the Rockabill and Dalkey Island SAC, designated for harbour porpoise, see Figure 22. The occurrence, abundance, distribution and community composition are well informed by records collated over two decades. The Rockabill and Dalkey Island SAC is approximately 1.7km at the nearest point to the proposed array, see Figure 22. Grey and harbour seal are also understood to be present in low numbers within the SAC with Dalkey Island being a known haul-out and breeding site for grey seals (NPWS, 2013)56. Harbour seal forms part of the mixed colony (with greys) around Dalkey Island and Dublin Bay. The Rockabill and Dalkey Island SAC identifies grey and harbour as present but does not list them as a qualifying interest for the site.

Page 91 of 220 675000 700000 725000

LEGEND Wind Farm Area and Offshore Cable Corridor

5925000 5925000 Special Area of Conservation

Rockabill to Dalkey Island SAC (reefs) 5900000 5900000

Data Source:

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Geographical overview of Rockabill and Dalkey Island SAC

VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB LS

DRAWING NUMBER: 22

SCALE 1:300,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

0 10 20

5875000 Kilometres 5875000

Service Layer Credits: Esri, Garmin, GEBCO, NOAA NGDC, and other contributors

675000 700000 725000 Methodology

5.7.6 For the purposes of the baseline, the marine mammal study area will be defined to represent a realistic maximum spatial extent of potential impacts on receptors. The study area will largely be derived from the numerical underwater noise modelling as it will provide site and activity specific impact ranges. The baseline characterisation will require an understanding of the study area in terms of the species that are found there, use of the area, the abundance of animals and the degree of spatial and temporal variation in abundance. 5.7.7 In addition, a regional context will be provided across a wider geographic area in terms of the species present and their estimated densities and abundance, this will be defined at the appropriate scale for each marine mammal population. The rationale for assessing at a population level is owing to the highly mobile nature of these species. 5.7.8 A variety of sources of information will be considered as part of a desk-based study to describe the baseline environment, including both peer reviewed scientific literature and the ‘grey literature’ such as other development submissions and reports. A detailed review of all available grey literature will be undertaken during the characterisation of the baseline; however, it is anticipated to include other relevant offshore wind farm, ports and maritime developments within the vicinity of the proposed development. 5.7.9 Published literature on marine mammal ecology and distribution, and on the potential impacts of wind farms will also be considered. Marine mammals are highly mobile, and therefore it is necessary to consider their occurrence in the wider region including into other national jurisdictions. The data will provide context to the project area temporally and spatially within the wider Irish Sea and identify any connectivity with designated sites. Consultation with NPWS and Irish Whale and Dolphin Group (IWDG) has been undertaken to identify all relevant data available. 5.7.10 The Guidance Part 2 (DCCAE, 2018) outlines the different visual survey methods (land, boat or aircraft) appropriate for marine mammal baseline characterisation. The desk based study will therefore be supplemented by at least 12 months of visual surveys including line transect boat based site specific data collection which commenced in June 2019 and has continued into 2020. The standard line transect approach outlined in Buckland et al., (2015)57 is being adopted to ensure accurate angle and distance measurements for all detected surfacing marine mammals. In addition to utilising the Macleod et al. (2010) 58, guidance on the design and protocols for marine mammal line transect surveys. The use of data aquired from acoustic monitoring has not been undertaken for characterisation purposes as it would not provide a density estimate. Sufficient data from the visual surveys and other existing data sources outlined below are available to determine the presence of species and to generate density estimates sufficient to inform a quantitative impact assessment in the EIAR.

Page 93 of 220 5.7.11 The data will be analysed using statistical spatial modelling techniques to provide spatially explicit predictions of animal density. The impact assessment will consider the potential ecological effects, as informed by the results of the survey data analysis and also by the results of the underwater noise modelling. 5.7.12 The 2019/2020 surveys will be supplemented by other key datasets that will be used to inform the baseline and will include:  Baseline boat transect surveys conducted between 2001 & 2002 and 2010 & 2011 to inform the original Foreshore Lease applications for the proposed development;

 Visual line transect surveys in and towed hydrophone acoustic surveys conducted in 2013 at Rockabill to Dalkey Island SAC to obtain density and abundance estimates (Berrow and O'Brien, 2013)59;

 IWDG inshore surveys – concurrent visual and acoustic surveys undertaken east of the project;

 Small Cetaceans in the European Atlantic and North Sea (SCANS) surveys undertaken in 1994, 2005 and 2016xxvi. SCANS surveys provide sightings, density and abundance estimates at a wide spatial scale providing additional context to the study area;

 ObSERVE surveysxxvii- aerial surveys undertaken 2015 and 2016;

 Joint Cetacean Protocolxxviii (JCP) Phase 111 Analysis, including datasets from 38 sources, totalling over 1.05 million km of survey effort between 1994 and 2010 from a variety of platforms; and

 Seal Usage Maps: The Estimated at-sea Distribution of Grey and Harbour Seals (Russell et al., 2017)60.

xxvi SCANS-III is coordinated by the Sea Mammal Research Unit at the University of St Andrews in Scotland, with partner institutes from other supporting countries. Further details are available from: https://synergy.st-andrews.ac.uk/scans3/ xxvii The programme was established by the DCCAE in partnership with the Department of Culture, Heritage and the Gaeltacht in 2014. xxviii The Joint Cetaceans Data Programme is a stakeholder-inclusive project, with a steering group of consisting of governmental departments, NGOs, academia, industry and technical advisors.

Page 94 of 220 Potential Impacts

5.7.13 DCCAE 2017 guidelines identify the potential impacts relevant to offshore renewable energy projects and have been used to inform the scope of the assessment for Dublin Array. Consideration will be given to the following potential impacts on marine mammals arising from the proposed development and within each phase of development as presented in Table 14. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so would not be applicable to the construction and decommissioning phases of the proposed development.

Table 14 – Potential impacts on marine mammals arising from the proposed development

Potential Impact Project Phase Construction O&M Decommissioning

Auditory injury as a result from foundation piling activity Direct impacts from underwater noise generated by construction (piling activity) may result in hearing damage/auditory injury in marine  mammals. Noise modelling will be used to inform a quantitative assessment of potential impacts using defined thresholds for individual species.

Behavioral displacement and disturbance from foundation piling activity.  Direct impacts from underwater noise (piling activity) may lead to behavioural disturbance and displacement of marine mammals.

Disturbance from other activities Disturbance from other construction activities (including dredging, trenching and vessel noise) can lead to behavioural disturbance and    displacement of marine mammals. Evidence on disturbance ranges from noise modelling and from the literature will be presented in order to assess the likely magnitude of impact.

Collision risk

The presence of vessels poses a potential for increased collision risk and    disturbance leading to behavioural disturbance/ displacement of marine mammals.

Page 95 of 220 Potential Impact Project Phase Increases in suspended sediment concentrations Impacts on the water quality from construction activities resulting in increases in suspended sediment concentrations has the potential to    impact on the ability of marine mammals to forage, consideration will be given to the outputs of the physical processes assessment.

Changes in prey availability and distribution There is the potential for indirect impacts on marine mammals, key    prey species will be defined, and consideration will be given to the findings of the fish and shellfish ecology assessments.

5.7.14 An assessment of cumulative and transboundary effects (as outlined in Sections 3.10 and 3.11 of this Scoping Report respectively) on marine mammal species will be undertaken as part of the impact assessment process. The NIS will include a full assessment of the potential impacts on SAC sites designated for marine mammal features. 5.8 Seascape, Landscape and Visual Amenity Introduction

5.8.1 This section of the Scoping Report sets out the approach to identifying the seascape, landscape and visual receptors of relevance to the project and study area. It also summarises the intended scope of, and approach to the Seascape Landscape Visual Impact Assessment (SLVIA) which will consider the potential effects of the proposed development on seascape, landscape and visual receptors during the construction, operational and decommissioning phases, and in respect of the baseline context, as well as future cumulative contexts. 5.8.2 This section should be read in conjunction with Section 6.9 Landscape and Visual as the two topics are inter-related and dependent upon one another. Policy and Guidance

5.8.3 The assessment will comply with guidance relevant to the design and acquisition of data, standards in terms of data quality and coverage of the baseline and assessment for SLVIA, as presented in Section 3.2. 5.8.4 This DCAAE guidance provides a high level overview of content and approach to the assessment of SLVIA and includes reference to existing other appropriate guidance for established best practice for SLVIA and cumulative assessment from offshore renewables, that will be used to provide the detail specific to SLVIA to inform the EIAR. The relevant guidance (or revised versions) as identified in the DCCAE guidance includes:  Guide to Best Practice in Seascape Assessment (Briggs et al., 2001)61;

Page 96 of 220  Offshore Renewables: Guidance on Assessing the Impact on Coastal Landscape and Seascape: Guidance for Scoping an Environmental Statement (SNH, 2012)62;

 Guidelines for Landscape and Visual Impact Assessment Third Edition, (Landscape Institute and Institute of Environmental Management and Assessment, 2013)63;

 Visual Representation of Wind Farms (SNH, 2017)64; and

 Assessing the Cumulative Impact of Onshore Wind Energy Developments (SNH, 2012a)65.

5.8.5 It is the Applicant’s understanding that the Marine Institute are preparing a Draft Seascape Characterisation Report which will be used to inform the assessment, if available during the preparation of the EIAR. The methodology and findings of the ORDEP SEA will also be considered in the SLVIA assessment. Receiving Environment – Baseline

5.8.6 The coast from north County Dublin south to Wicklow town is predominantly linear (in SLVIA terms and relative to the north and south coasts) with few indentations, and only a number of small islands located close to the coast, such as Ireland’s Eye and Dalkey Island. The bays tend to be long and slowly curving. The most significant bay is Dublin Bay, which is marked to the south by Sorrento Point and Dalkey Island, and to the north by Howth Head. There are a number of marked headlands along the coast, some of which are elevated, including Howth Head, Bray Head and Wicklow Head. The coastal region within the study area is dominated in the north by the urban area of the City of Dublin. Moving south of the urban conurbation there are a number of settlements, along the coastline including Bray and Greystones. 5.8.7 Moving southwards along the coastline, the spatial extent of the towns tends to decrease. Progressing inland from this coastal region, the land is predominantly low-lying, although there are a number of hills from which panoramic views of the coast can be seen. 5.8.8 Inland from the coast the land generally rises in elevation, comprising a series of mountains, hills and ridges, which are regarded as the foothills of the Wicklow Mountains. Examples of these peaks include the Great Sugar Loaf (501 m) and Carrickgollogan Hill (276 m), whose views are described in detail later. The western edge of the study area is defined by higher ridges and mountain slopes including Kippure (757 m), Duff Hill (720 m), Djouce Mountain (725 m), Carrigvore (682 m), Tonduff (642 m), Corrig Mountain (618 m) and Prince William Seat (555 m). 5.8.9 The largest rivers in the Study Area include the Liffey, the Glencullen, the Dargle and the Vartry. The River Liffey rises south of Kippure Mountain, thirteen miles from Dublin and travels through County Kildare, County Dublin and Dublin City before entering the sea. 5.8.10 The coastal edge is characterised by pebble and sandy beaches as well as exposed rock in places. Sand dunes also occur and are typically covered with grasses. West of the coastal strip the land is dominated by pasture farmland, defined by hedgerows. Rising to the higher ground, the vegetation is a mixture of bogland and forestry.

Page 97 of 220 5.8.11 The northern half of the study area is highly urban in character, being dominated by Dublin City. The area contains a high density of structures, such as residential and commercial buildings, road and rail networks, ports and associated infrastructure, communication routes and electrical utilities. 5.8.12 The proposed array and cable area of search are not subject to international, national or regional designation intended to protect landscape quality; however a number of landscape designations exist along the east coast of Ireland. Of particular importance to the SLVIA assessment, are the Wicklow National Park, the Wicklow Mountains and Lakeshore Area of Outstanding Natural Beauty (AONB) and the Wicklow Coast AONB (see Figure 23). The proposed viewpoints for assessment are presented in Figure 23 and are as follows:  Viewpoint 1 - Over Wicklow Town from scenic car park;

 Viewpoint 2 - Six Mile Point, Newcastle;

 Viewpoint 3 - N11 road at Kilmullin;

 Viewpoint 4 - Greystones Harbour;

 Viewpoint 5 - Sugar Loaf Mountain;

 Viewpoint 6 - Bray Head walkway;

 Viewpoint 7 - Bray Promenade;

 Viewpoint 8 - Hill at Carrick Gollogan, near Shankill;

 Viewpoint 9 - Killiney Hill Obelisk;

 Viewpoint 10 – Shankhill Beach;

 Viewpoint 11 - Vico Road seating area;

 Viewpoint 12 - Coliemore Harbour seating area;

 Viewpoint 13 - Dun Laoghaire Harbour East Pier;

 Viewpoint 14 - R131 road close to Martello Tower, Sandymount;

 Viewpoint 15 - Promenade near Clontarf village;

 Viewpoint 16 - Near the Bull Wall, North Bull Island;

 Viewpoint 17 - R105 road, Sutton;

 Viewpoint 18 - Howth Head near Martello Tower;

 Viewpoint 19 - Car park close to Martello Tower, Portrane;

Page 98 of 220  Viewpoint 20 - Entrance to new housing estate, Rush;

 Viewpoint 21 - Offshore view 7km south-east of Howth Head;

 Viewpoint 22 - Tonelagee; and

 Viewpoint 23 - – Djouce Mountain.

5.8.13 A Seascape assessment was undertaken as part of the OREDP SEA though it is noted that the assessment was based on the technology at the time (5 to 7MW turbines) which are lower than those under consideration for the new development. Most Planning Authorities have produced county level Landscape Character Areas, along with descriptions and guidance. In most cases this is presented in their Development Plans. The Development Plans for Dun Laoghaire - Rathdown County, Fingal County, Wicklow County and Dublin City all reference Views and Prospects, which are visually sensitive points, or a series of points, that require special protection. Dun Laoghaire - Rathdown County, Fingal County and Wicklow County present these Views/Prospects as part of the Development Plan, while Dublin City has not identified specific Views/Prospects. 5.8.14 Minogue and Associates on behalf of the Marine Institute are undertaking a assessment of Seascape Character for Ireland at the time of writing. This study is intended to support the National Marine Planning Framework. It is the Applicant’s intention to include the relevant outputs from this assessment to inform and supplement the characterisation of receiving environment, if available prior to application.

Page 99 of 220 675000 700000 725000

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17 LEGEND 18 Wind Farm Area and Offshore Cable Corridor 14 15 16 Viewpoints Wicklow Mountains National Park Wicklow Areas of Outstanding Natural Beauty 13 Coastal Area Glencree/Glencullen 12 Mountain Uplands 11 Poulaphuca Reservoir 10 The Northern Hills 9

8

5900000 7 5900000

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5 4 Data Source: PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM 23 DRAWING TITLE Geographical overview of the SLVIA study area and proposed viewpoints for assessment 3 VER DATE REMARKS Drawn Checked 2 1 24/08/2020 Scoping BPHB LS

DRAWING NUMBER: 23

SCALE 1:250,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

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5875000 1 Kilometres 5875000 Service Layer Credits: Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, © OpenStreetMap contributors, and the GIS User Community

675000 700000 725000 Methodology

5.8.15 There is no specific guidance setting out the distance to which the SLVIA study area should extend. DCAAE, 2017 recognises the difficulty at scoping stage to establish the full extent of the impacts of the entire project. It is therefore appropriate to adopt a precautionary approach to ensure that the study includes all areas where there is potential for significant effects. The study area has been largely defined by the Zones of Theoretical Visibility (ZTV). The ZTV illustrates where there would be no visibility at all or where there would be low to high numbers of turbines theoretically visible, but it does not indicate the extent to which each turbine may be visible. Considering these factors, a study area of 50km from the array is proposed for the purposes of SLVIA; which has been defined based on the ZTV analysis undertaken for the proposed development. 5.8.16 The seascape and coastal characterisation will be supplemented by the production of viewpoints. Viewpoints will be defined that represent visual receptors associated with the coastal edge and inland to ensure sensitive landscapes are fully represented. It is anticipated that a total of 23 viewpoints will be considered in the SLVIA, as presented in Figure 23 5.8.17 These viewpoints were selected to ensure consistency with the previous EIS and additional viewpoints were identified inland for sensitive landscapes, such as the Wicklow Mountains. 5.8.18 The baseline data will require seascape and coastal characterisation to be undertaken. Coastal Character Areas will be defined as part of the SLVIA for Dublin Array based on existing information available at the time of publication. The SNH Guidance Note (SNH, 2012)62 promotes an approach whereby coastal characterisation relates directly to landscape characterisation by following the same principles and methodology for classification. If no formal Seascape or Coastal Assessment is published in time, then a seascape and coastal characterisation will be carried out as the basis for the SLVIA. 5.8.19 National Landscape Characterisation, Landscape Character Areas and guidance for the production of local landscape character assessments is currently available. The framework has been identified within the National Planning Framework and the National Landscape Strategy for Ireland 2015-2025 produced at a national level by the Department of Housing, Planning and Local Government and Department of Arts, Heritage and the Gaeltacht’s respectively. 5.8.20 Dun Laoghaire - Rathdown County, Fingal County and Wicklow County Councils have presented information on county Landscape Character Areas in their Development Plans. Dublin City Council plan to produce a landscape character assessment, but to date this has not been published. The information available will be referenced in the SLVIA and supplemented with findings from site visits (and photographs) to each of the key viewpoints.

Page 101 of 220 5.8.21 Where regard to ‘Views’ and ‘Prospects’xxix (as identified in relevant Development Plans) if these occur on the coast, then nearby viewpoints have been proposed. Most of the other Views are located inland and owing to the enclosure of landform and built form, would not be affected by the proposed development however the EIAR will have due regard to these to confirm no significant effects will arise. 5.8.22 Data to inform the characterisation will be gathered from official, reliable and up-to-date sources including Ordnance Survey Ireland map-based data, as well as data on landscape characterisation, landscape designations and other Governmental and local authority data of relevance. 5.8.23 SLVIA will adopt standard landscape and visual assessment methodologies (e.g. character definition, alternatives, assessment as outlined in the policy and guidance above), which are adapted to the marine and coastal environments. The objective of the assessment will be to predict the likely significant effects on the seascape, landscape and visual resource. 5.8.24 The significance of effects will be assessed through a combination of the sensitivity of the landscape or visual receptor/view and the magnitude of change that will result from the project on:  Character of the seascape and landscape and its sensitivity (maritime, coastal edge, intertidal zones and hinterland); and

 Particular views and visual amenities (from both land and sea).

5.8.25 The characterisations will be supplemented through use of ZTV, generated by Geographic Information System (GIS) to demonstrate the relative number of turbines that may theoretically be seen from any point in the study area, as recommended by SNH (2017)64. This process uses computer modelling and digital terrain mapping to determine the visibility of an object in the surrounding landscape. Importantly, interactions with other environmental considerations, (e.g. tourism and marine leisure, cultural heritage) will be an integral part of, or will be informed by, the assessment.

xxix The Development Plans for Dun Laoghaire - Rathdown County, Fingal County, Wicklow County and Dublin City all make reference to Views and Prospects, which are visually sensitive points, or a series of points, that require special protection.

Page 102 of 220 Potential Impacts

5.8.26 DCCAE 2017 guidelines identify the potential impacts relevant to offshore renewable energy projects and have been used to inform the scope of the assessment for Dublin Array. Consideration will be given to the following potential impacts on marine mammals arising from the proposed development and within each phase of development as presented in Table 15. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so would not be applicable to the construction and decommissioning phases of the proposed development.

Table 15 – Potential impacts on SLVIA arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Impact on seascape character The activities and structures located within the array area may alter the seascape character of the array area itself through alterations to it and    within the wider area through visibility of the changes within the array area.

Impact on the landscape character receptors The activities and structures located within the array area will be visible    from the coast and may therefore affect the character of the landscape as part of its context.

Impact on onshore visual receptors The activities and structures located within the array area will be visible    from the coast and may therefore affect the character of the views from onshore receptors.

Impact of lighting The aviation and navigational lighting will be visible and may affect the  views from the coast and further inland.

Page 103 of 220 5.8.27 The offshore cable route will be constructed along the sea bed and would therefore not be visible during operation. During the construction and decommissioning of the cable route the only effect on the seascape, landscape and visual resource would be the visibility of a small number of vessels out at sea, which are a common occurrence as part of the baseline character and views and therefore not likely to give rise to a significant effect. 5.8.28 An assessment of cumulative effects on the seascape character will be undertaken as part of the impact assessment process (as outlined in Section 3.10 of this Scoping Report). Transboundary effects are not anticipated based on the ZTV. 5.9 Shipping and Navigation Introduction

5.9.1 This section of the Scoping Report sets out the approach to the characterisation of shipping and navigational features across the array and the surrounding offshore area, and the intended scope of and approach to the assessment of impacts on shipping and navigation. Policy and Guidance

5.9.2 The DCCAE Guidance provides a reference for existing information and good practice and outlines the guidance that is available for shipping and navigation. This includes:  Safety of Navigation: Offshore Renewable Energy Installations (OREIs) – Guidance on UK Navigational Practice, Safety and Emergency Response (2016) (Marine Guidance Note (MGN) 543)66;

 Marking of Man-Made Offshore Structures O-139 (International Association of Marine Aids to Navigation and Lighthouse Authorities (IALA), 2013)67; and

 Methodology for Assessing the Marine Navigational Safety Risks of Offshore Wind Farms (MCA, 2015)68.

5.9.3 Following consultation meetings with the Department of Transport, Tourism and Sport (DTTAS) and Commissioner of Irish Lights (CIL) in April 2019, it was broadly agreed that MGN 543 should be considered with regards to marine traffic surveys and identification of baseline conditions. Receiving Environment – Baseline

5.9.4 The key navigational features in the area are considered to be the shallow banks within the site (Kish and Bray) given that they dictate vessel routeing in the area. Given the shallow water depths associated with the Kish and Bray banks (on which the project is sited), larger commercial vessels currently avoid the project area, with only smaller fishing or recreational vessels transiting through the proposed site. Page 104 of 220 5.9.5 While commercial traffic does currently avoid the banks, the surrounding area has a number of high density vessel routes passing to the west and north of the site, which are in the majority associated with transiting into and out of Dublin Bay (and associated ports and harbours). This includes regular passenger and freight ferry routes, fishing (actively fishing and in transit) and recreational traffic. Shore Based Surveys

5.9.6 The location of the proposed Dublin Array site close to the coastline makes it likely that there will be notable levels of smaller, non-AIS equipped vessels such as fishing vessels and recreational vessels. This is particularly relevant during summer periods due to favourable recreational sailing conditions. Therefore, to quantify these non-AIS equipped vessels the Applicant will undertake marine traffic surveys. 5.9.7 Following consultation meetings with Department of Transport, Tourism and Sport (DTTAS) Marine Survey office, DTTAS Coastguard and the Commissioners of Irish Lights (CIL) in April 2019, it was broadly agreed that MGN 54366 should be considered with regards to marine traffic surveys and identification of baseline conditions. 5.9.8 An up-to-date marine traffic survey of the proposed development area has been undertaken within 24 months prior to the submission of the consent documents. These data will be combined with analysis of existing AIS data and additional consultation including outreach to local recreational clubs and regular commercial operators, a hazard workshop and working with the Fisheries Liaison officer to ensure that fisheries data is effectively understood. 5.9.9 A shore based vessel winter period traffic survey (carried out from the Baily) was undertaken in November 2019. The distribution of vessel types recorded within the study area during the first survey period (during November 2019) recorded throughout the survey period colour- coded by vessel type is presented in Figure 24. 5.9.10 During the winter survey, on average 54 unique vessels per day were recorded within the study area throughout the survey (excluding the vessels removed from the analysis which were associated with the Alexandra Basin Redevelopment which will be completed prior to construction of Dublin Array). The most common vessel types were cargo (35% of total traffic) and fishing vessels (21%). 5.9.11 The average length and draughtxxx of vessels was 91.2m and 5.6m respectively. The longest vessel recorded transiting through the study area was the 234m long cargo vessel Celine. The vessel with the deepest draught recorded was the tanker Thun Lidkoping, with a draught of 9.3m.

xxx The draught of a ship's hull is the vertical distance between the waterline and the bottom of the hull (keel), with the thickness of the hull included; in the case of not being included the draught outline would be obtained. Draught determines the minimum depth of water a ship or boat can safely navigate.

Page 105 of 220 5.9.12 Throughout the survey period the majority of vessels were transiting in a westbound or southbound direction. The average speed of vessels transiting the study area was 9 knots. The fastest vessel recorded was the ROPAX vessel Epsilon travelling at 24.2 knots. 5.9.13 The most frequently broadcast destinationxxxi was Dublin (28%). The most common cargo route was between Dublin and Liverpool, while passenger vessels mostly transited between Dublin and Holyhead. 5.9.14 There were on average 11 unique vessels recorded per day within 1nm of the proposed Dublin Array location, the majority of which were cargo vessels (49%). On average one vessel per day passed within the Dublin Array main development site boundary.

xxxi A vessel’s AIS transceiver sends the data including the name, type of ship/ cargo, draught and destination.

Page 106 of 220

Methodology

Baseline

5.9.15 For the purposes of characterising the baseline environment, the zone of influence for shipping and navigational features will be considered within a 10 nautical mile (nm) buffer of the Dublin Array. The 10nm buffer around the array is standard practice, and historically used for analogous studies undertaken for offshore windfarm developments, to define the study area for shipping and navigation assessments for offshore wind farm developments. This buffer is considered large enough to encompass any vessel routeing which may be impacted, while still remaining site specific to the project being assessed. 5.9.16 The guidance (MGN 543)66 relevant to ports, shipping and navigation identifies the need to provide a baseline of shipping and port activity and any navigational features present for commercial or recreational vessels. 5.9.17 The baseline will also establish the activity in the study area of all types of marine craft, both recreational and commercial through consideration of the numbers of vessels recorded in the surveys. The baseline will describe the types and sizes of vessels presently using the area, together with non-transit uses of the area, e.g. fishing, day cruising by leisure craft, commercial passenger vessels undertaking visits to the wind farm, racing, or maintenance dredging. Data collated will also include records of any marine incidents, locations of active fishing grounds and commercial port activity. The various Aids to Navigation in the area (most notably the Kish Bank Lighthouse) will also be defined during the characterisation of the baseline. 5.9.18 The baseline will be established through a combination of desk-based data collation and collection of site specific contemporary data, the baseline will incorporate:  Marine traffic survey data;

 Vessel monitoring system (VMS) data (where available), satellite tracking system used to track fishing vessel locations;

 Existing navigational features;

 Admiralty Sailing Directions;

 Admiralty Charts; and

 Maritime incident data.

Page 108 of 220 5.9.19 The baseline data, as described above will be used to estimate the encounter probability, and vessel to vessel collision risk. To account for the future baseline, a 10% shipping level increase will be made to model estimated future case results. This assumption reflects aspirational sectoral growth (such as Dublin Port’s Masterplan), historical trends in trade, trends in vessel arrivals, and likely macroeconomic fluctuations that may arise as a result of uncertainty in domestic trade and in overseas and domestic trade relationships. Navigational Risk Assessment

5.9.20 The marine traffic survey data will also inform a Navigational Risk Assessment (NRA), considering the receptors and effects as identified by MGN 54366. The outputs will also be used during ongoing consultation with regulatory stakeholders including the Commissioners of Irish Lights, DTTAS, the Marine Survey Office (DTTAS) and Dublin port Authority; as well as other local stakeholders and regular recreational users. 5.9.21 The NRA and formal consultation process will be supported by a hazard workshop. The hazard workshop is a standard and effective consultation activity, as recommended under MGN 54366, undertaken as part of the development of an NRA for offshore windfarm developments. The workshop allows a working group of local users and stakeholders (identified from the baseline and statutory consultees) to further risk assess marine traffic movements and the potential interactions within the project area. The output of the hazard workshop, the hazard log, will be used as the basis of the impact assessment undertaken within the NRA and EIAR. 5.9.22 The NRA will inform the EIA assessment of shipping and navigation, together with the cumulative and transboundary assessment. Where any impact pathway is found, an assessment will be undertaken. An extent of 50nm from the array area to screen in projects for consideration cumulatively in the NRA is proposed (see Figure 25). This extent has been proposed based on expert judgement and is considered to encapsulate all major routes which could potentially be affected by the proposed development.

Page 109 of 220 600000 700000 800000 6000000 6000000

LEGEND Wind Farm Area 50nm Buffer from Wind Farm Area 5900000 5900000

Data Source:

PROJECT TITLE DUBLIN ARRAY OFFSHORE WINDFARM

DRAWING TITLE Proposed extent of the projects to be considered in the NRA

VER DATE REMARKS Drawn Checked 1 24/08/2020 Scoping BPHB LS

DRAWING NUMBER: 25

SCALE 1:850,000 PLOT SIZE A3 DATUM WGS84 PROJECTION UTM29N

0 25 50

Kilometres

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600000 700000 800000 Collision and Allision Modelling

5.9.23 Following identification of the baseline routeing within a defined study area, future case routes will be produced based on likely deviations arising due to the Dublin Array site. It will be assumed that the deviated routes will keep a distance of at least one nautical mile from the Dublin Array site boundary as a worst case scenario and in line with standard NRA practice. These future case routes will be used as an input into the collision and allisionxxxii modelling. 5.9.24 A quantitative assessment of major hazards associated with the Dublin Array site will be carried out. This is divided into a base case and a future case assessment with and without the Dublin Array site and includes major hazards associated with:  Increased vessel to vessel collision risk;

 Additional powered vessel to structure allision risk;

 Additional fishing vessel to structure allision risk; and

 Additional allision risk associated with vessels Not Under Command (NUC). Potential Impacts

5.9.25 The DCCAE guidelines and the OREDP SEA identify the potential effects relevant to offshore renewable energy projects and have been used to inform the scope of the EIA assessment for Dublin Array. The findings of the NRA will inform the EIA for shipping and navigation receptors. Consideration will be given to the following potential effects on shipping and navigation arising from the proposed development and within each phase of development are presented in Table 16. The cells shaded in grey indicate that there is no source-receptor-pathway for that phase of the development. For instance, the impact may require the presence of project infrastructure and so would not be applicable to the construction and decommissioning phases of the proposed development.

xxxii Allision is a violent striking (such as in a collision) with a fixed object.

Page 111 of 220 Table 16 – Potential impacts on shipping and navigation arising from the proposed development

Project Phase

Potential Impact Construction O&M Decommissioning

Increase in vessel to vessel collision risk. Displaced shipping and the proximity of the array to traffic routeing    measures has the potential to lead to an increased risk of collision for shipping.

The potential for displacement of shipping Vessels may be displaced from their established routes due to    construction areas into new routes.

Potential for reduced access to port and decrease in trade    opportunities

Potential interference with communications and position fixing equipment from the presence of the turbines.  Communication and position fixing equipment may be affected by the presence of the structures/within the array area, or the cables.

Vessel to structure allision risk  Structures within the array area creating allision risk to passing traffic.

Reduction of Search and Rescue (SAR) capability due to increased incident rates and reduced access for surface/air responders The presence of the OWF will increase the number of vessels in the  area which could increase the number of incidents. The layout of the turbines within the array could reduce access for SAR responders.

Impacts on helicopter operations The presence of infrastructure may reduce the air space for helicopter  operators.

5.9.26 An assessment of cumulative and transboundary effects (as outlined in Sections 3.10 and 3.11 of this Scoping Report respectively) on shipping and navigation receptors will also be undertaken as part of the impact assessment process (where appropriate). Given the international nature of shipping transboundary effects are inherent within the assessment.

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