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SSE RENEWABLES () LTD Celtic Array Foreshore Licence Application for Marine Survey Work - Supporting Document

LF000037-REP-002_P2278_R4673_Rev2 | 18 March 2019

This document has been prepared for SSE by Intertek Energy & Water Consultancy Services Exchange House, Station Road, Liphook, Hampshire GU30 7DW, SSE RENEWABLES (IRELAND) LTD Celtic Sea Array Foreshore Licence Application for Marine Survey Work - Supporting Document

DOCUMENT RELEASE FORM

SSE RENEWABLES (IRELAND) LTD LF000037-REP-002_P2278_R4673_Rev2 Celtic Sea Array Foreshore Licence Application for Marine Survey Work - Supporting Document

Author/s

Kerri Gardiner

Project Manager Authoriser

Anna Farley Anna Farley

Rev No Date Reason Author Checker Authoriser Rev 0 07/03/2019 Original KAG PD/ALF ALF Rev 1 15/03/2019 Final HS ALF ALF Rev 2 18/03/2019 Change to UK SAC status ALF - -

Intertek Energy & Water Consultancy Services is the trading name of Metoc Ltd, a member of the Intertek group of companies.

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SSE RENEWABLES (IRELAND) LTD Celtic Sea Array Foreshore Licence Application for Marine Survey Work - Supporting Document

CONTENTS

DOCUMENT RELEASE FORM I

1. INTRODUCTION 1 1.1 Developer 1 1.2 Project Overview 1 1.3 Foreshore Application Area 2

2. DESCRIPTION OF THE PROPOSED SURVEY WORKS 6 2.1 Survey Schedule 6 2.2 Geophysical Survey 6 2.3 Geotechnical Survey 9 2.4 Wind Resource and Metocean Characterisation 13 2.5 Landfall Topographic Survey 16 2.6 Environmental Survey 16 2.7 Survey Vessels 16 2.8 General Requirements 17 2.9 Embedded Mitigation 18

3. ENVIRONMENTAL CONSIDERATIONS 20 3.1 Protected Sites 20 3.2 Intertidal and Benthic Communities 22 3.3 Birds 26 3.4 Fish 26 3.5 Marine Mammals 31 3.6 Commercial Fishing 33 3.7 Shipping and Navigation 35 3.8 Subsea Infrastructure and Wrecks 38 3.1 Recreation 38 3.2 Other Proposed Activities in the Area 38

4. POTENTIAL ENVIRONMENTAL EFFECTS 41 4.1 Identification of Pressures 41

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4.2 Intertidal and Benthic Communities 42 4.3 Protected Sites 43 4.4 Marine Mammals 44 4.5 Fish 52 4.6 Birds 54 4.7 Sea and Air Navigation Systems 55 4.8 Archaeology 55 4.9 Marine Activity 55 4.10 Recreational Resource 57 4.11 Waste Management 58

REFERENCES 59

Appendix A Stage 1 - Appropriate Assessment (AA) Screening A-1 A.1 Introduction A-2 A.2 Approach to AA Screening A-3 A.3 Describe the Project A-3 A.4 Identification of Relevent Natura 2000 Sites A-4 A.5 Assessment of LIkely Significant Effect A-16 A.6 Screening Statement and Conclusions A-24

Appendix B B-1 B.1 Introduction B-2 B.2 Keeragh islands spa B-2 B.3 Mid-Waterford Coast spa B-6

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LIST OF TABLES AND FIGURES

Tables Table 2-1 Calculated borehole survey footprint 13 Table 2-2 Embedded mitigation 18 Table 3-1 Protected sites 20 Table 3-2 EUNIS Habitats present within the application area 22 Table 3-3 Summary of spawning and nursery periods for commercially important fish species within the application area 28 Table 3-4 Cetacean species whose distribution includes the application area 31 Table 3-5 Development applications near to Celtic Sea application area 39 Table 4-1 auditory bandwidth 44 Table 4-2 Injury criteria for marine mammals (impulse) - SPL (unweighted) 45 Table 4-3 Summary of results 47 Table A-1 Search areas – zone of influence A-6 Table A2 Screening assessment A-8 Table A-3 Breeding season A-18 Table A-4 Summary - Potential for likely significant effects A-25 Table B-1 Cross-reference to other supporting information B-2 Table B-2 Assessment of potential impacts B-3 Table B-3 Assessment of potential effects B-6

Figures Figure 1-1 Location Overview (Drawing P2278-A2-LOC-001) 3 Figure 1-2 Location Overview (Drawing P2278-A2-LOC-002) 4 Figure 1-3 Location Overview (Drawing P2278-A2-LOC-003) 5 Figure 2-1 Kongsberg EM2040 MBES 8 Figure 2-2 EdgeTech 4200 SSS 8 Figure 2-3 Geometrics G-882 magnetometer 9 Figure 2-4 EdgeTech 3200 SBP 9 Figure 2-5 Fugro Seacalf CPT system 11 Figure 2-6 Fugro C25 Marine Drill 12 Figure 2-7 ROV drill 12 Figure 2-8 Fugro seafloor drill 12

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Figure 2-9 Example of LiDAR buoy 15 Figure 2-10 Example of wave rider buoy 15 Figure 2-11 Example of ADCP 15 Figure 3-1 Protected sites (Drawing P2278-A2-PROT-001) 21 Figure 3-2 Benthic Habitats (Drawing P2278-A2-HAB-001) 25 Figure 3-3 Fish spawning and nursery grounds (Drawing P2278-A2-FISH-001) 29 Figure 3-4 Fish spawning and nursery grounds continued (Drawing P2278-A2-FISH-002) 30 Figure 3-5 Fishing activity (Drawing P2278-A2-FISH-003) 34 Figure 3-6 Commercial vessel tracks by type (56 days AIS) 36 Figure 3-7 Fishing vessel tracks by length (56 days AIS) 37 Figure 3-8 Recreational vessel tracks by length (56 days AIS) 38 Figure 3-9 Other users (Drawing P2278-A2-OTHR-001) 40 Figure A-1 AA Screening Process A-3

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1. INTRODUCTION SSE wish to assess the suitability of an area of interest with potential for a future offshore wind development. The area of interest lies off the coastline of counties Cork, Waterford and Wexford. As part of the assessment process, SSE wish to carry out geophysical, geotechnical and environmental surveys of the prospect area. To carry out the site investigation works, SSE will require a non-exclusive Foreshore Licence from the Department of Housing, Planning and Local Government. To minimise the risk associated with poor winter weather conditions, SSE would seek to carry out most of the proposed site investigation works between April and October within the five years following award of a Foreshore Licence. This document has been prepared to support the Foreshore Licence application and provides: ▪ Description of the proposed marine surveys; ▪ Assessment of environmental sensitivities in the ; ▪ Review of shipping and navigation; ▪ Assessment of potential effects of the proposed surveys; ▪ Results of Appropriate Assessment Screening; and ▪ Natura Impact Assessment. 1.1 Developer At SSE we’re proud to make a difference. From small beginnings we’ve grown to become Ireland’s second largest energy provider and the country’s leading developer and investor in cleaner energy infrastructure. At SSE, we are committed to playing our part in ensuring society realises the ambition of the Paris Climate Agreement to bring net greenhouse gas emissions down to zero. Since 2008, SSE has invested over €2.5 billion in growing our energy business here – creating jobs in Ireland, sustaining employment, driving competition and greening our economy. Our 29 onshore wind farms have a combined generation capacity of 740MW, making us the largest generator and provider of renewable energy in the integrated all-island Single Electricity Market. SSE is a leading developer of offshore wind in with almost 900MW of operational capacity and a further 7GW in development stage. SSE are currently constructing the 588MW Beatrice wind farm in Scotland which is expected to power approximately 450,000 homes. In Ireland SSE is progressing the development of Arklow Bank Wind Park – Phase 2 off the coast of Arklow, Co. Wicklow. SSE plc is committed to continuing to invest in new renewable energy and as a leading developer and operator of offshore wind energy, we believe offshore wind development will be key to achieving Ireland’s transition to a low carbon economy.

1.2 Project Overview SSE wish to assess the suitability of an area of interest with potential for a circa 800MW offshore wind development. The main area which SSE would like to investigate is located off the coastline of counties Cork, Waterford and Wexford, approximately 25km offshore. The proposed area to survey has been chosen following a phased site selection process which included regional resource and constraints analysis and an assessment of renewable generation capacity requirements. In addition, a preliminary shipping and navigation assessment was undertaken to ensure navigational risks were understood should the proposed area be taken forward for

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development. This assessment has informed the position, size and shape of the proposed area to survey. To ensure alignment with the Government’s plan, the findings and recommendations of the strategic environmental assessment which underpin the Department of Communications, Climate Action and Environment’s (DCCAE) Offshore Renewable Energy Development Plan have been used as a basis for the survey area selection process. The proposed geophysical, geotechnical and environmental surveys of the area of interest will enable: ▪ Detailed mapping of nearshore shallow geological and seabed character; ▪ Reconnaissance level mapping of seabed relief and features (i.e. archaeology); ▪ Greater understanding of wind resource and metocean conditions; and ▪ Baseline environmental mapping. The knowledge gained from the proposed surveys would be used to minimise uncertainty in ground conditions at an early design stage and optimise any future development proposal. Survey information would also be used to assess the suitability of the area of interest for a renewable energy project from an environmental, economic and wider stakeholder prospective. Depending on the results of the proposed site investigations, other consents and permissions required to develop, install, operate and ultimately decommission an offshore wind energy project may be sought at a future date. Data acquired during the proposed surveys would be used to inform environmental assessments in support of any required applications by providing information on the current situation and allowing impacts to be predicted, and subsequently appropriate mitigation to be developed. It may also be used at a later date to provide a baseline against which to monitor post construction effects of construction/operation/decommissioning.

1.3 Foreshore Application Area The total proposed survey area is approximately 689km2 (68,941 hectares); of which approximately 303km2 (30,288 hectares) of the area lies within the foreshore area (see the red area shown in Figure 1-1 [Drawing P2278-LOC-A2-001]). Co-ordinates for the area are provided in the Foreshore Licence application form. The main area which SSE would like to investigate is located approximately 25km off the coast of counties Cork, Waterford and Wexford, and lies outside the 12Nm Foreshore area. Information from the proposed surveys carried out across this main area would be used to assess its suitability for offshore wind turbine installations. The area of interest within the Foreshore area includes two cable corridor options. Information from the proposed surveys carried out across these areas of search would be used to assess their suitability for installation of export cables required to bring renewable generated power to shore. The two potential nearshore landfall areas are shown on Figures 1-2 (Drawing P2278-LOC-A2-002) and 1-3 (Drawing P2278-LOC-A2-003). Whilst the proposed site investigation works be conducted over the entire offshore licence area, for the proposed cable corridor options it is likely that a 1km corridor within the application area will be surveyed. The spacing and number of the geophysical survey lines will be determined following further desk-based studies and liaison with geophysical survey contractors.

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2. DESCRIPTION OF THE PROPOSED SURVEY WORKS

2.1 Survey Schedule The proposed survey works will likely be carried out between April and October within the five years following award of the Foreshore Licence to minimise the risk associated with operating offshore in poor winter weather conditions. SSE would like the Foreshore Licence to start on 01 August 2019. The geophysical survey campaign is expected take up to 2 months. Geotechnical survey works will be undertaken once geophysical works have been completed and the necessary archaeological assessment of data has been carried out. Geotechnical survey works are expected to take up to 3 months. A LiDAR buoy, acoustic doppler current profiler (ADCP) and potentially Waverider buoys are also expected to be deployed within the 5-year period. Further information regarding the proposed surveys and equipment expected to be used is outlined in the following sections.

2.2 Geophysical Survey The geophysical survey acquisition methodologies will comprise multi beam echo sounding (MBES), side scan sonar (SSS), magnetometry, and sub-bottom profiling (SBP). All geophysical survey activities are non-intrusive and will not interact with the seabed. The objectives of the proposed geophysical survey are to: ▪ Map the seabed and sub-surface to optimise cable routing and wind turbine position within the application area and to enable assessment of cable burial depth and wind turbine piling depth; ▪ Plan the scope and positioning of the geotechnical sampling programme in the application area; ▪ Identify marine habitat areas from which the benthic survey can be undertaken; ▪ Identify sensitive marine habitats which will need to be avoided during geotechnical and environmental sampling and cable and wind turbine installation; and ▪ Provide the geophysical data from which a marine archaeological assessment can be undertaken as part of the consenting process. To meet these objectives, the geophysical survey will undertake the following tasks: ▪ Measure intertidal topography and sea bed , surface morphology and identify the nature of the seabed sediments - in particular the height, length and slopes of sand waves (topography, bathymetry, side scan sonar); ▪ Identify the distribution and thickness of superficial sediments and rock head where possible (sub bottom profiling); ▪ Identify the distribution of subsea geological features such as areas of exposed bedrock (bathymetry, side scan sonar); and ▪ Identify the location, extent and nature of any impediments to wind turbine installation and laying or burial of the cables such as wrecks, debris on seafloor, rock outcrop, other cables, pipelines etc. (magnetometer, bathymetry, side scan sonar). The interpretation of the geophysical survey for wind turbine positioning and cable routing forms the basis of the scope of work for geotechnical and benthic surveys.

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The geophysical survey is non-invasive but is based on acoustic methods. The bathymetric, side scan and sub-bottom profiling systems proposed are characterised by a limited acoustic footprint with the high directional, high frequency, short duration output attenuated within a few hundred metres of the survey vessel. It is Good Industry Practice for geophysical surveys in Irish waters to follow the Department of Arts, Heritage and the Gaeltacht “Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters” (2014). Section 4.3.4(ii) is applicable to the type of geophysical survey proposed and will be implemented by the survey contractor. This includes the following procedures: ▪ Sound-producing activities shall only commence during daylight hours where effective visual monitoring by the MMO, has been achieved. Where effective visual monitoring, as determined by the MMO, is not possible the sound-producing activities shall be postponed until effective visual monitoring is possible. ▪ Agreed and clear on-site communication signal must be used between the MMO and the Works Superintendent as to whether the relevant activity may or may not proceed, or resume following a break (see below). It shall only proceed on positive confirmation with the MMO. ▪ Survey activities must not commence is marine mammals are detected within a 500m radius of the sound source. ▪ In waters up to 200m deep, the MMO shall conduct pre-start-up constant effort monitoring at least 30 minutes before the sound-producing activity is due to commence. Sound-producing activity shall not commence until at least 30 minutes have elapsed with no marine mammals detected within 500m radius by the MMO. ▪ A ramp-up procedure (i.e. soft start) will be used. a. Where it is possible according to the operational parameters of the equipment concerned, the device’s acoustic energy output shall commence from a lower energy start-up (i.e., a peak sound pressure level not exceeding 170 dB re: 1μPa @1m) and thereafter be allowed to gradually build up to the necessary maximum output over a period of 20 minutes. b. This controlled build-up of acoustic energy output shall occur in consistent stages to provide a steady and gradual increase over the ramp-up period. c. Where the acoustic output measures outlined in steps (a) and (b) are not possible according to the operational parameters of any such equipment, the device shall be switched “on” and “off” in a consistent sequential manner over a period of 20 minutes prior to commencement of the full necessary output. ▪ Once the ramp-up procedure commences, there is no requirement to halt or discontinue the procedure at night-time, nor if weather or visibility conditions deteriorate nor if marine mammals occur within a 500m radial distance of the sound source. ▪ If there is a break in sound output for a period greater than 30 minutes (e.g., due to equipment failure, shut-down, survey line or station change) then all pre-start monitoring and a subsequent ramp-up procedure must be undertaken. Specific equipment to be used during the geophysical survey have not yet been specified to date. Examples of industry standard equipment for the purpose of geophysical and geotechnical survey have been used in this assessment. Frequencies and decibels used to obtain the data will be within similar ranges for all equipment used.

2.2.1 Multibeam echo sounder (MBES) A multibeam echo sounder (MBES) is a remote sensing acoustic device typically attached to a vessels hull. The purpose of this equipment will be to map the water depth to seabed (bathymetry). The

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Kongsberg EM2040 is an example of a MBES device that may be used for the proposed survey works (Figure 2-1). Figure 2-1 Kongsberg EM2040 MBES

2.2.2 Side scan sonar (SSS) A SSS is a remote sensing acoustic device attached to the vessel hull or as part of a towed array. The purpose of the equipment will be to produce seabed imagery within the proposed application area. The EdgeTech 4200 is an example of SSS that may be used during the proposed survey works (Figure 2-2). The SSS will be dual frequency hydrographic sonar with a lowest operating frequency of not less than 100 kHz. Due to consent conditions in Irish waters, the higher frequency of the side scan sonar must be between 410 and 500 kHz. Figure 2-2 EdgeTech 4200 SSS

2.2.3 Magnetometer A magnetometer is a passive remote sensing device that detects ferrous objects, which may present an obstruction or risk (potentially unexploded ordnance) to intrusive seabed works such as geotechnical surveys, and construction activities. Magnetometers are typically towed behind a survey vessel. The marine magnetometer will be of the Caesium Vapour type and capable of recording

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variations in magnetic field strength during survey to an accuracy of±0.5nT. The Geometrics G-882 is an example of magnetometer that may be used for the proposed survey works (Figure 2-3). Figure 2-3 Geometrics G-882 magnetometer

2.2.4 Sub-bottom profiler (SBP) The SBP is a remote sensing device, or array of devices that are towed behind a vessel. The purpose of the sub-bottom profiler is to produce a 2D cross section of the soil and rock beneath the seabed. It is likely that two different systems will be used; a high-resolution profiler that will emphasise the top 3 to 5m of sediment with a resolution of 0.25m or better in a variety of geological conditions; and a system that provides increased penetration of up to twenty metres. Three systems (pinger, boomer and chirp) will be made available so that the most appropriate system can be chosen dependent on the seabed conditions. The EdgeTech 3200 is an example of a sub-bottom profiler that may be used for the proposed survey works (Figure 2-4). Figure 2-4 EdgeTech 3200 SBP

2.3 Geotechnical Survey The purpose of the proposed geotechnical survey is to evaluate the nature and mechanical properties of the superficial seabed sediments and intertidal sediments in the application area. Following review of geophysical data only one export cable corridor and one landfall will be selected for geotechnical sampling.

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The geotechnical survey techniques that may be used during the proposed marine survey include grab sampling, seabed cone penetrometer tests (CPT), vibrocoring (VC), and boreholes. Boreholes will be used to determine deeper soil conditions in the main prospect area and at the export cable landfall. VC and CPTs will be used across the entire application area. VC and CPTs will be acquired at the same or separate locations as determined by review of SBP data interpretation. The exact location, quantity, type, and penetration of the geotechnical samples will be determined following interpretation of geophysical survey but indicatively may comprise of the following: ▪ 40 vibrocore samples; ▪ 20 seabed CPTs; and ▪ 12 boreholes (2 in the foreshore at the selected landfall, and 10 in the offshore prospect area). It should be noted that the geotechnical samples will be acquired across both the foreshore and offshore prospect area. As it is uncertain how many of the geotechnical samples would be acquired in the foreshore, as a worst-case, the assessment assumes that all 40 vibrocores and 20 CPTs would be located within the foreshore.

2.3.1 Survey strategy – location of sampling stations Geotechnical sampling locations will be selected based on analysis and interpretation of the geophysical data. Typically, stations are positioned to confirm the geophysical interpretation and sample each change in geological unit. However, the positioning of stations also needs to take into consideration environmental constraints such as the position of sensitive habitats or archaeological features. Desk-based studies have identified potential areas of rocky reef within the application area. Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive) lists the habitat ‘Reef’ on Annex I as a ‘natural habitat type of community interest that requires the designation of Special Areas of Conservation (SAC)’. Whilst the potential areas of reef are not within a SAC, they are still sensitive habitat. The geophysical data will be used to confirm the presence and positions of potential reef prior to locating geotechnical and environmental sampling stations. Sampling stations will be positioned to avoid reef habitat. If geophysical interpretation is not conclusive, drop down camera will be used to visualise the seabed prior to intrusive sampling to ensure reef features are avoided. Geophysical data will be reviewed by a qualified and experienced archaeologist and if necessary archaeology exclusion zones will be identified and communicated to the survey contractor. The archaeologist will also carry out a walk-over survey of the intertidal area at the selected landfall. The archaeologist will review the geotechnical station positions and if necessary propose adjustments to ensure known and potential archaeological features are avoided. The appropriate permits will be acquired from the National Monuments Service ahead of the use of detection devices (e.g. geophysical equipment) and intrusive seabed works (geotechnical testing). In order to avoid interaction with the existing pipelines in the area, geotechnical and environmental sampling locations will be positioned a minimum of 250m from the assets marked positions. The asset- owners will be contacted prior to the survey to determine if a proximity agreement is required. During survey the deployment of equipment on the seabed will be kept to a minimum in order to minimise seabed disturbance.

2.3.2 Vibrocore A vibrocore will be used to retrieve a soil sample by the lowering of a sample tube that is vibrated into the seabed. The vibrocore will be launched from a vessel crane or A-frame.

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Vibrocores may penetrate up to 6m into the seabed and have a diameter of 150mm. Therefore, sample volumes will be up to 0.12m3. Assuming 40 samples are collected, the worst-case volume of sediment removed will be 4.8m3. The Fugro HPC (high performance corer) is an example of a vibrocore that may be used for the proposed survey works.

2.3.3 Cone Penetrometer Test (CPT) A CPT will be used to test the characteristics of the soil by pushing an instrumented cone into the ground at a constant speed, with continuous measurement of the cone end resistance, the friction along the sleeve of the cone, and the pore water pressure. The CPT will be launched from a vessel crane or A-frame and can achieve penetrations of up to 40m. The Fugro Seascalf is an example of a seabed CPT system that may be used for the proposed survey works (Figure 2-5). Figure 2-5 Fugro Seacalf CPT system

2.3.4 Borehole

2.3.4.1 Scope of work A borehole is a method of drilling into the seabed to recover samples and enable downhole geotechnical testing to be completed. A drilling head is lowered to the seabed via a drill string and stabilised using a seabed frame. The drill string is then rotated to commence boring. Tools are lowered into the drill string to recover samples or conduct in-situ soil testing. The drilling flush and drill cuttings are largely returned to the vessel and re-used, however some loss of flush and cutting should be expected. All drilling fluids will be in compliance with environmental requirements. The Fugro C25 Marine Drill is an example of a borehole drilling setup that may be used for offshore borehole drilling (Figure 2-6). Alternative methods of drilling a borehole may also be considered such as ROV drill and Fugro seafloor drill (Figure 2-7 and 2-8). Boreholes at the landfall will be drilled from a jack up barge (JUB) using a percussion and a rotary corer.

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Figure 2-6 Fugro C25 Marine Drill

Figure 2-7 ROV drill Figure 2-8 Fugro seafloor drill

2.3.4.2 Technical specification Depending upon the requirement identified from interpretation of the geophysical data, approximately ten boreholes will be required in the offshore prospect area and two will be required at the chosen landfall site within the foreshore. For completeness details of all boreholes have been provided in this section.

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Each borehole will acquire a core sample up to 112mm in diameter, creating a hole 143mm in diameter (0.016m2). The risings generated by drilling will be dispersed around the drill site as cuttings piles.

Foreshore area - Landfall boreholes The two landfall boreholes will be drilled from a JUB. The number of legs used for the operations is dependent on seabed conditions, current strength and wave action. For the application area, four legs are the most likely scenario. Each leg has a seabed footprint of approximately 2.54m2.

Each borehole will have a seabed footprint of approximately 0.016m2. Assuming a borehole depth of 25m, the core sample removed will be approximately 0.25m3. Risings dispersed around the drill site will have a volume of approximately 0.15m3. Assuming cuttings will form a simple cone with an 18° slope angle around the drill head it has been estimated that they will cover an area of 1.82m2. The borehole will be left to collapse naturally following completion of drilling where the cuttings are likely to fall back down the hole.

Prospect Area - Offshore boreholes The 10 offshore boreholes will be drilled using a dynamically positioned vessel, which will not create a seabed footprint. It is assumed that as a worst-case the Seadrill equipment will be used which will have a seabed footprint of 20.52m2. The actual diameter of the borehole will be significantly less but will be drilled up to 30m deep. Each core sample removed will have a volume of approximately 0.3m3. Risings dispersed around the drill site will have a volume of approximately 0.18m3, covering an area of approximately 2m2.

The borehole will be left to collapse naturally following completion of drilling where the cuttings are likely to fall back down the hole.

The total expected seabed footprint of the geotechnical borehole sampling is shown in Table 2-1 below.

Table 2-1 Calculated borehole survey footprint

Activity Seabed footprint (m2) 2 landfall boreholes 10 offshore boreholes- outside foreshore Jack-up barge legs (worst case assumes 4 legs 20.32 - deployed) Seadrill footprint - 20.52 Borehole extraction* 0.032 0.16 Drill cuttings 3.64 20 Total 23.96m2 40.68m2 *Footprint from Borehole extraction is not included within total as it is assumed that it will be within the area of seabed disturbed by drill cuttings

2.4 Wind Resource and Metocean Characterisation The purpose of the proposed equipment outlined in this section is to evaluate the wind, wave and current conditions across the area of interest. A LiDAR buoy will be deployed to collect wind and wave metocean data (Figure 2-9) within the prospect area i.e. outside the foreshore. Exact details of the LiDAR buoy, deployment location within the prospect area, associated mooring arrangement and installation vessel will not be available until a contract has been awarded. The following description,

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taken from a Notice to Mariners issued as part of an SSE project in Scotland provides an overview of a typical LiDAR deployment in waters of similar depths to be found at the Celtic Sea application area. The LiDAR will be mounted on a buoy and will be moored using 150m long mooring chain and 3 tonne concrete anchor. The buoy will be moored to the seabed for a duration of 12 to 36 months and will be powered by solar panels and micro wind turbine generators. The buoy will be yellow in colour and will be clearly marked with two navigation lights (flashing amber, 5 flashes every 20 seconds, nominal range 3‐6 nm visibility and fitted with a Radar reflector. If additional data is required to describe the wave climate offshore of Celtic Sea, further Waverider buoys (up to 3) may also be installed for a duration of up to 12 months. Similar to the LiDAR buoy, exact details of Waverider buoys, deployment locations within the propsect area, associated mooring arrangement and the installation vessel will not be available until a contract has been awarded. However, the following points provide an overview of a typical Waverider buoy illustrated in Figure 2- 10: ▪ Physical diameter: 1.10 m diameter outside bumper 0.91 m diameter hull. ▪ Weight (including four batteries): 197 kg. ▪ Navigation light: Amber LED. Programmable ODAS flash sequence with three nautical miles visibility. ▪ Hull materials: stainless steel. Dome: impact resistant polycarbonate. ▪ 3-year battery life. ▪ Telemetry: Orbcomm (2-way) satellite communication. ▪ Bespoke mooring systems for selected water depth. ▪ Anchor: anchor weights (1000 kg of chain per buoy). ▪ Anchor weight footprint ca. 1.5m x 1.5m. The installation vessel will be on station for approximately four hours during the deployment, service and recovery visits. A Notice to Mariners will be issued to vessels requesting to them to maintain a safe distance when passing the installation vessel and at lowest possible speed to avoid vessel wash effects. An acoustic doppler current profiler (ADCP) may also be deployed via a vessel’s on-board crane and would rest on the seabed. The purpose of the ADCP is to determine the principal tidal current regime offshore of Celtic Sea. Exact details of any ADCP and deployment location within the application area will not be available until a contract has been awarded, however the following points provide a brief overview of an ADCP system, illustrated in Figure 2-11. ▪ The ADCP is expected to sit within a stainless-steel frame; dimensions of a typical ADCP, 1.8m base and 0.6m height off seabed. ▪ The total weight of the frame and ADCP will be in the order of 300kg. ▪ The ADCP and stainless-steel mooring frame will be attached to a ground line, a clump weight (approx. 150kg) and to an acoustic release system carrying a rope retrieval system. This will ensure that all equipment is recovered from the seabed after the monitoring period (minimum period of 30 days). ▪ It is expected that no surface marker buoys will be used.

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Figure 2-9 Example of LiDAR buoy

Figure 2-10 Example of wave rider buoy

Figure 2-11 Example of ADCP

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2.5 Landfall Topographic Survey A topographic survey will be undertaken to ensure that there are continuous height measurements between the landfall and the export cable route and to delineate hard features that will present an obstacle to cable installation. One of two techniques will be selected to acquire the data; either a traditional topographic survey using levels and reference points, or a drone.

2.6 Environmental Survey The aim of the proposed environmental survey is to map the distribution and extent of marine benthic habitats along the selected export cable corridor and across the prospect area. This will comprise a benthic sampling programme (using grab sampling) and video or still photographs. The sampling locations will be determined based upon interpretation of the geophysical data and selected to sample different habitats.

A grab sampler will be used to retrieve a soil sample of the seabed by the lowering of a mechanical grab. The grab will be launched from a vessel crane or A-frame. The Fugro Box Corer or Grab Sampler is an example of grab that may be used for the proposed survey works. It is currently estimated that 40 grab stations will be selected across the survey area. It is likely that three grab samples will be taken at each station; two for faunal analysis and one for sediment and chemical analysis. Each grab samples a volume of approximately 0.1m3. Grabs are required to obtain a sample greater than 5cm in depth, to try and achieve this, samples will be repeated for up to three attempts. For the purposes of assessment, it has been assumed that all 40 stations will be within the foreshore, although this is unlikely.

For the land / intertidal area a Phase 1 intertidal habitat walkover survey will be carried out by an experienced ecologist. The aim of the survey will be to identify and map the extent and distribution of intertidal biotopes.

2.7 Survey Vessels Geophysical survey vessels are typically between 15m and 60m in length and have an endurance of up to 14 days. These vessels are likely to use a local port for mobilisation and replenishment. Geotechnical survey vessels are typically 55-90m in length and have an endurance of up to 28 days. Their port of mobilisation will depend on previous work but may be Irish, UK, or another European location. The exact vessels to be used will be confirmed following a tender process to procure the survey contractor. All vessels shall be fit for purpose, certified, and capable of safely undertaking all required survey work. The survey contractor and vessels will comply with international and national statute as appropriate. A non-exhaustive list of examples includes: ▪ S.I. No. 507/2012 - Merchant Shipping (Collision Regulations) (Ships and Water Craft on the Water) Order 2012. ▪ Sea Pollution Act 1991 which transposes into Irish statute the requirements of the International Convention for the Prevention of Marine Pollution from Ships (MARPOL 73/78) ▪ Sea Pollution (Amendment) Act, 1999 - which gives effect to the International Convention on Oil Pollution Preparedness, Response and Co-operation, 1990 (OPRC). ▪ S.I. No. 372/2012 - Sea Pollution (Prevention of Pollution by Garbage from Ships) Regulations 2012.

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▪ S.I. No. 492/2012 - Sea Pollution (Prevention of Pollution by Sewage from Ships) (Amendment) Regulations 2012 ▪ Sea Pollution (Miscellaneous Provisions) Act 2006 – which gives effect to the International Convention on Ballast Water Management 2004 (amongst others) Notices to Mariners will be issued by the survey contractor ensuring that as well as the Maritime Safety Directorate, in particular local fishing organisations, Waterford Port Company, and harbour masters at Dunmore East, Kilmore Quay, Duncannon, Dungarvan and Youghal are included in the distribution list. During the works other vessels will be requested to maintain a safe distance from the survey vessels due to the restricted manoeuvrability of the vessels.

2.8 General Requirements

2.8.1 Environmental protocol The exact environmental protocols to be followed during the survey will not be known until award of the survey contract. In addition, to the international and national statute listed in Section 2.7 above, the following standard environmental procedures/protocols will be followed during the survey campaign: ▪ All vessels will comply with the latest International Maritime Organization (IMO) and Safety of Life at Sea (SOLAS) and environmental requirements for their classification and with any national requirement of the territorial or offshore waters to be operated in. ▪ The Contractor will maintain a suitably certified environmental management system. ▪ The contractor will take particular care when handling or storing hazardous materials, radiation sources and chemicals. ▪ Liquid or non-liquid pollutants or waste material will not be dumped, thrown or otherwise disposed of into the sea. ▪ All refuse and materials shall be kept onboard the vessel and safely disposed of onshore according to the MARPOL convention. ▪ All substances handled and/or used whilst undertaking the works will be handled, used, stored and documented in accordance with assessments and recommendations of the Control of Substances Hazardous to Health (COSHH) Regulations 1994. ▪ Where Fuels, Oils and Lubes are required to bestowed on boats, suitable containers will be used and stowed to allow ventilation and safe dissipation of any accidental leaked gas and retention of any leaked liquid. ▪ No liquid will be discharged into the water at any stage of the work on site. No smoking will be permitted in the vicinity of fuel in storage or when in use.

2.8.2 Access/egress arrangements on the Foreshore Access/egress arrangements to and from the foreshore for the duration of the works will not be determined until: a. the geophysical survey is complete, and a preferred landfall is selected; and b. the survey contractor is procured.

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2.8.3 Health and Safety procedures Health, safety and environmental protection shall be given foremost consideration in the execution of the work and shall be promoted in a proactive and highly visible manner throughout the survey campaign. Established safety procedures will be followed by both survey personnel and the vessels crew. Notices to Mariners will be issued by the survey contractor ensuring that as well as the Maritime Safety Directorate, in particular local fishing organisations, Waterford Port Company, and harbour masters at Dunmore East, Kilmore Quay, Duncannon, Dungarvan and Youghal are included in the distribution list. During the works other vessels will be requested to maintain a safe distance from the survey vessels due to the restricted manoeuvrability of the vessels.

2.9 Embedded Mitigation The design of the survey scope of works has sought to avoid or reduce environmental effects through careful design and the incorporation of Good Industry Practice. Mitigation is the actions or systems proposed to manage or reduce potential negative environmental impacts that have been identified by an environmental assessment of the proposed works. Generally, mitigation is split into two categories: ▪ Embedded mitigation - which are actions considered to be standard practice to manage commonly occurring environmental effects or are actions which are taken to meet existing legislative requirements. These are may include modifications to the design of the works during the pre- application phase to avoid effects e.g. adjusting the boundaries of the application area to avoid a sensitive habitat. These actions are included in the project design and form the ‘base case’ that is assessed. ▪ Project Specific mitigation – which are actions that are identified during the environmental assessment or consultation to reduce or avoid the significance or likelihood of adverse effects. Embedded mitigation included in the survey design is provided in Table 2-2 below. Table 2-2 Embedded mitigation

ID Embedded mitigation measure EM1 The survey contractor will follow the Department of Arts Heritage and the Gaeltacht (DAHG) ‘Guidance to Manage the Risk to Marine Mammals from Man-made sound sources in Irish Waters’ (DAHG 2014); in particular Section 4.3.4 (ii) applicable to MBES, SSS and SBP surveys. EM2 Geophysical data and the existing biotope maps for the area will be used to identify potential reef and priority habitats, and position geotechnical and environmental stations to avoid intrusive sampling in these areas. If geophysical interpretation is inconclusive, drop down camera will be used to visualise the seabed prior to sampling. EM3 An archaeology desk-based assessment will be undertaken by a qualified and experienced marine archaeologist. An archaeologist will carry out a walkover inspection of the land/intertidal area prior to commencement of any intrusive survey works. Geophysical data will be reviewed by an archaeologist and geotechnical sampling locations moved as appropriate to avoid features of interest.

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ID Embedded mitigation measure EM4 Geotechnical and environmental sampling locations will be positioned a minimum of 250m from third-party assets e.g. pipelines. All asset owners will be contacted prior to survey to determine if proximity agreements are required. EM5 Deployment of equipment on the seabed will be kept to a minimum. EM6 All survey vessels will follow relevant International and National Statute. EM7 Notice to Mariners will be issued to the Maritime Safety Directorate, local fishing organisations, Waterford Port Company, and harbour masters at Dunmore East, Kilmore Quay, Duncannon, Dungarvan and Youghal. EM8 A Fisheries Liaison Officer will be appointed. EM9 Environmental protocol listed in Section 2.8 will be followed to prevent pollution to the marine environment

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3. ENVIRONMENTAL CONSIDERATIONS An understanding of the potential impacts from an operation on the environment requires a clear understanding of the present state of the environmental baseline. For the purposes of this report this section focuses on the environmental receptors which have the potential to be affected by the planned survey.

3.1 Protected Sites In accordance with the provisions of Article 6(3) of the EC Habitats Directive (92/43/EEC) transposed into Irish statute by the European Communities (Birds and Natural Habitats) Regulations 2011, SI 477/2011, Screening for Appropriate Assessment (Stage 1) has been undertaken for Natura 2000 sites. and is presented in Appendix A. All Natura 2000 sites (SACs and Special Protection Areas [SPA]) near to application area are shown on Figure 3-1 (Drawing P2278-A2-PROT-001-A). Sites assessed by the Screening for Appropriate Assessment are listed in Table 3-1. Table 3-1 Protected sites

Area Type Site Code & Name Special Area of Conservation (SAC) IE000764 Hook Head SAC IE000707 Saltee Islands SAC UK0013116 Marine/ Sir Benfro Forol SAC IE002137 Lower SAC IE002162 and SAC IE002170 Blackwater River (Cork/Waterford) SAC IR003000 Rockabill to Dalkey Island SAC UK0012712 Cardigan Bay/ Bae Ceredigion SAC UK0030396 Approaches / Dynesfeydd Môr Hafren SAC UK0030397 West Marine / West Gorllewin Cymru Forol SAC UK0030398 North Anglesey Marine / Gogledd Môn Forol SAC UK0030399 North Channel Special Protection Area (SPA) IE004118 Keeragh Islands SPA IE004020 Ballyteigue Burrow SPA IE004193 Mid-Waterford Coast SPA IE004033 Bannow Bay

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3.2 Intertidal and Benthic Communities Intertidal and benthic ecology comprises the habitats and species (flora and fauna) present in, on or closely associated with the seabed. A high-level assessment of the key sensitive intertidal and benthic habitats and species within the application area has been made by reviewing the following desk-based data sources: ▪ European Marine Observation Data Network (EMODnet) Seabed Habitats project (www.emodnet- seabedhabitats.eu) - EUSeaMap broad-scale predictive mapping based on physical hydrographic information within different habitats areas and water depths The MESH project has collated studies and survey data to map European Nature Information System (EUNIS) and Marine Strategy Framework Directive (MSFD) broadscale habitats present on the seabed of north-west . This data is predictive rather than definitive however it does provide some indication to the types of benthic habitats that may be found within the application area. The EUNIS habitats identified within the foreshore and prospect area are listed in Table 3-2 and shown in Figure 3-2 (Drawing P2278-A2-HAB-001) below. Table 3-2 EUNIS Habitats present within the application area

EUNIS code EUNIS name Typical fauna

Habitats within the foreshore area A3.1 Atlantic and Rocky habitats in the infralittoral zone subject to exposed to extremely Mediterranean exposed wave action or strong tidal streams. Typically the rock supports a high energy community of kelp Laminaria hyperborea with foliose seaweeds and animals, infralittoral rock the latter tending to become more prominent in areas of strongest water movement. The depth to which the kelp extends varies according to water clarity, exceptionally (e.g. St Kilda) reaching 45 m. The sublittoral fringe is characterised by dabberlocks Alaria esculenta. In EUSeaMap broad-scale predictive mapping this habitat is classified as ‘infralittoral rock and biogenic reef’. It is therefore possible that EC Habitats Directive Annex listed habitat biogenic reef maybe observed in these areas. A5.25 or Circalittoral sand A5.25 - Clean fine sands with less than 5% silt/clay in deeper water, either on A5.26 the open coast or in tide-swept channels of marine inlets in depths of over 15- 20 m. The habitat may also extend offshore and is characterised by a wide range of echinoderms (in some areas including the pea urchin (Echinocyamus pusillus), polychaetes and bivalves. This habitat is generally more stable than shallower, infralittoral sands and consequently supports a more diverse community. A5.26 - Circalittoral non-cohesive muddy sands with the silt content of the substratum typically ranging from 5% to 20%. This habitat is generally found in water depths of over 15-20m and supports animal-dominated communities characterised by a wide variety of polychaetes, bivalves such as Abra alba and Nucula nitidosa, and echinoderms such as Amphiura spp and Ophiura spp., and Astropecten irregularis. These circalittoral habitats tend to be more stable than their infralittoral counterparts and as such support a richer infaunal community. A4.1 Atlantic and Occurs on extremely wave-exposed to exposed circalittoral bedrock and Mediterranean boulders subject to tidal streams ranging from strong to very strong. Typically high energy found in tidal straits and narrows. The high energy levels found within this circalittoral rock habitat complex are reflected in the fauna recorded. Sponges such as Pachymatisma johnstonia, Halichondria panicea, Esperiopsis fucorum and Myxilla incrustans may all be recorded. Characteristic of this habitat complex is the dense 'carpet' of the hydroid Tubularia indivisa. The barnacle Balanus crenatus is recorded in high abundance on the rocky substrata. On rocky outcrops, Alcyonium digitatum is often present.

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EUNIS code EUNIS name Typical fauna

Habitats within the foreshore area In EUSeaMap broad-scale predictive mapping this habitat is classified as ‘circalittoral rock and biogenic reef’. It is therefore possible that EC Habitats Directive Annex listed habitat biogenic reef maybe observed in these areas. A5.27 Offshore Offshore (deep) circalittoral habitats with fine sands or non-cohesive muddy circalittoral sand sands. Very little data is available on these habitats however they are likely to be more stable than their shallower counterparts and characterised by a diverse range of polychaetes, amphipods, bivalves and echinoderms. A5.35 Circalittoral mud Circalittoral, cohesive sandy mud, typically with over 20% silt/clay, generally in water depths of over 10 m, with weak or very weak tidal streams. This habitat is generally found in deeper areas of bays and marine inlets or offshore from less wave exposed coasts. Sea pens such as Virgularia mirabilis and brittlestars such as Amphiura spp. are particularly characteristic of this habitat whilst infaunal species include the tube building polychaetes Lagis koreni and Owenia fusiformis, and deposit feeding bivalves such as Mysella bidentata and Abra spp. A5.23 or Infralittoral sand A5.23 - Clean sands which occur in shallow water, either on the open coast or A5:24 in tide-swept channels of marine inlets. The habitat typically lacks a significant seaweed component and is characterised by robust fauna, particularly amphipods (Bathyporeia) and robust polychaetes including Nephtys cirrosa and Lanice conchilega A5.24 - Non-cohesive muddy sand (with 5% to 20% silt/clay) in the infralittoral zone, extending from the extreme lower shore down to more stable circalittoral zone at about 15-20 m. The habitat supports a variety of animal- dominated communities, particularly polychaetes (Magelona mirabilis, Spiophanes bombyx and Chaetozone setosa), bivalves (Fabulina fibula and Chamelea gallina) and the urchin Echinocardium cordatum. Habitats outside the foreshore area A5.37 Offshore In mud and cohesive sandy mud in the offshore circalittoral zone, typically circalittoral mud below 50-70 m, a variety of faunal communities may develop, depending upon the level of silt/clay and organic matter in the sediment. Communities are typically dominated by polychaetes but often with high numbers of bivalves such as Thyasira spp., echinoderms and foraminifera. This habitat is located within the prospect area, outside of the foreshore, see Figure 3-2. A5.15 Offshore Offshore (deep) circalittoral habitats with coarse sands and gravel or shell. This circalittoral habitat may cover large areas of the offshore although there coarse sediment is relatively little quantitative data available. Such habitats are quite diverse compared to shallower versions of this habitat and generally characterised by robust infaunal polychaete and bivalve species. Animal communities in this habitat are closely related to offshore mixed sediments and in some areas settlement of Modiolus modiolus larvae may occur and consequently these habitats may occasionally have large numbers of juvenile M. modiolus. In areas where the mussels reach maturity their byssus threads bind the sediment together, increasing stability and allowing an increased deposition of silt leading to the development of the biotope A5.622. This habitat is located within the prospect area, outside of the foreshore, see Figure 3-2.

The seabed sediments within the prospect area are fairly homogenous and largely comprised of offshore circalittoral sand (A5.27). These sediments are likely to be characterised by polychaetes, amphipods, bivalves, foraminifera and echinoderms. Sediments in the foreshore, closer inshore along the eastern export route corridor largely consist of circalittoral sand (A5.25 or A5.26) with small areas of high energy circalittoral rock (A4.1). Sediments in the foreshore along the western export cable corridor consist of circalittoral sand (A5.25 or A5.26), high energy circalittoral rock (A4.1) and high

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energy infralittoral rock (A3.1). The sandy areas are likely to be dominated by echinoderms, bivalves and polychaetes. The shallow rocky areas (circalittoral) are likely to be dominated by seaweed and kelp and the infralittoral rocky areas are likely to be dominated by hydroids, sponges and barnacles. Areas of biogenic reef (A3.1 and A4.1) have also been recorded in areas on the eastern export cable.

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3.3 Birds The coastal sea cliffs, estuaries and offshore islands of Ireland are host to a number of nationally and internationally important bird species, with many areas designated as SPAs. Coastal habitats provide important breeding sites for many species of seabirds, a number of which are protected under national and European legislation. At least 45 species of seabird (including divers and grebes) have been recorded during at-sea surveys in Irish waters, of which 23 species regularly breed around Ireland (Pollock et al 2008, Mackey et al 2004). In addition, a further 59 species of waterfowl and wader regularly occur at coastal sites such as estuaries around Ireland; including 5 grebe species, 2 heron species, 26 species of wildfowl and 26 wader species (Crowe 2005). Some of these species are migratory and are present only during migration periods in spring and autumn; others come to Ireland to breed or to spend the winter, while some are resident all year round. The application area lies in close proximity to the following SPAs, designated for breeding and over- wintering bird species: ▪ Keeragh Islands SPA; ▪ Saltee Islands SPA; ▪ Ballyteigue Burrow SPA; ▪ Mid-Waterford Coast SPA; and ▪ Bannow Bay SPA Further details on these sites are provided in the Screening for Appropriate Assessment, Section A.5.1.

3.4 Fish Offshore gravelly sediments on the shelf in the are dominated by elasmobranchs (rays, skates and sharks), gurnards, cod, large whiting and a few flatfish species. Soft muddy sediments have higher numbers of gadoids and lower densities of and dab than found in shallower sandy areas. The seasonal distributions of pelagic species such as mackerel, horse mackerel and herring are present within Irish waters largely on a seasonal basis, migrating between spawning and feeding grounds (DCCAE 2015). Fish communities present within coastal areas include juvenile flatfish and sandeel over sandy sediments, with seasonal influxes of sprat, herring, juvenile gadoids and mullet. Rocky shore fish assemblages are diverse and dominated by small species such as wrasses, gobies and blennies, as well as juvenile pollock and saithe (DCCAE 2015). The foreshore area and prospect area are within the spawning and nursery grounds for sixteen species of fish (Figure 3-3 Drawing P2278-A2-FISH-001-A and Figure 3-4 P2278-A2-FISH-002-A). A summary of the spawning and nursery periods for these fifteen commercially important fish species is outlined in Table 3-3. The foreshore and prospect area is a primary spawning ground for cod (Gadus morhua), herring (Clupea harengus), Nephrops (Nephrops norvegicus), plaice (Pleuronectes platessa), haddock (Melanogrammus aeglefinus), sprat (Sprattus sprattus) and whiting (Merlangius merlangus) (see Table 3-3 below). The EC Habitats Directive Annex II listed species, sea lamprey, river lamprey, brook lamprey, twaite shad and Atlantic salmon are listed as designated features of the River Barrow and River Nore SAC, Lower River Suir SAC and Blackwater River (Cork/Waterford) SAC. Although these sites lie more than 10km distant from the application area, all are migratory species that may be found in the application area at certain times of the year:

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▪ Sea lamprey – late April to early June ▪ River lamprey – September to June ▪ Twaite shad – year round and migrate into rivers from April-July ▪ Atlantic salmon – May to June and autumn months. Brook lamprey does not migrate to the sea and therefore will not be observed in the application area. The eastern export cable route lies 5km south east of the Bannow shellfish waters and 10km east of Waterford Harbour shellfish waters and the western export cable route is located 11km east of Dungarvan Harbour and (Checkpoint/Arthurstown/Creadan Head) Shellfish Water. Important Nephrops norvegicus grounds occur on soft muddy sediments within the Celtic and Irish . Brown, or edible, crabs are distributed throughout the continental shelf area to the north and west of Ireland and the rocky areas of the Irish Sea. Populations of scallops and queen scallops may also occur in areas of gravelly sediments (DCENR 2015). Fisheries data from the Marine Management Organisation (MMO) and Scientific, Technical and Economic Committee for Fisheries (STECF) fisheries (landings and activity) has found that the area is important for lobster, Nephrops, crabs, scallops, razor clams and whelks (STECF 2018 and MMO 2018).

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Table 3-3 Summary of spawning and nursery periods for commercially important fish species within the application area

Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Anglerfish (Lophius piscatorius) (N) N N N N N N N N

Blue whiting (Micromesistius poutassou) (N) N N N N N

Atlantic cod (Gadus morhua) (S)(N) SN S*N S*N SN N N European hake () (N) N N N N N N N N Herring (Clupea harengus) (S) (N) SN SN SN N N Lemon sole (Microstomus kitt) (S) (N) N N N N N N N N Ling (Molva molva) (N) N N N N N N Atlantic mackerel (Scomber scombrus) (N) N N N N N N N

Nephrops (Nephrops norvegicus) (S)(N) SN SN SN S*N S*N S*N SN SN SN SN SN SN

Plaice (Pleuronectes platessa) (S) S* S* S S Sandeel (Ammodytes marinus) (N) N N N N N N Sprat (Sprattus sprattus) (S) S S S S Whiting (Merlangius merlangus) (S) (N) SN SN SN SN SN N N Haddock (Melanogrammus aeglefinus) (S) SN SN SN SN N N (N) Horse Mackerel (Trachurus trachurus) (N) N N N N N N N N Megrim (Lepidorhombus whiffiagonis) (N) N N N N N N S = Spawning, N = Nursery, SN = Spawning and Nursery, Blank = No Data, *peak spawning. Grey shading indicates likely survey period. Source: Coull et al. 1998; Ellis et al. 2012. Marine Institute 2019a, ICES 2009

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3.5 Marine Mammals Marine mammals present in the survey area are restricted to cetaceans (whales, dolphins and porpoises) and pinnipeds (seals), with otter possibly present in the nearshore area. All cetaceans are European Protected Species (EPS) protected under Annex IV of the EC Habitats Directive (92/43/EEC), which lists species of Community Interest in need of strict protection. It is an offence to deliberately capture, kill, injure or disturb animals classed as EPS. In 1997, the Habitats Directive was transposed into Irish national law through Statutory Instrument (S.I) Number 94/1997 - European Communities (Natural Habitats) Regulations 1997. These were subsequently revised and consolidated in S.I. No. 477/2011 - European Communities (Birds and Natural Habitats) Regulations 2011, which covers the terrestrial environment and marine waters up to the 12nm limit. , , grey seal and common/harbour seal are listed under Annex II of the Habitats Directive, which lists species whose conservation requires designation of SAC. Of the 24 species of cetacean recorded in Irish waters, approximately 12 of these have been recorded off the east coast and may be present in the survey area at least on a seasonal basis (Table 3-4). It is unlikely that deep water species such as the blue whale and long-finned pilot whale will be present. The Irish Whale and Dolphin Group (IWDG) website (http://www.iwdg.ie/) has 67 records of cetacean sightings near the survey area for the period February 2018 to February 2019. Species identified include harbour porpoise; ; Risso’s dolphin; bottlenose dolphin; common dolphin; and humpback whale. Observations have been included in Table 3-4. Most cetaceans are wide-ranging, and individuals encountered within Irish waters form part of a much larger biological population whose range extends into adjacent jurisdictions. As a result, management units (MUs) have been outlined for seven of the common regularly occurring species following advice from the Sea Mammals Research Unit (DECC 2016) and the International Council for the Exploration of the Sea (ICES). These provide an indication of the spatial scales at which impacts of anthropogenic activities should be taken into consideration. The relevant MUs are listed in Table 3-4. Table 3-4 Cetacean species whose distribution includes the application area

Species Frequency of sightings* IWDG sightings Estimation of Applicable Abundance (April 2018 – January 2019) density MU*** of animals in (animals/km2) MU*** ** Toothed whales (odontocetes) Harbour Common from June April, May, July & 0.118-0.239 Celtic and 47,229 porpoise through the November. Individuals and Irish Seas (Phocoena autumn/winter. Peak up to 6 animals. phocoena) period in August. Commonly recorded off the Hook Head Peninsula. Short- Peak period is spring and Large pod in region (off 0.374 Celtic & 56,556 beaked summer and winter peak Helvic Head) numbering Greater common on the south coast 100-150 animals observed North Seas dolphin associated with prey October to January. (Delphinus items. delphis) Bottlenose Common year round but 1 animal sighted July. 0.008 - 0.06 Offshore 4,856 dolphin most frequent in Channel (Tursiops summer. and SW truncatus)

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Species Frequency of sightings* IWDG sightings Estimation of Applicable Abundance (April 2018 – January 2019) density MU*** of animals in (animals/km2) MU*** ** Striped Irregular in Irish Sea. - 0.005 N/A No data dolphin Summer and early available (Stenella autumn months. coeruleoalba ) Risso’s Peak period in April - Sept June, July, September. 0.031 Celtic & No data dolphin Individuals and up to 15 Greater available (Grampus animals. North Seas griseus) White- Irregular in Irish Sea. - No data Celtic & 15,895 beaked More regular in late available Greater dolphin summer – autumn. North Seas (Lagenorhyn chus albirostris) Long-finned Most frequent between - No data N/A No data pilot whale April and September available available (Globicephal a melas) Killer whale Occasional sightings in - No data N/A No data (Orcinus Irish Sea waters. available available orca) Baleen whales (mysticetes) Minke whale Peak period July and May, July, November. 0.017 Celtic & 23,528 (Balaenopter August Individuals and up to 4 Greater a animals. North Seas acutorostrat a) Humpback Occasional sightings in October, November. No data N/A No data whale Irish Sea waters. Individuals available available (Megaptera novaeanglia e) Fin whale Unclear, contradictory October through to January. No data N/A No data (Balaenopter evidence with sightings Individuals and up to 6 available available a physalus) during summer months, animals. and acoustic monitoring data suggest a peak in November – December.

Sources: * Marine Institute (2019a), Reid et al. (2003), IWDG (2019); ** Hammond et al (2017) ICES Management Units D (Irish seas) and *** DECC (2016). The survey area is within the Celtic and Irish Sea MU for harbour porpoise. Within the MU there are five SACs designated for the conservation of harbour porpoise; Rockabill to Dalkey Island SAC in Irish waters; and the Bristol Channel Approaches / Dynesfeydd Môr Hafren SAC, West Wales Marine / Gorllewin Cymru Forol SAC; North Anglesey Marine/ Gogledd Môn Forol SAC; and North Channel SAC in UK waters (JNCC 2017). As harbour porpoise are highly mobile species, animals from these sites maybe visitors to the survey area. In UK waters, the Cardigan Bay/Bae Ceredigion SAC has been designated for the conservation of bottlenose dolphin. Two species of seal are resident within Irish waters and maybe observed in the survey area; grey seal (Halichoerus grypus) and harbour (or common) seal (Phoca vitulina). Both species are listed on Annex II of the EC Habitats Directive.

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Grey seal use the area of the Saltee Islands SAC (1km east of the application area) as one of the very few breeding grounds in eastern Ireland. The breeding population was estimated at 571-744 individuals in 2005. A one-off moult count in 2007 gave a figure of 246 individuals. Pupping time occurs primarily from August through to December. After three weeks the pups moult with adults congregating in large numbers on beaches between December and February to moult. This species is a primary feature for the designation of the Saltee Island SAC (NPWS 2013a). Harbour seal come ashore during June to give birth and mate again around this time. Harbour seals also come to shore to moult during July and August often forming large groups on sheltered shores that have ready access to the sea. The harbour seal is widespread around the shores of Ireland, but population density varies greatly from place to place with low numbers at many sites. Sightings of the harbour seal within the survey area are thought to be infrequent. Otter (Lutra lutra) are protected within Ireland under the Wildlife Amendment Act (2000) where it is now illegal to hunt, disturb, or intentionally kill otters. The otter is also listed on Annex II and Annex IV of the EU Habitats Directive (92/43/EEC). Although otter are a Special Conservation interest feature of the River Barrow and River Nore SAC, given the distant to the site (16km) they are unlikely to be in the survey area.

3.6 Commercial Fishing The seas around Ireland are among the most productive and biologically sensitive areas in EU waters. The overall 2016 fishing opportunities for stocks to which the Irish fleet has access to, were 1.1 million tonnes of fish, with an estimated landed value of €1.26 billion. Ireland’s total share of these Total Allowable Catches (TAC) in 2016 amounted to 216,261 tonnes with a value of € 201 million (Marine Institute 2016). In the offshore area of the Irish Sea, sandy or muddy sand sediments, which cover a large area of the shelf, support fisheries for cod, whiting, haddock, anglerfish, hake and saithe. Marine Atlas indicates that the survey area lies within a low-moderate intensity area for offshore fisheries (Marine Institute 2019a). Commercial fishing in the Irish Sea is widely distributed and of the fisheries that are active, demersal and shellfish are the most important. Demersal target species include: cod, haddock, ling, monkfish, plaice, ray and skate and sole black; whilst shellfish species include lobster; crayfish; spider, brown, green and velvet crabs; scallops; surf and razor clams; periwinkles; and whelks (DCCAE 2015). Pelagic fish landings from the Irish Sea are mainly of herring and mackerel, and of relatively less economic importance. Although there is known to be a seasonally important herring fishery off the coast of Wexford. The Marine Institute (2009) reports that the majority of Irish fishing effort of vessels are 10m and over; landings from vessels under 10m have been declining since 2003. Average pelagic landings for the period 2006 – 2008 in the vicinity of the survey area are low in comparison to the rest of Irish waters at 140 to 460 tonnes (DCENR 2011). Ireland Marine Atlas indicates that mid trawl (net) fishing, pot fishing, nets fishing, periwinkle harvesting and dredge fishing take place near and within the foreshore application area (Marine Institute 2019a); see Figure 3-5 (Drawing P2278-A2-FISH-003). The dredge fishing targets scallops, whilst the pot fishing targets crabs and whelk.

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3.7 Shipping and Navigation Marine navigational safety issues must be considered when preparing a Foreshore Licence application. To ensure that potential risks to navigation and the marine environment were considered for the proposed site investigation works, SSE commissioned Anatec to undertake a shipping and navigation review of the area of interest. The following sections provide an overview of the review undertaken.

3.7.1 Data sources and limitations The review was not intended to replace or inform a baseline for a Navigational Risk Assessment and does not fully satisfy the criteria of such regulations; it was however intended to guide SSE in identifying a developable area from a shipping and navigation perspective at a relatively high level and meet the Foreshore Licence Application requirements for the proposed temporary site investigation work being planned. The following data was used in the review: ▪ United Kingdom Hydrographic Office (UKHO) Admiralty Charts 2049 and 1123 updated January/July 2018; ▪ Irish Coast Pilot, Admiralty Sailing Directions, 19th Edition, 2013; ▪ Automatic Identification System (AIS) data for two x 28-day periods (March and July 2018); and ▪ Irish Sailing Association Website. It should be noted that the review considered desk-based sources only and was limited to four weeks of AIS data in summer and winter (eight weeks in total). Therefore, it should be assumed that some seasonal activity and adverse weather routeing may not have been identified and vessels which are not required to carry AIS mandatorily may have been excluded. In particular, vessels under 300 Gross Registered Tonnes (GRT), commercial fishing vessels under 15m length and recreational vessels unless carrying AIS voluntarily. Also, AIS coverage of the whole area may not be fully comprehensive for the entire survey period, depending on atmospheric conditions and range of vessels from receivers. Finally, no navigational stakeholder consultation was been carried out to validate and/or extend knowledge of vessel activity in the area.

3.7.2 Navigational features The following points summarise the main navigational features identified in proximity to the area of interest: ▪ Nearby ports and harbours include Dunmore East, Waterford Harbour and Kilmore Quay; ▪ The Tuskar Rock Traffic Separation Scheme (TSS) is located off the south-east coast of Ireland. This is an International Maritime Organisation (IMO) routeing measure; and ▪ The closest RNLI stations are at Fethard and Kilmore Quay.

3.7.3 Marine traffic analysis An average of 32 unique vessels per day was recorded within the study area during March, compared to 44 per day in July. The following subsections present more detailed analysis of the main categories of vessels observed over the combined eight weeks.

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3.7.3.1 Commercial vessels (excluding fishing and recreation) The tracks recorded from all vessels (excluding fishing and recreation) within the study area during the combined eight weeks, colour coded by type and length, are presented in Figure 3-6. The vast majority were cargo vessels with smaller numbers of tankers, passenger vessels, and other / miscellaneous vessel types. There were 35 passenger vessels tracked within the study area during the survey period. The majority were cruise ships mainly bound for , Dunmore East and Waterford. A number of dredger / subsea vessel tracks can be observed heading to/from Waterford. These were made by the oceanographic survey vessel Mallet in July 2018. The main destinations of vessels transiting the study area were Waterford, Cork, Dunmore East and New Ross, Ireland. The following areas of relatively high shipping activity within the study area can be seen: ▪ Approaches to Waterford/Dunmore East – vessels heading to or from Waterford/Dunmore East, with outbound vessels heading to New Ross, Cork, Southampton and Dublin. ▪ East-West traffic passing parallel to the southern Irish coastline mainly heading to or from the Tuskar Rock Traffic Separation Scheme (TSS) off the south-east coast of Ireland. An example transit would be Cork-Dublin. Figure 3-6 illustrates how vessels take different routes according to their course. According to their navigational status broadcast on AIS there were 35 unique cargo vessels and two passenger vessels broadcasting as at anchor whilst in or in proximity to Waterford Harbour. Figure 3-6 Commercial vessel tracks by type (56 days AIS)

Source: Anatec (2019)

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3.7.3.2 Fishing vessels There were an average of approximately 20 fishing vessels per day recorded during March and 19 per day in July. The most common gear types were bottom and midwater otter trawls, beam trawls, otter twin trawls, boat dredges and drift nets. A number of vessels appear to be based at Kilmore Quay, a small fishing village in and Dunmore East, a popular tourist and fishing village in County Waterford. Although AIS carriage is not mandatory for fishing vessels below 15m in length, a number of smaller vessels were observed, especially in coastal waters east of Waterford. However, such vessels may be under-represented. The majority of fishing vessels were 24-25m. Tracks recorded from fishing vessels during the entire survey period, colour coded by vessel length are presented in Figure 3-7. Again it should be noted that seasonal variations in fishing vessel activity will not be fully captured by the data. Figure 3-7 Fishing vessel tracks by length (56 days AIS)

Source: Anatec (2019)

3.7.3.3 Recreational vessels AIS tracks recorded from recreational vessels within the study area during the combined eight-week period are presented in Figure 3-8, colour coded by vessel length. Recreational vessels of length greater than 24m are classed as passenger vessels and are included in Figure 3-8. There was an average of less than one unique recreational vessel per day in March compared within 13 per day in July. This is likely due to higher recreational activity in the summer. The length of vessels was primarily in the 10m-12m or the 12m-15m category. The majority of vessels visiting facilities in the area were routeing to / from Kilmore Quay and Dunmore East. Other vessels were transiting on passage through the area, mostly east-west. Again, it is emphasised that only a minority of recreational vessels broadcast on AIS.

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Figure 3-8 Recreational vessel tracks by length (56 days AIS)

Source: Anatec (2019)

3.8 Subsea Infrastructure and Wrecks Two telecommunication cables cross the eastern export cable route foreshore area, the retired Celtic cable from Sennon to Kilmore and the active Solas cable from Kilmore to Port Eynon (see Figure 3-9 Drawing P2278-A2-OTHR-001). No subsea pipelines are located within the application area. There are 49 shipwrecks within and close to the site as identified on the National Monuments Service Wreck Viewer mapping tool, see Figure 3-9 (P2278-A2-OTHR-001).

3.1 Recreation The landfall for the proposed Celtic export cables has not been selected. The two proposed export corridors included in the Foreshore Licence application cover approximately 5km of coastline at each site. Blackhall Beach and the western end of Cullenstown Beach lie within the eastern corridor, whilst Ballydowane Bay lies in the western corridor. It is likely that the beaches will be popular for bathing, fishing and walking in the summer holiday period (July – August). Cullenstown Beach has a ball alley where beach users can play handball, tennis, squash and football.

3.2 Other Proposed Activities in the Area A search of Foreshore Applications for surveys or other activities which could interact with the proposed works was conducted using the DHPLG ‘Applications and Determinations’ website. Table 3- 5 lists all applications listed on the website which could interact with the Celtic Sea survey area. These areas are also shown on Figure 3-9 (Drawing P2278-A2-OTHR-001).

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Table 3-5 Development applications near to Celtic Sea application area

Name of Licence Type of When Licence Status Distance development ref survey/activity planned to from commence application area (km) IFC-1- Ireland - FS006766 MBES, magnetometer, September2017 Consultation Intersects Subsea SSS, grab, CPT, VC and August 2018 western Cable Ltd - archaeological export route Clonea Ireland: Inis TBC Assumed to be - MBES, TBC Pre-Consultation 40km* Ealga FOW – magnetometer, SSS, (not available on Co. Cork grab, CPT, VC, DHPLG ecological, ‘Applications and archaeological, wind Determinations’) and current monitoring Greenlink TBC Cable installation 2020 -2023 Not submitted Intersects Interconnector (including pre- eastern installation geophysical export route survey- MBES, magnetometer, SSS) *Note: Coordinates from the location of the Inis Ealga survey application area not available, therefore it was only possible to roughly plot the potential location of the windfarm using https://www.dpenergy.com/projects/wind/ireland- inis-ealga-fow-co-cork/.

Greenlink Interconnector – Greenlink Interconnector Limited - Baginbun Beach A foreshore licence application was submitted on 21 December 2017 to carry out survey works to assess the site and seabed in order to select an optimum route for two submarine electricity power cables. Public consultation was carried out from 23 January 2018 to 22 February 2018. Although the DHPLG website indicates that the application is still in the ‘Consultation’ phase, SSE is aware that the licence was granted and geophysical surveys were completed in autumn 2018. According to the project website (www.greenlink.ie) the project is expecting to receive full regulatory approval by early 2020. The cable is due to be installed in 2020-2023, subject to obtaining the necessary permits and consents. There is therefore the potential that cable installation works could occur at the same time as the proposed Celtic Sea survey.

Ireland: Inis Ealga FOW –DP Energy – Although the application is not available on the DHPLG ‘Applications and Determinations’ website, the DHPLG has confirmed that a pre-application to carry out marine surveys to inform the development of the Inis Ealga offshore windfarm has been submitted. Therefore, there is potential that the survey works for this project would overlap (in time) with the proposed Celtic Sea survey.

IFC-1 Subsea Fibre Optic Cable System - France Subsea Cable Ltd – Dungarven A foreshore licence application was submitted on 21 June 2017 to carry out survey works to assess the site and seabed in order to select an optimum route for the proposed IFC-1 subsea fibre optic cable system. Public consultation was carried out from 18 August 2017 to 18 September 2017. The geophysical surveys were intended to be carried out between September 2017 and August 2018 for three months, however, the DHPLG website indicates that the application is still in the ‘Consultation’ phase which would indicate that permission has not yet been granted. There is potential that the survey works for this project would overlap (in time) with the cable survey works for the proposed Celtic Sea survey.

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4. POTENTIAL ENVIRONMENTAL EFFECTS To assess the significance of effects on the environment from the proposed survey it is first necessary to identify the pressures and impacts the survey may have. Pressures are the mechanism through which an activity has an effect on any part of the ecosystem. The nature of the pressure is determined by the activity type, intensity and distribution. A list of marine physical / chemical and biological pressures and their definitions has been formally agreed by the OSPAR Intercessional Correspondence Group on Cumulative Effects (ICG-C) (OSPAR 2011) and has been used in the assessment. The ICG pressure list does not include human pressures, and therefore, categories have been developed based on industry experience. An impact is the consequence of the pressure i.e. a predicted change in the baseline environment. The effect is the consequence of the impact and is usually measurable. Effects only occur when an impact is present within an environment that is sensitive to it. In assessing the significance of the effect, the magnitude (the spatial extent of the impact, the duration and frequency) and sensitivity, recoverability and importance of the receptor are considered. The EPA (2017) definitions of significance have been used in the assessment as follows: ▪ Imperceptible – An effect capable of measurement but without significant consequences. ▪ Not Significant – An effect which causes noticeable changes in the character of the environment but without significant consequences. ▪ Slight – An effect which causes noticeable changes in the character of the environment without affecting its sensitivities. ▪ Moderate – An effect that alters the character of the environment in a manner that is consistent with existing and emerging baseline trends. ▪ Significant – An effect which, by its character, magnitude, duration or intensity alters a sensitive aspect of the environment. ▪ Very Significant – An effect which, by its character, magnitude, duration or intensity alters most of a sensitive aspect of the environment. ▪ Profound – An effect which obliterates sensitive characteristics. This section describes the potential impacts that the proposed survey could have on the environment and the significance of the resulting effects. The section is ordered by receptor. If necessary and appropriate, Project Specific Mitigation has been proposed to reduce the significance of effects.

4.1 Identification of Pressures Potential pressures associated with the proposed survey were identified as: ▪ Penetration and/or disturbance of the substrate; ▪ Visual disturbance; ▪ Introduction or spread of non-indigenous species; ▪ Siltation rate changes, including smothering; ▪ Underwater sound changes; ▪ Death or injury by collision; ▪ Displacement of vessels fishing activity; ▪ Loss or damage to fisheries habitats/fish stocks;

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▪ Direct or indirect damage to an archaeological asset; ▪ Damage to or interference of an external cable asset; ▪ Restricted access to recreational users; and ▪ Cumulative and in-combination effects. 4.2 Intertidal and Benthic Communities

4.2.1 Potential impacts

4.2.1.1 Penetration and/or disturbance of the substrate Small areas of seabed will be removed by the geotechnical and environmental sampling. Based on figures presented in Section 2.3 and Section 2.6, combined, the geotechnical and environmental sampling will remove approximately 20.3m3 of sediment from the foreshore area and prospect area. Within the foreshore licence area, at the selected landfall the JUB legs and two boreholes will affect an area of 23.96m2. Offshore, in the prospect area, 10 geotechnical boreholes are expected to affect 40.68m2 of seabed. Following completion of drilling, the borehole will be left to naturally backfill with sediments and cuttings material. As discussed in Section 3.2 sediments in the majority of the survey area consists of coarse sediment and sand. The geotechnical sampling programme will create small depressions (from the JUB legs and the offshore drilling equipment if a Seadrill is used) and mounds (from risings) on the seabed. Given the region is subject to strong tidal streams and swells (DCCAE 2015), any mounds or depressions created during sampling are likely to be quickly dispersed and infilled following equipment removal. All benthic communities in the footprint of sampling equipment will be impacted through minor disturbance around the drill site and a very small volume of substratum loss, direct displacement or smothering during sampling. Any smothering will be a thin layer due to small volumes of sediment displaced during the sampling. The area of disturbance will back fill leaving no permanent significant loss or damage. Areas of sandy and coarser sediments are highly recoverable given that the sample depressions will be quickly infilled following cessation of disturbance and therefore typical species are able to quickly recolonise the area (Dernie et al 2003). The impact of geotechnical sampling on the two areas of biogenic reef in the eastern export cable corridor will be minimal. The survey has been designed to avoid locating intrusive seabed stations on these areas (see embedded mitigation EM2). The benthic habitats identified within the survey area are widespread and common for the region. Therefore, any disturbance is not expected to have an impact on the wider population of benthic fauna and the significance of any effect will be imperceptible.

4.2.1.2 Siltation rate changes, including smothering As the borehole is drilled and the core extracted, a small amount of sediment is likely to be suspended. The resultant suspended sediment dispersion and deposition are unlikely to have any significant smothering effect on the surrounding marine environment due to the extremely small volume of material extracted and the localised footprint. The offshore geotechnical boreholes are in a region of mud, sand and coarse sediment which is subject to wave action and tidal streams. The suspension and deposition levels resulting from the survey are likely to be within storm background levels for the area. In addition, the majority of species observed in the areas are infaunal and will therefore be adapted to high sediments loads and will be able to burrow away from areas of sediment deposition. Any disturbance from smothering and siltation rate changes is not expected to have an impact on the wider population of benthic fauna and the significance of any effect will be imperceptible.

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4.2.2 Project Specific Mitigation No Project Specific Mitigation has been proposed.

4.3 Protected Sites

4.3.1 Potential impacts The AA Screening, Appendix A, assessed 16 Natura 2000 sites that are either within the direct zone of influence of the proposed surveys or contain mobile Annex II species which could potentially travel into the survey area. It was identified that the proposed survey would induce the following pressures on Special Conservation Interests: ▪ Underwater sound changes; and ▪ Visual disturbance. Consideration was given to other planned activities in the area that could interact with the proposed survey to cause cumulative effects. The proposed survey activities are temporary and localised. Of the 16 sites assessed, it is considered possible that there exists an impact-receptor pathway between the proposed survey and the designating features of thirteen sites (See Table A-3). Of these 13 sites, screening has identified two sites, the Keeragh Island SPA and Mid-Waterford Coast SPA, where there is potential that the survey could have a likely significant effect. A Natura Impact Statement has been completed and is attached as Appendix B.

4.3.2 Project Specific Mitigation Project Specific Mitigation is proposed in the Natura Impact Statement (Appendix B) as follows. Keeragh Ireland SPA – proposed mitigation: ▪ It is recommended that the survey vessels stay at least 750m away from the base of the Keeragh Islands during the period February to September to minimise disturbance to nesting birds. ▪ It is recommended that the survey of the application area from the coast to 4km offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. Mid-Waterford Coast SPA - proposed mitigation: ▪ It is recommended that the survey of the application area from the coast to 2km offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. ▪ It is recommended that borehole works are conducted as late in the breeding season as possible and no earlier than August. By postponing the survey disturbance of incubating or chick-rearing adults will be reduced and chicks will have fledged. ▪ Geotechnical boreholes should be located a minimum of 100m from known breeding habitat e.g. caves, rock crevasses and sea cliffs.

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4.4 Marine Mammals

4.4.1 Potential impacts

4.4.1.1 Underwater sound changes One of the most important environmental concerns related to the proposed activities is the potential effects of underwater sound. This section considers the potential for marine mammals to be affected by sound associated with the geophysical survey (MBES, pinger/chirper, SSS) and borehole drilling. Both cetaceans and pinnipeds have evolved to use sound as an important aid in navigation, communication and hunting (Richardson et al. 1995). It is generally accepted that exposure to anthropogenic sound can induce a range of behaviour effects to permanent injury in marine mammals. Loud and prolonged noise may mask communicative or hunting vocalisations, preventing social interactions and effective hunting. High intensity noises such as from seismic survey, explosions and pile driving can cause temporary or permanent changes to animals’ hearing if the animal is exposed to the sound in close proximity and, in some circumstances, can lead to the death of the animal (Richardson et al. 1995). Where the threshold of hearing is temporarily damaged, it is considered a temporary threshold shift (TTS), and the animal is expected to recover. If there is permanent damage (permanent threshold shift (PTS)) where the animal does not recover, social isolation and a restricted ability to locate food may occur, potentially leading to the death of the animal (Southall et al. 2007). The assessment below considers the potential for the proposed geophysical survey and borehole drilling to generate sound at a level that exceeds the thresholds at which the onset of injury (PTS) or disturbance (TTS) effects may occur. The thresholds to define PTS and TTS are described below.

Injury thresholds In order to evaluate the potential of the geophysical survey and borehole drilling to cause harm to marine mammals, an assessment has been conducted using both the recently published American National Marine Fisheries Service (NMFS) (2018) thresholds for the onset of PTS and TTS and the thresholds defined by Southall et al. (2007). Both approaches separate marine mammals into five groups based on their functional hearing, namely: low-frequency cetaceans; mid frequency cetaceans; high frequency cetaceans; pinnipeds (Phocid) in water; and pinnipeds (Otariid) in water. Table 4-1 presents the species identified as present in the survey area according to their functional hearing category. Table 4-1 Marine mammal auditory bandwidth

Group Low-frequency Mid-frequency High-frequency Pinnipeds (Phocid) Otariid cetaceans cetaceans cetaceans in water in water Generalised 7Hz – 35kHz 150hz – 160kHz 275Hz – 160kHz 50Hz – 86kHz 60Hz – hearing range 39kHz (NMFS 2018) Species Baleen whales Most toothed whales, Certain toothed True seals Otter dolphins whales, porpoises Species Minke whale Short-beaked common Harbour porpoise Grey seal Otter potentially in Humpback whale dolphin Harbour seal application area Fin whale Bottlenose dolphin during April to Striped dolphin October Risso’s dolphin White-beaked dolphin Long-finned pilot whale Killer whale Source: NFMS (2018)

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The thresholds for the onset of PTS and TTS, as published in NMFS (2018) and Southall et al. (2007), are provided in Table 4-2. These reflect the current peer-reviewed published state of scientific knowledge. The threshold levels (Table 4-2) have been used to determine the range at which sound levels from the proposed marine survey dissipate to below the thresholds i.e. the range within which there is the potential for injury to marine mammals. Received sound by marine mammals from the geophysical survey and the borehole drilling are considered as near-continuous, rather than impulsive. However, there are no publicly available data on sound exposure levels (SEL) for the geophysical equipment and borehole drilling. For the purpose of this assessment, sound pressure levels (SPL), which are more readily available, have been used instead to compare the sound levels of the geophysical equipment and borehole drilling against PTS and TTS thresholds (for near-continuous noise the thresholds are provided in SEL as this accounts for the time element as well as the noise level whereas impulsive just considers the noise). Table 4-2 Injury criteria for marine mammals (impulse) - SPL (unweighted)

Group NFMS (2018) Southall et al. (2007) PTS TTS PTS TTS

Peak SPL (SPL0-peak Peak SPL (SPL0-peak dB re: 1 µPa (peak) dB re: 1 µPa (peak) dB re 1 μPa2s) dB re 1 μPa2s) (flat) (flat) (unweighted) (unweighted) Low-frequency 219 213 230 224 cetaceans Mid-frequency 230 224 230 224 cetaceans High-frequency 202 196 230 224 cetaceans Pinnipeds (Phocid) 218 212 218 212 in water Pinnipeds (Otariid) 232 226 - - in water Source: Southall et al. (2007); NFMS (2018)

Disturbance thresholds Behavioural disturbance from underwater sound sources is more difficult to assess than injury and is dependent upon many factors related to the circumstances of the exposure (Southall et al. 2007, NFMS 2018). An animal’s ability to detect sounds produced by anthropogenic activities depends on its hearing sensitivity and the magnitude of the noise compared to the amount of natural ambient and background anthropogenic sound. In simple terms for a sound to be detected it must be louder than background and above the animal’s hearing sensitivity at the relevant sound frequency. Behavioural responses caused by disturbance may include animals changing or masking their communication signals, which may affect foraging and reproductive opportunities or restrict foraging, migratory or breeding behaviours; and factors that significantly affect the local distribution or abundance of the species. An animal may swim away from the zone of disturbance and remain at a distance until the activities have passed. Behavioural disturbance to a marine mammal is hereafter considered as the disruption of behavioural patterns, for example: migration, breeding and nursing. NMFS has not yet published guidelines on behaviour thresholds due to the complexity and variability of the responses of marine mammals to anthropogenic disturbance.

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For the purposes of this assessment the threshold for behavioural disturbance has been assessed as 160 dB rms for all cetacean species (BOEM 2017, NMFS 2018).

Assessment Sound attenuates as it propagates through water and the local oceanographic conditions will affect both the path of the sound in the water column and how much sound is transmitted. The NMFS Technical Guidance on Marine Mammal Hearing: Acoustic Thresholds for onset of permanent and temporary threshold shift (NMFS 2016) spreading model was used for this assessment to calculate the distance at which sound generated by the survey activities will attenuate to below the injury and disturbance thresholds. It assumes that sound is spread geometrically away from the source but does not account for attenuation or directional sources; it therefore provides conservative estimates. It also does not take into consideration the conditions within the application area, such as bathymetry, water depth or sediment type and thickness. Modelling results, i.e. the distances from the source at which sound levels will diminish to below the NMFS (2018) and Southall et al. (2007) criteria thresholds, for each location are summarised in Table 4-3 below. The distance from the sound source (‘range’) at which disturbance effects may be observed is also presented in Table 4-3 below. There is limited sound source information available for sound produced by borehole drilling (rotary coring). An investigation into the effects of noise from near-shore marine drilling activity taken from hydrophone readings in the water column (ICOE 2010) compared sound propagation from rotary coring in to different seabed types. The study identified that during soft sediment coring the highest sound pressure level recorded (at 23m from the JUB) was 107db re 1 1µPa (Peak) at 10Hz. For hard rock drilling the highest sound pressure level recorded was also at 107db re 1µPa (Peak)) at 7.5m from the JUB. Therefore, borehole drilling within soft sediments is below the threshold for injury for all cetacean species groups.

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Table 4-3 Summary of results

Auditory group Threshold Distance in metres at which threshold is exceeded MBES SSS Chirp & Pinger Boomer SPL: 232dB(rms)re 1µPa SPL: 226dB(rms) re 1µPa SPL: 208dB(rms) re 1µPa SPL: 208dB(rms) re 1µPa @1m (converted to 235 @1m (converted to 229 @1m (converted to 211 @1m (converted to 211 2 2 2 dB0-peak re 1µPa -s) * dB0-peak re 1µPa -s) * dB0-peak re 1µPa -s) * dB0-peak re 1µPa2-s) * Frequency: 95kHz Frequency: 114kHz Frequency: 1.5kHz Frequency: 2.5kHz Low-frequency PTS NFMS (2018) 219 15 5 Threshold not exceeded Threshold not exceeded cetaceans Southall et al. (2007) 230 2.6 Threshold not exceeded Threshold not exceeded Threshold not exceeded TTS NFMS (2018) 213 40 13 Threshold not exceeded Threshold not exceeded Southall et al. (2007) 224 7 2.6 Threshold not exceeded Threshold not exceeded Mid-frequency PTS NFMS (2018) Threshold not exceeded 230 2.6 Threshold not exceeded Threshold not exceeded cetaceans Southall et al. (2007) TTS NFMS (2018) Threshold not exceeded 224 7 2.6 Threshold not exceeded Southall et al. (2007) High-frequency PTS NFMS (2018) 202 110 60 4.6 4.6 cetaceans Southall et al. (2007) 230 2.6 Threshold not exceeded Threshold not exceeded Threshold not exceeded TTS NFMS (2018) 196 180 110 11 11 Southall et al. (2007) 224 7 2.6 Threshold not exceeded Threshold not exceeded Pinnipeds PTS NFMS (2018) 15 7 Threshold not exceeded Threshold not exceeded 218 (Phocid) in Southall et al. (2007) water TTS NFMS (2018) 40 15 Threshold not exceeded Threshold not exceeded 212 Southall et al. (2007) Pinnipeds PTS NFMS (2018) 232 2 Threshold not exceeded Threshold not exceeded Threshold not exceeded (Otariid) in TTS NFMS (2018) 226 4.6 2 Threshold not exceeded Threshold not exceeded water All species Disturbance BOEM (2017), NMFS 160 940 720 2,600 2,500 (2018) Note: *derived from Genesis Oil and Gas Consultants (2011)

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Potential injury The geometric spreading modelling results (Table 4-3) indicate that all cetaceans and pinnipeds species are at risk of injury or disturbance from the geophysical survey. Section 3.5 and Table 3-4 above identified a total of 11 species that have been observed in waters within the survey area. Of these, minke whale, bottlenose dolphin, Risso’s dolphin, harbour porpoise, grey and harbour seals are likely to be found in the survey area during the April to October period. Short beaked dolphin may also be found in October to January, when there is a winter peak in numbers. The remaining 8 species are unlikely to be present in the survey area during this period or are rare visitor of the east coast of Ireland. Table 4-3 above has identified that sound levels from the MBES equipment represent a worst-case impact to marine mammals (injury only). The assessment concluded: ▪ Minke whale are the only low frequency cetacean species likely to be found in the survey area during April to October. Both the MBES and the SSS could result in injury to this species, with permanent injury (PTS) within 15m of the source and temporary injury within 40m (Table 4-3). ▪ Mid-frequency cetaceans, such as bottlenose dolphin, common dolphin and Risso’s dolphin, are expected to be impacted by the MBES within up to 2.6m of the source. TTS is however likely to occur from both MBES and SSS, respectively within 7m and 2.6m. ▪ Harbour porpoise is classified as a high frequency cetacean. All geophysical survey equipment has the capacity to produce noise capable of causing PTS, up to 110m (MBES), 60m (SSS) and 4.6m (chirp/pinger and boomer). TTS may occur up to 180m from MBES, 110m (SSS) and 11m (chirp/pinger and boomer). ▪ Grey and harbour seal (Phoceid) in water have the potential to be permanently injured by the MBES and SSS within up to 15m and 7m respectively. Temporary injury (TTS) could occur within 40m and 15m of the sound source. Individuals originating from protected sites may be present within the survey area, as marine mammals are highly mobile species (see Section 3.5). The closest protected site for harbour porpoise is the West Wales Marine / West Gorllewin Cymru Forol SAC, located 83km from the survey area, whilst Saltee Island SAC, (designated for grey seal) is located 1km distant from the eastern export cable route. Animals present in the survey area will be part of the wider Irish Sea populations and are known to range widely across the Irish Sea, and East Atlantic. Cetacean species distribution is linked to the availability of their preferred prey items. Although modelling indicates the risk of injury, it should be noted that the calculation for TTS and PTS does not account for the directional quality of the noise source, seabed interactions, seabed type, change in salinity, bathymetry, temperature or density, which would reduce the zone of esonification. In addition to cylindrical spreading loss for acoustic propagation in the water column, higher frequency acoustic energies are more quickly absorbed through the water column than sounds with lower frequencies. Due to these factors, the distances for TTS and PTS are highly conservative and worst case. The most sensitive species to underwater noise change within the survey area is harbour porpoise. As part of an appropriate assessment looking at impact of underwater sound on an area of importance for harbour porpoise, BEIS (2018) stated that "Geophysical surveys (primarily 2D and 3D seismic) have the potential to generate sounds that exceeds thresholds of injury, but only within a limited range from source (tens to hundreds of metres); for site surveys [which includes sub-bottom profilers], the range from source over which injury may occur will be even smaller." The Saltee Island SAC lies 1km from the application area and therefore it is possible that grey seal from the site will be present in the water, especially during the earlier months of the proposed survey

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window e.g. May to August. From August through to December animals are likely to be hauled up on beaches for pupping, at closest range the beaches are located 6.2km from the application area. As discussed above it is possible that grey seal from this site could be injured if they come within 40m of the sound source. However, as discussed in Section 4.4.1.3, seals are likely to flee if vessels approach within 900m; suggesting that they will avoid the area before they encounter sound levels that will harm them. Given the zone of influence (2.4km for disturbance) and the distance to Saltee Island itself (6.2km) it is unlikely that breeding, moulting and resting seals on the haul out sites of Saltee Islands SAC would be affected by the proposed survey. The survey contractor will follow the DAHG ‘Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters’ (DAHG 2014). The guidance requires the following: pre- start monitoring prior to the start of any sound-generating activities; ramp-up procedure (i.e. soft- start) of all equipment; and the presence of a minimum of one marine mammal observer onboard the survey vessel (DAHG 2014). The survey will not start until the pre-start monitoring search is completed and no marine mammal is observed within 500m of the sound source. Following this best practice significantly reduces the likelihood that marine mammals are injured by the survey activity. The significance of the effect has therefore been assessed as Not significant.

Disturbance The geometric spreading model suggests that disturbance could occur within up to 2,600m from the sound source as a worst-case (Table 4-4). This suggests that all marine mammals could be disturbed by the sound emitted by the chirp/pinger, boomer, MBES and SSS. The worst-case disturbance is resulting from noise emitted from the chirp/pinger. Responses to behavioural disturbance are complex and variable for each marine mammal individual. Results indicate that studies into marine mammal disturbance by anthropogenic noise acknowledge a high degree of variation in results and even when information on equipment specifications is known it is still difficult to predict the level of disturbance for marine mammals accurately. It is widely recognised that further study and monitoring of marine mammal reactions and recoverability is required (NMFS 2018). With regard to disturbance, evidence of the effects of geophysical surveys on cetaceans is limited but BEIS (2018) summarises the results of a study carried out in the Moray Firth that observed responses to a 10-day 2D seismic survey. The 2D seismic survey took place in September 2011 and exposed a 200km2 area to noise throughout that period. A 470 cubic inch airgun array was used, which generated peak-to-peak source levels of 242-253 dB re-1μPa @ 1m. A relative decrease in density of harbour porpoise within 10km of the survey vessel was reported. However, these effects were short-lived, with porpoise returning to the area within 19 hours after cessation of activities. BEIS (2018) also states that “information on the potential effects of other geophysical surveys (e.g. sub-bottom profilers) is currently very limited and the most recent UK Offshore Energy Strategic Environmental Assessment (DECC 2016) concluded that effects are negligible but with a high degree of uncertainty”. The underwater noise changes associated with MBES, SSS, chirper/ping and boomer, and therefore the associated potential for disturbance is generally acknowledged as small when compared to activity such as use of air guns during 2D and 3D seismic and wind farm piling. The proposed geophysical survey will be a one-off event and will progress slowly within the survey area. Animals will have sufficient time to avoid the survey spread, and it is unlikely that they will swim under operating equipment. Animals may actively avoid the survey but as demonstrated by the research in the Moray Firth will return to the area once the survey has passed through i.e. within a day if not hours. It will therefore not act as a barrier to migration routes or cause significant long-term disturbance As discussed, marine mammals are highly mobile, and species identified as likely to be observed in the survey area range widely across the Irish Sea, North Sea and East Atlantic. While the survey may create a disturbance for marine mammals that lead to them avoiding the area temporarily, the species are

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wide ranging and will return. Section 3.7 above has identified the area is routinely used by commercial shipping. It is therefore likely that the marine mammals within the application area and its vicinity are habituated to background levels of anthropogenic sound resulting from shipping and other activities. Only noises which are relatively loud compared to background levels (such as seismic survey) are likely to result in a discrete behavioural response such as displacement from or avoidance of an area, although this is not to say that exposure to chronic background noise is without impact (e.g. Rolland et al. 2012). Animals could also be expected to respond differently to sudden (e.g. impulsive) sound and continuous noise, although there is potential for habituation in both situations. Equally, not all animals will respond in the same manner and there may be marked differences between responses to the same sound source even for individuals of the same species (e.g. Brandt et al. 2016). Sightings data from the IWDG suggest that animals were still being recorded in the region of the Greenlink Interconnector geophysical surveys (undertaken October/November) and have continued to be observed post-survey operations; indicating that marine survey works did not result in significant short-term disturbance to marine mammals in the area. It is likely that marine mammals within the application area will experience transient disturbance and the embedded mitigation (i.e. following DAHG ‘Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters’) will help to reduce the likelihood of significance effects. It is therefore considered that the significant of the effect of disturbance on any marine mammals is slight.

Cumulative effects Section 3.9 has identified a number of other geophysical surveys in the same region as the application area. The assessment above concluded that the significance of the effect of the proposed survey on marine mammals is Not Significant for injury level effects. Although, it concluded that the significance of disturbance effects is Slight, when considered alongside other activities occurring within the same region it may give rise to significant cumulative effects. The disturbance and subsequent displacement of animals from an area surrounding a development has the potential to affect communication, feeding and foraging opportunities and may restrict migration routes. An animal may swim away from the zone of discomfort and be excluded until the activities have passed. Marine mammals are wide ranging across the Celtic Sea but their range could be restricted if a number of similar noisy activities in a region reduced the suitable available habitat. Cumulative effects are likely to result where localised disturbance from more than one activity either occurs simultaneously resulting in a wider zone of disturbance restricting foraging, migratory or breeding behaviour; or consecutively within a restricted area resulting in an extended period of disturbance producing a barrier. The underwater sound assessment established that disturbance could occur within a radius of 2.6km of the sound source (worst-case). Section 3.9 identified the following two projects within the application area that will generate underwater sound: ▪ Ireland - France Fibre Cable survey– intersects the application area. A geophysical and geotechnical survey was due to be conducted during September 2017 and August 2018. However, the application is still under consultation, so it is possible that this survey will be conducted during the same period as the Celtic Sea survey. ▪ Ireland: Inis Ealga offshore windfarm – located 40km from the western export cable route area. Dates of potential survey start dates are not available therefore its prudent to assume that survey works could overlap in time with survey works on the proposed Celtic Sea survey. ▪ Greenlink Interconnector – intersects the application area. It is likely that pre-cable installation a limited geophysical survey will be conducted to determine if there is any debris along the route. This is likely to occur between 2020 and 2023.

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No underwater sound assessment was provided for Ireland – France fibre cable system, the Inis Ealga application is not available and the foreshore licence application for the Greenlink Interconnector is yet to be submitted. As the survey scopes are similar to the proposed works within the application area it is therefore assumed that the zone of disturbance from these projects will be similar. It is planned that the survey in the application area will be conducted between April and October, within the 5 years following award of the Foreshore Licence. SSE would like the Foreshore Licence to start on 1st August 2019 (Section 2.1). Based on the current timing of the three surveys (see above, and Table 3-5), there is the potential for a temporal overlap with two surveys occurring concurrently or two surveys occurring consecutively. However, data acquisition can be impaired if two geophysical surveys occur at the same time in close proximity due to equipment interference. It is therefore more likely that the surveys would occur consecutively. This would result in an extension of the time period that marine mammals would be disturbed. The cumulative effect would be temporary and Slight. Given that distance of the application area to Saltee Islands SAC (1km), the largest potential for a cumulative effect would be on grey seals from this SAC. At closest range the, Ireland - France Fibre Cable survey is located 50km from the Saltee Islands SAC, the Greenlink Interconnector is located 10km from the Saltee Islands SAC and the Inis Ealga potential windfarm location is located 40km from the Saltee Islands SAC. Given that the ZOI for disturbance is 2.6km, it is unlikely that there will be a spatial overlap of disturbance and or injury to marine mammals. There is however potential that marine mammals could be displaced from one ZOI to another ZOI. However, a study on the potential cumulative impacts from a number of nearby windfarms on Harbour Porpoise in the Southern North Sea SAC, found that harbour porpoise displacement was temporary and harbour porpoise relocated elsewhere. It was concluded that seismic surveys would not have an adverse effect upon the integrity of the Southern North Sea SAC. Taking this study into consideration along with the fact that there will not be a spatial overlap into the ZOI from survey works, the cumulative effect of underwater sound on seals in the area will be temporary and Slight.

4.4.1.2 Risk of injury from collision There is the risk that animals could collide with survey vessels. Shipping collision is a recognised cause of marine mammal mortality worldwide, the key factor influencing the injury or mortality caused by collisions being ship size and speed. Ships travelling at 14 knots or faster are most likely to cause lethal or serious injuries. Vessels involved in the survey are likely to be either stationary or travelling considerably slower than this and therefore the collision risk is likely to be lower than that posed by commercial shipping activity. Therefore, risk of injury from collision to marine mammals is very low, and the significance of any effects will be imperceptible.

4.4.1.3 Visual disturbance Seals hauled out on land could react to the presence of vessels. In general, ships more than 1,500m away from hauled out grey or common seals are unlikely to evoke any reactions, between 900 and 1,500m seals could be expected to detect the presence of vessels and at closer than 900m a flight reaction could be expected (Brasseur & Reijnders,1994). This impact would be most significant for breeding and moulting seals, hauled out on the coast and on intertidal banks. The Saltee Island SAC lies 1km from the edge of eastern export cable route and the land where seals will be hauled out is located 6.2km from the application area. It is unlikely that seals hauled out on land will react to the presence of the survey vessels, therefore the AA screening concluded that there is no likely significant effects on the Saltee Islands SAC (Section A.4.1.4). It is considered that the significance of any effects to seals will be imperceptible.

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4.4.2 Project Specific Mitigation The project has already identified the potential for disturbance and therefore following Good Industry Practice has incorporated the use of the DAHG (2014) guidelines into the survey design (See Section 2.9, EM1). The assessment has identified the potential for cumulative effects with other surveys in the region. SSE will liaise with Greenlink Interconnector Limited and Ireland-France Subsea Cable Limited to determine whether survey schedules will overlap. Efforts will be made to coordinate survey activities in a manner that reduces cumulative effects.

4.5 Fish

4.5.1 Potential impacts

4.5.1.1 Underwater sound changes The survey operations will generate noise from a variety of sources, including: vessel activity; side scan sonar; multi-beam echosounder; sub bottom profiler; geotechnical borehole sampling; and VC and CPT sampling. Potential effects on fish from anthropogenic sounds ranges from: behavioural changes, such as moving towards or away from a sound source or leaving a feeding or breeding site and increased stress; through to temporary impacts such as temporary hearing loss and the masking of biologically relevant sounds; and in extreme cases (where intense sound sources are used such as explosives and 3D seismic surveys) injuries that might either directly result in death or make the fish vulnerable in the short term. Longer lasting sounds, such as those associated with shipping noise, cause a general increase in low frequency background noise (<1kHz). Some marine fish can produce and detect noise, and while not fully understood, this is thought to be associated with alarm calls and social behaviour, and studies have found that an increase in background noise can cause an avoidance or attraction reaction in fish (Thomsen et al. 2006). Fish ability to hear noise is dependent on their hearing structures, which indicate their sensitivity to sound. High sensitivity hearing species (including herring, shad and sprat) have specialisations of the auditory apparatus; medium sensitivity species (including salmon and cod) have a swim bladder; and low sensitivity species with no swim bladder include flat fish such as plaice and dab (Nedwell et al 2004). There is also potential for some fish and shellfish species to be vulnerable to acoustic survey activities during sensitive life stages, for example during the egg and larvae development stages. All SAC’s within 40km of the application area have been screened for the presence of Annex II migratory fish species as qualifying designating interest features, in recognition that as mobile species, fish could potentially enter the survey. It is possible that the following Annex II listed species are likely to be within or moving through the application area at certain times of the year: ▪ Sea lamprey – late April to early June ▪ River lamprey – September to June ▪ Twaite shad – year-round and migrate into rivers from April-July ▪ Atlantic salmon – May to June and autumn months. Of these four species, only Atlantic salmon and twaite shad are known to be sensitive to underwater noise.

Twaite shad, as a member of the herring family, is a hearing specialist fish. There is no information on the hearing sensitivity of shad, so information on herring has been used to infer sensitivity. The swim bladder and inner ear in herring are connected, allowing fish to detect frequencies to over 5kHZ; with

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optimum sensitivity between 30Hz-1kHz (Nedwell et al. 2004). The frequencies at which the peak sound pressure levels of the geophysical survey techniques proposed are at the upper limit of the audible range for herring. However, disturbance and injurious effects can occur from the sudden change in pressure generated by activities. The greater the sound pulse the greater the likely effects to herring.

Nedwell et al. (2012) estimates approximate avoidance ranges for herring using a 90 dBht criterion; interpreted as the level at which strong avoidance behaviour by virtually all individuals will result. The study looks at noise created during offshore windfarm installation and includes figures for seismic surveys. Although a seismic survey is not specifically defined, seismic airgun sources are mentioned. Airguns typically generate higher sound pressure levels1 (Wyatt 2008) than those proposed for the geophysical survey, and therefore would constitute a worst-case. The study estimates an impact range of 4km for seismic survey. Assuming worst case seismic survey sound pressure levels, fish will avoid the immediate area around the survey vessel (for approximately 4km radius) once operations have started and are unlikely to return to the area until the sound source has passed or drops below 90dBht. Therefore, it is extremely unlikely that fish will experience significant impact other than temporary displacement from the immediate area surrounding the geophysical survey activity. Geophysical surveys progress relatively quickly, typically 1m/s (approximately 2 knots) and the maximum time that any point within a 4km radius of the survey vessel would experience noise levels above the 90dBht is approximately 4 hours. Twaite shad migrate from the sea to rivers between April and July. As the survey period has not been defined it is therefore possible that the geophysical survey will overlap with this migratory period. The closest SAC for which Twaite shad is a qualifying interest feature is the River Barrow and River Nore SAC. However, the geophysical survey lies to the west and east of the estuary and would not act as a barrier to fish entering the rivers. It should be noted that the noise source and potential impact zone that is present during the proposed survey as well as being limited in range is also moving slowly in a constant direction (in the order of 1 m/s) along the principal survey line orientation. It is also expected that any fish species susceptible to stress and within range of the potential noise impact would be able to maintain adequate separation.

Drilling operations are not continuous, and studies indicate that if pelagic fish are within 7.5m of the geotechnical drill site (drilled through rock) when operations begin, may experience barotraumas to the swim bladder. This would reduce the fish’s ability to survive in the environment (ICOE 2010). However, the likelihood of pelagic fish (including salmon) being within the zone of ensonification of the drill site (due to the increase in localised disturbance from support and survey vessels prior to drilling) is extremely low.

Fish will avoid the survey area once operations have started and are extremely unlikely to move towards the sound source. Therefore, it is unlikely that fish will experience a significant impact other than temporary displacement from the immediate area surrounding the survey activity.

Any loss of individuals (adults or juveniles) within the immediate area of the survey is considered to be unlikely and given the wider geographic extent of the spawning and nursery areas, the effect will be slight.

4.5.2 Project Specific Mitigation No Project Specific Mitigation has been proposed.

1 Wyatt (2008) report values of 249 to 266 dB re 1 µPa m (peak to peak); at frequencies of 0 to 20kHz for airgun arrays in comparison to 214dB dB re 1 µPa m (peak to peak) for a boomer.

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4.6 Birds

4.6.1 Potential impacts

4.6.1.1 Visual disturbance The additional activity in the region during the proposed surveys (both at the beach and in the foreshore area) may disturb birds which use the area for feeding, loafing and breeding. Disturbance can lead to a number of physiological and behavioural responses which can affect demographic characteristics of the population. Responses to disturbance can result in: loss of energy; impaired breeding; unrest through increased vigilance; and disruption to incubation leading to increased nest failures due to predation and nest abandonment (Valente et al. 2011). The extent to which a seabird responds to disturbance is dependent upon a number of factors including: period of breeding cycle during which disturbance occurs; duration, type and intensity of the disturbance; presence of opportunistic predators; and the degree of habituation with the disturbance (Showler et al. 2010). Some seabirds are more resilient to disturbance than others. Whilst birds present on the surface waters in the vicinity of the survey vessel could be temporarily displaced from their chosen feeding/resting location, they are likely to readily move to another nearby location. Given the short duration of the operations with the vessel moving steadily forward along the survey route, any disturbance at a given location is likely to be minimal and given the level of shipping activity in the region, disturbance is unlikely to be felt against background levels. Therefore, the significance of effects on birds from the survey will be imperceptible. The birds most vulnerable to disturbance would be any nesting birds in the immediate vicinity of the survey works during the breeding season. Disturbance to nesting birds due to vessel presence, could have an impact on the success rate of the breeding population. The zone of impact of disturbance on nesting birds (notably guillemots, razorbills and kittiwake) is considered to be up to approximately 2km surrounding the application area (NE and JNCC 2012). Therefore, all SPAs within this 2km distance were screened for nesting birds as part of the Appropriate Assessment Screening presented in Appendix A. The AA screening concluded that for two sites, the Keeragh Island SPA and Mid-Waterford Coast SPA, there is potential that the survey could have a likely significant effect on the conservation objectives. These sites are located within 2km of survey operations and contain qualifying interest features which breed within the site. It is therefore possible that survey works could disturb breeding bird populations. A Natura Impact Statement has been completed for the two sites and is presented in Appendix B. Project Specific Mitigation has been proposed to reduce the likely significant effect.

4.6.2 Project Specific Mitigation Project Specific Mitigation is proposed in the Natura Impact Statement (Appendix B) as follows. Keeragh Ireland SPA – proposed mitigation: ▪ It is recommended that the survey vessels stay at least 750m away from the base of the Keeragh Islands during the period February to September to minimise disturbance to nesting birds. ▪ It is recommended that the survey of the application area from the coast to 4km offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. Mid-Waterford Coast SPA - proposed mitigation:

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▪ It is recommended that the survey of the application area from the coast to 2km offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. ▪ It is recommended that borehole works are conducted as late in the breeding season as possible and no earlier than August. By postponing the survey disturbance of incubating or chick-rearing adults will be reduced and chicks will have fledged. ▪ Geotechnical boreholes should be located a minimum of 100m from known breeding habitat e.g. caves, rock crevasses and sea cliffs.

4.7 Sea and Air Navigation Systems There will be no equipment on the vessel or on the land-based equipment which will interfere with any sea or air navigation systems.

4.8 Archaeology

4.8.1 Potential impacts

4.8.1.1 Direct or indirect damage to an archaeological asset The geophysical survey is non-intrusive and therefore it is not anticipated it will have any impact on archaeological features. In addition, to obtaining the environmental conditions of the seabed, the geophysical survey is intended to determine the location of any unknown archaeology. The magnetometer data acquired during the geophysical survey is a key component of this. A detection device consent will be applied for ahead of the survey, and consultation undertaken with the DAHG – Underwater Archaeology Unit to ensure that all requirements are met during the application process. The results of the geophysical survey will be interpreted by a licensed marine archaeologist to inform: the positioning of the intrusive features of the geotechnical and environmental surveys e.g., vibrocores, CPTs, geotechnical boreholes and environmental grab sample stations; and future environmental assessment. In addition to this, an archaeologist will carry out a walkover inspection of the intertidal area prior to commencement of any intrusive survey works. All sample locations will be positioned to avoid archaeological sensitive areas. An archaeological excavation licence will be applied for once the geophysical data has been reviewed. Mitigation embedded into the survey design and compliance with Irish statute will ensure that the effect of the proposed survey on archaeology will be imperceptible.

4.8.2 Project Specific Mitigation A written scheme of investigation and protocol for archaeological discoveries will be prepared and followed by the survey contractor. An archaeologist will be on-hand during the survey should any archaeological finds be made.

4.9 Marine Activity

4.9.1 Potential impacts

4.9.1.1 Displacement of vessels and fishing activity The types of marine activity that occur in the application area relate to shipping, fisheries and leisure/sports traffic categories.

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This section summarises the potential impacts of the proposed site investigation works based on the navigational features and traffic identified in the review as well as Anatec’s experience in assessing offshore wind farms in the UK and internationally, informed by relevant guidance such as: ▪ Maritime and Coastguard Agency (MCA). Marine Guidance Note (MGN) 543, Offshore Renewable Energy Installations (OREI) – Guidance on United Kingdom (UK) Navigational Practice, Safety and Emergency Response Issues (MCA, 2016); ▪ MCA Methodology for Assessing Marine Navigational Safety Risk of Offshore Renewables (MCA, 2011); and ▪ International Regulations for the Prevention of Collisions at Sea (COLREGs) 1972 as amended (IMO, 1972). The proposed site investigation works are relatively minor, temporary activities involving geophysical and geotechnical vessels on location for a few months plus deployment of buoys and an ADCP on the seabed. Therefore, any potential effect is expected to be minor and temporary. For example, risk of collision between vessels, allision with buoy or fishing gear interaction with ACDP. Notices to Mariners will be issued by the survey contractor requesting that vessels keep a safe distance from the works. SSE’s Fisheries Liaison Officer for the survey will ensure that all local fishing organisations are in receipt of the Notice to Mariners and are aware of the survey ahead of mobilisation. Other marine users will be requested to keep a safe distance from the survey vessels; this is generally 500m radial distance, although it might be extended further to the rear of the survey vessel if towed gear is in use. The FLO will request fishermen with static gear in the application area move the pots until the survey has been completed. The survey contractor will define specific ‘blocks’ in which survey activities will be completed before the next block starts. This will minimise the time a particular area has to be cleared by static gear. Section 3.6 indicates that mid trawl (net) fishing, pot fishing, nets fishing, periwinkle harvesting and dredge fishing take place along the inshore waters of the cable export corridors. As the exclusion zone moves with the survey spread, potential impacts will be temporary and restricted to this relatively small zone. The geotechnical vessels will also have a temporary exclusion zone due to their restricted manoeuvrability. The execution of the proposed offshore surveys will increase the volume of shipping traffic by a imperceptible amount; within the boundary of seasonal fluctuations. Therefore, there will be no additional navigational safety implications. However, established marine navigation practices will be adhered to and maintained by the survey vessels involved. As the works are temporary there will be no effect on marine navigation and fishing activity once the survey has been completed. Therefore, the significance of effects on commercial fisheries in the area will be imperceptible. The proposed Greenlink interconnector intersects the eastern Celtic Sea export cable route and the Ireland-France interconnector survey area intersects the western Celtic Sea export cable route. There is therefore the potential for cumulative effects on commercial fisheries. The worst-case is that fishermen using static gear (pot fishing) are requested to move fishing gear for more than one survey, extending the period in which they cannot access their traditional grounds. However, the cumulative effect will be temporary as fishermen will be able to return to the area once the survey has passed and therefore it is concluded that the significance of cumulative effects will be slight.

4.9.1.2 Loss or damage to commercial fisheries habitats/fish stocks Given that the application area lies 5km south east of the Bannow shellfish waters, 11km east of Dungarvan Harbour and 10km east of Waterford Harbour (Checkpoint/Arthurstown/Creadan Head) Shellfish Water, survey activities will not affect water quality within these areas.

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As discussed in Section 3.5 commercially exploited shellfish species in the area include lobster; crayfish; spider, brown, green and velvet crabs; scallops; surf and razor clams; periwinkles; and whelks (DCCAE 2015). The likelihood of borehole drilling activities affecting these species will be minimal as these species commonly occur in naturally turbid environments and have the ability to recover from environmental disturbance (Marlin 2019). Furthermore, the re-suspension of sediments from this activity is likely to be localised. Therefore, effects on these commercially exploited species will be imperceptible.

4.9.1.3 Damage to or interference of an external cable or pipeline asset Two submarine cables cross the application area, the retired Celtic submarine cable from Sennon to Kilmore, operated by BT and the active Solas submarine cable from Kilmore to Port Eynon, operated by Vodaphone. The geotechnical and environmental sampling locations will be positioned to avoid all existing cables by a minimum of 250m. No subsea pipelines are located within the application area. The significance of effects on the cable asset will be imperceptible.

4.9.2 Project Specific Mitigation The assessment has identified the potential for cumulative effects with other surveys in the region. SSE will liaise with Greenlink Interconnector Limited and Ireland-France Subsea Cable Limited to determine whether survey schedules will overlap. Efforts will be made to coordinate survey activities in a manner that reduces cumulative effects. The Anatec (2019) assessment concluded that to mitigate against risks to shipping and navigation, standard industry measures should be adequate, including: ▪ Liaison with local fishermen; ▪ Liaison with local ports and harbours; ▪ Notices to Mariners; ▪ Consultation with Irish Lights regarding marking and lighting; ▪ Consultation with Irish Coast Guard; and ▪ Vessel assurance and management including procedures such as compliance with COLREGS, use of appropriate marking and lighting, AIS broadcasts with up-to-date navigational status, adverse weather policy, emergency response plans, etc.

4.10 Recreational Resource

4.10.1 Potential impacts

4.10.1.1 Restricted access The key recreational activity relating to the offshore area is likely to be restricted to sailing and possibly diving. Notices to Mariners will be issued by the survey contractor requesting that vessels keep a safe distance from the works (see Section 2.7). The main concern in the intertidal / nearshore area of the application area will be maintaining access to the beach areas for recreational use during the works. The location of the geotechnical boreholes are currently not known, but it is possible that a location within the intertidal area will be required. Any restrictions on the beach will be limited in duration (i.e. one to two weeks) and the beach will be left in a pre-impact condition. Disturbance to recreational users will be temporary. Therefore, effects on recreational users in the area will be imperceptible.

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SSE will consult with all the relevant stakeholders e.g., local authorities, sailing clubs, Greenlink Interconnector Limited and Ireland-France Subsea Cable Limited, as appropriate ahead of planned survey works.

4.10.2 Project Specific Mitigation The geotechnical boreholes will be programmed so that no works in the intertidal or nearshore area (i.e. out to the 10m water depth contour) will be undertaken during July and August.

4.11 Waste Management The survey vessels will operate under international standards (MARPOL) with respect to black and grey waste water and food waste discharges, which are designed to eliminate impacts to coastal waters, and reduce the levels of discharge in offshore waters. Therefore, no effects are expected.

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Otter Survey of Ireland 2010/12. Irish Wildlife Manuals on the breeding success of ground-nesting and - No. 76. National Parks and Wildlife Service, nesting birds? CEE review 05-010 (SR16). Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland. 73 Southall, B.L., Bowles, A.E., Ellison, W.T., Finneran, J.J., Gentry, R.L., Greene Jr, C.R., Kastak, Ketten, D.R., 65 Reid, J.B., Evans, P.G.H. and Northridge, S.P. (2003). Miller, J.H., Nachtigall, P.E., Richardson, W.J., Thomas, Atlas of Cetacean distribution in north-west European J.A. and Tyack, P.L. (2007). Marine Mammal Noise waters. Joint Nature Conservation Committee, Exposure Criteria: Initial Scientific Recommendations. Peterborough, UK. Aquatic Mammals, 33: Number 4. [online] Available at: http://sea- 66 Richardson, W.J., Greene, C.R. Jr., Malme, C.I., and inc.net/assets/pdf/mmnoise_aquaticmammals.pdf Thomson, D.H. (1995). Marine Mammals and Noise. (Accessed January 2019) Academic Press, San Diego, CA, USA.576p. 74 Thomsen, F., Ludemann, K., Kafemann, R. and Piper, 67 Rolland, R.M., Parks, S.E, Hunt, K.E., Castellote, M., W. (2006) Effects of Offshore Windfarm Noise on Corkeron, P.J., Nowacek, D.P., Wasser, S.K. and Kraus, Marine Mammals and Fish. Report prepared by Biola S.D. (2012). Evidence that ship noise increases stress in for COWRIE Ltd. Hamberg, Germany. 62pp. right whales. Proceeding of the Royal Society of Biological Sciences, 10. 1098/rspb. 2011. 2429. 75 Valente, J.J. and Fischer, R.A (2011). Reducing human disturbance to waterbird communities near 68 RSPB (2019a). Chough – breeding and nesting corps of engineers projects. Report reference ERDC habitats). [online] Available at: TN-DOER-E29. [online] Available at: https://www.rspb.org.uk/birds-and-wildlife/wildlife- http://el.erdc.usace.army.mil/elpubs/pdf/doere29.pd guides/bird-a-z/chough/breeding-and-nesting-habits/ f (Accessed February 2019) (Accessed February 2019) 76 Waterford Birds (2013). The Waterford Bird Atlas 69 RSPB (2019b). Peregrine – breeding and nesting 2006-2013. [Online] Available at: habitats). [online] Available at: http://www.waterfordbirds.com/atlas_specieslist.ht https://www.rspb.org.uk/birds-and-wildlife/wildlife- ml (accessed March 2019) guides/bird-a-z/peregrine/nest-sites-and-breeding- habits/ (Accessed February 2019) 77 Wexford Naturalists (2012). The Keeragh Islands. [online] Available at: 70 RSPB (2019b). Herring gull – breeding and nesting http://jncc.defra.gov.uk/pdf/Joint_SNCB_Interim_Dis habitats). [online] Available online: placement_AdviceNote_2017.pdf (Accessed February https://infrastructure.planninginspectorate.gov.uk/w 2019) p- content/ipc/uploads/projects/EN010039/EN010039- 78 Wyatt, R (2008). Joint Industry Programme on 000874-Palm%20Paper%20Ltd%20- Sound and Marine Life Review of Existing Data on %2016.3%20M.%20Ruddock%20&%20D.P.%20Whitfi Underwater Sounds Produced by the Oil and Gas eld(2007)%20A%20report%20from%20Natural%20Re industry Issue 1. August 2008. Seiche Measurements search%20(Projects)%20Ltd%20to%20Scottish%20Nat Limited Ref – S186. [online] Available at: ural%20Heritage%20(Part%201).pdf (Accessed https://gisserver.intertek.com/JIP/DMS/ProjectReport February 2019) s/Cat1/JIP-Proj1.4_Soundsinventory_Seiche_2008.pdf (Accessed March 2018) 71 Ruddock, M and Whitfield (2007). A report from Natural Research (Projects) Ltd to Scottish Natural Heritage. [online] Available online: https://www.rspb.org.uk/birds-and- wildlife/advice/gardening-for-wildlife/animal- deterrents/gulls/gull-breeding-habitats-and-nest- sites/ (Accessed March 2019)

72 Showler, D.A., Stewart, G.B., Sutherland, W.J., and Pullin, A.S. (2010). What is the impact of public access

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APPENDIX A

STAGE 1 - APPROPRIATE ASSESSMENT (AA) SCREENING

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A.1 INTRODUCTION In accordance with the provisions of Article 6(3) of the EU Habitats Directive and the Irish Habitat Regulations (2011) (S.I. No. 477 of 2011), an Appropriate Assessment (AA) Screening has been undertaken to consider the possible impacts of the proposed survey on relevant Natura 2000 sites. This Appendix presents the findings of this AA screening in support of the Foreshore Licence Application and has been based on the following guidance documents: ▪ The European Commission notice "Managing Natura 2000 sites. The provisions of Article 6 of the 'Habitats' Directive 92/43/EEC", 21 November 2018. ▪ The Department of Environment, Heritage and Local Government (DEHLG) Guidance “Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities, 11 February 2010.” ▪ The European Commission Guidance “Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC, November 2001”. ▪ The Department of Arts, Heritage and the Gaeltacht “Marine Natura Impact Statements in Irish Special Areas of Conservation: A Working Document, April 2012.” In accordance with the above guidance the sites considered in the AA screening are Natura 2000 sites which comprise Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). A.1.1 Legislative background

Under Article 6(3) of the Habitats Directive, any plan or project within or adjacent to Natura 2000 sites must be assessed with regard to their implications for the site conservation objectives. The Habitats Directive (Council Directive 92/43/EC) and Birds Directive (Council Directive 2009/147/EC) enable European Union member states to work together within the same legislative framework to protect Europe’s most valuable species and habitats, irrespective of political or administrative boundaries. At the heart of these Directives is the creation of a network of Europe’s most valuable species and habitat sites known as Natura 2000. Natura 2000 sites form an ecological network for the protection of sites that are of particular importance for rare, endangered or vulnerable habitats and species within the EU. The Natura 2000 network in Ireland is made up of SACs and SPAs. In Ireland, the Habitats and Birds Directives are transposed into national legislation by the European Communities (Birds and Natural Habitats) Regulations 2011, SI 477/2011. SACs and SPAs are fully protected by law in the Ireland from when the Minister gives notice of the decision to designate the sites. Candidate and proposed SACs and Sites of Community Importance (SCI) sites are also included as part of the Natura 2000 network. The obligation to undertake appropriate assessment derives from Article 6(3) and 6(4) of the Habitats Directive. Article 6(3) is concerned with the strict protection of sites, while Article 6(4) is the procedure for allowing derogation from this strict protection in certain restricted circumstances. Both articles require a number of steps and tests to be applied in sequential order. Each step in the process precedes and provides a basis for other steps. The results of each step must be clearly documented for decision making. To establish whether, in relation to the project activities, a significant impact will occur to Nature 2000 sites, an Appropriate Assessment (AA) Screening is required (Stage 1). The purpose of AA Screening is to determine, on the basis of a preliminary assessment and objective criteria, whether the project, alone and in combination with other plans and projects, could have any significant effect on a Natura

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2000 site in view of the site’s conservation objectives. A precautionary principle should be applied; therefore, where significant effects are likely, uncertain or unknown at screening stage, AA will be required. If significant impacts are considered likely then an AA would need to be undertaken by the competent authority to consider the impacts on the integrity of the Natura 2000 sites either alone or in combination with other projects in view of their conservation objectives. To support an AA, data and information on the site must be obtained and presented in a Natura Impact Statement (NIS). This is referred to as Stage 2. A.1.2 Scope of the AA Screening

The foreshore licence application which this AA Screening supports covers all proposed survey works planned between April and October within the five years following licence award. A separate foreshore licence application, including a separate AA screening report and if necessary a NIS, will be prepared for the installation of the wind turbines and marine cables should the project go ahead. In recognition that the survey extends into Irish offshore waters, the AA Screening has covered the application area and proposed survey area in offshore waters. It is noted that although the Irish Natura 2000 sites in the region of the application area are all coastal there are a number of UK Natura 2000 sites designated for mobile species (e.g. marine mammals) and these have been included in the assessment as appropriate in recognition that the species may travel in to the application area. A.2 APPROACH TO AA SCREENING A.2.1 Overview

This AA screening has been undertaken according to the process set out in the NPWS and DEHLG (2010) Guidance; following the process illustrated in Figure A-1. It has taken into account all case law relevant to the Habitats Directive summarised in the recently issued European Commission Guidance (November 2018). Figure A-1 AA Screening Process

Describe the project and site characteristics

Identify relevant Natura 2000 sites and compile information on their qualifying interests and conservation objectives

Assess likely effects – direct, indirect & cumulative.

Screening statement with conclusions

The structure for the remainder of the AA screening therefore reflects the key steps in this process. A.3 DESCRIBE THE PROJECT Full details of the scope of work are covered in the main document in Section 2. The site characteristics i.e. the baseline environment within the application area, are described in Section 3.

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A.4 IDENTIFICATION OF RELEVENT NATURA 2000 SITES This section has been split into two main parts: ▪ A.4.1 Screening of sites – this section provides information on how the relevant Natura 2000 sites were identified; and ▪ A.4.2 Information on the relevant Natura 2000 sites – this section provides further details on the selected sites, including information on their conservation objectives to inform the assessment of likely affects in Section A.5. A.4.1 Identifying Natura 2000 sites

The potential for a Natura 2000 site to be significantly impacted depends on whether receptors which are designating features of a Natura 2000 site: a. Can come into contact with the surveys; and b. Are sensitive to the survey activities to the extent that the activity is likely to have an adverse impact on the conservation objectives for the features. Identifying relevant Natura 2000 sites has therefore been achieved by applying the following steps: 1. Identify which receptors could be sensitive to the survey activities; 2. Identify potential impacts the surveys could have on these receptors and what the zone of influence for these receptors is, i.e. how far from the survey could a receptor be potentially impacted; 3. Screen SACs and SPAs within these zones of influence to identify designating features and assess whether interest features of the site could be significantly affected by the proposed survey activities; and 4. Assess whether any SACs and SPAs further afield from the survey area have mobile qualifying species which may travel into the zone of influence and have the potential to be significantly affected. A.1.1.2 Identification of sensitive receptors The receptors which could potentially be affected by the marine surveys and could be the designating interest features of Natura 2000 sites in the region are: ▪ Benthic habitats; ▪ Fish; ▪ Birds; and ▪ Marine mammals. A.1.1.3 Identification of potential impacts and defined zones of influence For each of the identified receptors, a description has been provided below to explain how these receptors could be affected and what the zone of influence is likely to be. The geographical extent of the likely zone of influence for non-mobile receptors such as benthic communities will represent the required search area for relevant Natura 2000 sites. For highly mobile species such as fish, birds and marine mammals the Natura 2000 sites which are most likely to be

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significantly affected will be those within or near the zone of influence. A justification for the established zone of influence for each receptor is explained below: Benthic habitats have the potential to be affected in three ways: ▪ During the geotechnical and environmental surveys from the very small removal of sediment samples; ▪ Through localised temporary smothering by the deposition of risings from the geotechnical boreholes; and ▪ Through smothering by positioning of equipment on the seabed e.g. JUB legs, concrete anchor, Seadrill. Given that sampling points are subject to change, the zone of influence for benthic communities has been assumed to be the entire application and prospect area. Relevant sites would include SACs designated for Annex I habitats which support benthic communities. Therefore, all SACs which the application area passes directly through have been screened for Annex I habitats which could be affected. Fish have the potential to be impacted by the geophysical survey from underwater noise within the immediate vicinity of the survey vessel. As discussed in Section 4.4.1 effects can either be direct e.g. causing behavioural changes or temporary hearing loss, or indirect e.g. noise acting as a barrier impeding migration pathways. Of the three migratory Annex II species known to be present in the vicinity of the application area, only twaite shad and Atlantic salmon are known to be sensitive to underwater noise and as such, sea lamprey and river lamprey have been screened out of the assessment. The zone of influence for direct impacts from underwater noise to Atlantic salmon and twaite shad would be within 4km of the application area (see Section 4.5.1). However, there is the potential that the noise could also impeded migration from rivers near the application area. Natura 2000 sites within 40km of the application area have therefore been screened for the presence of Atlantic salmon and twaite shad as a designating interest feature. Marine birds – the physical presence of the survey vessels could cause a small degree of disturbance to birds in the vicinity of the works. Whilst birds present on the surface waters near the survey vessel could be temporarily displaced from their chosen feeding/resting location, they are likely to readily move to another nearby location. Given the short duration of the operations with the vessel moving steadily forward along the survey route any disturbance at a given location is likely to be minimal. Combined with the existing shipping activity in the region, the introduction of the survey vessels is unlikely to be felt against typical fluctuations in background levels. Therefore, most birds are unlikely to be significantly disturbed. Advice on how to present assessment information on the extent and potential consequences of seabird displacement from offshore wind farm developments published by the UK Joint Statutory Nature Conservation Bodies (JNCC 2017) states that for most bird species a standard displacement buffer of 2km is recommended. For divers and sea ducks this should be extended to 4km. The most vulnerable birds to disturbance would be nesting birds in the breeding season in the immediate vicinity of the survey. Disturbance to nesting birds caused by the presence of the survey vessel could have an impact on the success rate of the breeding population. The zone of influence of disturbance on nesting birds is considered to be up to 2km from the application area. Therefore, all SPAs within 2km of the application area have been identified and the presence of nesting birds within each SPA has been checked. SPAs for which nesting birds are a Special Conservation Interest feature will be assessed. Marine mammals have the potential to be impacted by the generation of underwater noise. Annex II marine mammal species present in the application area include grey seal, harbour sea, bottlenose dolphin and harbour porpoise.

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The zone of influence from underwater noise on marine mammals, according to the marine mammal risk assessment (Section 4.5.1.1), has conservatively been estimated as within 2.6km of the sound source. This represents the distance at which the threshold for disturbance of marine mammals is reached. Relevant sites would include SACs designated for marine mammals within 3km of the application area. However, in recognition of the highly mobile nature of marine mammals, the following has been assumed and used to define the area of search for relevant Natura 2000 sites: ▪ Any harbour porpoise or bottlenose dolphin from Natura 2000 sites located in the relevant Management Unit could be present in the application area. The MU for harbour porpoise is the Celtic and Irish Sea; for bottlenose dolphin it is the Irish Sea and offshore Channel and SW England; ▪ It is estimated that grey seal forage up to 100km from their haul out sites (DECC 2016); and ▪ Harbour seal are not known to make trips greater than 50km from haul out sites (DECC 2016). In summary, Table A-1 defines the zone of influences used to define search areas for sites. Table A-1: Search areas – zone of influence

Interest feature Zone of influence Species Fish 40km Atlantic Salmon; twaite shad Birds 2km Most bird species 4km Divers, seaduck Cetacean Management unit Cetacean sp. [2.6km disturbance] Pinniped 100km Grey seal 50km Harbour seal

A.1.1.4 Screening of Natura 2000 sites A geographic information system (GIS) was used to map the boundaries of SACs and SPAs in relation to the application area. All SACs and SPAs which are within the defined zones of influence for identified receptors have been listed along with their qualifying features. A total of 18 sites were screened in this assessment and are shown in Table A-3. For each site the potential impacts to the designating features where identified and it was determined whether there is the potential for an interaction between the proposed survey and the receptors i.e. whether there is an impact-receptor pathway. This is determined by comparing information such as the extent of the zone of influence with information regarding the conservation feature e.g. species foraging distances, spatial extent of habitats etc. The interactions were defined as follows: ▪ Possible: A pathway between the proposed survey and the conservation feature can be identified that is likely to result in an effect; or ▪ Unlikely: Either a pathway between the proposed survey and the conservation features cannot be identified or a pathway exists but there is no physical overlap of the impact and the conservation feature. A likely effect is defined as one that cannot be ruled out on the basis of objective information. The test is a ‘likelihood’ of effects rather than a ‘certainty’ of effects. Where the proposed survey is likely to undermine the site’s conservation objectives, it must be considered likely to have a significant effect on the site. The assessment of that risk must be made in the light, amongst other things, of the characteristics and specific environmental conditions of the site concerned. If an interaction between

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the project activities and the conservation features is possible, the potential for a likely significant effect on the conservation objectives will be considered.

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Table A2 Screening assessment

Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey SPA IE004118 Keeragh The Special Conservation Interests are: 0km Visual disturbance Possible – It is possible that survey activities could disturb Islands ▪ Cormorant (Phalacrocorax carbo) breeding and nesting cormorant. (breeding) NPWS (2014b) SPA IE004020 Ballyteige The Special Conservation Interests are 0.7km Visual disturbance Unlikely - birds identified as being sensitive to the proposed Burrow Overwinter: survey are nesting birds and individuals within 2km of the ▪ Light-bellied Brent Goose (Branta application area. The SPA is important for overwintering birds and bernicla hrota) not breeding birds. As the survey will be conducted during ▪ Shelduck (Tadorna tadorna) summer months (April to October) outside of the over wintering period there will not be a temporal overlap between the Pluvialis apricaria ▪ Golden Plover ( ) designating features and the proposed works. Birds will not be ▪ Grey Plover (Pluvialis squatarola) disturbed by the proposed works. In addition, there is no spatial ▪ Lapwing (Vanellus vanellus) overlap between the important habitat and the intrusive survey ▪ Black-tailed Godwit (Limosa limosa) works. ▪ Bar-tailed Godwit (Limosa lapponica) The Wetland habitats are identified as of conservation importance for non-breeding (migratory) waterbirds. NPWS (2014c) SPA IE004193 Mid- The Special Conservation Interests are 0km Visual disturbance Possible – It is possible that survey activities could disturb Waterford Coast breeding: breeding and nesting birds. ▪ Cormorant (Phalacrocorax carbo) (nationally important) ▪ Peregrine (Falco peregrinus) (nationally important) ▪ Herring Gull (Larus argentatus) (nationally important) ▪ Chough (Pyrrhocorax pyrrhocorax) (internationally important) ▪ NPWS (2014d)

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey SPA IE004033 Bannow The Special Conservation Interests are 1km Visual disturbance Unlikely - birds identified as being sensitive to the proposed Bay Overwinter: survey are nesting birds and individuals within 2km of the ▪ Light-bellied Brent Goose (Branta application area. The SPA is important for overwintering birds and bernicla hrota) not breeding birds. As the survey will be conducted during summer months (April to October) outside of the over wintering ▪ Shelduck (Tadorna tadorna) period there will not be a temporal overlap between the ▪ Pintail (Anas acuta) designating features and the proposed works. Birds will not be ▪ Oystercatcher (Haematopus ostralegus) disturbed by the proposed works. In addition, there is no spatial ▪ Golden Plover (Pluvialis apricaria) overlap between the important habitat and the intrusive survey ▪ Grey Plover (Pluvialis squatarola) works. ▪ Lapwing (Vanellus vanellus) ▪ Knot (Calidris canutus) ▪ Dunlin (Calidris alpina) ▪ Black-tailed Godwit (Limosa limosa) ▪ Bar-tailed Godwit (Limosa lapponica) ▪ Curlew (Numenius arquata) ▪ Redshank (Tringa totanus) ▪ Wetland and Waterbirds NPWS (2018) SPA IE004002 Saltee The Special Conservation Interests are: 5.5km Visual disturbance Screened out – The site is outside of the zone of influence of the Islands Breeding survey for both nesting birds (2km) and divers and sea ducks ▪ Fulmar (Fulmarus glacialis) (4km). The species that are Special Conservation Interests of the ▪ Gannet (Morus bassanus) site forage widely and therefore the temporary disturbance caused by the survey is unlikely to affect their ability to access habitat or ▪ Cormorant (Phalacrocorax carbo) food sources. ▪ Shag (Phalacrocorax aristotelis) ▪ Lesser Black-backed Gull (Larus fuscus) ▪ Herring Gull (Larus argentatus) ▪ Kittiwake (Rissa tridactyla) ▪ Guillemot (Uria aalge) ▪ Razorbill (Alca torda) ▪ Puffin (Fratercula arctica) NPWS (2011)

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey SAC IE000764 Hook Head The Special Conservation Interests are: 0km Penetration and/or Unlikely - The western cable export corridor clips the corner of the ▪ Large shallow inlets and bays disturbance of the SAC. No geotechnical sampling will be undertaken within this SAC ▪ Reefs substrate and therefore there is no potential to disturb / damage sensitive reef habitats. ▪ Vegetated Cliffs Siltation rate changes Consideration has been given to whether suspended sediments NPWS (2014a) e.g. from geotechnical boreholes, could be deposited over the reef. However, the application area is located 3.5km from known reef features as mapped in NPWS (2014a). Therefore, given the distance, the small volume of risings, and the tidal conditions in the area it was concluded that levels of suspended sediment generated by the survey would not be noticeable against the normal level of background fluctuations. SAC IE000696 Ballyteigue The Special Conservation Interests are: 0.17km Penetration and/or Unlikely - The footprint of the intrusive survey works will be Burrow ▪ Estuaries disturbance of the limited to the application area and will not overlap with the SAC. ▪ Mudflats and sandflats not covered by substrate Consideration has been given to whether suspended sediments seawater at low tide Siltation rate e.g. from geotechnical boreholes, could be deposited over the ▪ Coastal lagoons changes habitats. However, given the small volume of risings, and the tidal ▪ Annual vegetation of drift lines conditions in the area it was concluded that levels of suspended ▪ Perennial vegetation of stony banks sediment generated by the survey would not be noticeable against ▪ Salicornia and other annuals colonising the normal level of background fluctuations. mud and sand ▪ Spartina swards (Spartinion maritimae) ▪ Atlantic salt meadows (Glauco- Puccinellietalia maritimae) ▪ Mediterranean salt meadows (Juncetalia maritimi) ▪ Mediterranean and thermo-Atlantic halophilous scrubs (Sarcocornetea fruticosi) ▪ Embryonic shifting dunes ▪ Shifting dunes along the shoreline with Ammophila arenaria (white dunes) ▪ Fixed coastal dunes with herbaceous vegetation (grey dunes) ▪ Atlantic decalcified fixed dunes (Calluno- Ulicetea)

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey NPWS (2014e) SAC IE000697 Bannow The Special Conservation Interests are: 1km Penetration and/or Unlikely - The footprint of the intrusive survey works will be Bay ▪ Estuaries disturbance of the limited to the application area and will not overlap with the SAC. ▪ Mudflats and sandflats not covered by substrate Consideration has been given to whether suspended sediments seawater at low tide Siltation rate e.g. from geotechnical boreholes, could be deposited over the ▪ Annual vegetation of drift lines changes habitats. However, given the small volume of risings, and the tidal ▪ Perennial vegetation of stony banks conditions in the area it was concluded that levels of suspended ▪ Salicornia and other annuals colonising sediment generated by the survey would not be noticeable against mud and sand the normal level of background fluctuations. ▪ Atlantic salt meadows (Glauco- Puccinellietalia maritimae) ▪ Mediterranean salt meadows (Juncetalia maritimi) ▪ Mediterranean and thermo-Atlantic halophilous scrubs (Sarcocornetea fruticosi) ▪ Embryonic shifting dunes ▪ Shifting dunes along the shoreline with Ammophila arenaria (white dunes) ▪ Fixed coastal dunes with herbaceous vegetation (grey dunes) NPWS (2012) SAC IE000707 Saltee The Special Conservation Interests are: 1km Penetration and/or Unlikely – The footprint of the intrusive survey works will be Islands ▪ Mudflats and sandflats not covered by disturbance of the limited to the application area and will not overlap with the SAC. seawater at low tide substrate Consideration has been given to whether suspended sediments ▪ Large shallow inlets and bays Siltation rate e.g. from geotechnical boreholes, could be deposited over the ▪ Reefs changes habitats. However, given the small volume of risings, and the tidal ▪ Vegetated sea cliffs of the Atlantic and conditions in the area it was concluded that levels of suspended Baltic coasts sediment generated by the survey would not be noticeable against ▪ Submerged or partially submerged sea the normal level of background fluctuations. caves ▪ Grey Seal (Halichoerus grypus) Underwater sound Possible - Underwater noise from the geophysical survey could NPWS (2013a) changes disturb grey seal from the site.

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey SAC IR003000 Rockabill to The Special Conservation Interests are: 154km Penetration and/or Unlikely - The footprint of the intrusive survey works will be Dalkey Island ▪ Reefs disturbance of the limited to application area. substrate

▪ Harbour Porpoise (Phocoena phocoena). Underwater sound Possible - Underwater noise from the geophysical survey could NPWS (2013c) changes impact harbour porpoise from the site if they are in the application area. SAC UK0013116 The Special Conservation Interests are: 70km Penetration and/or Unlikely - The footprint of the intrusive survey works will be Pembrokeshire ▪ Estuaries disturbance of the limited to the application area and will not overlap with the SAC. Marine/ Sir Benfro ▪ Large shallow inlets and bays substrate Given the considerable distance to the site siltation rate changes Forol ▪ Reefs Siltation rate will not be experienced. ▪ Shore dock (Rumex rupestris) changes ▪ Grey seal (Halichoerus grypus), Underwater sound Possible - Underwater noise from the geophysical survey could JNCC (2019a) changes disturb grey seal from the site if they are in the application area. SAC IE002137 Lower The Special Conservation Interests are: 30km None Special Conservation interest screened out – as no pressure River Suir ▪ Hydrophilous Tall Herb Communities, receptor pathway ▪ Old Oak Woodlands, ▪ Alluvial Forests, ▪ Yew Woodlands ▪ Atlantic Salt Meadows, Penetration and/or Unlikely - The footprint of the intrusive survey works will be ▪ Mediterranean Salt Meadows, disturbance of the limited to the application area and will not overlap with the SAC. ▪ Floating River Vegetation, substrate Given the distance to the site siltation rate changes will not be ▪ Freshwater Pearl Mussel (Margaritifera Siltation rate experienced. margaritifera), changes ▪ White-clawed Crayfish (Austropotamobius pallipes), ▪ Otter (Lutra lutra) Underwater sound Unlikely – Will not be present in application area or zone of ▪ Brook Lamprey (Lampetra planeri), changes influence for underwater sound changes. ▪ River Lamprey (Lampetra fluviatilis), Underwater sound Unlikely - Sea lamprey and river lamprey are not considered ▪ Sea Lamprey (Petromyzon marinus), changes sensitive to underwater sound changes. ▪ Twaite Shad (Alosa fallax), Underwater sound Possible - Underwater noise from geophysical survey could disturb ▪ Atlantic Salmon (Salmo salar), changes Atlantic salmon and twaite shad during migration. NPWS (2013b)

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey SAC IE002162 River The Special Conservation Interests are: 16km Penetration and/or Unlikely - The footprint of the intrusive survey works will be Barrow and River ▪ Estuaries disturbance of the limited to the application area and will not overlap with the SAC. Nore ▪ Mudflats and sandflats not covered by substrate Given the distance to the site siltation rate changes will not be seawater at low tide Siltation rate experienced. ▪ Salicornia and other annuals colonizing changes mud and sand ▪ Atlantic salt meadows (Glauco‐ Puccinellietalia maritimae) ▪ Mediterranean salt meadows (Juncetalia maritimi) ▪ Nore freshwater pearl mussel Margaritifera durrovensis ▪ Desmoulin's whorl snail Vertigo moulinsiana, ▪ Freshwater pearl mussel Margaritifera margaritifera, ▪ White‐clawed crayfish Austropotamobius pallipes, ▪ Killarney fern Trichomanes speciosum None Special Conservation interest screened out – as no pressure ▪ Water courses of plain to montane levels receptor pathway with the Ranunculion fluitantis and Callitricho‐Batrachion vegetation ▪ European dry heaths, Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels, Petrifying springs with tufa formation (Cratoneurion) ▪ Old sessile oak woods with Ilex and Blechnum in the British Isles ▪ Alluvial forests with Alnus glutinosa and Fraxinus excelsior Alno‐Padion, Alnion incanae, Salicion albae. ▪ Otter Lutra lutra Underwater sound Unlikely – Will not be present in application area or zone of ▪ Brook lamprey Lampetra planeri changes influence for underwater sound changes.

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey ▪ River lamprey Lampetra fluviatilis Underwater sound Unlikely - Sea lamprey and river lamprey are not considered ▪ Sea lamprey Petromyzon marinus changes sensitive to underwater sound changes. ▪ Twaite shad Alosa fallax Underwater sound Possible - Underwater noise from geophysical survey could disturb ▪ Atlantic salmon (Salmo salar) (only in changes Atlantic salmon and twaite shad during migration. fresh water) NPWS (2016a) SAC IE002170 Blackwater The Special Conservation Interests are: 32km Penetration and/or Unlikely - The footprint of the intrusive survey works will be River ▪ Estuaries, disturbance of the limited to the application area and will not overlap with the SAC. (Cork/Waterford) ▪ Mudflats and sandflats not covered by substrate Given the distance to the site siltation rate changes will not be seawater at low tide, Siltation rate experienced. ▪ Perennial vegetation of stony bank, changes ▪ Salicornia and other annuals colonizing mud and sand, ▪ Atlantic salt meadows (Glauco‐ Puccinellietalia maritimae), ▪ Mediterranean salt meadows (Juncetalia maritimi), ▪ Freshwater pearl mussel Margaritifera margaritifera, ▪ White‐clawed crayfish Austropotamobius pallipes, ▪ Water courses of plain to montane levels None Special Conservation interest screened out – as no pressure with the Ranunculion fluitantis and receptor pathway Callitricho‐Batrachion vegetation, ▪ Old sessile oak woods with Ilex and Blechnum in the British Isles, ▪ Alluvial forests with Alnus glutinosa and Fraxinus excelsior Alno ‐Padion, ▪ Brook lamprey Lampetra planeri Underwater sound Unlikely – Will not be present in application area or zone of ▪ Otter Lutra lutra changes influence for underwater sound changes.

▪ Sea lamprey Petromyzon marinus Underwater sound Unlikely - Sea lamprey and river lamprey are not considered ▪ River lamprey Lampetra fluviatilis changes sensitive to underwater sound changes.

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Designation Site Code & Name Designated Features Distance to Potential Pressures Likelihood of interaction between survey works and designating application on site from feature(s) area Proposed Survey ▪ Atlantic salmon (Salmo salar) Underwater sound Possible - Underwater noise from geophysical survey could disturb ▪ Twaite shad Alosa fallax changes Atlantic salmon and twaite shad during migration. NPWS (2016b) SAC UK0012712Cardigan ▪ Bottlenose dolphin (Tursiops truncatus) 117km Underwater sound Possible - Underwater noise from the geophysical survey could Bay/ Bae Ceredigion ▪ Site is within the Offshore Channel and changes impact bottlenose dolphin from the site if they are in the SW England (OCSW) Management Unit application area. JNCC (2019f) SAC UK0030396 Bristol ▪ Harbour porpoise (Phocoena phocoena) 119km Underwater sound Possible - Underwater noise from the geophysical survey could Channel Approaches ▪ Site is within the Celtic and Irish Seas changes impact harbour porpoise from the site if they are in the application (CIS) Management Unit / Dynesfeydd Môr area. Hafren JNCC (2019b) SAC UK0030397 West ▪ Harbour porpoise (Phocoena phocoena) 83km Underwater sound Possible - Underwater noise from the geophysical survey could Wales Marine / West ▪ Site is within the Celtic and Irish Seas changes impact harbour porpoise from the site if they are in the application (CIS) Management Unit Gorllewin Cymru area. Forol JNCC (2019c) SAC UK0030398 North ▪ Harbour porpoise (Phocoena phocoena) 205km Underwater sound Possible - Underwater noise from the geophysical survey could Anglesey Marine / ▪ Site is within the Celtic and Irish Seas changes impact harbour porpoise from the site if they are in the application Gogledd Môn Forol (CIS) Management Unit area. JNCC (2019d) SAC UK0030399 North ▪ Harbour porpoise (Phocoena phocoena) 278km Underwater sound Possible - Underwater noise from the geophysical survey could Channel ▪ Site is within the Celtic and Irish Seas changes impact harbour porpoise from the site if they are in the application (CIS) Management Unit area. JNCC (2019e)

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A.5 ASSESSMENT OF LIKELY SIGNIFICANT EFFECT The initial assessment identified that the Special Conservation Interests of 18 Natura 2000 sites are within the zone of influence of the proposed survey. Table A-3 identified that it is possible that a receptor-impact pathway exists for 13 of the sites; for the remaining 5 it is unlikely that there is a spatial or temporal overlap between the proposed survey and Special Conservation Interests of the site. Table A-3 identifies that there are two pressures from the proposed survey that could effect the Special Conservation Interests of Natura 2000 sites. These are: ▪ Visual disturbance; and ▪ Underwater sound changes. This section describes the possible pressures and potential effects and, assesses the likely significant effect of the proposed survey on the conservation objectives of the site both singly and in-combination with other plans or projects. A.5.1 Visual Disturbance

Table A-3 identified a ‘possible’ pressure-receptor pathway between the proposed survey and the Special Conservation Interests of two sites for the pressure Visual Disturbance. The sites were the Keeragh Islands SPA and the Mid-Waterford Coast SPA. As discussed in Section A.4.1 the most vulnerable birds to disturbance would be nesting birds and breeding birds within breeding season in the immediate vicinity of the survey (2km zone of influence). There is the potential that breeding and nesting birds may be disturbed by the presence of survey vessels and equipment. Both visual and noise disturbance may result from the presence of the vessels and equipment whilst noise disturbance is likely to be the most significant cause of disturbance during borehole operations. Prolonged disturbance could result in impaired breeding, disruption to incubation, increased nest failures due to predation and nest abandonment (Valente et al. 2011). These factors could affect the demographic characteristics of the population. The extent to which a seabird responds to disturbance is dependent upon factors including period of breeding cycle during which disturbance occurs; duration, type and intensity of the disturbance; presence of opportunistic predators; and the degree of habituation with the disturbance (Showler et al. 2010). Some seabirds are more resilient to disturbance than others. The survey operations are planned between April and October; therefore, it is possible that breeding and nesting birds may be present and disturbed by the presence of the JUB and survey vessels close to the coast. A.1.1.5 Keeragh Islands SPA Conservation objectives To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA. The favourable conservation status of a species is achieved when:

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▪ Population dynamics data on the species concerned indicate that it is maintaining itself on a long- term basis as a viable component of its natural habitats, and ▪ The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and ▪ There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis. Assessment against conservation objectives The Keeragh Islands SPA has been designated for nationally important population of breeding cormorant (200 pairs). Cormorant usually start breeding on Keeragh Island in March and their eggs usually hatch after one month, their young fledge in about two months and after that are dependent on their parents for food for a further three months. Therefore, the breeding season extends from February to September (Wexford Naturalists 2012). The zone of influence of disturbance on nesting birds is considered to be up to 2km from the survey vessels (NE and JNCC 2012). The Keeragh Islands SPA lies within the application area (eastern export cable corridor). It is 0.8km from the coastline (at the closest approach), and 2km from the seaward extent of the SPA to the coast. All survey activity from the mean high water mark out to 4km from the coastline would place the SPA within the zone of influence for disturbance of nesting birds. Therefore, it is possible that temporary visual and noise disturbance from survey works could disturb breeding or nesting cormorant on Keeragh Island. The extent to which a marine bird responds to disturbance is dependent upon factors including period of breeding cycle during which disturbance occurs; duration, type and intensity of disturbance; presence of opportunistic predators; and the degree of habituation (Showler et al. 2010). The Joint SNCB Interim Displacement Advice Note (2017) categorises species by their sensitivity to disturbance and their habitat specialisation. Cormorant is classed as having a moderate habitat specialisation and high susceptibility to disturbance (score of 3 out of 5 for specialism and 4 out of 5 for disturbance). In relation to the conservation objectives, the proposed survey will not reduce, other than temporarily the natural range of cormorant, nor will it have a significant effect on the habitat that the cormorant require to maintain the population. However, given that the survey is scheduled for summer months when cormorant are breeding and the line plan within the application area is not yet know, it cannot be ruled out that the survey works would not disturb nesting birds. There is therefore the potential that there could be a likely significant effect on the population dynamics conservation objective. Screening Conclusion: Potential for Likely Significant Effect. A.1.1.6 Mid-Waterford Coast SPA Conservation objectives To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA. The favourable conservation status of a species is achieved when: ▪ Population dynamics data on the species concerned indicate that it is maintaining itself on a long- term basis as a viable component of its natural habitats, and ▪ The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and ▪ There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis. Objective:

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Assessment against conservation objectives The Mid-Waterford Coast SPA has been designated for its internationally important breeding chough (20 pairs recorded in 2002/03 survey). This site is also designated for nationally important peregrine population (10 pairs in 2002), cormorant (79 pairs) and herring gull (147 pairs). The important breeding season for these species is summarised in Table A-3 below: Table A-3 Breeding season

Species Breeding season Comments Chough April - July Build their nests in caves, crevasses and on rock faces in April. Female chough incubate alone for 17-21 days. Young fly at 6-7 weeks of age (RSPB 2019a). Cormorant February - September Breed on the ground and coastal cliff locations. They lay their nests in tress, islets and cliffs. Start breeding in March and eggs hatch after a month. Young fledge two months after hatching but are dependent on their parents for food for a further three months. Peregrine April - September Nest on grassy areas on cliff edges, quarries or other inaccessible undisturbed locations. Females lay their eggs in late March or April and incubation takes around 29-32 days. Herring gull May - September Likely to build their nests on sea cliffs and sand dunes. Eggs are incubated for 30 days in May and June. Parents look after chicks until they fledge after five or six weeks and for a period afterwards.

Taken into account the breeding season of chough, peregrine, herring gull and cormorant, the breeding season for this SPA will last from February through to September. The SPA lies along the coastline of the western export cable corridor. Two sources of disturbance have been identified: ▪ Disturbance from geophysical survey vessel movements; and ▪ Disturbance from geotechnical borehole drilling, if the export cable corridor is selected for geotechnical investigation. The zone of impact of disturbance on nesting birds is considered to be up to 2km from the survey (NE and JNCC 2012). As the SPA lies at the coastline, this means any survey works within 2km of the coastline could potentially disturb nesting birds. The extent to which a marine bird responds to disturbance is dependent upon factors including period of breeding cycle during which disturbance occurs; duration, type and intensity of disturbance; presence of opportunistic predators; and the degree of habituation (Showler et al. 2010). The Joint SNCB Interim Displacement Advice Note (2017) categorises species by their sensitivity to disturbance and their habitat specialisation. As land-based birds, chough and peregrine have not been categorised in the advice note. However, cormorant is classed as having a moderate habitat specialisation and

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high susceptibility to disturbance, whilst herring gull has a low disturbance susceptibility (score of 2 out of 5) and a low habitat specialism (score of 2 out of 5). This indicates that herring gull breeding would not be affected by the proposed survey works but there is the potential that breeding cormorant could be disturbed. In relation to the conservation objectives, the proposed survey will not reduce, other than temporarily the natural range of the species of Special Conservation Interest, nor will it have a significant effect on the habitat that the species require to maintain the population. However, given that the survey is scheduled for summer months when the four bird species are breeding and the geotechnical borehole locations have not been selected, it cannot be ruled out that the survey works would not disturb nesting birds. There is therefore the potential that there could be a likely significant effect on the population dynamics conservation objective. Screening Conclusion: Potential for Likely Significant Effects A.5.2 Underwater sound changes

Table A-1 identified a ‘possible’ pressure-receptor pathway for the pressure underwater sound changes between the proposed survey and three Natura 2000 sites for which the Special Conservation Interests are Annex II migratory fish species. These sites were the River Barrow and River Nore SAC, the Lower River Suir SAC and the Blackwater River (Cork/Waterford) SAC. It is recognised that fish are mobile species and therefore Annex II listed migratory species have the potential to cross the application area during the survey operations. Atlantic salmon and twaite shad are sensitive to noise and therefore potentially vulnerable to the proposed survey operations. River lamprey and sea lamprey are not known to be sensitive to noise and are not considered further in the screening exercise. A.1.1.7 River Barrow and River Nore SAC, Lower River Suir SAC and Blackwater River (Cork/Waterford) SAC. These three sites are designated as SACs to protect a number of different habitats and species. However, Table A-1 identified that all three sites contain the Special Conservation Interests: ▪ Atlantic Salmon; and ▪ Twaite shad. The conservation objectives for the relevant Special Conservation Interests in each site are the same. Atlantic Salmon

Conservation objectives To restore the favourable conservation condition of Atlantic salmon in the site, which is defined by the following list of attributes and targets: ▪ Distribution: extent of anadromy - 100% of river channels down to second order accessible from estuary, ▪ Adult spawning fish Number - Conservation Limit (CL) for each system consistently exceeded, ▪ Salmon fry abundance - Maintain or exceed 0+ fry mean catchment‐wide abundance threshold value Currently set at 17 salmon fry/5 min sampling, ▪ Out‐migrating smolt abundance - No significant decline, ▪ Number and distribution of redds - No decline in number and distribution of spawning redds due to anthropogenic causes, and

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▪ Water quality - At least Q4 at all sites sampled by EPA.

Assessment against conservation objectives: The upper stretches of the River Barrow and River Nore SAC, Lower River Suir SAC and Blackwater River (Cork/Waterford) SAC are important spawning areas. Salmon are anadromous, migrating from the sea to freshwater to spawn. In Ireland most rivers get a girlse run (i.e. salmon which have only been to sea for one year come to spawn) from spring until autumn (Fishing in Ireland 2019). Smolts (1-3 years old) leave rivers for the sea in cohorts in early spring/summer, usually between April and June (Holm et al. 2000; Hendry & Cragg-Hine 2003). This is triggered by combinations of environmental stimuli such as water temperatures greater than 10°C and rates of high flow in river. When they have reached the estuary, they will generally enter the sea during ebb-tide and follow the direction of tidal streams (Hendry & Cragg-Hine 2003; Malcolm et al. 2010), which for the application area is a general south westerly direction parallel to the coast. Once they have reached the sea they will then migrate to the rich feeding grounds of the and the greater expanse of the North Atlantic and return to the rivers the following spring/summer (Marine Institute 2019b). Therefore, Atlantic salmon are likely to be present in the application area in their highest numbers from spring through to autumn (i.e. during migration from sea to river and river to sea). The proposed geophysical survey is primarily offshore and not within the estuaries of any of the important Salmon rivers. Given that spawning occurs upstream in the relevant rivers, outside the zone of influence of the survey, the survey will not affect salmon spawning, fry abundance and the distribution of redds. In addition, the survey will not cause a deterioration in water quality.

Given the large open area of sea surrounding the application area, and the transient nature of the proposed survey, Atlantic salmon are likely to be able to readily alter their course slightly to avoid the survey if necessary. Therefore, the survey will not act as an artificial barrier or cause a reduction in migrating smolt abundance.

It is unlikely that the conservation objectives for Atlantic salmon in these sites will be significantly affected.

Screening Conclusion: No likely significant effects Twaite shad

Conservation objectives To restore the favourable conservation condition of twaite shad in the site, which is defined by the following list of attributes and targets: ▪ Distribution: extent of anadromy - greater than 75% of main stem length of rivers accessible from estuary, ▪ Population structure: age classes - more than one age class present, ▪ Extent and distribution of spawning habitat - No decline in extent and distribution of spawning habitats, ▪ Water quality: oxygen levels – no lower than 5mg/l, and ▪ Spawning habitat quality: Filamentous algae; macrophytes; sediment - Maintain stable gravel substrate with very little fine material, free of filamentous algal (macroalgae) growth and macrophyte (rooted higher plants) growth.

Assessment against conservation objectives The upper stretches of the River Barrow and River Nore SAC, Lower River Suir SAC and Blackwater River (Cork/Waterford) SAC are designated for the presence of twaite shad. Twaite shad occur in coastal waters and in estuaries along the southeast coast of Ireland. Like salmon, twaite shad are

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anadromous, migrating to freshwater to spawn in early summer (May to July). At maturity (3 years old for males and 5 years old for females), they stop feeding and congregate in the estuaries of suitable rivers in April and May. Upstream migration from the estuaries appears to be triggered by temperature, with peak migratory activity occurring at water temperatures of 10–14°C. Given that twaite shad reach maturity at age 3-5, twaite shad are likely to be found in coastal areas of the application area all year round, with the greatest density likely to be observed during the May-July migration.

The proposed geophysical survey is primarily offshore and not within the estuaries of any of the important Twaite shad rivers. Given that spawning occurs upstream in the relevant rivers, outside the zone of influence of the survey, the survey will not affect twaite shad spawning habitat or cause a deterioration in water quality.

Given the large open area of sea surrounding the application area, and the transient nature of the proposed survey, twaite shad are likely to be able to readily alter their course slightly to avoid the survey if necessary. Therefore, the survey will not act as an artificial barrier or cause a reduction in the abundance of migrating adult shad.

It is unlikely that the conservation objectives for Atlantic salmon in these sites will be significantly affected.

Screening Conclusion: No likely significant effects A.5.3 Underwater sound changes causing injury or disturbance to Annex II cetacean or pinniped species

Table A-2 identified a ‘possible’ pressure-receptor pathway for the pressure underwater sound changes between the proposed survey and seven Natura 2000 sites for which the Special Conservation Interests are Annex II cetacean or pinniped species. The geophysical survey includes the use of multi-beam echo-sounders, side scan sonars, sub bottom profilers. One of the most important environmental concerns related to the proposed activities is the potential effects of underwater sound on marine mammals. Both cetaceans and pinnipeds have evolved to use sound as an important aid in navigation, communication and hunting (Richardson et al. 1995). It is generally accepted that exposure to anthropogenic sound can induce a range of effects on marine mammals. These range from insignificant impacts to behavioural changes, non-injurious type effects including masking of biologically relevant sound signals, such as communication signals, and ultimately can lead to physical injury and death if the sound source is sufficiently intense. The AA screening has used the underwater noise modelling in Section 4.4.1.1 to inform assessment. The main conclusions relevant to the AA screening were as follows: ▪ Grey and harbour seal could be exposed to sound levels that exceed the threshold for temporary injury within 40m of the geophysical sound source. ▪ Harbour porpoise could be exposed to sound levels that exceed the thresholds for temporary injury within 180m of the geophysical sound source. ▪ Harbour porpoise, grey and harbour seal could be exposed to sound levels that are sufficient to cause disturbance within 2.6km of the geophysical sound source. The noise assessment presented was conservative and did not account for the directional quality of the noise or conditions within the application area, such as bathymetry, water depth or sediment type and thickness, which will all reduce the propagation of the sound, decreasing the zone of influence of the geophysical survey.

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As part of the survey scope (embedded mitigation EM1) the survey contractor will be required to follow the DAHG ‘Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters’ (DAHG 2014). A.1.1.8 Saltee Island SAC Conservation objectives To maintain the favourable conservation condition of Grey Seal in Saltee Islands SAC, which is defined by the following lists of attributes and targets: a. Access to suitable habitat – species range within the site should not be restricted by artificial barriers to site use. b. Breeding behaviour – The breeding sites should be maintained in a natural condition. c. Moulting behaviour - The moult haul-out sites should be maintained in a natural condition. d. Resting behaviour - The resting haul-out sites should be maintained in a natural condition. e. Population composition - The grey seal population occurring within this site should contain adult, juvenile and pup cohorts annually Assessment against conservation objectives The Saltee Island SAC lies 1km from the application area (eastern cable export corridor) and therefore it is possible that grey seal from the site will be present in the water, especially during the earlier months of the proposed survey window e.g. May to August. From August through to December animals are likely to be hauled up on beaches for pupping. At closest range the beaches are located 6.2km from the application area. Seals are likely to flee if vessels approach within 900m (Brasseur & Reijnders,1994); suggesting that they will avoid the area before they encounter sound levels that will harm them. The survey will be transient and sound levels generated will not act as an artificial barrier. Therefore, survey activities will not restrict access to suitable grey seal habitat at the site and the surrounding area. With respect to the conservation objectives, given the zone of influence (2.6km for disturbance) and the distance to Saltee Island itself (6.2km) it is unlikely that breeding, moulting and resting seals on the haul out sites of Saltee Islands SAC would be affected by the proposed survey. It is therefore unlikely that the survey will have a significant effect on population composition. Screening Conclusion: No likely significant effects. A.1.1.9 Pembrokeshire Marine/ Sir Benfro Forol SAC Conservation objectives Grey seal populations should not be reduced as a consequence of human activity. The species population within the site (grey seal) is such that the natural range of the population is not being reduced or likely to be reduced for the foreseeable future. ▪ Their range within the SAC and adjacent inter-connected areas is not constrained or hindered. ▪ There are appropriate and sufficient food resources within the SAC and beyond. ▪ The sites and amount of supporting habitat used by these species are accessible and their extent and quality is stable or increasing.”

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Assessment against conservation objectives The Pembrokeshire Marine/ Sir Benfro Forol SAC the site is located 70km from the seaward extent of the application area. The haul out sites for grey seal within the Pembrokeshire Marine/ Sir Benfro Forol SAC are along the coastline which is 95km distant. Animals are known to forage up to 100km from their haul out sites, therefore the application area is located at largest extent of grey seal foraging range. It is therefore unlikely that grey seal from the site will be present in sufficient numbers within the application area. In addition, the proposed survey will not affect their range, the food resources or habitat. Screening Conclusion: No likely significant effects A.1.1.10 Cardigan Bay/ Bae Ceredigion SAC Conservation objectives The conservation objectives for the bottlenose dolphin is: “To maintain at favourable conservation status its long-term population viability, natural range and the structure and function of its habitat within the site.” Assessment against conservation objectives It is possible that bottlenose dolphin from this site maybe observed in the area given that the application area is located in the same management unit as the Cardigan Bay/ Bae Ceredigion SAC (i.e. the Offshore Channel and SW England MU). However, given the zone of influence (2.4km for disturbance) and the distance to Cardigan Bay/ Bae Ceredigion SAC (117km), survey operations will not affect the long-term population viability nor the natural range of bottlenose dolphin from this site. Furthermore, survey operations will not affect the structure or the function of bottlenose dolphin habitat. Screening Conclusion: No likely significant effects. A.1.1.11 Bristol Channel Approaches/Dynesfeydd Môr Hafren, West Wales Marine/ Gorllewin Cymru Forol, North Anglesey Marine/ Gogledd Môn Forol and North Channel SACs Conservation objectives The conservation objectives for the four sites in UK waters are the same: To avoid deterioration of the habitats of the harbour porpoise or significant disturbance to the harbour porpoise, thus ensuring that the integrity of the site is maintained and the site makes an appropriate contribution to maintaining Favourable Conservation Status (FCS) for the UK harbour porpoise. To ensure for harbour porpoise that, subject to natural change, the following attributes are maintained or restored in the long term: 1. The species is a viable component of the site. 2. There is no significant disturbance of the species. 3. The supporting habitats and processes relevant to harbour porpoises and their prey are maintained. Assessment against conservation objectives It is possible that harbour porpoise from these sites may be observed in the area given that the application area is located in the same management unit as these sites (Celtic and Irish Sea MU). However, given that the zone of influence of disturbance is small (2.6km) and these sites are located

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between 83 and 278km from the seaward extent of the application area, survey operations will not result in significant disturbance to harbour porpoise from these sites. In addition, survey operations will not affect harbour porpoise habitat or prey items and harbour porpoise will still be a viable component of these sites. Screening Conclusion: No likely significant effects. A.1.1.12 Rockabill to Dalkey Island SAC Conservation objectives To maintain the favourable conservation condition of Harbour porpoise in Rockabill to Dalkey Island SAC, which is defined by the following list of attributes and targets: ▪ Access to suitable habitat – species range within the site should not be restricted by artificial barriers to site use. Disturbance - Human activities should occur at levels that do not adversely affect the harbour porpoise community at the site Assessment against conservation objectives It is possible that harbour porpoise from these sites may be observed in the area given that the application area is located in the same management unit as Rockabill to Dalkey Island SAC (Celtic and Irish Sea MU). However, given that the zone of influence of disturbance is small (2.6km) and this site is located 154km from the seaward extent of the application area, survey operations will not result adversely affect the harbour porpoise community at the site. In addition, the survey will be transient and sound levels generated will not act as an artificial barrier. Therefore, survey activities will not restrict access to suitable harbour porpoise habitat at the site and the surrounding area. Screening Conclusion: No likely significant effects.

A.6 SCREENING STATEMENT AND CONCLUSIONS To determine whether the proposed survey is likely to have a significant effect on any Natura 2000 sites, either individually or in-combination with other plans or projects, AA screening was carried out. The screening assessed 18 Natura 2000 sites that were either within the direct zone of influence of the proposed surveys or contain mobile Annex II species which could potentially travel into the application area. It was identified that the proposed survey would induce the following pressures on Special Conservation Interests: ▪ Underwater sound changes; and ▪ Visual disturbance. Consideration was given to other planned activities in the area that could interact with the proposed survey to cause cumulative impacts. Of the sites assessed, it is considered possible that there exists an impact-receptor pathway between the proposed survey and the designating features of twelve sites (Table A-4). Of these 13 sites, screening has identified two sites, the Keeragh Island SPA and Mid- Waterford Coast SPA, where it cannot be ruled out that the survey will not have a likely significant effect.

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Table A-4: Summary - Potential for likely significant effects

Site Applicable conservation Potential pressure on Conclusion feature site IE004118 Keeragh Islands Breeding cormorant Visual disturbance Potential for Likely significant SPA effect IE004193 Mid-Waterford Breeding cormorant, peregrine, Visual disturbance Potential for Likely significant Coast SPA herring gull and chough effect IE000707 Saltee Islands SAC Grey Seal Underwater sounds No likely significant effect changes IR003000 Rockabill to Dalkey Harbour porpoise Underwater sounds No likely significant effect Island SAC changes

UK0013116 Pembrokeshire Grey Seal Underwater sounds No likely significant effect Marine/ Sir Benfro Forol changes SAC IE002162 River Barrow and Atlantic salmon and twaite shad Underwater sounds No likely significant effect River Nore SAC changes IE002137 Lower River Suir Atlantic salmon and twaite shad Underwater sounds No likely significant effect SAC changes IE002170 Blackwater River Atlantic salmon and twaite shad Underwater sounds No likely significant effect (Cork/Waterford) SAC changes UK0012712Cardigan Bay/ Bottlenose dolphin Underwater sounds No likely significant effect Bae Ceredigion changes UK0030396 Bristol Channel Harbour porpoise Underwater sounds No likely significant effect Approaches / Dynesfeydd changes Môr Hafren SAC UK0030397 West Wales Harbour porpoise Underwater sounds No likely significant effect Marine / West Gorllewin changes Cymru Forol SAC UK0030398 North Anglesey Harbour porpoise Underwater sounds No likely significant effect Marine / Gogledd Môn changes Forol SAC UK0030399 North Channel Harbour porpoise Underwater sounds No likely significant effect SAC changes

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APPENDIX B

Stage 2 - Natura Impact Statement

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B.1 INTRODUCTION The Stage 1 screening provided in Appendix A concluded that there is the potential for likely significant adverse effects on the Keeragh Islands SPA and Mid-Waterford Coast SPA, and that an Appropriate Assessment (AA) is required. The AA is a focused and detailed impact assessment of the implications of the plan of project alone and in combination with other plans and projects, on the integrity of a Natura 2000 site in view of its conservation objectives. It is undertaken by the competent authority, which for Foreshore Licence applications is the Department of Housing, Planning and Local Government. To inform the AA, the proponent of the plan (i.e. SSE) must provide a Natura Impact Statement (NIS) which provides data and information on the project and an analysis of potential effects on the Natura 2000 site. NPWS guidance (2012) on the content of the Natura Impact Assessment states: “The more detailed ecological assessment of proposed activities requires that two key questions be addressed: ‘What are the likely impacts of the proposed activity?’ and ‘How quickly could the qualifying interest recover from the impact, if at all?’”. The guidance identifies specific questions which should be considered when providing information to support the AA. The questions relevant to Annex II species have been used to guide the assessment presented below. This Natura Impact Statement draws on information provided in the Foreshore Licence main supporting document and Appendix A – AA Screening as outlined in Table B-1. It considers the two sites for which the potential for a likely significant effect has been identified and provides further assessment of the significant effects on the conservation features of these sites. Where appropriate it proposes mitigation measures which could be taken by SSE to reduce the significant of effects. Table B-1: Cross-reference to other supporting information

Keeragh Islands SPA Mid-Waterford Coast SPA

Description of works Section 2 Section 2 Conservation objectives of the A.5.1.1 A.5.1.2 Natura 2000 site Assessment of aspects of the A.5.1.1 A.5.1.2 proposed project which could negatively affect the conservation objectives of the Natura 2000 site

B.2 KEERAGH ISLANDS SPA B.2.1 Screening conclusion

The Keeragh Islands SPA is designated to protect the Annex II listed species cormorant (Phalacrocorax carbo). The conservation objective is to maintain or restore the favourable conservation status of the Annex II species. This is achieved when: ▪ Population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats, and

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▪ The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and ▪ There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis. The AA screening concluded that in relation to the conservation objectives, the proposed survey will not reduce, other than temporarily the natural range of cormorant, nor will it have a significant effect on the habitat that the cormorant require to maintain the population. However, given that the survey is scheduled for summer months when cormorant are breeding and the line plan within the application area is not yet know, it cannot be ruled out that the survey works would not disturb nesting birds. There is therefore the potential that there could be a likely significant effect on the population dynamics conservation objective. B.2.2 Assessment of effects

Given the potential for significant effects on breeding cormorant from visual disturbance, further assessment is required in order to firstly understand the nature and extent of these effects and to then identify suitable mitigation measures to avoid or reduce effects such that adverse effects on the integrity of the SAC will not arise. Table B-2 outlines the specific questions detailed in the NPWS (2012) guidance on Marine Natura Impact Statements that need to be considered by the assessment. Table B-2 Assessment of potential impacts

Questions Response

Will the proposed operation or activity Yes – The geophysical survey vessel will acquire survey data across a 1km swathe result in death, injury or disturbance of of seabed, transiting back and forth in approximately 15 lines. It will be within individuals? 2km of the SPA for a few days up to two weeks. In addition, if the export cable corridor is selected for geotechnical investigations, then up to two vessels will undertake brief geotechnical and environmental work within 2km of the SPA and a third vessel will be present at the mainland coast to drill geotechnical boreholes for approximately eight days. Survey activity will be temporary and localised, but it is scheduled to overlap with the cormorant breeding season. The site is well isolated with little disturbance. Marine traffic in the area is of low density, with less than 100 vessels passing the islands in a year. Therefore, the presence of the survey vessels close to the site could cause disturbance to breeding cormorant. The magnitude of the impact on the SPA will depend on the degree of disturbance. The most disruptive activities to birds are those that are sudden, noisy or fast. As such, helicopters and speedboats usually cause the greatest disturbance (Natural England and Suffolk Coast and Heaths 2012). Vessels travelling at faster speeds cause a greater level of disturbance in terms of the proportion of birds flushing and at further distances. Survey vessels will be slow moving, only between 3.6km/h to 5km/h which is slower or the same as walking speed, and at times stationary. At such slow speeds, the vessels are effectively stationary in terms of bird displacement. Studies have shown that slow moving vessels cause little disturbance to birds and birds may habituate to frequent and relatively benign events and noises (Hill et al 1997 in Natural England and Suffolk Coast and Heaths 2012). It is therefore likely that any disturbance to breeding cormorant will be temporary. Is it possible to estimate the number of No – Cormorant were first recorded breeding on the islands in 1970. Tierney et al individuals that are likely to be affected (2011) report that 239 apparently occupied nests were recorded during the SCR census (1985-88). The Natura 2000 data form for the site states that 200 pairs were recorded in 2000 (NPWS 2014b). A mean of 194 apparently occupied nests (range 131 – 242) was recorded in the period 2008 – 2014 (Wexford Naturalist 2012). This suggests the colony has been relatively stable over the past 30 years.

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Questions Response European Commission (2016) states that cormorant populations have increased moderately since the early 1970s; although the sub-species which occurs in ‘core Europe’ has increased dramatically. Declines in several core breeding areas are partly explained by extra cold winters affecting survival and individual body condition. Given the position of the islands within the application area it is unlikely that seabed on both sides of the island would be surveyed. It is more likely that a 1km wide swathe would be chosen to either the west or east of the islands. Therefore only birds on one side of the SPA would be directly affected. However, the assessment could not find any information to suggest the location of nesting sites on the islands and therefore how many birds could be affected. Will individuals be disturbed at a sensitive Yes, the survey is scheduled to be conducted between April and October and will time or location during their life cycle therefore overlap with the breeding season which runs from February through to September. Are the impacts likely to focus on a There is very limited information available on the reaction of cormorant to particular section of the population, e.g., disturbance by boats. As discussed in the AA screening, cormorant is classed (by adults vs. juveniles, males vs. females the Joint SNCB Interim Displacement Advice Note 2017) as highly susceptible to disturbance (score 4 out of 5). Two studies have looked into responses of cormorant to marine traffic. The first study conducted in Barkley Island, British Columbia (Clyde et al 2012) found that cormorant visited their nests less when there was vessel activity in the area. On the contrary, a study in the Strait of Georgia (Giesbrecht 2001) found that nesting cormorant did not respond to marine traffic, even when within 10m of the colony. The difference in findings is believed to be down to the fact that birds in the Strait of Georgia are more habituated to vessel noise given that it is in an area with higher levels of marine traffic than Barkley Island. Keeragh Islands is in an area of low vessel density (less than 100 vessels pass the Island in one-year), it is therefore unlikely that cormorant will be habituated to marine traffic, suggesting that the first study may be of more relevance. Therefore, the presence of the survey vessel could cause adults to startle or change their behaviour, which indirectly may leave eggs or juveniles exposed to predation. Will the operation/activity cause Activities could cause brief displacement from the surrounding marine waters as displacement from key functional areas the vessel(s) pass the Keeragh Islands. However, the proposed survey will not act as a barrier and birds will be able to quickly return to the Islands or waters once the vessel has passed. Is the habitat of the species likely to No – the marine survey will not affect the habitat of breeding cormorant. deteriorate causing disturbance to individuals or populations How quickly is the affected population in The geophysical vessel will pass backwards and forwards past the Keeragh Islands the SPA likely to recover once the as it acquires each line of data. Each disturbance episode will be brief, but the operation/activity has ceased vessel could be present near the islands for up to two weeks and therefore cormorants will experience multiple disturbance events. The worst case is that disturbance at the wrong time in the breeding season could open the colony up to predation of nests reducing the number of chicks reared for the year. Female cormorants lay 3-5 eggs, and survival for the fledgling can be as high as 90%. However, it is usually less with 2.0 to 2.5 birds per nest common. Under unfavourable conditions this can be further reduced to 0.5 birds per nest. It is estimated that 40% of juveniles die each year (European Commission 2011). The colony at Keeragh Islands has remained reasonably stable over the past 30 years with fluctuations in the number of apparently occupied nests year on year. Temporary disturbance at the wrong time of the breeding season could therefore be likened to the colony experiencing a bad year. It is likely that against the natural annual fluctuations effects related to temporary disturbance will not be noticeable and recovery will be quick. In the absence of mitigation, are the effects The SPA extends from the islands out to cover the surrounding marine area for a of the proposed operation/activity on distance of 200 metres. Annex II species likely to have a significant

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Questions Response effect on the favourable conservation In the absence of mitigation, it is uncertain as to whether temporary disturbance condition of the Annex II species at the site of nesting cormorant would lead to a significant effect on the favourable conservation objective of the Annex II species at the site. Repeated disturbance over a period of two weeks at the wrong time of year, could lead to a delay in breeding for individuals or nest abandonments. What measures can be implemented to A frequent tool used to avoid disturbance effects is to designate a buffer zone mitigate the significance of the likely around animals distribution in which human activity is restricted. Commonly adverse impact into insignificance? either the alert distance, the distance at which the animal changes its behaviour in response to the approaching disturbance source, or the flight initiation distance, the point at which the animal flushes or moves away from the approaching disturbance source are used. A review of disturbance distances in selected bird species (Ruddock and Whitfield 2007) looked at 25 priority bird species which breed in Scotland. An initial review identified that there were few previous studies that quantified disturbance distances for bird species. The authors therefore undertook an expert opinion study in which opinion was solicited on static and active disturbance distances when birds were approached by a single pedestrian when incubating eggs and when with chicks. There is no comparable research for boat disturbance and therefore this study has been used to determine a reasonable buffer zone for the proposed survey. Cormorant were not one of the priority bird species selected but red-throated diver, black-throated diver and Slavonian grebe were. These are all similar diving species, with red-throated and black-throated diver classed as very highly susceptible to disturbance (score 5 out of 5) and Slavonian grebe moderately susceptible to disturbance (score 3 out of 5); as classified by the Joint SNCB Interim Displacement Advice Note 2017. The study concluded that during incubation the alert distance for the three species ranged between <10m to 750m, with the range for the flight initiation distance being similar. During chick-rearing the upper limit for the flight initiation distance was slightly lower at 500m but the alert distance was the same as during incubation. This suggests that a buffer of 750m from nesting birds would be recommended. In addition, it is recommended that the geophysical survey of the application area from the coast to 4km offshore occurs during the period August through to February. By postponing the survey to August disturbance of incubating or chick- rearing adults will be reduced and chicks will have fledged.

B.2.2.1 Mitigation/Recommendation Mitigation measures in this section are proposed to inform the appropriate assessment. ▪ It is recommended that the survey vessels stay at least 750m away from the base of the Keeragh Islands during the period February to September to minimise disturbance to nesting birds. ▪ It is recommended that the survey of the application area from the coast to 4km offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. B.2.3 Conclusion

Visual disturbance caused by the survey vessels could temporarily disturb breeding cormorant on Keeragh Islands and could therefore result in a short-term significant effect to the breeding population. Given the uncertainties in the assessment, e.g. lack of knowledge on nest locations, measures (Section B.2.2) have been proposed to ensure that breeding cormorant will not be significantly disturbed and that the conservation objectives of the SPA will not be adversely affected.

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B.3 MID-WATERFORD COAST SPA B.3.1 Screening conclusion

The Mid-Waterfod Coast SPA is designated to protect the Annex II listed species cormorant (Phalacrocorax carbo); peregrine (Falco peregrinus); herring gull (Larus argentatus); and chough (Pyrrhocorax pyrrhocorax). The conservation objective is to maintain or restore the favourable conservation status of the Annex II species. This is achieved when: ▪ Population dynamics data on the species concerned indicate that it is maintaining itself on a long- term basis as a viable component of its natural habitats, and ▪ The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and ▪ There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis. The AA screening concluded that in relation to the conservation objectives, the proposed survey will not reduce, other than temporarily the natural range of the four Annex II species nor will it have a significant effect on the habitat that these species require to maintain the population. However, given that the survey is scheduled for summer months when cormorant, peregrine, herring gull and chough are breeding; and that the location of boreholes and the survey line plan within the application area is not yet known, it cannot be ruled out that the survey works would not disturb nesting birds. There is therefore the potential that there could be a likely significant effect on the population dynamics conservation objective. The Joint SNCB Interim Displacement Advice Note (2017) categorised herring gull as having a low disturbance susceptibility (score of 2 out of 5) and a low habitat specialism (score of 2 out of 5). This indicates that breeding herring gull would not be affected by the proposed survey works. Therefore, herring gull were screened out of the assessment. B.3.2 Assessment of effects

Given the potential for significant effects on breeding cormorant, peregrine and chough from visual disturbance (from the presence of survey vessels and borehole drilling), further assessment is required in order to firstly understand the nature and extent of these effects and to then identify suitable mitigation measures to avoid or reduce effects such that adverse effects on the integrity of the SAC will not arise. Table B-3 outlines the specific questions detailed in the NPWS (2012) guidance on Marine Natura Impact Statements that need to be considered by the assessment. Table B-3: Assessment of potential effects

Questions Response

Will the proposed operation or activity Survey vessels: result in death, injury or disturbance of Yes - The geophysical survey vessel will be within 2km of the SPA for up to one week individuals? as it transits back and forth acquiring data across a 1km wide corridor. In addition, if the western export cable corridor is selected for geotechnical investigations, then up to two vessels will undertake brief geotechnical and environmental work within 2km of the SPA. Survey activity will be temporary and localised, but it is scheduled to overlap with the breeding season of cormorant, peregrine and chough. Marine traffic in the area is of low density. Therefore, it is unlikely that birds will be habituated to marine traffic. As such, the presence of the survey vessels close to the site could cause disturbance to breeding birds.

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Questions Response The magnitude of the impact on the SPA will depend on the degree of disturbance. The most disruptive activities to birds are those that are sudden, noisy or fast. As such, helicopters and speedboats usually cause the greatest disturbance (Natural England and Suffolk Coast and Heaths 2012). Vessels travelling at faster speeds cause a greater level of disturbance in terms of the proportion of birds flushing and at further distances. Survey vessels will be slow moving, only between 3.6km/h to 5km/h which is slower or the same as walking speed, and at times stationary. At such slow speeds, the vessels are effectively stationary in terms of bird displacement. Studies have shown that slow moving vessels cause little disturbance to birds and birds may habituate to frequent and relatively benign events and noises (Hill et al 1997 in Natural England and Suffolk Coast and Heaths 2012). It is therefore likely that any disturbance to breeding cormorant, peregrine and chough will be temporary. Borehole drilling: Yes – Drilling the geotechnical boreholes will take approximately eight days. During this time there is the potential that breeding cormorant, peregrine and chough could be disturbed. Jackson (2012) provide thresholds for a likely significant effect on bird populations as 70dB for continuous noise and 50dB for impulsive noise, based on a review of relevant research and literature. These figures take into account more sensitive species reactions to concur with the requirements of the Habitats Directive to adopt a ‘precautionary principle’. For the proposed borehole drilling, the avoidance of ‘complete flight’ startling effects is desirable to ensure there will be no significant effects on breeding species. The Wilson Report (HMSO 1963) indicates that limited data suggests a noise level of approximately 85dB is required to scare a bird; which has been assumed to result in ‘complete flight’. However, the use of this level as a limit to avoid ‘complete flight’ has limitations because it is based on specific species (RSK 2011). RSK (2011) conducted a review of published research for the UK Environment Agency, which concluded that due to the inter and intra-species variability, seasonal effects and difficulties of conducting research which distinguishes the effect of noise from other disturbances, there is considerable uncertainty in identifying thresholds that clearly demonstrate that noise has no adverse effect on the integrity of a protected site. Noise outputs for the proposed borehole survey are not available however below are two examples of noise assessments for similar drilling based activity: ▪ A borehole survey in the Ribble Estuary (RSK 2011) provides noise data for a comparable geotechnical drilling rig albeit on marshland. The noise output for the cable percussive rig had a sound pressure level (SPL) of 68dB at 25m. This information was used to model the impact of the drilling on the surrounding marsh environment, in this case a UK Site of Special Scientific Interest (SSSI). The model results indicated that drilling boreholes on the marsh would result in a noise level of 55dB(A) or greater, at a maximum radius of 93m and 76dB(A) occurred at approximately 10 – 11m from the rig.

▪ The noise associated with drilling an exploratory shale-gas well from a 7.2 metre rig on land was calculated to be 75dB(A) at 10m falling to 62dB(A) over 50m (Ecology Services 2013).

Based on the examples provided above it would suggest that drilling activity is potentially below the suggested threshold of 85dB which would cause a ‘complete flight’ startle reaction, but sufficient to cause a likely significant effect (i.e. above 55dB) within 100m of borehole drilling activities.

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Questions Response Is it possible to estimate the number of No - Only breeding birds within 100m of the borehole location will experience individuals that are likely to be affected noise levels sufficient to cause a likely significant effect. As the borehole locations are not known it is uncertain as to how many nests could be effected. Cormorant: The site synopsis indicates that in 1999-2000 the SPA supported a nationally important population of cormorant (79 pairs). The Waterford Birds Atlas (2013) indicates that there are confirmed locations of breeding cormorant within the application area and records indicate that between 1-43 birds were observed as breeding in 2008. Peregrine: The site synopsis indicates that in 2002 the SPA supported a nationally important population of cormorant (10 pairs). Chough: The site synopsis indicates 24 breeding pairs were recorded from the site in the 1992 survey and 20 pairs in the 2002/03 survey. In addition, five flocks totalling 59 birds were noted in the 1992 survey and a flock of 24 birds in the 2002/03 survey. The Waterford Birds Atlas (2008) indicates that there are confirmed locations of breeding chough within the application area, however there is no information on breeding numbers. Therefore, it is not possible determine how many birds could be affected.

Will individuals be disturbed at a sensitive Yes, the survey is scheduled to be conducted between April and October and will time or location during their life cycle therefore overlap with the breeding season which runs from February through to September. Are the impacts likely to focus on a There is very limited information available on the reaction of cormorant, peregrine particular section of the population, e.g., and chough to disturbance by boats. adults vs. juveniles, males vs. females Cormorant is classed (by the Joint SNCB Interim Displacement Advice Note 2017) as highly susceptible to disturbance (score 4 out of 5). Two studies have looked into responses of cormorant to marine traffic. The first study conducted in Barkley Island, British Columbia (Clyde et al 2012) found that cormorant visited their nests less when there was vessel activity in the area. On the contrary, a study in the Strait of Georgia (Giesbrecht 2001) found that nesting cormorant did not respond to marine traffic, even when within 10m of the colony. The difference in findings is believed to be down to the fact that birds in the Strait of Georgia are more habituated to vessel noise given that it is in an area with higher levels of marine traffic than Barkley Island. The Mid Waterford Coast is in an area of low vessel density with less than 2 vessels passing the islands over a 56 day period. it is therefore unlikely that cormorant will be habituated to marine traffic, suggesting that the first study may be of more relevance. A study by Ruddock and Whitfield (2007) looking at the disturbance of peregrine, suggested flushing of peregrine in the presence of humans did not occur “until at close range” but could attribute to possible nest failure. This study also found that breeding peregrines are most likely disturbed by activities taking place above their nests. Therefore, given that borehole works and survey works will take place in the intertidal area below nesting site survey works are unlikely to result in the flushing of peregrine from their nest sites A study by Bullock et al (1983) noted that chough were tolerant to human disturbance and chough are found to breed in areas of busy tourist spots. It therefore could be said that chough maybe tolerant to borehole and survey works. Given that lack of information it is considered prudent to assume that the presence of the survey vessel could cause adults to startle or change their behaviour, which indirectly may leave eggs or juveniles exposed to predation. Will the operation/activity cause Survey vessels and borehole works could cause brief displacement from the displacement from key functional areas surrounding marine waters as the vessel(s) pass the SPA and within 100m of boreholes works. However, the survey will not act as a barrier and birds will be able to quickly return to the SPA once the vessel has passed and borehole works has ceased.

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Questions Response Is the habitat of the species likely to No – the marine survey and borehole works will not affect the habitat of breeding deteriorate causing disturbance to cormorant, peregrine and chough. individuals or populations How quickly is the affected population in The geophysical vessel will pass backwards and forwards past the Mid-Waterford the SPA likely to recover once the Coast SPA as it acquires each line of data. In addition, breeding birds within 100m operation/activity has ceased of borehole works will disturbed. Each disturbance episode will be brief, but the vessel could be present near the SPA for up to one week and borehole works will take approximately 8 days. Therefore breeding cormorant, peregrine and chough will experience multiple disturbance events. The worst case is that disturbance at the wrong time in the breeding season could open the nests up to predation reducing the number of chicks reared for the year. Female cormorants lay 3-5 eggs, and survival for the fledgling can be as high as 90%. However, it is usually less with 2.0 to 2.5 birds per nest common. Under unfavourable conditions this can be further reduced to 0.5 birds per nest. It is estimated that 40% of juveniles die each year (European Commission 2011). Temporary disturbance at the wrong time of the breeding season could be likened to the colonies experiencing a bad year. It is likely that against the natural annual fluctuations, effects related to temporary disturbance will not be noticeable and recovery will be quick. In the absence of mitigation, are the effects In the absence of mitigation, it is uncertain as to whether temporary disturbance of of the proposed operation/activity on nesting cormorant, peregrine and chough would lead to a significant effect on the Annex II species likely to have a significant favourable conservation objective of the Annex II species at the site. Repeated effect on the favourable conservation disturbance over a period of up to one week for nearshore survey works and up to condition of the Annex II species at the site 8 days for boreholes works at the wrong time of year, could lead to a delay in breeding for individuals or nest abandonments. What measures can be implemented to Survey vessels: mitigate the significance of the likely It is recommended that the survey of the application area from the coast to 2km adverse impact into insignificance? offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. Borehole works: It is recommended that borehole works are conducted as late in the breeding season as possible and no earlier than August. By postponing the survey disturbance of incubating or chick-rearing adults will be reduced and chicks will have fledged. Geotechnical boreholes should be located a minimum of 100m from known breeding habitat e.g. caves, rock crevasses and sea cliffs.

B.3.3 Mitigation/Recommendation

Mitigation measures in this section are proposed to inform the appropriate assessment. ▪ It is recommended that the survey of the application area from the coast to 2km offshore occurs during the period August through to February to avoid disturbance of incubating or chick-rearing adults. Borehole works: ▪ It is recommended that borehole works are conducted as late in the breeding season as possible and no earlier than August. By postponing the survey disturbance of incubating or chick-rearing adults will be reduced and chicks will have fledged. ▪ Geotechnical boreholes should be located a minimum of 100m from known breeding habitat e.g. caves, rock crevasses and sea cliffs.

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B.3.4 Conclusion

Visual disturbance caused by the survey vessels and borehole drilling could temporarily disturb breeding birds within the Mid-Waterford Coast SPA and could therefore result in a short-term significant effect to the breeding population. Given the uncertainties in the assessment, e.g. lack of knowledge on nest locations, mitigation measures have been proposed to ensure that breeding cormorant, peregrine and chough will not be significantly disturbed and that the conservation objectives of the SPA will not be adversely effected.

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