Appendix 3 Ecology Response 1 1. Avifauna General comment The comments from Bird Watch Ireland and An Taisce are welcome. The Response has been prepared in a short period of time and a review of available literature on impacts is on‐going by the bird survey team. Since the Ecological Assessment of the EIA was prepared, a draft guidance document on survey and monitoring in relation to marine renewable deployments in Scotland was produced by Scottish Natural Heritage. Several reviews of the environmental impacts of marine renewable energy devices have been published (e.g. Grecian et al., 2010, Witt et al., 2011) and conferences on or including the theme of marine renewables have been held (e.g. ICES, 2011, EIMR, 2012). While the industry is developing quickly, data to describe the interactions between wave energy devices and birds is still limited. Within this context the following response has been prepared: Bird Watch Ireland comment 1: Consideration of the interests of SPAs in the Appropriate Assessment screening process: Bird Watch Ireland notes that the Screening for Appropriate Assessment report identifies a number of Special Protection Areas and their distances from the proposal area. It does not identify the species concerned, their ecological needs or the potential for impacts as a result of the proposal. They appear to be screened out of the assessment process though the detailed rationale for this is not provided. The Ecological Assessment report (Annex 3: Ecological Assessment For The Proposed Atlantic Marine Energy Test Site) prepared for this proposal identifies potential impacts on Avifauna of Special Conservation Interest for nearby SPAs which are considered to be of “High” or “Unknown” significance which is a direct contradiction. It is Bird Watch Ireland’s view that an assessment on the ecological needs of seabirds is required prior to decision‐making. While there are significant data gaps for the marine environment, existing information on the ecology of species needs could be used to inform an assessment along with more recent research on the interactions between species and renewable energy infrastructure. This is not included in the assessment process. Response: To address the above concerns of Bird Watch Ireland the following steps were taken: i. “Qualifying” species (special conservation interests) for the coastal SPA’s which lie within 30km of the study site where listed (Table 1a and 1b below). ii. Migratory species or species which may be linked to more distant Irish or UK SPA’s and which were recorded in the study site, where listed (Table 2 below). iii. A Risk Assessment for the species listed in tables 1 and 2 based on the ecological needs of these species (considered in species groups), current risks, their use of the study site and their potential interactions with WEDs and AMETS was completed (Appendix 1). This Risk Assessment used standard reference texts (e.g. Mitchell et al.,2004), Birdwatch Ireland Action Plans (BWI, 2011), the SNH Draft Guidance document on marine renewable (Jackson & Whitfield, 2011) and the Strategic Environmental Assessment of Marine Renewable Energy Development in Scotland (Wilson et al.,2007). The Risk Assessment includes a number of additional species which commonly occur within the study site and which are part of the species groups being considered in the Risk Assessment. Conclusions from the Risk Assessment are presented below. 2 iv. The conclusions from the Risk Assessment were incorporated into a revised Appropriate Assessment Screening (Appendix 2). The conclusions of this Screening Assessment are presented below. i. Qualifying species. The qualifying species within the SPA’s identified in the Appropriate Assessment Screening (EIA, 2011) are listed in Table 1. (see also tables 3.1.1 and 3.1.2 of the Ecological Assessment: Annex 3 of the EIA). Table 1a: Qualifying wintering species for coastal SPA’s lying within 20 km of the study site and which have used the study site. “*” indicates Annex I species. Wintering Species SPA Barnacle Geese* Inighlora Inishkeeragh Termoncarragh and Annagh Lake Machair Blacksod Broadhaven Bay Inishkea Islands Duvillaun Islands Light Bellied Brent Goose Blacksod Broadhaven Bay Great Northern Diver* Blacksod Broadhaven Bay Ringed Plover Blacksod Broadhaven Bay Inishkea Islands Sanderling Blacksod Broadhaven Bay Inishkea Islands Dunlin Blacksod Broadhaven Bay Curlew Blacksod Broadhaven Bay Purple Sandpiper Inishkea Islands Turnstone Inishkea Islands 3 Table 1b: Qualifying breeding species for coastal SPA’s lying within 20 km of the study site and which have used the study site. “*” Indicates Annex I species. Breeding Species SPA Storm Petrel* Inishglora and Inishkeeragh Duvillaun Islands Ilanmaster Stags of Broadhaven Leach’s Petrel* Stags of Broadhaven Arctic Tern* Inishglora and Inishkeeragh Inishkea Islands Sandwich Tern* Blacksod/Broadhaven Bay Little Tern* Inishkea Islands Cormorant Inishglora and Inishkeeragh Shag Inishglora and Inishkeeragh Inishkea Islands Lesser Black backed Gull Inishglora and Inishkeeragh Inishkea Islands Herring Gull Inishglora and Inishkeeragh Inishkea Islands Common Gull Inishkea Islands Puffin Illanmaster Stags of Broadhaven Fulmar Duvillaun Islands ii. Additional Species. Additional species considered in the Risk Assessment given that they are migratory species and/or that they are likely part of the qualifying interest in distant Irish or UK SPAs are listed in Table 2. These species are taken from the list of more commonly occurring species recorded within the study site (Ecological Assessment, Annex 3 EIA). Table 2: Migratory species and species which species which may be linked to distant Irish or UK SPA’s and which use the study site. Species Importance Gannet Distant SPA, foraging activity in study site Skuas Migratory – occurrence on passage Manx Shearwater Distant UK/Irish SPA (possibly) and migratory, large numbers in Spring, foraging. Great & Sooty Migratory – occurrence on passage Shearwater iii. Conclusions from the Risk Assessment Appendix I of this Response provides summary information on the ecological needs of each of the qualifying species (considered in species groups), together with an assessment of the risk of a 4 negative interaction between the proposed development and the qualifying species. Conclusions from this assessment are as follows: The risk of negative interactions between cable laying activities within the Bay and the qualifying species is considered to be low, given the short duration and temporary nature of activities. Likely significant effects on the qualifying wintering and breeding birds which use the Bay are therefore considered unlikely. Monitoring of the Bay is recommended. Displacement of foraging birds from the berth areas is considered to be of low impact for all species groups. The footprint of the berth areas is relatively small and alternative foraging habitat is available. There is also, so far, no indication that the berth areas provide favoured feeding habitat and are thus attractive to, any species group. Displacement is therefore unlikely to have significant effects on the qualifying species which use the AMETS. Monitoring is recommended. For the protection of all species the active use of a comprehensive spill prevention and response plan is important. The risk of collision for all species groups is considered to be low due to the small footprint of the development. Notwithstanding this assessment the risk of collision is higher for a number of species due to aspects of their behaviour (Table 3). Table 3: Species groups at higher risk of collision with WEDs. Species Group Reason for higher collision risk Terns Plunge divers Petrels Nocturnal habits Shearwaters Low flying, nocturnal habits. Auks Pursuit divers, low fast flight. Monitoring is recommended at the wave energy test site to examine the interactions between birds and the wave energy devices. Without such data the impacts of wave energy devices on birds cannot be fully assessed. iv. Conclusions from the revised Appropriate Assessment Screening. The AMETS is not likely to have a significant effect on the species of conservation interest within the SPAs identified in the Revised Appropriate Assessment. This conclusion is based on the information contained in the Ecological Assessment for the EIA, and the Risk Assessment completed as part of this Response. Given that the significance of some impacts are unknown and given the limited data with which to assess other impacts, monitoring is recommended. Bird Watch Ireland comment 2: Data available for decision‐making in the marine environment: Bird Watch Ireland recognises that there are serious data deficiencies for the marine environment in particular relating to the status and behaviour of seabirds and their ecological needs. Notwithstanding ongoing research relating to seabirds in other countries, it is important to build a knowledge base in an Irish context and to ensure informed decision‐making at both a sectoral and project level. A series of unknowns need to be proactively addressed to assist decision‐making in this case: 5 Building a baseline: While significant work has been carried out by the applicant particularly in the last year, this provides a snapshot of usage of the location by certain species. This snapshot needs to become more applied. It is Bird Watch Ireland’s view that a single year of data is not sufficient in order to assess usage of the area by species, and that a more encompassing baseline assessment needs to be designed and rolled out. Specifically; surveys of off‐shore islands for terns and Eider for example, and the examination of foraging distances from nearby seabird colonies, and of species densities in the context of ecological needs is required. Research & monitoring the test project: A coherent research and monitoring programme should be designed as part of the application process so as to ensure the proposed ‘test phase’ project contributes to better understanding the interactions of seabirds and energy infrastructure. Again the design of monitoring should ensure data gaps are addressed for Irish seabirds. Response: One year of survey data is not sufficient to establish usage of the AMETS study site.