1. Introduction

This Outline Construction Environmental Management Plan (OCEMP) refers to the construction of the onshore transmission works of the Berwick Bank Wind Farm, an offshore wind project, by Berwick Bank Wind Farm Limited (BBWFL) (hereafter referred to as “the Applicant”), a wholly owned subsidiary of SSE Renewables Limited (“SSER”). Berwick Bank Wind Farm (hereafter referred to as “the Project”) includes both the offshore and onshore infrastructure required to generate and transmit electricity from the offshore array area to a Scottish Power Energy Networks (SPEN) 400kV Grid Substation located onshore at Branxton, southwest of Torness Power station.

The onshore transmission works (hereafter referred to as “the Proposed Development”) comprises the onshore elements of the Project, located on the landward side of Mean Low Water Springs (MLWS). The key components of the Proposed Development, which this OCEMP covers, are:

  • cable landfall
  • onshore substation
  • onshore cables within a cable corridor between the cable landfall and the new onshore substation, and between the new onshore substation and the National Grid Branxton substation; and
  • associated ancillary infrastructure.

 

The OCEMP will be updated and finalised post consent in line with any relevant planning conditions and in agreement with East Lothian Council (ELC).

 

The full CEMP will form part of the induction which is mandatory for all employees, contractors and visitors attending the site. All employees and contractors shall familiarise themselves with the content of the CEMP.

1.1. Purpose

The CEMP will be a key document assisting the Applicant and Principal Contractor in complying with set planning conditions and relevant legislation, policy, and guidance. The CEMP will be a live document, updated as required throughout the planning and construction process.

The aim of this OCEMP is to establish the main mitigation and control measures that will be utilised to provide robust environmental management throughout the construction period to avoid or minimise the adverse effects of the Proposed Development. On confirmation of Principal Contractor, the OCEMP will be updated to reflect specific proposed construction methods and the document reviewed and agreed with ELC before construction works begin. The CEMP will therefore evolve and is subject to refinement, amendment, and expansion as necessary.

Throughout the planning and construction phases of the Proposed Development, the CEMP will be subject to continual review, for example:

  • To address any conditions stipulated in the Planning Permission;
  • To address any update in current legislation; 
  • To ensure it reflects good practice during construction;
  • To ensure it incorporates the findings of any pre-construction site investigations and surveys; and
  • To accommodate the working practices of the appointed Principal Contractor.

1.2. Content

This document sets out the minimum standards to be adopted when constructing the Proposed Development. It also provides information about the associated Management Plans which should be read in conjunction with this CEMP.

  • Outline Pollution Prevention and Contingency Plan;
  • Outline Construction Noise & Vibration Management Plan;
  • Outline Construction Dust and Air Quality Management Plan;
  • Outline Site Waste Management Plan;
  • Outline Water Quality Management Plan;
  • Outline Soils Management Plan;
  • Outline Habitat Management Plan;
  • Outline Species Protection Plan;
  • Outline Construction Traffic Management Plan; and
  • Outline Archaeological Management Plan

1.3. Site and Surroundings

The Proposed Development location is provided in the Environmental Impact Assessment (EIA) Report Volume 2 Figure 1.1 The extent of the Proposed Development red line Planning Application Boundary (hereafter referred to as “the site”) is situated near Torness and the village of Innerwick, south-east of Dunbar in East Lothian, Scotland. The centre of the site is OSGB36, British National Grid (BNG) 374080, 673982. The site is approximately 598 ha in size.

The proposed cable landfall is located north-west of Torness Power Plant and Skateraw harbour. The onshore cable corridor runs west of the settlement of Skateraw, under the East Coast Main Line (ECML) railway and the A1 trunk road, to the onshore substation, located in open agricultural land north-east of Innerwick. The onshore cable corridor then runs south through agricultural land between Innerwick and Thorntonloch Glen, crossing underneath overhead power lines, to continue south of the Braidwood Burn and the proposed location of the National Grid Branxton substation.

The site is predominantly arable, open agricultural land, interspersed with rural properties and crossed by transport routes including the ECML and the A1. There is industrial development in the wider vicinity including Torness Power Plant and Oxwell Mains Cement Works and Quarry on the coastline. 

Further details of the site and its surroundings are provided in EIA Report Volume 1, Chapter 5.

1.4. Proposed Development Description

The Proposed Development comprises the following buildings and infrastructure, which have been considered in this OCEMP:

  • Onshore substation; within an agricultural field currently used for arable agriculture, approximately 680 m north-east of Innerwick settlement. Landfall and Transition Joint Bays; eight proposed transition joint bays located approximately 130 m north-west of Skateraw harbour, to connect the offshore and onshore cables.
  • Onshore Cables; onshore cables installed underground through agricultural land.
  • Permanent Access Road; a new permanent access road to the onshore substation to the southwest.
  • Temporary Access Road; constructed within the site along the length of the onshore cable corridor. The temporary access roads will be maintained for the duration of the construction period as required. Following construction, the temporary surface will be removed and the previous land use reinstated.
  • Construction Compounds; multiple temporary construction compounds erected across the site.
  • Trenchless Technology Compounds; required to enable onshore cables to be routed beneath locations including; landfall, the East Coast Mainline (ECML) railway, the A1 trunk road and existing cable infrastructure,  and beneath a scheduled monument.
  • Sustainable Drainage System Pond; located in the east of the onshore substation.
  • A cable bridge crossing of the Braidwood Burn.

Further details on each infrastructure component are provided in the EIA Report Volume 1, Chapter 5.

2. Document Control

The CEMP is a “live” document and will be subject to periodic review and updating. The document is intended for use by the Applicant and their contractors specifically involved in the construction of the Proposed Development. When this document is amended, the document control table will be updated (Table 1) and it will be issued to all personnel specified on the distribution list below (Table 2), which will be updated with relevant details at the stage of submission of the full CEMP.

Table 1:
Document Control

Table 1: Document Control

 

Table 2:
Distribution List

Table 2: Distribution List

 

3. Responsibilities

3.1. Environmental Policy and Management Systems

The Principal Contractor will ensure that copies of their environmental policies are clearly displayed on site notice boards during the construction period. All employees are expected to comply with the requirements of the Environmental Policy and the requirements of the Environmental Management System (EMS) under a suitable accreditation such as ISO14001.

The Applicant and the Principal Contractor expects their employees and support staff (contractors, sub-contractors, suppliers etc.) to actively promote and administer a strong environmental culture. To achieve this, a number of initiatives will be implemented during the construction phase from Day One. This will include the use of environmental inductions, poster campaigns to raise awareness of topical subjects (such as seasonal activities and timings) and toolbox talks (TBT) involving all members of the project team and site workforce.

As part of the EMS for the site, a Project Environmental File (PEF) will be maintained by the Principal Contractor. Within this PEF, a legislation register will be stored which will be reviewed periodically and updated as necessary. Any changes to relevant environmental legislation will be disseminated to project management immediately, after which the method statements of any affected construction activities will be amended as necessary.

3.2. Consents and Licences

A register of required consents and licences will be held in the PEF, including the relevant reference numbers, and responsible/named competent persons.

3.3. Roles and Responsibilities

It is the responsibility of all staff involved with the Proposed Development, including the Applicant, Principal Contractor, and sub-contractors, to ensure the correct implementation of the CEMP and the environmental mitigation contained within.

The key environmental responsibilities during the construction phase of the Proposed Development are summarised below:

  • The Applicant – responsible for ensuring that the Proposed Development is built in accordance with the planning conditions and that all environmental mitigation measures stated within the EIA Report and the CEMP are implemented.
  • Principal Contractor – responsible for regularly reviewing and updating the CEMP and ensuring that all staff and sub-contractors abide by and implement the CEMP. The Principal Contractor will be responsible for the implementation of the CEMP and all the environmental mitigation measures outlined in the EIA Report.
  • Consents and Environment Manager – A Consents and Environment Manager (CEM) will be appointed as part of the Applicant’s or Principal Contractor’s team. They shall have overall responsibility for the management of the construction phase. The Applicant and Principal Contractor will ensure that a suitable, independent person with appropriate knowledge and experience of similar scale or type of projects will be employed.

The CEM will:

–      Programme any required pre-construction surveys and samples into the construction schedule and continue with any monitoring to be undertaken during construction as required. These will then be the responsibility of the ECoW (Ecological Clerk of Works);

–      Progress any discharge of conditions, especially those that require access agreements to be in place to allow for pre-commencement sampling or surveying to be undertaken;

–      Ensure all required consents are in place before work starts and compliance with consents;

–      Ensure that all mitigation measures and commitments are implemented properly and effectively;

–      Supervise construction processes with potential for environmental consequences such as trenchless technology operations and installation of temporary site drainage;

–      Ensure compliance with the topic-specific Management Plans by, for example, undertaking spot checks and audits on the timing of Heavy Goods Vehicles (HGVs) and abnormal load deliveries, speed checks on the approach to site and along access tracks throughout the site, and observations of works in sensitive areas (if not already undertaken by a specific ECoW);

–      Undertake weekly audits/site checks;

–      Ensure environmental and waste requirements are included on requisitions and in subcontracts and orders;

–      Ensure oil, including diesel, is stored in properly bunded tanks/drip trays;

–      Report incidents and non-conformances to the Applicant, Principal Contractor, and relevant authorities in line with the reporting procedure in this CEMP;

–      Include environmental performance, review of contract objectives and targets (including environmental), review of incidents and non-conformances at the project review meetings;

–      Ensure employees and subcontractors implement the controls outlined in the finalised and approved CEMP and any other appropriate plans, mitigation measures or commitments;

–      Ensure employees and subcontractors receive induction training (including project environmental issues) and toolbox talks, as appropriate;

–      Ensure personnel needed for audits are available when required; and

–      Verify actions resulting from corrective action requests and observations raised during audits are completed by the deadlines.

 

The CEM will also act as the main point of contact between the:

–      Regulators such as ELC and SEPA;

–      Local stakeholders;

–      Local communities; and

–      The public and visitors to the area.

 

The CEM will be the focal point for queries, comments, and questions on project progress meetings, reporting and also communication on critical activities of the Proposed Development. This will include communicating when pre-construction works are likely to commence and then keeping the local communities and stakeholders aware of the continuing activities which will occur during the construction phase including regular updates on progress.

 

The CEM will specifically communicate the following construction activities to local communities (please note this list is not exhaustive):

–      Works which involve the loss or temporary replacement of access (for example road diversions or closures, or impacts to recreational routes);

–      Works adjacent to or within key sensitive areas such as watercourses;

–      Progress/compliance with mitigation measures and reporting;

–      Notification of monitoring at relevant locations, including requests for permission to access third party land or property where there is a proposed monitoring or sampling point; and

–      Changes in working hours, particularly any proposed out-of-hours working.

 

Once the Principal Contractor is appointed and the construction programme confirmed, the CEM will communicate this programme to the community and facilitate meetings as required.

 

The CEM will ensure that records of communication (including verbal communication) are kept, and that regular reporting is provided to ELC, SEPA and the local communities.

 

  • Ecological Clerk of Works (ECoW) – reports to the CEM and is responsible for monitoring the implementation of the landscape and ecological mitigation measures on site prior to, during and post-construction. The ECoW will be a Suitability Qualified Ecologist (SQE).
  • Archaeological Clerk of Works (ACoW) – employed to oversee the archaeological programme of works and will be responsible for the successful implementation of the Archaeological Management Plan (AMP).
  • All construction staff – responsible for understanding the requirements of the CEMP and the environmental sensitivities of the Proposed Development. All staff have an obligation to abide by the CEMP and the relevant environmental legislation.

3.4. Subcontractor Management

The project will engage various subcontractors to carry out project construction related activities. These subcontractors are responsible for performing all work in conformance with relevant environmental legislation, the requirements of the CEMP, and contractual environmental requirements.

Subcontractors are required to develop suitable, adequate, and effective method statements that explicitly define the measures to be taken to manage significant environmental risks associated with their scope of works. No works will be permitted to commence until such method statements have been developed and approved by the CEM. Additionally, subcontractors are required to provide sufficient and competent resources to monitor conformance with their own defined method statements.

The Principal Contractor will conduct monthly Environmental Reviews that will assess the environmental performance of subcontractors.

4. Program of Works

The current indicative construction programme for the Proposed Development outlines the key construction activities and the timescales within which these activities are planned to take place (see Figure 4.1). On-site activities will not necessarily be ongoing for the entire duration of each indicated timescale. This construction programme indicates an estimated final installation date in 2030.

 

Figure 4.1 - Indicative development and installation programme for the Proposed Development

5. Safety

Site specific risk assessments and method statements will be undertaken in accordance with the applicable legislation prior to the commencement of construction activities; to identify any potential risks, assess their likelihood and significance, and to identify mitigation measures to be implemented to ensure the safety of workers and the general public.

Site security during the construction phase will be strict. Access to the site will be prevented by the use of temporary fencing to prevent unauthorised access. Compounds for the temporary storage of equipment or materials will be provided, with segregation of materials (hazardous or otherwise) as required, and designated re-fuelling areas. These will be locked with restricted access. Security staff will be utilised as appropriate.

The Applicant will ensure that adequate arrangements are in place for the discharge of all duties under the Construction (Design and Management) (CDM) Regulations 2015.

A Health and Safety Plan will be prepared by the Principal Contractor which will set out how all health and safety matters on site are to be managed and how risks are to be identified and managed in accordance with current good practice and legal requirements.

6. Security

A Permit to Work system (or equivalent) will be introduced during construction to ensure that only authorised construction personnel are allowed within the construction area and that an accurate record of site-based personnel is available in case of emergency.

The Principal Contractor will ensure that the construction sites are secure. Access to the site will be limited to specified entry points only and all personnel entrances and exits will be recorded and monitored for both security and health and safety purposes.

Visitors to the Proposed Development site during construction will be required to report to the construction reception office (location to be confirmed) and will only be permitted to access the construction area under escort by appropriately authorised staff or following successful completion of specific safety induction training.

All working areas will be appropriately fenced off from members of the public and to prevent animals from straying onto working areas.

7. Construction Operations

7.1. Site Access

Access to each element of the Proposed Development (Onshore Substation, Cable Landfall and Onshore Cable Route) will be via the A1 trunk road (A1(T)) and subsequently by the local road network. These accesses will be agreed with ELC and Transport Scotland and will be detailed in the final Construction Traffic Management Plan (CTMP).

7.2. Construction and Delivery Hours

Planning permission is being sought for 24-hour, 7days per week construction working hours. The 24-hour construction period is anticipated to be only necessary for the trenchless solutions, as once drilling has started it needs to be completed regardless of the time of day. Other construction works will be limited where practicable to weekday daytimes and Saturday mornings. As such, any necessary night time working will be minimised as far as reasonably practicable.

The majority of deliveries will be programmed to arrive during normal working hours only. Night-time deliveries will be minimal and will only be undertaken with special consideration. Care will be taken to minimise noise when unloading vehicles, and construction traffic will be prohibited from unnecessary idling within the site boundary or at the site access points.

Works will be phased to minimise effects on the surrounding environment and local communities by:

  • Scheduling construction activities to minimise the area and period of time that soil will be exposed, particularly during wetter periods;
  • Timing soil handling and overburden stripping to suit weather conditions;
  • Timing noise, vibration and dust producing activities to avoid key sensitive times most disturbing to the local residential and commercial properties; and
  • Scheduling works to minimise disruption to pastoral farming activities.

7.3. Construction Site Housekeeping

Good construction site housekeeping practice will be applied at all times. As far as reasonably practicable, the layout of the site will be designed using the following principles:

  • All work areas will be secured;
  • Any fuels or liquid materials will be stored and bunded in compliance with the relevant regulations;
  • Signage and boundary fences, where required, will be regularly inspected, repaired, and replaced as necessary;
  • All working areas will be kept in a clean and tidy condition;
  • Wheel washing and dust suppression facilities will be provided when and where required;
  • All practicable measures will be taken to minimise the risk of fire and the Principal Contractor will comply with the requirements of the local fire authority;
  • Waste will be removed at frequent intervals;
  • Construction waste susceptible to spreading by wind or liable to cause litter will be stored in secure containers;
  • The Principal Contractor shall take all necessary and practicable precautions to prevent the occurrence of smoke emissions or fumes from site plant or stored fuel oils for safety reasons and to prevent, as far as is reasonably practicable, such emissions or fumes drifting into residential areas, nearby workplaces, or areas of public open space. In particular:

–      Plant shall be well maintained, regularly serviced and measures taken to ensure that engines are not left running for long periods when not directly in use;

–      Plant which emits visible emissions after warm-up shall be taken out of service and either repaired or replaced; and

–      Vehicle exhausts will be directed away from the ground and other surfaces and preferably upwards to avoid road dust being re-suspended to the air and should be positioned at a sufficient height to ensure adequate local dispersal of emissions.

  • The Principal Contractor will ensure that all construction vehicles will conform to at least Euro 4 emissions standards;
  • Open fires will not be permitted on site; and
  • All works, at all phases of the Proposed Development, will be undertaken in accordance with SEPA Pollution Prevention Guidelines (PPG) and Guidance on Pollution Prevention (GPP) (which will ultimately replace PPGs). 

7.4. Pre-construction Enabling Works

Prior to any enabling or pre-construction works, no topsoil stripping will be undertaken without the written permission of ELC in consultation with the appropriate stakeholders.

All groundworks, clearing land and reprofiling will take into consideration the Guidance contained within SEPA’s Supporting Guidance (WAT-SG-75) Sector Specific Guidance: Construction Sites (February 2018), which provides guidance on the application of environmental standards and good management practice techniques in relation to large scale construction sites and pollution control.

7.5. Construction Compound

Temporary site infrastructure is expected to consist of, but not be limited to, boundary fencing, security lighting, temporary construction site facilities (welfare cabins, stores, skips, etc.), and storage for Control of Substances Hazardous to Health (COSHH) substances. Power for the temporary facilities during the construction phase will comprise temporary connection to the local grid and mobile diesel generator. The type and exact location will be selected by the Principal Contractor and confirmed in a later revision to this document.

The Construction Compounds will meet standard good management practices which include but are not limited to:

  • Compound design and layout will align with standards for distances from watercourses;
  • Appropriate temporary drainage and settlement ponds to manage anticipated surface water run-off from the compound area;
  • Bunds will be used where required to meet the requirements of the SEPA PPGs and oil storage regulations;
  • Adequate parking will be provided to ensure that the safety and efficient operation of the public highway is not reduced;
  • Welfare facilities will be provided to minimise the need for offsite trips by staff during the working day;
  • Compound design and layout will ensure that dust emission sources are located away from sensitive receptors; and
  • If compound lighting is required, it will be designed to minimise light pollution to the surrounding area.

7.6. Welfare Facilities

Workers’ Safety Information Sheets and COSHH safety data sheets will be kept on site.

Where portable generators are used, industry good practice will be followed to minimise noise and pollution from such generators.

Prior to construction, the Principal Contractor will prepare the arrangements for welfare provision and will be responsible for the maintenance of the facilities throughout the construction of the Proposed Development. The nature and scale of facilities required will be in proportion to the size and location of the Proposed Development. Facilities will include:

  • Toilets;
  • Washing facilities;
  • Changing rooms, drying rooms and lockers; and
  • Canteen and kitchen facilities.

All foul waste will be disposed of by an appropriate contractor to a suitably licenced facility. It is expected that a suitably sized storage tank will be provided and will be periodically pumped out by a specialist contractor so that the water could be disposed of at a suitably licenced waste facility.

The risk of infestation by pests or vermin will be minimised by the appropriate collection, storage and regular collection of waste, the prompt treatment of any pest infestation and effective preventative pest control measures.

Wastewater facilities will be arranged with appropriate sewerage provisions included within these facilities and all necessary consents obtained from ELC and SEPA.

7.7. Artificial Lighting

At night and during periods of darkness, directional security lighting will be used. Lighting will be selected and sited to minimise visual intrusion to local communities, residences, and environmental receptors, whilst maintaining the safe and efficient operation of the Proposed Development.

The Principal Contractor will comply with the requirements of the Environmental Protection Act (UK Government, 1990). As well as implementing relevant measures set out in the Guidance Notes for the Reduction of Obtrusive Light GN01:2011 (Institute of Lighting Professions, 2011). Measures to reduce the impacts of artificial lighting include:

  • Unnecessary lighting will be avoided and, following completion of the task, lighting will be switched off and/or removed. All lighting will be switched off during daylight hours;
  • All lighting will be designed to avoid visual intrusion and/or light spillage. Lighting will be positioned and directed to avoid nuisance to residents and wildlife and/or causing distractions to drivers on adjacent roads. Lighting will also avoid spillage onto neighbouring habitats; and
  • Where mobile lighting relies on portable diesel generators for power, the containment of the diesel will be monitored to check for leaks and spills. Spill kits will be made available, and staff provided with appropriate training on their use.

7.8. Storage of Plant and Materials

Fuel, equipment, and construction materials will be stored appropriately so as to minimise the risk of pollution. The following measures will be implemented to prevent spillage of hazardous materials:

  • Development of a Spill Response Plan and provision and maintenance of spill response equipment.
  • Storage of hazardous materials no less than 20 m away from a watercourses/drainage gully.
  • Completion of a COSHH assessment for hazardous materials.
  • Development of a COSHH Register documenting materials stored and handling requirements.
  • Segregation of COSHH raw material stores and COSHH waste stores.
  • Storage of hazardous material containers on secondary containment systems that will contain 110% of the contents of the largest container or 25% of the total, whichever is greater.
  • Protection of hazardous materials in locked containers to minimise the ingress of rainwater and secure them against accidental damage.
  • Staff training in the use of spill kits and the correct disposal of used material.
  • Maintenance of a log of any incidents; and
  • Inspection of all construction plant and machinery on a daily basis to check for fuel and oil leaks and, where necessary, drip trays or plant nappies will be used to collect leaks.

7.9. Wheel Washing

The Principal Contractor will implement a wheel washing system (with rumble grids to dislodge accumulated dust and mud prior to leaving the site where reasonably practicable) to reduce debris on the public road network. The Principal Contactor will ensure there is an adequate area of hard surfaced road between the wheel wash facility and the site exit, wherever site size and layout permits.

7.10. Parking

Parking for construction workers, deliveries and site visitors will be accommodated within the Proposed Development site and will not impact on the public road network.

7.11. Site Demobilisation

After the main construction activities have been finalised, permanent fencing will be installed where necessary, temporary infrastructure will be removed, and temporary compounds will be restored to previous land use.