Introduction
Best practice in Environmental Impact Assessments (EIA) recommends the use of a Schedule of Environmental Commitments, which can act as a quick reference for anyone interested in the mitigation measures to which the Applicant has committed to implementing and upon which the assessment of residual effects presented within the EIA Report has been based. It will be utilised by the Applicant throughout development of the detailed design, and the appointed contractors will be required to allow for, and ultimately implement, each of the measures in this schedule as a minimum.
Table 15.1.1 presents a Schedule of Environmental Commitments for the Proposed Development, listed according to the relevant environmental topic area. Individual EIA Report chapters should be referred to for full details of the mitigation.
As detailed in Volume 1, Chapter 2, mitigation is classified into three types, as per IEMA’s Guidance (2016):
- Primary – inherent mitigation which is part of the proposed development’s design;
- Secondary – foreseeable mitigation which requires further activity, identified through the EIA process, e.g. implementation of traffic management measures or planning conditions; and
- Tertiary – inexorable mitigation which will be implemented regardless of the design process and the EIA, e.g. contractor standard industry practices which manage potential nuisance activities or compliance with statutory requirements.
Table 15.1.1 Schedule of Environmental Commitments
Mitigation Category |
Environmental Commitment |
Implementation Phase |
---|---|---|
General |
||
Primary |
Trenchless technology (e.g., horizontal directional drilling (HDD)) will be utilised at the following sections along the cable route to avoid impacts on sensitive receptors:
|
Design |
Primary |
A cable bridge crossing will cross over the Braidwood Burn, the final solution and detailed design of the crossing will be confirmed and agreed with Scottish Environment Protection Agency (SEPA). |
Design, Pre-Construction |
Secondary |
Details of the final design of all components of the substation are proposed to be agreed with ELC following award of planning permission. |
Design |
Tertiary |
The final solution and detailed design for all water crossings will be addressed through an appropriately worded condition in order to ensure that the works comply with the Water Environment (Controlled Activities) (Scotland) Regulations 2011 (also known as the Controlled Activities Regulations (CAR)). |
Design |
Tertiary |
The onshore substation welfare facilities will be connected to a filtration system for foul drainage, which will be maintained by a licensed contractor and the contents disposed of at a licensed off-site location. |
Operation |
Tertiary |
The Applicant will produce a Construction Environmental Management Plan (CEMP), which will include measures to avoid, reduce or offset environmental effects of the construction works, and will include the following:
|
Construction |
Tertiary |
A Proposed Development Communication Plan will:
|
Pre-construction and Construction |
Tertiary |
Trenchless technology along the route will be in operation for 24 hours a day, with the exception of at the Scheduled Monument. Normal construction hours for all other construction activities will be Monday to Sunday 07.00-19.00; any exceptions to this will be agreed in advance with ELC. |
Construction and Decommissioning |
Tertiary |
A Decommissioning Plan will be in place in the event of permanent cessation of the installed infrastructure. |
Decommissioning |
Landscape and Visual |
||
Primary |
The site selection process considered constraints relating to physical landscape elements (including woodland, trees and hedgerows), landscape character and visual amenity, together with other environmental and technical constraints. The close proximity of existing industrial development and land uses, combined with existing electricity generation and distribution sites, provide a context of electrical infrastructure within the immediate setting of the Proposed Development. This context was considered during the site selection process. |
Design |
Primary |
The siting of the substation, landfall(s), access tracks and cable route has been selected with the sensitivity of landscape and visual resources in mind to help avoid or reduce the potential impacts. |
Design |
Primary |
As far as reasonably practicable, hedgerow and tree loss will be reduced along the onshore cable corridor through careful siting of the works areas. |
Design |
Primary |
The specification and design of permanent security fencing at landfall Transitional Joint Bays shall be consistent with the coastal and agricultural setting, where possible, to reduce effects upon visual amenity in this location. |
Design |
Primary |
Colour and finish of onshore substation buildings specified during the detailed design process shall be consistent with the vernacular of large-scale agricultural buildings within the context of the site. |
Design |
Secondary |
To avoid or reduce landscape and visual effects for the onshore substation l andscape mitigation proposals would be developed in consultation with key stakeholders, including ELC, local landowners and Transport Scotland. The following outline principles are considered to be appropriate:
|
Design, Pre-construction & Construction |
Secondary |
Trees will be protected during the construction phase where appropriate. Reinstatement or replacement will occur of removed trees (where reasonably practicable) and sections of hedgerow. |
Construction |
Tertiary |
Restoration will occur of all temporary construction, material storage and laydown areas to reinstate ground cover and return to previous land-use, where practical. |
Construction |
Ecology and Ornithology |
||
Primary |
The onshore cabling will be installed alongside tracks and/or field margins wherever possible to minimise habitat loss and/or disturbance. |
Design |
Primary |
Proximity to watercourses has been avoided wherever possible. |
Design |
Primary |
Areas considered to be more sensitive in terms of protected habitats such as semi-natural woodland, wetland habitats, and coastal habitats have been avoided wherever possible. |
Design |
Primary |
Trenchless technology (e.g., Horizontal Directional Drilling (HDD)) is to be used to install sections of the onshore cable including at the landfall within Barns Ness Site of Special Scientific Interest (SSSI). This method is an alternative to open trenching techniques and will minimise habitat loss and/or disturbance. |
Design and Construction |
Primary |
Watercourse crossings will be designed to enable passage by mammals where reasonably practicable. |
Design and Construction |
Tertiary |
A suitably qualified Ecological Clerk of Works (ECoW) will be appointed. The ECoW will be present and oversee all construction activities as well providing toolbox talks to all site personnel with regards to priority species and habitats, as well as undertaking monitoring works and briefings to relevant staff and contractors as appropriate. |
Pre-construction and Construction |
Tertiary |
To protect habitats within Barns Ness SSSI, protective fencing and signage will be installed as necessary, under the supervision of the ECoW, to delineate the edge of the designated to Site and prevent movement of plant and personnel, or storage of materials, within the SSSI. |
Pre-Construction |
Tertiary |
A pre-construction survey for badger, otter and bats will be carried out. Preconstruction surveys will be undertaken in advance of works commencing on site. The ECoW will survey the footprint of works and an appropriate buffer to update the baseline survey results and identify any new ecological constraints. |
Pre-Construction |
Tertiary |
If there is a risk that works are likely to be within 10 m of stands of Invasive Non-Native Species (INNS), an INNS plan will be produced to prevent the spread of these species within and off the Site. The management plan will include suitable precautions to prevent spread of plant fragments/seeds including exclusion zones, biological control, on-site treatment or removal by an approved company that specialises in non-native species disposal. |
Pre-Construction |
Tertiary |
The ECoW will search for any bird nests ahead of the commencement of works scheduled to take place during the breeding bird season and where appropriate implement working buffers around active nests. |
Pre-Construction |
Tertiary |
The ECoW will supervise the clearance of any dense areas of scrub, bracken and ruderal vegetation to ensure that any badger setts or otter resting sites (where clearance works are along watercourses) are identified and protected. |
Pre-Construction and Construction |
Tertiary |
A Species Protection Plan (SPP) will be produced as part of the CEMP. The SPP will detail measures to safeguard protected species known to be in the area and will include for pre-construction surveys for protected species as well as ensuring the use of best practice measures during all construction activities. The SPP will describe the process to be followed in the case that new protected species are recorded on site that will therefore also need to be protected during construction works, as well ensuring the implementation of effective toolbox talks to raise awareness of site personnel to sensitive ecological receptors on site. |
Pre-construction and Construction |
Tertiary |
Best practice techniques to prevent pollution of watercourses within the site will be employed. These may include use of buffer strips, infiltration trenches, settlement swales or lagoons. |
Pre-construction and Construction |
Tertiary |
To prevent great crested newts moving into the works area, barrier fencing will be installed in advance of works commencing on the site, where works are required within 500m of a confirmed breeding pond. |
Pre-Construction and Construction |
Tertiary |
Opportunities for biodiversity enhancements, such as planning species-rich hedgerows and establish and manage species-rich grasslands, within the site will be identified. |
Design |
Tertiary |
A proposed planting scheme, as part of a Habitat Management Plan (HMP) will be implemented on the completion of construction at the site. The planting will involve the creation of native grassland, hedgerow and woodland habitats and will be used to screen the margins of the A1 trunk road and surround the onshore substation. |
Post-Construction |
Tertiary |
Protection of breeding bird nests from damage and/or destruction during the breeding season in accordance with the Wildlife and Countryside Act 1981 (as amended by the Nature Conservation (Scotland) Act 2004). Wherever reasonably practicable, all vegetation clearance will occur outside the bird breeding season (i.e. between September – mid-March, inclusive), to avoid damage to or destruction of active nests by the proposed works. If work is required after the mid (15th) March, the ECoW will search areas of clearance in advance of works and recommend a buffer around active nests as appropriate. This would include any areas of clearance and vegetation removal for access tracks, compounds or onshore substation areas due to the populations of ground nesting birds on and around the site. |
Construction |
Noise |
||
Primary |
Quieter equipment will be selected where reasonably practicable. |
Design |
Primary |
Equipment will be located to take advantage of screening inherent in the design, i.e. from the substation hall(s) or control room buildings where reasonably practicable. |
Design |
Secondary |
Based on noise modelling results, where noise has the potential to cause disturbance the use of mufflers, acoustic barriers and screening will be considered. |
Construction and Decommissioning |
Secondary |
Measures will be adopted within the CEMP to ensure that the potential for disturbance from construction activities is minimised. The mitigation measures will include the provision of localised noise barriers to specific items of construction plant and/or the boundary of compounds where necessary. |
Construction |
Secondary |
Operational noise from the onshore substation will be limited to a noise rating level of no greater than 5dB above the representative background. During detailed design of the onshore substation, mitigation strategies, such as the use of landscaped bunds, equipment selection to reduce/eliminate tonality, provision of barriers and/or enclosures and to reduce overall noise level of each contributing item of equipment, will be developed to ensure the operational noise commitment will be met. |
Operation |
Tertiary |
The construction and decommissioning works would use Best Practicable Means (BPM) to limit the impacts of noise at sensitive receptors. |
Construction and Decommissioning |
Tertiary |
Acoustic enclosures and barriers will be installed. |
Construction |
Tertiary |
Exhausts/outlets for air handling/cooling units will be silenced. |
Operation |
Tertiary |
Noise related complaints will be monitored. |
Construction and Operation |
Air Quality |
||
Tertiary |
A Dust and Air Quality Management Plan will be included within the CEMP and will include best practice measures in accordance with the Institute of Air Quality Management (IAQM) recommended guidance. |
Pre-construction and Construction |
Tertiary |
The Contractor will, in line with the Proposed Development Communication Plan:
|
Construction |
Tertiary |
The Contractor will undertake air quality monitoring by:
|
Construction |
Tertiary |
Measures to prepare and maintain the site will be detailed within the CEMP and may include:
|
Pre-construction and Construction |
Tertiary |
Site operations will:
|
Construction |
Tertiary |
The Contractor will:
|
Construction |
Cultural Heritage |
||
Primary |
Landscaping mitigation will take account of the settings of designated heritage assets. |
Design |
Primary |
Avoidance of Scheduled Monuments by design where possible, including a buffer of at least 10 m. Fencing off, of designated extents of Scheduled Monument to ensure no risk of accidental damage to the scheduled monuments during construction works. |
Design, Pre-Construction and Construction |
Secondary |
Set piece excavations may be required where heritage assets (including buried archaeological remains) cannot be avoided. |
Construction |
Secondary |
Watching briefs/archaeological monitoring may be required in archaeologically sensitive areas during topsoil stripping and construction works as required under planning conditions. |
Construction |
Tertiary |
Trial trench evaluation at areas of archaeological sensitivity, as identified through the results of geophysical surveys, will be undertaken. |
Pre-construction |
Tertiary |
A Written Scheme of Investigation (WSI) will be included in the CEMP laying out the scope of archaeological works, the scope of which will be agreed in advance prepared in consultation with ELCAS. |
Pre-Construction and Construction |
Tertiary |
A professionally qualified archaeological contractor would be appointed to act as an Archaeological Clerk of Works (ACoW) during construction phase. |
Pre-Construction and Construction |
Tertiary |
Scheduled Monument Consent (SMC) will be sought to enable trenchless technology (e.g., HDD) beneath the Castledene Enclosure (SM 5849). |
Pre-Construction |
Tertiary |
Construction phase archaeological guidelines will be provided to the Principal Contractor for dissemination to all construction contractors, advising on the need to avoid adverse effects on buried archaeological remains and to inform the ACoW if any suspected archaeological remains are uncovered. |
Construction |
Tertiary |
Fencing off/marking out areas of constraint, including the designated extent of Scheduled Monuments, for avoidance during the construction phase would be carried out, where there are upstanding earthwork remains that require preservation. |
Construction |
Tertiary |
Post-excavation analysis and reporting of any new discoveries made during set piece excavations or archaeological monitoring would be carried out to the satisfaction of ELCAS and in compliance with any planning conditions. |
Construction |
Geology, Hydrology, Soil & Flood Risk |
||
Primary |
Where practicable a 50m buffer will be implemented around all watercourses considered to have continuous flow throughout the year. Where it is not possible to maintain a 50m buffer i.e. where a watercourse will require to be crossed, these works will be regulated under the Controlled Activities Regulations (CAR) licensing regime and necessary licences will be sought from SEPA prior to construction works. |
Design |
Tertiary |
The draft CEMP will include a detailed drainage strategy and pollution prevention plan which will be implemented in accordance with the SEPA’s guidance. This is anticipated to include, but is not limited to:
|
Pre-construction and Construction |
Tertiary |
A Water Quality Monitoring Programme will be implemented before and during construction to record the pre-existing water conditions and ensure that no deterioration occurs during construction. |
Pre-construction and Construction |
Tertiary |
The CEMP will contain a Soils Management Plan which will include, but not be limited to, the following measures:
|
Pre-construction and Construction |
Tertiary |
Preparation of a surface water drainage strategy to include appropriate SuDS measures to manage surface water runoff from the permanent infrastructure. |
Operation |
Tertiary |
Preparation of a foul water drainage strategy to safely manage foul water arisings from the operational development. |
Operation |
Traffic and Transport |
||
Primary |
The site entrances will be designed and constructed in accordance with ELC and Tr ansport Sc otland (TS) design guidelines. |
Design and Construction |
Primary |
Trenchless technology ( e.g., HDD) will be utilised for cabling under the East Coast Main Line (ECML) and A1. This will ensure that there is no adverse impact on the ECML or A1 as a result of cabling activities. |
Design and Construction |
Tertiary |
A Construction Traffic Management and Routeing Plan (CTMRP) will be developed and implemented during the construction phase. The CTMRP would be agreed with ELC prior to construction works commencing. Measures will be adopted to ensure that construction traffic associated with the Proposed Development is efficiently managed. These will likely include:
|
Pre-Construction and Construction |
Tertiary |
An Abnormal Load Transport Management Plan (ALTMP) will be developed and implemented during the construction phase. The ALTMP would be agreed with ELC prior to construction works commencing. |
Pre-Construction and Construction |
Tertiary |
A Core Path Management Plan (CPMP) will be developed and implemented during the construction phase. The CPMP would be agreed with ELC prior to construction works commencing. |
Pre-Construction and Construction |
Tertiary |
The Applicant proposes to enter into a Section 96 agreement to cover wear and tear on the public road deemed to have occurred as a result of the Proposed Development. This would be informed by pre-construction and post-construction condition surveys. Any repair works would be undertaken at the Applicant’s expense, rather than by the local authorities. There would be a regular road review and any debris and mud would be removed from the carriageway using an onsite road sweeper to ensure road safety for all road users |
Pre-construction and Construction |
Tertiary |
The hours of construction will be managed to mitigate the impact on sensitive receptors, with the construction access route chosen to minimise the impact on residential properties adjacent to the route, as far as possible. |
Construction |
Socio-economics |
||
Tertiary |
A Supply Chain Engagement Plan setting out initiatives to enhance opportunities for procurement from Local and Scottish suppliers and to drive the investment in new facilities will be implemented. |
Pre-Construction |
Tertiary |
A Local Recruitment Plan will be implemented setting out initiatives to ensure Local residents are aware of and given opportunity to access employment opportunities. This will include a Local Skills Plan setting out opportunities and actions for engagement to enable Local residents and training providers to prepare for anticipated employment opportunities. |
Pre-Construction and Construction |
Tertiary |
A Berwick Bank Community Benefit Fund would be established in partnership with Local stakeholders. The details of the Community Benefit Fund would be established after a consent determination has been made for both offshore and onshore aspects of the Project. Ahead of establishing any formal Fund, the Project team are keen to support Local initiatives where possible and have invited Local stakeholders to discuss opportunities directly with the Project team. |
Pre-Construction and Construction |
Land Use, Tourism and Recreation |
||
Primary |
The building materials for the onshore substation will be of a colouring that are sympathetic to the surrounding landscape and aid in visually blending the buildings into the background and ensuring the Proposed Development is visually attractive. The height of the onshore substation and its location within the landscape mean the Proposed Development will minimise the disruption to view beyond the Site. |
Design |
Primary |
The footprint of the Proposed Development has been refined and minimised through the design work to date to ensure that temporary and permanent direct impacts on land use are minimised. |
Design |
Primary |
It is proposed that trenchless techniques (i.e. HDD) will be used to install the cables at landfall to minimise the impact on coastal habitats and the John Muir Link Path. |
Design |
Tertiary |
An Access Management Plan will be developed in consultation with ELC and be included within the CEMP. It will include measures to minimise temporary disruption to pedestrian access and include requirements for signage |
Pre-construction and Construction |
Tertiary |
The Applicant will consult with local tourism receptors, so they are aware of timing and duration to construction works in the area. The Applicant will work with ELC to promote other attractions and areas for recreation to visitors. This will minimise public use of recreational/tourist areas within the vicinity of the site during construction. |
Pre-Construction and Construction |
Tertiary |
Temporary screening will be erected at localised locations and specific items of construction plant during construction to minimise disruption from construction activities. |
Pre-Construction and Construction |
Tertiary |
Agricultural land not required through the operational phase will be reinstated to ensure it can return to agricultural use. |
Operation |
EMF |
||
Primary |
The cables will be insulated, installed within sheaths, and primarily buried underground, offering screening to EMFs. |
Design |
Tertiary |
A perimeter fence will be erected around the substation which will offer screening to EMFs generated by the equipment within the substation. |
Design |
Tertiary |
Construction and operation of the Proposed Development would be in compliance with The Control of Electronic Fields at Work Regulations (2016). |
Construction and Operation |