8.8. Scoping Questions to Consultees

• Do consultees agree with the receptors and impacts scoped out of the EIA?
• Do consultees agree with the proposed ecological and ornithological survey scope and methodology?
• Are there any developments or infrastructure schemes which should be taken into account when considering potential cumulative ecological impacts?
  9.              References

  References

• Bibby CJ, Burgess ND, Hill DA, Mustoe S and Lambton S (2000). Bird Census Techniques. Academic Press, London
• Chanin P (2003). Monitoring the Otter Lutra lutra. Conserving Natura 2000 Rivers Monitoring Series No. 10. English Nature, Peterborough
• CIEEM (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater, Coastal and Marine. Chartered Institute of Ecology and Environmental Management, Winchester
• Collins, J (ed.) (2016). Bat Surveys for Professional Ecologists: Good Practice Guidelines (3rd ed.). The Bat Conservation Trust, London
• East Lothian Biodiversity Partnership (2008). East Lothian Biodiversity Action Plan 2008-13. August 2008. Available at: https://www.eastlothian.gov.uk/download/meetings/id/8894/20208_east_lothian_biodiversity_action_plan_2008-13 Note that a more recent document is not publicly available
• Eaton MA, Aebischer NJ, Brown AF, Hearn RD, Lock L, Musgrove AJ, Noble DG, Stroud DA and Gregory RD (2015). Birds of Conservation Concern 4: the population status of birds in the United Kingdom, Channel Islands and Isle of Man. British Birds 108, 708–746. Available at: https://www.britishbirds.co.uk/wp-content/uploads/2014/07/BoCC4.pdf
• Google (2020). Google Maps. Available online at: https://www.google.com/maps
• Grellier, K., and C. Lacey. (2012). Analysis of The Crown Estate Aerial Survey Data for Marine Mammals for the FTOWDG Region. SMRULSGW-2012-015. Unpublished report to The FTOWDG.
• Gilbert G, Gibbons DW and Evans J (1998). Bird Monitoring Methods: A Manual of Techniques for Key UK Species. RSPB, Sandy
• JNCC (2010). Handbook for Phase 1 Habitat Survey - a technique for environmental audit. Revised re-print. Joint Nature Conservation Committee, Peterborough
• Rodwell JS (2006). National Vegetation Classification Users’ Handbook. 2012 reprint edition. Joint Nature Conservation Committee, Peterborough
• Rodwell JS (ed.) (1991 et seq.). British Plant Communities. 5 volumes: Vol. 1 (1991) -  Woodlands and Scrub; Vol. 2 (1991) - Mires and Heaths; Vol. 3 (1992) - Grasslands and Montane Communities; Vol. 4 (1995) - Aquatic Communities, Swamps and Tallherb Fens; Vol. 5 (2000) - Maritime Cliffs, Sand Dunes, Saltmarshes and Other Vegetation. Cambridge University Press, Cambridge
• Scottish Badgers (2018). Surveying for Badgers Good Practice Guidelines Version 1: 2018. Available at: https://www.scottishbadgers.org.uk/userfiles/file/planning_guidelines/Surveying-for-Badgers-Good-Practice-Guidelines_V1.pdf 
• Scottish Government (2013). Scottish Biodiversity List. Version 1.5. Available at: https://www.webarchive.org.uk/wayback/archive/20160402063428mp_/http://www.gov.scot/Resource/0041/00419456.xls.
• Scottish Natural Heritage (2020). SiteLink. Available online at: https://sitelink.nature.scot/map
• SEPA (2017). Land Use Planning System SEPA Guidance Note 31: Guidance on Assessing the Impacts of Development Proposals on Groundwater Abstractions and Groundwater Dependent Terrestrial Ecosystems. Scottish Environment protection Agency, September 2017. Available at: https://www.sepa.org.uk/media/144266/lups-gu31-guidance-on-assessing-the-impacts-of-development-proposals-on-groundwater-abstractions-and-groundwater-dependent-terrestrial-ecosystems.pdf.
• Sparling, C. (2012). Seagreen Firth of Forth Round 3 Zone Marine Mammal Surveys. Report number SMRUL-ROY-2012-006 to Royal Haskoning and Seagreen Wind Energy Ltd, March, 2012.
• Strachan R, Moorhouse T and Gelling M (2011). Water Vole Conservation Handbook, 3rd edition. The Wildlife Conservation Research Unit.

9. NOISE
   1.              Introduction

   Introduction

NOISE Introduction

This chapter of the Scoping Report considers the potential noise and vibration effects from the Proposed Development. The potential for likely significant effects is limited to noise emissions from the construction and operation of the onshore substation, construction works at the landfall(s), access tracks and along the indicative temporary works area of the cable. Decommissioning impacts are anticipated to be similar to construction impacts. The assessment will be undertaken in accordance with the guidance contained within Technical Advice Note 1:2011 Assessment of Noise.

9.2. Study Area

For construction and decommissioning, the study area for the onshore substation will be a 2 km buffer around the Search Area for the Site Boundary. Significant noise and vibration effects are not expected beyond this distance. For construction vibration the study area will be a buffer of up to 100 m from any construction activity.

For operation the study area will encompass a 2 km area around the substation and associated permanent surface infrastructure.

The study areas have been developed to reflect people’s increased sensitivity to noise at night, where night-time noise effects from construction and operation are possible.

The study area distances are shown in Figure 9.1 The study area will be reviewed and amended in the EIAR as the onshore cable route is refined and substation site selected.

9.3. Baseline Environment

A desk-based study has been undertaken to provide an initial understanding of the baseline environment, using online data sources, such as Google imagery (Google, 2020).

The baseline environment within the study area is mainly rural with occasional residential properties and industrial sites. Noise in this area is likely to be dominated by road traffic on the A1 trunk road and rail traffic on the ECML railway, with some noise from nearby industrial sites including Torness Nuclear Power Station, Dunbar Cement Works and the landfill site and open cast mine to the north-west of Skateraw.

9.3.1.         Baseline Methodology

A desk-based review and consultation will be undertaken to identify potentially sensitive receptors. Background noise monitoring will be undertaken at residential properties where the potential for significant noise effects from the onshore substation is identified, and where needed to inform the construction assessment. Any surveys will be agreed in continuous consultation with ELC throughout the EIA process and will be carried out for a sufficient period to allow typical sound levels to be established, taking account of different types of noise sources and weather conditions that occur. Noise surveys may be accompanied by the acquisition of supplementary non-acoustic data (rainfall and wind records), as required.

The following data sources will be used in the EIA:

• Ordnance Survey mapping;
• Topographical data;
• On-site noise monitoring data;
• Traffic data;
• Construction data;
• DWG/DFX drawings;
• Noise modelling and propagation calculations; and
• Consultation with all relevant local authorities.

A baseline survey will be necessary to quantify existing noise levels at sensitive receptor locations close to potential noise generating activities associated with the Proposed Development:

• Landfall(s) and transition pits;
• cable route;
• access tracks; and
• substation.

Baseline survey measurements will be conducted in accordance with current guidance, including BS4142:2014+A1:20198 Method for Rating and Assessing Industrial and Commercial Sound, and BS 7445-2:1991 Description and measurement of environmental noise.

9.4. Tertiary Mitigation

As part of the Proposed Development design process, designed-in measures have been proposed to reduce the potential for impacts on noise and vibration. The embedded mitigation measures will evolve over the development process as the EIA progresses and in response to consultation.

9.4.1.         Construction and Decommissioning Phases Mitigation

Core working hours for the construction of the onshore elements of the Proposed Development are Monday to Sunday 07.00 – 19.00 hour.

Activities carried out during mobilisation and maintenance will not generate significant noise levels (such as piling, or other such noisy activities).

In certain circumstances, specific works may have to be undertaken outside the normal working hours and will be agreed in advance with ELC - such as:

• trenchless technology which may require 24-hour machinery operation, dependent on the ground conditions;
• remedial works, for example in the event of severe weather;
• delivery of electrical infrastructure;
• jointing operations along the cable route; and
• security of sites and protection of open assets.

Based on noise modelling results, where noise has the potential to cause disturbance the use of mufflers, acoustic barriers and screening will be considered.

The construction and decommissioning works would use Best Practicable Means (BPM) to limit the impacts of noise at sensitive receptors. Those measures would be set out in the CEMP.

Monitoring of noise related complaints should also be undertaken.

9.4.2.         Operation Phase Mitigation

Operational mitigation measures to be considered as part of the Proposed Development would involve:

• selection of quieter equipment where reasonably practicable;
• installation of acoustic enclosures;
• installation of acoustic barriers;
• screening substation further by the construction of a landform/embankment around the site may also provide up to 10dB attenuation;
• silencing of exhausts/outlets for air handling/cooling units;
• locating equipment to take advantage of screening inherent in the design, i.e. from the substation hall(s) or control room buildings where reasonably practicable; and
• monitoring of noise related complaints.

Potential impacts caused by noise barriers, enclosures or embankments on landscape and visual or ecology receptors will be considered in Chapters 7 and 8, respectively.

9.5. Potential Proposed Development Impacts

The assessment will consider the impacts of noise and vibration from the Proposed Development’s construction, operational and decommissioning activities on identified sensitive receptors.

9.5.1.         Approach to Assessment

Noise and vibration issues associated with the construction of the Proposed Development would be assessed using the guidance contained in BS 5228:2009+A1:2014, which defines the accepted prediction methods and source data for various construction plant and activities.

Construction and decommissioning noise impacts would be based on the likely construction programme and associated activities, including, substation works, cable laying using open trench and trenchless techniques, construction traffic and access routes.

The type of vehicles and plant required for construction/decommissioning will be detailed and the main sources of noise from the Proposed Development will be identified. The assessment will consider ‘worst case’ receptors i.e. that within the Search Area for the Site Boundary the vehicles and plant are located at the closest possible point to a receptor.

The study area of the construction/decommissioning noise assessment would include the following geographic coverage:

• 2 km from the Search Area for the Site Boundary where significant activities could affect noise sensitive receptors (including Public Rights of Way (PRoW)); and
• traffic routes and routes subject to significant changes in traffic flows (and/or percentage HGV) associated with the construction of the project.

Potential noise disturbance at night or other unsocial hours (i.e. weekends and public holidays) will be addressed.

Operational impacts would include noise impacts associated with the substation. The guidance and methodology contained in BS 4142:2014+A1:2019 would be used to assess noise impacts arising from the substation.

9.5.2.         Potential Impacts during Construction

9.5.2.1.        Construction Activities and Noise Impacts

The potential temporary impacts of construction noise may arise from:

• activities carried out on the surface along the onshore cable route corridor (mainly earth moving and excavation);
• construction activities at the substation including any potential landscaping;
• trenchless techniques and/or pipe thrusting activities;
• cable laying and pulling activities along the onshore cable route and at the shoreline (including noise from cable laying vessels working close to the shore and construction of the landfall(s));
• heavy goods vehicles servicing the onshore cable corridors and onshore substation, delivering or removing materials (including spoil and fill) and plant; and
• vibration will only be considered as an issue where significant piling works are required.

These activities could temporarily increase the noise levels experienced at identified receptors throughout the study area.

BS5228:2009+A1:2014 Code of practice for noise and vibration control on construction and open sites details the “ABC method”, which specifies a construction noise limit based on the existing ambient noise level and for different periods of the day. Therefore, the EIAR will assess the predicted construction noise levels against noise limits derived from advice within Annex E of BS 5228.

9.5.2.2.          Construction Road Traffic and Noise Impacts

There is potential for road traffic associated with the construction phase to impact noise sensitive receptors.

This will be assessed following the methodology contained in Design Manual for Roads and Bridges (DMRB, 2020), Volume 11, Section 3, Chapter 7 (LA 111), an initial screening assessment will be undertaken to assess whether there would be any significant changes in traffic volumes and composition on surrounding local roads as a result of the Proposed Development. Any road links with a predicted increase in traffic volume of 25%, or a decrease of 20%, or significant changes in traffic composition will be identified. Such changes in traffic volume and composition would correspond to a 1dB(A) change in noise level at the relevant road link. A change in noise level of less than 1dB(A) is regarded as imperceptible and, therefore, of negligible significance. If there are no increases greater than 25% or a decrease of 20% or greater, or significant changes in traffic composition then the DMRB guidance indicates that no further assessment needs to be conducted.

Details of the road network study area for the construction phase traffic assessment will be provided by the traffic consultants as Annual Average Weekday Traffic (AAWT) 18hr flows, % Heavy Goods Vehicles (HGV) and speed data to gain an understanding of the noise climate both with and without the Proposed Development to determine any impacts from increased traffic.

For links where the thresholds are exceeded, the significance of any predicted change in noise level will then assessed in accordance with the criteria contained in the DMRB (2020).

9.5.2.3.        Construction Activities and Vibration Impacts

Ground-borne vibration can result from construction works and may lead to perceptible levels of vibration at nearby receptors, which at higher levels can cause annoyance to residents. In extreme cases, cosmetic or structural building damage can occur, however vibration levels have to be very high for this effect to be manifested and such cases are rare. High vibration levels generally arise from ‘heavy’ construction works such as piling, deep excavation (from a borrow pit for example), or dynamic ground compaction. The use of piling during the construction of the Proposed Development may be required and therefore will be assessed.

Consideration will be given to all potential sources of vibration associated with the construction phase particularly those in proximity to residential and other sensitive receptors.

Guidance on the human response to vibration in buildings is found in BS 6472-1:2008 Guide to evaluation of human exposure to vibration in buildings, Part 1, Vibration sources other than blasting. For construction vibration from sources other than blasting, the vibration level and effects will be adopted based on Table B-1 of BS 5228-2. These levels and effects are based on human perception of vibration in residential environments.

9.5.2.4.        Noise and Vibration Impacts to Ecological/Geological Receptors:

Noise and vibration during construction activities may cause disturbance to wildlife, including protected species and designated sites. Vibration impacts may cause disturbance to designated geological sites such as the Barns Ness Coast SSSI.

Predictions of noise and vibration at identified ecological and geological receptors will be undertaken and provided to geologists and ecologists undertaking the assessment of noise and vibration impacts on such receptors.

9.5.3.         Potential Impacts during Operation

There are unlikely to be any noise and vibration impacts relating to operational or maintenance vehicular traffic as visits will be limited in number. It is therefore proposed that noise impacts arising from maintenance vehicular traffic should be scoped out from further consideration within the EIA.

There is unlikely to be any operational noise and /or vibration impacts from the landfall, cable routes or access tracks and it is proposed that these will be scoped out of the EIA.

9.5.3.1.        Noise Impacts

Noise impacts during the operational phase are most likely to arise from the operation of equipment within the substation (e.g. reactors and transformers). Therefore, an assessment will be undertaken to determine the likely environmental and health impacts due to operational noise emissions on identified sensitive receptors.

Where there are noise sources such as fixed plant associated with industrial operations, these will be assessed using BS 4142:2014+A1:2019 guidance. The guidance describes a method of determining the level of noise of an industrial noise source and the existing background noise level.

Operational transformer and shunt reactor noise is typically constant, with a ‘low frequency hum’ occurring at harmonics of the supply frequency; usually 100Hz and 200Hz components are dominant. Transformers generally run continuously except for occasional maintenance and fault outages.

Department of Energy & Climate Change (2011); Overarching National Policy Statement for Energy (EN-1), The Stationery Office, London states that any distinctive tonal and low frequency characteristics of the noise should be identified. The Low Frequency Noise element will be considered as part of the operational assessment in accordance with relevant guidance.

9.5.3.2.        Vibration Impacts

Transformers and other electrical equipment vibrate at twice the power frequency i.e. 100Hz and associated harmonic frequencies e.g. 200Hz, 300Hz, however the effects are negligible and are countered by the use of industry standard mitigation techniques such as the use of vibration isolation pads to prevent transmission of ground borne vibration. Embedded mitigation in the form of anti-vibration mounts would be used at the operational substations, which is likely to result in a negligible source of ground borne vibration.

There are considered to be no other significant sources of vibration associated with the operational scheme and operational vibration impacts. It is therefore proposed that this impact should be scoped out from further consideration within the EIA.

9.5.4.         Potential Impacts during Decommissioning

No decision has been made regarding the final decommissioning policy for the Proposed Development, as it is recognised that industry best practice, rules and legislation change over time. It is likely that the substation equipment would be removed and reused or recycled. It is expected that the cables would be removed from ducts and recycled.

The detail and scope of the decommissioning works would be determined by the relevant legislation and guidance at the time of decommissioning and agreed with the regulator.

It is anticipated that the decommissioning impacts would be similar in nature to those of construction but would be more limited in geographical extent and timescale. Assessment of decommissioning works is, therefore, scoped out of further assessment.

9.6. Potential Cumulative Impacts

Cumulative impacts on onshore receptors due to the onshore and offshore infrastructure associated with the Project will be assessed in liaison with the offshore EIA team.

It is anticipated that, for schemes considered cumulatively, a construction noise and vibration assessment would be undertaken, in accordance with BS 5228:2009+A1:2014 Code of practice for noise and vibration control on construction and open sites (British Standards Institute 2014), to specify best-practice mitigation to reduce the impacts at nearby receptors.

Operational noise impacts, specifically of the substation, will be considered in conjunction with other potential proposed developments, subject to the location of the substation.

The cumulative assessment of impacts will be undertaken in accordance with the tiered approach detailed within Chapter 6.

9.7. Receptors and Impacts Scoped In and Out of Assessment

Table 9.1 below summarises the potential impacts proposed to be scoped in and out of the EIAR.

Table 9.1: Summary of Impacts Relating to Noise and Vibration Scoped In () and Scoped Out (x)

9.8. Scoping Questions for Consultees

• Do consultees agree that all potentially significant sources of noise and vibration from the Proposed Development activities have been identified?
• Do consultees agree that appropriate standards and methods of assessment are proposed based on the potential for noise impact?
• Do consultees agree with the proposed scope as per Table 9.1?
• Are there any developments or infrastructure schemes which should be taken into account when considering potential cumulative noise impacts?
  9.              References

  References

• Scottish Government (2011). Technical Advice Note (TAN) 1:2011 Assessment of Noise, available at https://www.gov.scot/publications/technical-advice-note-assessment-noise/pages/1/
• BSI, (2014). British Standards Institution [BS] 5228-1:2009+A1:2014 “Code of practice for noise and vibration control on construction and open sites – Part 1: Noise”. BSI, London
• BSI, (2014). British Standards Institution [BS] 5228-2: 2009+A1:2014 “Code of practice for noise and vibration control on construction and open sites – Part 2: Vibration”. BSI London
• BSI, (2019). British Standards Institution BS4142:2014+A1:2019 Methods for rating and assessing industrial and commercial sound. BSI, London.
• BSI (2003). British Standards Institution BS 7445-1:2003 - Description and measurement of environmental noise. Guide to quantities and procedures. BSI, London.
• Department for Transport (DfT) (2020). Design Manual for Roads and Bridges, Volume 11, Section 3, Part 7: Noise and Vibration. London (DfT)
• Department of Energy & Climate Change (DECC) (2011d). Overarching National Policy Statement for Energy (EN-1), Planning for New Energy Infrastructure, Presented to Parliament pursuant to Section 5 (9) of the Planning Act, 2008, The Stationery Office, London.

10. AIR QUALITY
    1.         Introduction

    Introduction

AIR QUALITY Introduction

This chapter considers the potential effects of the Proposed Development for local air quality at onshore sensitive human and ecological receptors. 

10.2. Study Area

The study area for scoping includes the following in accordance with the Institute of Air Quality Management (IAQM) guidance (Holman et al, 2014):

• ecologically sensitive receptors sensitive to dust within 50m of possible construction activities within the Search Area for the Site Boundary (Barns Ness SSSI, areas of Ancient Woodland (36803, 36802, and 36809)); and
• human receptors (residential properties and public amenity areas) within 350 m of possible construction activities within the Search Area for the Site Boundary (less than 100 high sensitivity residential properties within 350 m).

The study area encompasses areas of potential construction activities for all options of landfall location, cable routing and substation location and is shown in Figure 10.1

10.3. Baseline Environment

A desk-based study has been undertaken to provide an initial understanding of the baseline environment.

The following data have been used to inform the baseline air quality:

• ELC Air Quality Management Areas (AQMA) map (Air Quality in Scotland, 2020a);
• ELC Local Air Quality Management (LAQM) Annual Progress Report (APR) (ELC, 2019); and
• Scottish Government (Air Quality in Scotland, 2020b) and Department for Environment Food and Rural Affairs (DEFRA) background concentrations maps (DEFRA, 2020) for nitrogen dioxide (NO2) and particulate matter (PM10) and (PM2.5).

There is only one AQMA in ELC located within Musselburgh High Street approximately 36 km to the west of the study area. The Proposed Development will have no effect on air quality within the AQMA.

As part of their LAQM obligations, ELC undertake monitoring of air quality at a number of locations across the Local Authority area. There is one continuous roadside automatic monitoring station within Musselburgh High Street measuring concentrations of NO2 and PM10, and 25 non-automatic monitoring stations measuring NO2 concentrations using passive diffusion tubes (PDT). The closest monitoring site to the study area is an urban background (PDT) site in Haddington (Lyn Lea site T16 in APR) (ELC, 2019) with a measured 2018 annual mean NO2 concentration of 7µg/m3. This is significantly below the air quality standard (AQS) of 40µg/m3 (Air Quality in Scotland, 2020c), however none of the ELC monitoring sites are at locations representative of the sensitive receptors in the rural study area.

The baseline concentration for the study area has therefore been taken from the Scottish Government and DEFRA background concentration maps for the 1km x 1km grid squares that cover the study area. These are shown in Table 10.1.

Table 10.1: Baseline Concentrations in the Study Area 2020

The baseline NOx concentration is relevant for sensitive ecological receptors. The baseline annual mean NOx concentration at the Barns Ness SSSI is 5.1 µg/m3.  All background concentrations within the study area are significantly below the annual mean AQSs of 30µg/m3 for NOx, 40µg/m3 for NO2, 18µg/m3 for PM10 and 10µg/m3, for PM2.5.

10.4. Tertiary Mitigation

This section details the proposed construction phase mitigation to reduce the potential impacts of dust and air quality.

As detailed in Chapter 5, a CEMP will be prepared for the Proposed Development and will include a specific Dust and Air Quality Management Plan (or plans for individual activities/areas) to minimise the generation and potential impacts of dust emissions on receptors relevant for human health, amenity and ecology.

The Dust and Air Quality Management Plan within the CEMP will include best practice measures in accordance with the Institute of Air Quality Management IAQM recommended guidance (Holman et al, 2014) proportionate to the likely impacts. The main measures for dust management to be included are summarised below.

10.4.1.    Proposed Mitigation for Communications

As part of a wider Proposed Development communication plan:

• The Applicant will include community engagement before work commences on site.
• Display the name and contact details of person(s) accountable for air quality and dust issues on the site boundary.
• Display the head or regional office contact information.
• Proposed Mitigation for Site Management:
• Record all dust and air quality complaints, identify cause(s), take appropriate measures to reduce emissions in a timely manner, and record the measures taken.
• Make the complaints log available to ELC when asked.
• Record any exceptional incidents that cause dust and/or air emissions, either on- or off-site, and the action taken to resolve the situation in the logbook.
• Hold regular liaison meetings with any other high-risk construction sites within 500 m of the site boundary to ensure plans are co-ordinated and dust and particulate emissions are minimised with particular attention to off-site transport/deliveries which may use the same strategic road network routes.
  2.     Proposed Mitigation for Monitoring
• Carry out regular site inspections to monitor compliance with the Dust and Air Quality Management Plan, record inspection results, and make an inspection log available to ELC when asked.
• Increase frequency of site inspections by the person accountable for air quality and dust issues on site when activities with a high potential to produce dust are being carried out and during prolonged dry or windy conditions.
• Where possible commence baseline monitoring at least three months before work commences.
  3.     Proposed Mitigation for Preparing and Maintaining the Site
• Plan site layout so that machinery and dust causing activities are located away from receptors, as far as possible.
• Erect solid screens or barriers around dusty activities or the site boundary that are at least as high as any stockpiles on site.
• Fully enclose site or specific operations where there is a high potential for dust production and the site is active for an extensive period, e.g. fine-screen fencing or temporary construction tent.
• Avoid site runoff of water or mud.
• Keep site fencing, barriers and scaffolding clean using wet methods.
• Remove materials that have a potential to produce dust from site as soon as possible, unless being re-used on site.
• Cover, seed or fence stockpiles to prevent wind whipping.
  4.     Proposed Mitigation for Construction Site Operations
• Ensure all Non-Road Mobile Machinery (NRMM) is compliant with the engine emission regulations in place at the time of use on site.
• Only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust suppression techniques such as water sprays or local extraction, e.g. suitable local exhaust ventilation systems.
• Ensure an adequate water supply on the site for effective dust/particulate matter suppression/mitigation, using non-potable water where possible and appropriate.
• Use enclosed chutes and conveyors and covered skips.
• Minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling equipment and use fine water sprays on such equipment wherever appropriate.
• Ensure equipment is readily available on site to clean any dry spillages and clean up spillages as soon as reasonably practicable after the event, using wet cleaning methods.
  5.     Proposed Mitigation for Waste Management
• Avoid bonfires and burning of waste materials.
  6.     Operating Vehicle/Machinery and Sustainable Travel
• Ensure all vehicles switch off engines when stationary.
• Avoid the use of diesel- or petrol-powered generators and use mains electricity or battery powered equipment where practicable.
• Issue all suppliers and contractors with delivery routes and access times/restrictions.
  7.       Proposed Mitigation Specific to Earthworks
• Re-vegetate earthworks and exposed areas/soils stockpiles to stabilise surfaces as soon as practicable.
• Use hessian, mulches or trackifiers where it is not possible to re-vegetate or cover with topsoil, as soon as practicable.
• Only remove the cover in small areas during work and not all at once.
• Proposed Mitigation Specific to Construction Activities
• Avoid scabbling (roughening of concrete surfaces) if possible.
• Ensure sand and other aggregates are stored in bunded areas and are not allowed to dry out, unless this is required for a particular process, in which case ensure that appropriate control measures are in place.
• Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery.
• For smaller supplies of fine powder materials ensure bags are sealed after use and stored appropriately to prevent dust.
  8.     Proposed Mitigation Specific to Track-Out
• Use water-assisted dust sweeper(s) on the access and local roads, to remove, as necessary, any material tracked out of the site. This may require a sweeper being continuously in use.
• Avoid dry sweeping of large areas.
• Ensure vehicles entering and leaving sites are covered to prevent escape of materials during transport.
• Inspect on-site haul routes for integrity and instigate necessary repairs to the surface as soon as reasonably practicable.
• Record all inspections of haul routes and any subsequent action in a site logbook.
• Implement a wheel washing system (with rumble grids to dislodge accumulated dust and mud prior to leaving the site where reasonably practicable).
  5.         Potential Proposed Development Impacts
     1.     Potential Impacts during Construction

  Potential Proposed Development Impacts Potential Impacts during Construction

The potential impacts associated with the construction phase of the Proposed Development are the effects of:

• The generation of dust and particulates (e.g. from earth moving, open cut trenching or trenchless techniques, transport and storage of dry materials) potentially having an adverse (smothering) impact on dust sensitive ecological receptors, effects on human health and nuisance caused by dust soiling of surfaces at residential properties; and
• Exhaust emissions from construction traffic and NRMM (plant and equipment) having the potential to increase local ambient concentrations of NOx and particulate matter (PM10 and PM2.5) and impact human health.
  1.     Dust Impacts at Ecological Receptors

The only high sensitivity ecological receptor within 50 m of potential construction activities is the Barns Ness SSSI, if the Skateraw landfall option is selected.

The SSSI is designated for saltmarsh, sand dunes and shingle.  The onshore EIA ecologist was consulted and advised that areas below the mean high-water line are unlikely to be sensitive to dust deposition. It is considered unlikely that shingle bank communities and saltmarsh would be highly sensitive to dust soiling or smothering, however as a precautionary approach the areas above the high-water line within 50m of construction are classified as high sensitivity receptors.

There is potential for construction activity within 50 m of the SSSI which in accordance with the IAQM guidance (Holman et al, 2014), is considered to have a high sensitivity to dust deposition.  However, the main dust generating activity is around the substation construction which is greater than 50m away from the SSSI and therefore the magnitude of dust impacts is assessed to be low. Overall the potential effects are considered to be negligible with the implementation of the mitigation measures outlined in Section 10.4.

There is one SWT Reserve adjacent to the site boundary which is considered a low sensitivity receptor. The tertiary mitigation identified in Section 10.4 would ensure that the magnitude of dust impacts would be low, and therefore the potential effects are considered to be negligible.

There are three areas of ancient woodland (Ancient Woodland Inventory ID 36803, 36802 and 368029 as shown in Figure 10.1 inside or within 50 m of the Search Area for the Site Boundary where construction activities could potentially occur.  These are considered to be low sensitivity receptors with a low magnitude of dust impacts as they are greater than 50 m away from the main construction activity of a substation. Overall, the potential effects are considered to be negligible with the implementation of the mitigation measures outlined in Section 10.4.

It is considered that the best-practice measures included in the Dust and Air Quality Management Plan within the CEMP will provide the necessary prevention and mitigation of potential impacts such that the effects will be negligible at all ecological receptors within the study area.

It is therefore proposed that further assessment of air quality impacts at ecological receptors is scoped out of the EIA.

10.5.1.2.    Dust Soiling Impacts at Residential Properties

All residential properties are considered to be have a high sensitivity to dust deposition. The number of residential properties within the air quality study area in Figure 10.1 falls into the IAQM guidance band (Holman et al, 2014) of 10-100 properties within 50-350 m of all potential construction activities, resulting in an overall low sensitivity. Dust deposition impacts decline with distance from the site and it is therefore considered that the best-practice measures included in the Dust and Air Quality Management Plan within the CEMP will provide the necessary prevention and mitigation of potential impacts such that the effects will be negligible.

It is therefore proposed that further assessment of dust soiling impacts at residential receptors is scoped out of the EIA.

10.5.1.3.    Human Health Impacts at Residential Properties

In accordance with the IAQM guidance (EPUK & IAQM, 2017) the sensitivity of the area to human health impacts is considered to be low when there are <100 properties within 350 m of potential construction activities and the baseline PM10 concentration is less than 14µg/m3. The average baseline PM10 concentration across the study area is 9.7 µg/m3.

It is considered that the best-practice measures included in the Dust and Air Quality Management Plan within the CEMP will provide the necessary prevention and mitigation of dust emissions such that the emission magnitude is small, and the effects will be negligible.

It is therefore proposed that further assessment of human health impacts at residential receptors is scoped out of the EIA.

10.5.1.4.    Construction Phase Traffic Emissions

The construction phase of the Proposed Development is likely to lead to a temporary increase in the number of vehicles, including cars and Heavy Good Vehicles (HGVs), on the local highway network for the duration of the construction works only.

The IAQM guidance (EPUK & IAQM, 2017) criteria triggering the need for a detailed air quality impact assessment of traffic emissions outside of an AQMA are:

• A change in HGV flows greater than 100 Annual Average Daily Traffic (AADT) equivalent, and/or;
• A change in light duty vehicles (LDVs) of greater than 500 AADT equivalent.

The forecast traffic flows associated with the construction phase are anticipated to be less than the above criteria for all phase of construction.

The construction traffic routes to the Proposed Development will be clearly defined, avoiding high sensitivity receptors and will be strictly controlled by the Traffic and Transport Management Plan.

The effect of construction road traffic emissions upon local air quality at sensitive receptors will be not significant and it is therefore proposed that further assessment of construction phase road traffic emissions is scoped out of the EIA.

10.5.2.    Potential Impacts during Operation

It is considered unlikely that the operational phase of the Proposed Development will have any impacts on local air quality due to the minimum number of vehicle trips associates with the operation and maintenance of the Proposed Development. It is not expected that any dust will be generated following completion of the construction works. Therefore, operational impacts of the Proposed Development on air quality are scoped out of further assessment in the EIA.

10.5.3.    Potential Impacts during Decommissioning

It is recognised that industry best practice and legislation change over time and it is therefore not possible to confirm a decommissioning strategy at this time. It is likely that the substation equipment would be reused or recycled, and onshore cables would be removed from ducts or trenches and recycled with any ducts left in place.

A Decommissioning Management Plan would be developed and agreed with the regulator prior to commencement of decommissioning works. It is anticipated that the potential decommissioning impacts would be similar in scale and nature to those of the construction phase and controlled through the measures identified in Section 10.4. Therefore, decommissioning impacts of the Proposed Development on air quality are scoped out of further assessment in the EIA.