10.2 Maximum design scenarios
43 Assessments for all European sites considered in this Part of the RIAA (i.e. SACs) are based on a realistic maximum design scenario derived from the design envelope for the Proposed Development. The maximum design scenario for each of the potential impacts for each receptor group are tabulated separately in each of the receptor chapters according to the effect-pathway under consideration. An overview of the maximum design scenarios considered for the assessment of potential impacts on receptor groups considered in this Part of the RIAA has been provided in Table 10.1 Open ▸ .
44 The maximum design scenarios are consistent with those used for assessment in relevant chapters of the Offshore EIA Report.
10.3 Designed-in measures
45 As part of the project design process, a number of designed-in measures have been included in the Proposed Development and are committed to be delivered by the Applicant as part of the Proposed Development. These designed-in measures are integrated into the project description for the Proposed Development and are not considered as mitigation measures intended to specifically avoid or reduce effects on European sites.
46 Designed-in measures of relevance to the assessment of potential impacts are tabulated separately in each of the receptor sections, according to the effect-pathway under consideration. An overview of the designed-in measures of relevance for all receptor groups is provided in Table 10.2 Open ▸ .
47 Measures intended specifically to avoid or reduce effects on European sites were not considered during the HRA Stage One Screening but are included within the HRA Stage Two Appropriate Assessment for determination of Adverse Effects on Integrity. The RIAA will indicate whether adverse impacts on European sites are likely and if so, whether those effects can be avoided through the introduction of mitigation measures that avoid or reduce the impact. These measures are referred to as Secondary Mitigation and may be taken from topic chapters within the Offshore EIA Report or, where necessary, may have been developed specifically to comply with HRA requirements. Where the latter is the case, this is made clear throughout.
10.4 Baseline Information
48 Baseline information on the European sites (i.e. SACs for this Part of the RIAA) identified for further assessment within HRA Stage Two Appropriate Assessment has been gathered through a comprehensive desktop study of existing studies and datasets. The key data sources are summarised in each of the receptor group sections and presented in detail within topic chapters in the Offshore EIA Report. Any additional sources of information used in the HRA Stage Two Appropriate Assessment are also summarised.
49 For brevity, information on the SACs is summarised within the main body of this Part of the RIAA, however, detailed reference information (such as attributes and targets for the conservation objectives, citations, condition status and existing pressures) is presented in appendix A and referenced in the HRA Stage Two Appropriate Assessment as appropriate.
10.5 Conservation Objectives and Conservation Advice
50 The statutory nature conservation bodies (SNCBs) have produced conservation advice for European sites under their statutory remit. This conservation advice provides supplementary information on sites and features, and although the content provided is similar, the format of the advice provided varies between the different SNCBs.
51 Due to the location and scale of the Proposed Development, European sites with the potential to be impacted fall variously under the remit of NatureScot, Natural England and the JNCC. The Berwickshire and North Northumberland Coast SAC conservation advice has been jointly developed by NatureScot and Natural England but is hosted on NE’s Designated Site System as an interactive Conservation Advice Package (CAP). The Southern North Sea SAC CAP has been jointly developed by Natural England and the JNCC but is hosted on JNCC’s website in the form of a ‘Conservation Objectives and Advice on Operations’ document. The Tweed Estuary SAC is under Natural England’s remit and therefore conservation advice is hosted on Natural England’s Designated Site System.
52 For European sites under the statutory remit of NatureScot, CAP documents have been produced for all terrestrial SACs (note that many of the sites screened in for Annex II fish species are considered terrestrial), while Conservation and Management Advice documents (CMAs) cover marine SACs and marine SPAs. These documents contain revised and updated conservation objectives for the features of each site, site-specific clarifications and advice in order for the conservation objectives to be achieved, and advice on management required to achieve the conservation objectives.
53 Conservation objectives set the framework for establishing appropriate conservation measures for each feature of the site and provide a framework against which plans or projects can be assessed. The conservation objectives set out the essential elements needed to ensure that the favourable conservation status of a qualifying habitat or species is maintained or restored at a site. If all the conservation objectives are met, then the integrity of the site will be maintained.
54 Within the NatureScot CAPs and CMAs, the conservation objectives comprise overarching objectives (objectives 1 and 2) that apply to all features of the site, and additional objectives (2a, 2b and 2c) that have been written for each feature. Each objective includes site-specific supplementary advice.
55 In this Part of the RIAA, the Applicant has referenced the most up-to-date conservation objectives and conservation advice available, which for Scottish sites under the remit of NatureScot includes the ‘new style’ conservation objectives provided by NatureScot in CAPs/CMAs and the ‘European Sites Casework Guidance’ (currently being updated - July 2021[1]). New CAPs include revised conservation objectives, which are better targeted for each feature and include supplementary advice for each headline objective. They also include either ‘maintain’ or ‘restore’ objectives. In addition to the new feature-specific objectives, it is noted that there are overarching objectives for the whole site, with Objective 2 related to site integrity.
56 It is recognised that in the CAP documents, if any feature of the SAC is in unfavourable condition, the integrity of the site is deemed to be compromised and the overarching objective is therefore to restore site integrity. NatureScot guidance, however, states that with the ‘new style’ conservation objectives it is not expected that plans or projects must include measures that lead to restoration of features (where restore objectives are in place) in order to gain approval from a competent authority. Instead, a plan or project should not prevent site integrity from being able to be restored where necessary. This means that a plan or project should not prevent a feature from being able to be restored. HRAs should, therefore, focus on and consider if the plan or project is likely to undermine the conservation objectives of the site.
57 Where Supplementary Advice to the Conservation Objectives, or site-specific conservation advice describes minimum targets for qualifying features in more detail, this detail is provided in appendix A and/or referenced in the course of the HRA Stage Two Appropriate Assessment.
58 Where Ramsar interests coincide with qualifying features within an SAC, the advice for overlapping designations is considered to be, sufficient to support the management of the Ramsar interests. Therefore, the conservation objectives are referenced for both designations.
10.6 Approach to the In-Combination Assessments
59 The approach taken for the assessment of in-combination impacts has been informed by the cumulative effects assessment (CEA) carried out for relevant topics in the Offshore EIA Report. The CEA methodology is described in detail in volume I, chapter 6 of the Offshore EIA Report and summarised below.
60 The cumulative impacts of the Proposed Development in conjunction with other proposed plans or projects have been considered within each topic chapter of the Offshore EIA Report. Due to the range of receptors being assessed, the projects which are relevant to the in-combination assessments will be different for each receptor.
61 The Marine Scotland Consenting and Licensing Guidance: For Offshore Wind, Wave and Tidal Energy Applications (Scottish Government, 2018) states that ‘Engagement with MS-LOT is required to identify which plans/projects/ongoing activities should be included in the in-combination element of the cumulative effects assessment.’ The offshore wind projects in the Firth of Forth and Tay region have been considered, alongside other developments, including those which:
- became operational since baseline characterisation;
- are under construction;
- those with consent and submitted but not yet determined;
- those projects with a Scoping Report; and
- plans and projects which are “reasonably foreseeable” (i.e. developments that are being planned, including, for example, offshore renewable energy projects which have a Crown Estate Agreement for Lease (AfL), offshore renewable energy projects that have been scoped).
62 The in-combination assessment has considered all other relevant plans, projects and activities where detail to inform the assessment is publicly available three months prior to the Proposed Development application.
63 The in-combination assessment presents relevant in-combination impacts of projects according to a tiered approach. This approach provides a framework for placing relative weight upon the potential for each project/plan to be included in the in-combination assessment to ultimately be realised, based upon the project/plan’s current stage of maturity and certainty in the projects’ parameters. The approach utilised within the in-combination assessment comprises the following tiers:
- tier 1 - Proposed Development (Berwick Bank Wind Farm offshore) with Berwick Bank Wind Farm onshore;
- tier 2 – All plans/projects assessed under Tier 1, plus projects which became operational since baseline characterisation, those under construction, and those with consent and submitted but not yet determined;
- tier 3 – All plans/projects assessed under Tier 2, plus those projects with a Scoping Report; and
- tier 4 – All plans/projects assessed under Tier 3, which are reasonably foreseeable, plus those projects likely to come forward where an AfL has been granted.
- Berwick Bank Wind Farm onshore elements and Cambois connection;
- other offshore wind farms and associated cabling and infrastructure;
- oil and gas infrastructure/development (cables and pipelines);
- other forms of cabling (i.e. telecommunications and interlinks);
- beach replenishment schemes;
- navigation and shipping; and
- aggregate extraction and disposal of dredging spoil.
The Applicant is aware that on 4 July 2022, Inch Cape Offshore Limited applied to Scottish Ministers to vary its offshore consent to construct and operate Inch Cape Offshore Wind Farm[2]. The proposed variation(s) are at a very early stage in the development process. It was concluded in the supporting EIA and HRA screening report[3] that there are no new or materially different impacts arising from the variation compared to the initial proposal (ICOL revised design as consented). Given that this is the most current information available (as of October 2022), the Applicant has continued to assess the ICOL revised design (as consented).
Table 10.1: Maximum Design Scenario Considered for the Assessment of Potential Impacts on Receptor Groups Considered in the RIAA
Table 10.2: Designed-in Measures of Relevance to the Assessment of Potential Impacts on European Sites
11 Appraisal of Potential Adverse Effects on Integrity: Annex I Habitats
11.1 Introduction
65 The Screening exercise (at Stage One of the HRA process) as updated (see section 9) in response to consultation on the Berwick Bank Wind Farm Offshore HRA Screening Report (SSE Renewables, 2021b) (hereafter, the HRA Screening Report) identified LSEs (as defined in Part One of this RIAA) on the following European sites designated for Annex I habitat features (as summarised in Table 9.1 Open ▸ and illustrated in Figure 9.1 Open ▸ ):
- Berwickshire and North Northumberland Coast SAC.
66 This section explains the approach taken to assess the potential impacts of the Proposed Development on European sites designated for Annex I habitat features and presents the Stage Two assessments for the above site. Broadly, the potential effects on this site are as follows and are addressed explicitly in sections 11.2 to 11.4:
67 During the construction and decommissioning phases:
- Increased suspended sediment concentrations and associated sediment deposition (offshore export cable only): potential for adverse effects from sediment disturbance arising from offshore export cable installation, and seabed preparation works ahead of offshore export cable installation which may result in increases in SSCs and associated sediment deposition (i.e. smothering effects).
68 During the operation and maintenance phase:
- Increased suspended sediment concentrations and associated sediment deposition (offshore export cable only): potential for adverse effects from sediment disturbance arising from offshore export cable maintenance (i.e. cable reburial or replacement works) which may result in increases in SSCs and associated sediment deposition (i.e. smothering effects); and
- Alteration of seabed habitats arising from effects of physical processes: potential for the presence of foundation structures, associated scour protection and cable protection to introduce localised changes to the tidal flow and wave climate, resulting in potential changes to the sediment transport pathways and associated effects on Annex I habitats.
69 The Stage Two assessments (considering effects both alone and in-combination) for this site are presented in sections 11.2 to 11.4. Integrity matrices summarising the assessments for the site are provided in Table 15.1 in section 15. A summary of all Appropriate Assessments undertaken within this report is provided in the concluding section of this report (see section 14).
11.2 Assessment Information
11.2.1 Maximum Design Scenarios
70 The maximum design scenario relevant to Annex I habitat features are set out in Table 11.2 Open ▸ , Table 11.4 Open ▸ and Table 11.5 Open ▸ . An overview of the maximum design scenario for all receptor groups is provided in Table 10.1 Open ▸ in section 10 of this Part of the RIAA.
11.2.2 Designed-in Measures
71 Designed-in measures relevant to Annex I habitat features are set out in Table 11.3 Open ▸ . An overview of the designed-in measures for all receptor groups is provided in Table 10.2 Open ▸ in section 10 of this Part of the RIAA.
11.2.3 Baseline Information
72 The key data sources are presented within volume 2, chapter 8 of the Offshore EIA Report and summarised below. In addition, the following information has informed the assessments:
- volume 3, appendix 8.1: Benthic Subtidal and Intertidal Ecology Technical Report;
- volume 2, chapter 7: Physical Processes; and
- volume 3, appendix 7.1: Physical Processes Technical Report.
73 Detailed European site information is presented in appendix A.
11.2.4 Conservation Objectives
74 The Conservation objectives for the site designated for Annex I habitat features identified for Stage Two assessment are provided in section 11.5. Where Supplementary Advice to the conservation objectives, or site-specific conservation advice describes minimum targets for qualifying features in more detail, this detail is provided in appendix A and/or referenced within the relevant Stage Two Appropriate Assessments.
11.2.5 Annex I Habitat Accounts
75 The following sections provide overview accounts of the Annex I habitat features of the Berwickshire and North Northumberland Coast SAC.
Mudflats and sandflats not covered by seawater at low tide
76 Intertidal mudflats and sandflats are submerged at high tide and exposed at low tide. They form a major component of the Annex I habitat - estuaries and large shallow inlets and bays - in the UK. The physical structure of the intertidal flats ranges from mobile, coarse-sand beaches on wave exposed coasts, to stable, fine-sediment mudflats in estuaries and other marine inlets.
77 Within the Berwickshire and North Northumberland Coast SAC, stretches of the English coastline support this Annex I habitat with a very extensive range of intertidal mudflats and sandflats, ranging from wave exposed beaches to sheltered muddy flats with rich infaunal communities. These have been selected as biologically diverse and extensive examples of clean sandflats[5] on the east coast. Those in the Lindisfarne and Budle Bay area (to the south of the Proposed Development export cable corridor) and on the adjacent open coast flats north of Holy Island, are the most extensive in north-east England. The largest intertidal beds comprise narrow-leaved eelgrass Zostera angustifolia and dwarf eelgrass Zostera noltii, a diverse infauna, and some large beds of mussels Mytilus edulis. Some of the bays along the open coast have mobile sediments, with populations of sand-eels Ammodytes sp., small crustaceans and polychaete worms. These communities are important in supporting predator communities such as macrofauna, juvenile fish and overwintering and migrating wading birds. More sheltered sediments have very stable lower shore communities of burrowing heart-urchins Echinocardium cordatum and bivalve molluscs (English Nature and SNH, 2000).
Large shallow inlets and bays
78 Large shallow inlets and bays are habitat complexes which comprise an interdependent mosaic of subtidal and intertidal habitats. These habitats include two of the Annex I habitats of the Berwickshire and North Northumberland Coast SAC (mudflats and sandflats not covered by sea water at low tide and reefs). Large shallow inlets and bays are large indentations of the coast, generally more sheltered from wave action than the open coast. They are relatively shallow (with water less than 30 m over most of the area), and in contrast to the Annex I habitat estuaries, generally have much lower freshwater influence.
79 Within the Berwickshire and North Northumberland Coast SAC, there are several characteristic, sediment-dominated embayments in north-east England. These areas are relatively exposed, uniform in nature and are characterised by crustacean/polychaete and bivalve/polychaete biotopes (English Nature and SNH, 2000).
Reefs
80 Reefs are rocky marine habitats or biological concretions that rise from the seabed. They are generally subtidal but may extend as an unbroken transition into the intertidal zone, where they are exposed at low tide. There are two main types of reefs, rocky reefs where animal and plant communities develop on rock or stable boulders and cobbles, and biogenic reefs where the reef structure is created by the animals themselves (JNCC, 2022[6]).
81 Within the Berwickshire and North Northumberland Coast SAC, moderately wave exposed rocky reef habitats occur throughout the site. Rocky reef communities are characterised by attached algae and invertebrates, usually associated with a range of mobile species such as fish and crustaceans. Factors which affect the biological composition and diversity of reef communities include the level of wave exposure, the degree of immersion by the tide and water movement. Water movement is particularly important for animal and plant communities on the reefs as it provides suspended food for filter feeders and limits the settlement of silt, which may lead to the clogging of gills and feeding organs of marine animals associated with reefs.
82 The subtidal rocky reefs and their rich marine communities, together with the wide variety of associated littoral reefs of this SAC, are the most diverse known on the North Sea coast. Their very varied nature is due to the wide range of physical conditions in the area, from wave-exposed locations on the open coast, through more sheltered reefs within bays, to those exposed to strong tidal streams in sounds and off headlands. As a consequence, reef habitats along the Berwickshire and North Northumberland Coast have a high diversity of communities and species (English Nature and SNH, 2000).
83 Along the Berwickshire and North Northumberland Coast, rock platforms extend offshore as a series of reefs and rocky plains. These platforms extend several kilometres out to sea as a series of underwater terraces. Although this part of the coast is exposed to the full fetch of the North Sea from the east or north-east, the wave action is rapidly attenuated on the more extensive wave cut, rocky platforms enabling a wide range of animal and plant communities to live in close proximity.
84 Sub-features of the Berwickshire and North Northumberland Coast SAC ‘Reef’ feature have been identified: rocky shore communities; kelp forest communities; and sublittoral faunal turf communities (English Nature and SNH, 2000). These sub-features are described further in paragraphs 85 to 91.
86 The shores associated with headlands such as St Abb’s in south-east Scotland are mainly steep and subject to strong wave surge conditions. Here, the high splash zone is dominated by lichens. The upper and middle areas of these shores are typically covered by barnacles Semibalanus balanoides and mussels, or limpets Patella vulgata, amongst which grow short plants of the red algae Mastocarpus stellatus and Ceramium spp. On the lower parts of these shores, S. balanoides is replaced by Balanus crenatus with a greater density of red algae (English Nature and SNH, 2000).
87 Biotopes present within the Scottish section of the SAC closest to the Proposed Development (Fast Castle Head – Eyemouth) include: Rock with mussels and barnacles (MytB, Ala.Myt) and Rock with fucoids and barnacles (BPat.Sem, FvesB, Ldig.Ldig).
88 Kelp forest communities - much of the open coast within the SAC is fringed by dense kelp forest communities. Kelp species such as Laminaria hyperborean, which largely occur subtidally but may also occur in the sublittoral fringe, support a rich understorey of red algal turf and short epifaunal turf. Beyond this fringing area, reefs in over 10 m water depth, are characterised by urchin grazed kelp habitats, small crabs, squat lobsters and anemones such as Urticina felina. Turbidity of the water determines the depth at which kelp grow in the nearshore by limiting light penetration through the water for photosynthesis. St Abbs, in the south-east Scotland section of the SAC, is renowned for its good water clarity, where estimates of underwater visibility range from 2 to 20 m depending on weather and sea conditions. Kelp forests flourish to at least 8 m below chart datum, which a good indicator of a generally low water turbidity for the south-east of Scotland and north-east of England (SNH, English Nature 2000).
89 Biotopes present within the Scottish section of the SAC closest to the Proposed Development (Fast Castle Head – Eyemouth) include: Kelp forest with red algae (Lhyp.Ft). and Tide swept kelp with dense red algae (LhypR.Ft, LhypFa).
90 Subtidal faunal turf communities – where kelp and other algae communities are unable to establish due to lack of light, faunal turf communities tend to dominate the reefs, forming a species rich and structurally and functionally important component of the reef ecosystem. This living turf comprises diverse assemblages of attached animals growing on subtidal substrate, ranging from, encrusting sea mats and sponges, to tall erect soft corals and sea fans. These communities also support prominent mobile species such as crustaceans, echinoderms, molluscs and fish. By definition, faunal turfs are dominated by animals although foliose and crustose red algae are present in the upper regions of this zone where it overlaps with the shallower infralittoral zone (SNH, English Nature 2000).
Submerged or partially submerged sea caves
92 Sea caves occur throughout the Berwickshire and North Northumberland Coast SAC in association with the Annex I reefs, in both the intertidal and the subtidal zones. Depending on the depth of the cave and its morphology, the site supports a range of distinct biological communities. These sub-features of the Berwickshire and North Northumberland Coast SAC ‘submerged or partially submerged sea caves’ feature are classified as either intertidal (partially submerged at some stage in the tidal cycle) or subtidal (submerged at all times). Each of these types of sea cave support a highly diverse assemblage of sea cave biotopes with characteristic zonation patterns.
93 Intertidal sea cave communities - Caves in the intertidal zone are frequently subject to conditions of strong wave surge and scour by coarse sediment. They are typically colonised by encrusting animal species but may also support shade-tolerant algae near their entrances and roofs. Intertidal sea caves are found throughout the SAC. An example in the SAC within south-east Scotland is the steep rocky shores between Fast Castle Head and the volcanic outcrop at St. Abb’s head, where erosion of soft rock intrusions within volcanic layers has created a series of narrow gullies, many leading to caves.
94 Subtidal sea cave communities - Caves that occur in the subtidal area are continually submerged in water and are not exposed to the air at low tide. Subtidal sea caves, tunnels and arches are present in the volcanic rock around St Abb’s head. Environmental conditions in these caves are not as harsh or extreme as in the intertidal sea caves and tend therefore to support a wider range of species. Subtidal sea caves are subject to less water movement from the surrounding sea than intertidal caves, and silt may accumulate on the cave floor. The sponges Dercitus bucklandi and Thymosia guernei, soft corals, solitary sea-squirts, bryozoans and sessile larvae of jellyfish are characteristic of deeper cave systems. Caves such as these provide an important source of shelter for crustaceans such as crabs and lobsters Homarus gammarus, and for a variety of reef-dwelling fish, such as the leopard-spotted goby Thorogobius ephippiatus (English Nature and SNH, 2000).
11.2.6 Approach to the In-Combination Assessments
95 The nature of effects that have been assessed for each Annex I habitat, and the scale over which those effects may occur, are based on assessment criteria applied during the HRA Stage One Screening exercise as presented in Section 9.3. These effects are detailed within the Proposed Development alone assessment (see section 11.5) and have not been re-iterated here.
96 The overarching approach to the assessment of in-combination effects is set out in section 10.6 and is not reiterated here.
Relevant plans and projects
97 The plans and projects set out in Table 11.1 Open ▸ have been considered within the in-combination assessment for European sites designated for Annex I habitat features.
98 The plans and projects included in this in-combination assessment for European sites designated for Annex I habitat features have been derived in part, from the Cumulative Effects Assessment (CEA) longlist presented in volume 3, appendix 6.4 of the Offshore EIA Report.
Table 11.1 : List of Other Developments with Potential for In-combination Effects on Annex I Habitat Features