APPENDIX J: SUMMARY OF PROPOSED MITIGATION AND …...safety authorities and prepare the pre-tender health and safety plan and ensure that a construction phase health and safety plan

Killala Community Wind Farm Appendix J REIS / EIAR Mitigation Summary

Jennings O’Donovan & Partners Ltd Page J-1 July 2017

APPENDIX J: SUMMARY OF PROPOSED MITIGATION AND MONITORING MEASURES Section Sub-Section Proposed Mitigation / Monitoring Measures

4. Population & Human Health

4.5.5 Accidents / Disasters (incorporating health and safety)

4.5.5.1 Design or Avoidance

The main mitigation measure is by design or avoidance. A suitable separation distance from turbines and other key infrastructure to properties has been embedded in the EIA Development design. Additional mitigation to protect site personnel and the public will also be implemented in the event of damage to a turbine and subsequent likely turbine or turbine component failure. These are:

- Turbines will be procured from a reliable manufacturer and will have undergone vigorous safety checks during design, construction, commissioning and operation.

- Physical and visual warnings such as signs will be erected as appropriate for the protection of site personnel and the public.

- Facility for remote turbine deactivation will be provided.

- Access to turbines for site personnel will be restricted in storm events. Where access by site personnel is required safety precautions may include remotely shutting down the turbine, yawing to place the rotor on the opposite side of the tower door and parking vehicles at a distance of at least 100m from the tower. All personnel will be fitted with appropriate PPE.

- Regular maintenance and inspections will take place during the 25 year operational phase. The final turbine model chosen will be in line with International Electrotechnical Commission IEC 61400-1 safety standards. Maintenance visits will take place as needed with the Scada control system monitoring turbine performance remotely. Access to the turbines will be via the door at the base of the turbines. The turbine access door will otherwise to securely locked at all times.

4.5.5.2 Health and Safety Procedures

The design and construction of the EIA Development will be managed in accordance with the Safety, Health & Welfare at Work Act 2005 and subsequent amendments and regulations made thereunder, including the Safety, Health & Welfare at Work (Construction) Regulations 2013 (S.I. No. 291 of 2013) as amended. The Health & Safety Plan for the EIA Development will be developed in accordance with the regulations and the duties of the Project Supervisor Design Process (“PSDP”) and the Project Supervisor Construction Stage (“PSCS”). Access to site will be restricted at all times and all visitors and contractors will go through a site induction prior to entering the site. The site will be constructed by a reputable, appropriately insured contractor who will develop a method statement and safe systems of work.

The appointed PSDP will liaise with the PSCS on design related issues. The PSCS will have responsibility for coordinating activities of all the contractors employed on site and see that the relevant regulations and guidance are followed.

Dust control measures such as damping down of surfaces where material could become friable will be implemented on site. Materials stockpiles and site roads will be maintained to a high standard. A wheel wash facility will be installed on site which all HGVs will be required to pass through prior to entering the public road network.

Vehicle emissions will be reduced through providing for regular maintenance of all vehicles and plant and turning off motors when idle. Regular maintenance of vehicles and plant will also provide that noise emissions are reduced.

Appendix J Killala Community Wind Farm Mitigation Summary REIS / EIAR

Page J-2 Jennings O’Donovan & Partners Ltd July 2017

Section Sub-Section Proposed Mitigation / Monitoring Measures

During construction and decommissioning of the EIA Development the weather will be monitored so that if high winds are predicted then turbine component erection and dismantling will not take place.

Local residents will be notified in advance of abnormal loads and large volumes of HV traffic, for example, during turbine base concrete pours. Any damage to the road network will be repaired by the Developer in a timely fashion. Any signage needed for the construction traffic routes will be agreed with Mayo County Council in advance and with Donegal, Leitrim, Sligo and Mayo County Councils for the proposed turbine components haul route. The turbine component traffic movements will also be agreed with An Garda Síochána in advance so that disruption to the public is minimised.

4.5.5.3 Design and Construction

The layout and design of the EIA Development takes into account the following health and safety considerations:

- Proposed Development Site boundary;

- Location and prevention of contact with underground and overhead services;

- Public access and safety;

- Other structures on-site;

- Access and egress;

- Traffic control;

- Stability of slopes; and

- Effects of the design life of the structures.

4.5.5.4 Risk Assessment

In order to effectively guard against the risk of accidents, a clear system of identifying hazards and implementing effective control measures would be put into place. The most effective manner of achieving this is through clear concise risk analysis.

This will take place at three different levels during the lifetime of the EIA Development:

- Designers will undertake a design review to design out in so far as is practicable any risks associated with the project. Those risks that cannot be designed out will be highlighted to the principal contractor within a pre-tender health and safety plan in the form of clear concise risk assessments;

- The principal contractor will be responsible for carrying out regular risk assessments for all operations that have an inherent risk of severe injury; and

- The designers and the principal contractor will liaise in order to produce risk assessments for all remaining residual risks involving the day-to-day running and maintenance operations and eventual decommissioning of the Development.

4.5.5.5 Health and Safety File

A competent, adequately resourced site supervisor will be appointed for the works. All relevant information relating to health and safety will be passed on to the site supervisor. The site supervisor will notify the relevant safety authorities and prepare the pre-tender health and safety plan and ensure that a construction phase health and safety plan is adequately developed. The site supervisor will collate information from the designers and principal contractor to produce a health and safety file for the project.

The site health and safety file will be completed as soon as is possible after




the construction of the Development. It will contain all relevant health and safety information relating to the EIA Development in relation to the day to day running and maintenance operations and eventual decommissioning. It is the owner’s duty to hold and make available any information contained in the file to anyone who would need such information.

4.5.5.6 Operation A Supervisory Control and Data Acquisition (“SCADA”) system will monitor the EIA Development’s performance. If a fault occurs then a message is automatically sent to the engineer preventing emergency situations.

Warning signs and security infrastructure will be in place around the onsite switchgear and control building to ensure public safety.

4.5.6.2 Shadow Flicker

If shadow flicker is found to be occurring and complaints are received, then an appropriate investigation will be undertaken to confirm the shadow flicker levels. This would involve a line of sight assessment, as well as window sizes, use of rooms and existing natural screening assessments. Residents will then be consulted of vegetative planting and/or screens or blinds may be specified. Turbines can also be programmed to shut down under specific weather conditions to prevent shadow flicker nuisance on affected properties.

4.5.6.3 Noise A warranty will be sought from the selected turbine manufacturer for the EIA Development to confirm that an assessment of noise would result in noise levels at all receptors being less than or equal to the noise limits set out in Section 9: Noise. The warranty will include the provision that there will be no clear tonal components audible at any receptor.

4.5.6.5 Air Quality Mitigation measures proposed include:

- Approach roads and construction areas will be cleaned on a regular basis to prevent mud built-up and from migrating around the site and off-site;

- Wheel wash facilities will be provided near the site compound to prevent mud/dirt being transferred from the site to the public road network;

- A mechanised road sweeper will be used at the public road entrance and along the access road to the Killala Business Park if required;

- ‘Damping down’ will be used if dust becomes an issue on any part of the site;

- Vehicles delivering materials to the site will be covered appropriately when transporting materials that could result in dust, e.g. crushed rock or sand;

- Ready-mix concrete will be delivered to site and it is envisaged that no batching of concrete will take place on site;

- Speed restrictions on access tracks will be implemented to reduce the likelihood to dust becoming airborne;

- Public roads along the construction haul route will be inspected regularly and if dirt/mud is identified that could result in dust generation then the road will be cleaned as necessary;

- Stockpiling of materials will be carried out in such a way as to minimise their exposure to wind where possible and damping down will be carried out where needed; and

- A complaints procedure will be implemented on site where complaints will be reported to the site manager, logged and appropriate action




taken.

4.5.6.6 Water Contamination

- See Section 7. Water

5. Biodiversity 5.6.1 Construction Phase

5.6.1.1 Mitigation by Avoidance

5.6.1.1.1 Protection of Watercourses

- All site access tracks and turbine locations have been situated away from any substantial watercourses or streams marked on OSI maps. There is one watercourse crossing within the Proposed Development Site, at its eastern end, where the Moyne River is culverted beneath existing access road leading to the Killala Business Park. Other than this, no significant watercourse occurs within or immediately adjacent to the proposed infrastructure as the Proposed Development Site is predominately drained by manmade land drains which generally run south to north.

- In the vicinity of the Moyne River culvert, and where construction of site tracks cross land drains within the Proposed Development Site, there will be no refuelling of machinery within a 20 metre buffer of all watercourses and site drains, and appropriate silt control measures will be installed to protect downstream watercourses. Such measures will be implemented within the Site’s Construction Method Statement (CMS).

- There will be no direct drainage to watercourses, including land drains. All outflows from drainage associated with construction will be by diffuse overland drainage at appropriate locations.

- Disturbed ground in the vicinity of drains or watercourses will be actively revegetated with appropriate site-typical vegetation immediately post construction. Specific measures to be taken to achieve this will be detailed in a Habitat and Species Management Plan (“HSMP”).

- The proposals to control potential pollution detailed within the Section 7: Water of this REIS / EIAR will be implemented in full. These include measures for developing appropriate drainage infrastructure, storage of potentially hazardous materials, de-watering operations, site management and the implementation of a 50 metre buffer to watercourses (achieved as part of embedded site design).

- An Ecological Clerk of Works (“ECoW”) will be employed from the commencement to completion of construction works, including tracks, substation, temporary compound, hardstand areas and turbine bases and cabling works at a minimum. Primary roles for the ECoW will include the setting out and monitoring of the working corridor and review of pollution control measures and working practices during the active construction period as well as ad hoc input into site remediation.

5.6.1.1.2 Protection of Important Habitats

The Proposed Development Site is principally composed of improved or partially improved agricultural fields with some wet grassland (GS4), therefore side-casting of material during construction is unlikely to be a significant issue.

Wet Grassland areas have been largely avoided in the site design, with four of the five proposed turbines being sited within Improved Agricultural Grassland.

As hedgerows and treelines within the site are considered to be habitats of greatest local biodiversity value, providing commuting corridors for a variety of mammal and plant species, loss of such features will be minimised where possible:




- Hedgerow and treeline removal to facilitate site track construction through the site will be minimised, and where possible site tracks will follow existing hedgerows, most notably from T4 to T5 and from T2 to T3. Other connecting site tracks will also follow existing hedgerows, to avoid fragmenting existing fields;

- Where hedgerows and treelines are to be removed, the minimum necessary area will be removed;

- There are some patches of scrub, scrub / dry meadows and grassy verges mosaic, and recolonising bare ground / calcareous grassland mosaic adjacent to the proposed access track (see Figure 5.6). Any necessary widening of the proposed access track will avoid these habitats where possible; and

- An Ecological Clerk of Works (ECoW) will be employed from the commencement to completion of construction works, including tracks, substation, temporary compound, hardstand areas and turbine bases and cabling works at a minimum. Primary roles for the ECoW will include the setting out and monitoring of the working corridor and review of pollution control measures and working practices during the active construction period.

5.6.1.1.3 Protection of Designated Areas

- Killala Bay/Moy Estuary SAC and SPA have downstream connectivity with the Moyne River (River Water Body Code IE_WE_34M190890) which is culverted beneath the existing access road close to the R314. There is also potential connectivity between Killala Bay/Moy Estuary SAC and SPA and the Proposed Development Site via a series of small land drains which connect to the small watercourse that originates some 160 metres to the north of T3 and T4, later joining the Cloonaghmore River and thence Killala Bay. The measures proposed to avoid impacts upon watercourses, if implemented in full, will similarly enable avoidance of impacts upon these designated areas.

5.6.1.1.4 Protection of Important Mammal Species

- The proposed site infrastructure layout has been designed to minimise impact on features which are important for mammals such as hedgerows.

- The commencement of works will be preceded by a due diligence ecological walkover survey of the site infrastructure layout and proposed turning area identified on Haul Route Option 2 (including a 100 metre buffer) (if used for transportation) within the year prior to works commencing. The aim of the survey will be to identify any badger setts or other protected species within the wider area.

- No works will be undertaken within 25m of an active badger sett entrance. All setts will be marked off prior to commencement of construction, to ensure protection of these locations.

- Any trees identified as having potential to support an active bat roost will not be felled during the construction phase until an emergence bat survey has been undertaken in to identify the location of any possible roosts, following the standard guidelines outlined in the guidance document produced by TII.

Felling of trees that may contain roosting bats will be scheduled for the period between late August and early November, to avoid impact upon breeding or hibernating bats which are most vulnerable to disturbance. As bats may move between different roost sites, roost emergence and re-entry surveys will be carried out on the day and night immediately prior to planned felling. Where possible, trees known to be utilised by roosting bats




will not be felled until bats have naturally left the roost. If this has not happened after repeated postponement of felling, it may be necessary to for a bat specialist to oversee exclusion procedures, under licence from NPWS, to prevent bats returning to the roost once they have left.

Even after following the precautionary measures outlined above, there is still a possibility that roosting bats may have been missed. Trees that have potential suitability to be used by roosting bats will be felled using “soft felling” techniques, where limbs are cut and left grounded for at least 24 hours to allow any bats present to make their way out. Further guidance for tree felling in areas used by bats is provided by the TII guidance document.

5.6.1.1.5 Protection of Important Bird Species

- Construction will be timed to commence outside the bird breeding season (April to July). This does not necessarily preclude construction continuing during the breeding season, but would allow birds to choose nesting sites away from sources of potential disturbance.

- Any required trimming of roadside vegetation (hedges and overhanging trees) along proposed Haul Route Option 1 will be undertaken outside the bird breeding season (March-August inclusive). This is in line with restrictions set out in Section 40 of the Wildlife Act 1976, as amended by the Wildlife (Amendment) Act 2000.

- Where construction takes place during the breeding season, care will be taken to avoid the accidental destruction of birds’ nests. Any works during the breeding season will also be preceded by a breeding bird survey to ascertain the location of active nests.

- An ECoW will be appointed to ensure best practice is implemented during the construction of the EIA Development and any construction during the bird nesting season will be monitored by an appropriately qualified ornithologist. The ornithologist’s role will include the application of appropriate buffers to ensure the protection of nesting birds from disturbance in line with current scientific understanding. Buffers stated in this document may be revised in the light of ornithological findings onsite.

- Appropriate buffers will be maintained around any known peregrine nest site, within which no potentially disturbing operations may take place. Peregrine sensitivity to disturbance is considered to be variable and depends on factors such as accessibility to the nesting site and habituation to sources of disturbance with responses to disturbance differing amongst individual birds and pairs of birds. Peregrine are particularly sensitive to disturbances occurring from above and at the same level as cliff-side eyries, rather than to disturbance below nest sites. Recommended buffer zones for breeding peregrine vary with habitat and season. A number of recommendations have been made in previous studies. Currie & Elliott (1997) proposed a 600 - 1000 m buffer for safe forestry work, while Petty (1998) recommends 400 – 600m for the same, and many states in the USA have recommended buffer distances of between 400m and 800m, which are also considered appropriate with respect to wind farm developments in England. A review of disturbance distances undertaken by Ruddock and Whitfield (2007) indicate that the upper limit of static or passive disturbance distances is between 500 and 750m. On review of the available literature, and taking into account the location of the known peregrine nest within an active quarry, in a west-facing location, facing away from the proposed EIA Development, it is considered appropriate at this site to maintain a 500m construction buffer around known peregrine nest sites, within which no construction or other potentially




disturbing operations may occur, for the duration of the peregrine breeding season (i.e. between late February, when peregrine begin to select breeding territories, until approximately mid-July, or when young birds have successfully fledged).

- Construction or other works will not be permitted in the vicinity of Turbine T5 during the peregrine breeding season (late February to mid-July, or until young birds have successfully fledged). T5 is the closest proposed turbine to the known peregrine breeding location, located approximately 420 away. Assuming a breeding pair is present within the quarry to the southwest of the Proposed Development Site, construction may be permitted following the successful fledging of chicks (mid-July of construction year).

5.6.1.2 Mitigation by Reduction


- The working corridor will be limited in or near areas of treelines and hedgerows to minimise impact or loss of these habitats. The working corridor will be agreed within the Construction Environmental Management Plan (“CEMP”) prior to the commencement of works.

- Where site tracks run along hedgerows or treelines these features will be maintained. However, there will be a requirement to create gaps in hedgerows at a number of locations to facilitate the construction of access tracks. Where this is necessary, hedgerow removal will be kept to a minimum. This will reduce the need for additional replanting post-construction as well as maintaining connectivity for commuting bat species.

- Where turbines are located close to hedgerows or treelines, an appropriate buffer will need to be created between such features and turbines to minimise potential collision risks for bats. This will require that some features be felled. Required buffers are illustrated in Figure 5.11: Required Buffers between Bat Features and Turbines, and are calculated as a 72m radius of the turbine for hedgerows, and an 84m radius for treelines. These figures have been calculated on the basis of feature height, turbine height, blade length and consequent rotor-swept area, as described in the Natural England Technical Information Note TIN051 Bats and Onshore Wind Farms – Interim Guidance. Care will be taken to ensure any felling required is kept to a minimum, and disturbance to adjacent retained habitats will be avoided.

- There will be an active approach to silt control within the Proposed Development Site. In areas being actively worked, dedicated construction staff will be tasked to place silt fences in areas of risk of overland flow of silt-laden water, particularly around T2. Silt fences must be visually checked on a weekly basis for efficacy, and daily in actively worked areas or during wet conditions. An approach to ensuring the above must be incorporated into a Construction Method Statement (“CMS”) to be adopted by the contractor.

5.6.1.3 Offsetting

5.6.1.3.1 Targeted enhancement of treelines and hedgerow habitats

It is proposed that a target management regime be implemented onsite for the enhancement of highest-quality habitats, namely hedgerows and treelines. Maintaining and enhancing these habitats has the potential to increase their biodiversity, by increasing their suitability for a broad range of species, notably bat and birds. Proposed enhancement measures for these habitats will be detailed in a Habitat and Species Management Plan (HSMP), proposed to be conditioned by the planning authority.

5.6.1.3.2 Habitat Restoration

- Mineral soils, sub-soil and turves will be stored separately in order to facilitate habitat restoration. All surface turves within improved grassland (GA1) will be lifted and stored separately from sub soil and




replaced as top-mat to facilitate rapid re-instatement of the surface vegetation of these habitats.

- An ECoW will be employed from the commencement to completion of construction works; responsibilities will include ad hoc input into site remediation, including reseeding.

- Areas of hedgerow/treelines lost to facilitate access through the Proposed Development Site will be replaced. Specific mitigation measures, including the location of replacement hedgerows, on a like for like linear basis and positioned to retain maximum connectivity with other hedgerows, must be detailed in an HSMP for the site prior to the commencement of construction. Areas have been identified where replanting will be carried out in order to offset the loss of hedgerow and a number of mature trees. This will help to maintain connectivity of commuting and feeding features for local bat species, birds, invertebrates and small mammals.

5.6.2 Operational Phase mitigation

5.6.2.1 Mitigation by avoidance

5.6.2.1.1 Important mammal species

- Turbines have generally been placed within areas of open agricultural land. Where hedgerows and treelines do occur, some will have to be removed to avoid impact on other species such as bats, as it will be necessary to maintain a minimum separation distance between the rotor tip and the nearest habitat feature (hedgerow or treeline). This will necessitate the removal of some hedgerow and treeline habitat, notably around T3 and T5 (see Figure 5.11: Required Buffers between Bat Features and Turbines). The required buffer between turbines and hedgerow features is 72m, while for treelines this figure is 84m. These figures have been calculated on the basis of feature height, turbine height, blade length and consequent rotor-swept area, as described in the Natural England Technical Information Note TIN051 Bats and Onshore Wind Farms – Interim Guidance41. Care will be taken to ensure any felling required is kept to a minimum, and disturbance to adjacent retained habitats will be avoided.

- All turbines are located well away from active badger setts (see Confidential Appendix F.2). The closest turbine, T5, is located some 90 metres to the east of an outlier sett.

5.6.2.1.2 Birds - Due to the presence of breeding peregrine within a quarry outside the southwest of the Proposed Development Site, T6, situated to the north of the quarry, has been removed from the EIA Development to reduce the potential for impact (collision and disturbance) on this species.

- As a result of removing T6 from the proposal, the EIA Development will not be visible to breeding peregrine at the current nesting site within the quarry, materially reducing the risk of peregrine avoiding or abandoning the site.

5.6.2.1.3 Watercourses

- Revegetation of disturbed areas in the vicinity of watercourses will be undertaken immediately post construction, in order to avoid run-off of silt-laden water impacting upon water quality within the watercourse arising in the northern part of the site (which ultimately connects to the Cloonaghmore River system and thus to Killala Bay).

- Mineral soils, sub-soil and turves will be stored separately in order to facilitate habitat restoration, and turves will be replaced as top-mat to facilitate rapid re-instatement of the surface vegetation of these habitats.

5.6.2.2 Mitigation by Reduction

- Although limited site tracks exist at the Proposed Development Site, all proposed infrastructure will be limited to a confined working corridor





to minimise the extent of land take.

- Proposed site access tracks will follow existing hedgerows within the Proposed Development Site, minimising fragmentation of habitat.

5.6.2.3 Offsetting

5.6.2.3.1 Restoration of Important Habitats

- Following implementation of the construction-phase restoration measures described in Section 5.5.1.3, monitoring of the success of habitat restoration will be undertaken. A monitoring programme, and requirements for remedial measures, will be incorporated into the HSMP for the site.

- There will be a like-for-like replacement of all hedgerow and treeline habitat lost as a result of the proposed infrastructure or required to be felled in order to achieve sufficient buffers to avoid potential impacts on bats. The approach for replacement will be incorporated into the HSMP in the form of a hedgerow and treeline replacement plan which maximises future hedgerow and treeline ecological function by specifying an appropriate species mix and replacement locations to maximise connectivity. In the latter case, full consideration must be taken of bat usage of the site.

5.6.3 Decommissioning Phase Mitigation

Decommissioning phase impacts are likely to be broadly similar to construction phase impacts, in terms of disturbance through increased noise levels, ground clearance works, and reinstatement; and potential surface water quality impacts from ground disturbance, refuelling and the storage of potentially hazardous materials onsite. The implementation of all mitigation measures detailed in the construction phase will help ensure that all such impacts are avoided.

Therefore, it is proposed that a Decommissioning Plan be drafted prior to removal of the EIA Development infrastructure. This will be put into place containing specific actions aimed at protecting important habitats and species, including all the mitigation measures specified for the construction phase. These include limitations on the working corridor, pollution control, minimised impact on hedgerows, and specific working practices in the vicinity of watercourses and badger setts.

These actions will relate to a revised map of important habitats, including hedgerows, treelines and wet grassland (GS4), prepared not more than two years prior to decommissioning, and species surveys undertaken not more than one year prior to decommissioning.

5.6.3.1 Mitigation by avoidance

5.6.3.1.1 Badger

Species surveys will reassess badger setts identified during preconstruction surveys and ensure that no new setts have been created in close proximity to the infrastructure route that may be affected by decommissioning operations.

5.6.3.1.2 Peregrine The removal of permitted Turbine T6 from the EIS Development means that there is reduced potential for the decommissioning phase to result in disturbance to peregrine breeding in the nearby quarry (as detailed in section (Section 5.4.3). T6 (in the 2010 Permission) would have been significantly closer to the quarry than the remaining turbines.

5.6.3.1.3 Watercourses

The Decommissioning Plan for the EIA Development will have an emphasis on the protection of surface water drainage from silt-laden run-off originating from bare ground, and on high quality habitat restoration to prevent ongoing potential for such run-off following the decommissioning stage.

5.6.3.1.4 Designated Areas

The Decommissioning Plan for the EIA Development will include measures for the protection of surface water drainage from silt-laden run-off




originating from bare ground, and for high quality habitat restoration to prevent ongoing potential for such run-off following the decommissioning stage. Such measures will also be effective in avoiding decommissioning-stage impacts upon Killala Bay/Moy Estuary SAC and SPA, since these designated areas are connected to the Proposed Development Site via the Cloonaghmore stream catchment. These consist of actions to ensure revegetation of disturbed areas close to watercourses is completed as rapidly as possible.

5.6.3.2 Offsetting A Decommissioning Plan will be put in place, containing specific actions aimed at high quality habitat restoration of areas impacted by the decommissioning works.

6. Soils and Geology 6.5.1 Construction Phases

6.5.1.1 Subsoil and Bedrock Removal

6.5.1.1.1 Mitigation by Avoidance

The following mitigation measures are proposed:

- The design of the proposed EIA Development has followed closely the design of the 2010 Permission which took into account the existing geotechnical and hydrological baseline and incorporated the engineering and environmental constraints of the Proposed Development Site at that time. Any variations from the existing design to accommodate the revised turbine dimensions have reflected this, in an updated baseline assessment;

- The soil and subsoil which will be removed during the construction phase will be mounded local to the turbine location and site tracks;

- No turbines or related infrastructure will be constructed in any designated sites such as NHAs or SACs or Features of Geological Significance and such areas have been avoided in the selection of the Haul Route Options; and

- Construction of settlement/attenuation ponds will be volume neutral, and all excess material will be used locally to form pond bunds/walls. These ponds will be retained post construction, i.e. throughout the operational phase to maintain greenfield runoff rates.

6.5.1.1.2 Mitigation by Reduction


- The excavation of materials should be minimised as far as possible on-site during the construction phase;

- Spoil removed from turbine locations and access roads will be used for landscaping, cast aside or stored long term at designated storage areas. Where possible, the upper vegetative layer will be stored with the vegetation part of the sod facing the right way up to encourage growth of plants and vegetation at the surface of the stored spoil within the storage areas. Re-seeding and spreading/planting of grass will also be carried out in these areas. These measures will prevent erosion of stored spoil in the long term;

- Any excess temporary mounded spoil in storage for long periods will be covered by a polyethylene sheet or seeded at the earliest opportunity. This will prevent erosion of soil. Silt fences will be installed around stockpiles to limit movement of entrained sediment in surface water runoff. The use of bunds around earthworks and mounds will prevent egress of water from the works;

- In order to minimise erosion of mineral subsoils and loss of organic matter, stripping of topsoil will not take place during extremely wet periods (to prevent increased silt rich runoff). Temporary drainage systems will be required to limit runoff impacts during the construction phase;




- Bog mats will be used to support vehicles on soft ground, reducing soil erosion and avoiding the formation of rutted areas, in which surface water ponding can occur; and

- Areas to be excavated for widening works along the Haul Routes will be minimised to that required for transport of turbine components. The extent of each area will be verified by a trial run in advance of component delivery.

6.5.1.2 Storage and Stockpiles



- Apart from designated spoil deposition areas which will be graded, covered in topsoil, and landscaped, there will be no permanent stockpiles of excavated materials left on-site following completion of the EIA Development. Materials will be reused for backfill or landscaping purposes, for example at turbine bases, hardstands and along the edges of access tracks; and

- There will not be any permanent stockpiles of excavated materials following completion of the Haul Route widening works.


The following mitigation measures are proposed for the Proposed Development Site and the Haul Route Options:

- Any excess temporary mounded spoil in storage for long periods will be covered by a polyethylene sheet or seeded at the earliest opportunity. This will prevent erosion of soil. Silt fences will be installed around stockpiles to limit movement of entrained sediment in surface water runoff. The use of bunds around earthworks and mounds will prevent egress of water from the works; and

- In order to minimise erosion of mineral subsoils, stripping of topsoil will not take place during extremely wet periods (to prevent increased silt rich runoff). Temporary drainage systems will be required to limit runoff impacts during the construction phase.

6.5.1.3 Vehicular Movements



- Plant and machinery should be restricted to movements within the delineated development footprint; and

- In order to minimise erosion of mineral subsoils stripping of topsoil will not take place during extremely wet periods (to prevent increased silt rich runoff). Temporary drainage systems will be required to limit runoff impacts during the construction phase.


On the Proposed Development Site and in areas of works on the chosen Haul Route Option, only plant and machinery selected specifically for construction of the works will be used. Once tasks are completed, plant will be removed from site.

6.5.1.4 Ground Stability


Mitigation measures proposed for the Proposed Development Site and the Haul Route Options will involve a geotechnical engineer visiting the sites of works (Proposed Development Site and works on Haul Route) to supervise all excavations and who will also review and approve the appointed contractor's method statement.



- Any excavations on identified unstable subsoils (very low likelihood) which could weaken the upslope area of the soil should be supported




by a structure such as a buttress, frame or rampart to prevent lateral slippage;

- In any excavations on unstable soil, the pore water pressure should be low at all times. Excessive ponding of water should not be permitted in newly excavated areas and following rainfall events, sumps should be drained to carry water away, thus preventing a build-up of pore water pressure which could potentially lead to instability of the soils; and

- Heavy rainfall events are a catalyst for landslides. Therefore, an emergency response system should be developed for the construction phase. This could involve 24-hour meteorological forecasting where the likelihood of an extreme rainfall event such as a 1:100 year rainfall event, responses such as cessation of construction activity on site until such a time as the runoff has flowed away from the excavations. It is recommended that an automatic rainfall gauge be provided on site for the construction phase.

6.5.1.5 Soil Contamination



- All construction materials imported to site during the construction period, for example, rock, cement, ducting or cables etc., will be removed from site following completion;

- As far as possible, a balance should be maintained between materials excavated and those brought to site for construction to reduce the need for storage and disposal of waste, particularly foreign materials which may have a different geochemistry or hydrochemistry. Recycling and reuse of materials on-site will be carried out as much as possible. It is envisaged that rock will be sourced from the adjacent quarries to be compatible with the local geochemistry;

- The appointed contractor will develop a Construction Environmental Management Plan (CEMP) which will specify the maintenance of plant and equipment, materials storage areas and drainage infrastructure for the duration of the construction phase. The plan will see that the designed measures are operating effectively, outline measures to prevent leakages of substances such as oils, identify issues with the drainage regime, and see that a record is kept of all actions/measures undertaken in the plan for management and audit purposes; and

- Hardcore material for use on works along the Haul Route will be sourced from a suitable supplier where the material has a similar geochemistry or hydrochemistry to the area where the works are to take place.



- Minimal refuelling or maintenance of construction vehicles or plant will take place on site. Off-site refuelling will occur at a controlled fuelling station;

- Minimal refuelling or maintenance of construction vehicles or plant will take place on site. Off-site refuelling will occur at a controlled fuelling station;

- On-site re-fuelling will be undertaken using a double skinned bowser with spill kits on the ready for accidental leakages or spillages;

- Fuels volumes stored on site will be minimised. Storage areas where required will be bunded appropriately for the fuel storage volume for




the time period of the construction and fitted with a storm drainage system and an appropriate oil interceptor;

- The electrical compound will incorporate bunded plinths so as to support electrical transformers and other equipment that may contain oils or other potential pollutants. Bunding will have, as a minimum, 110% capacity of the volume of the liquids likely to be stored, and will prevent leakage of any associated chemicals and to groundwater or surface water. The compound will be fitted with a storm drainage system and an appropriate oil interceptor;

- The plant used during construction will be regularly inspected for leaks and fitness for purpose; and,

- An emergency plan for the construction phase to deal with accidental spillages will be contained within the Construction Environmental Management Plan. Spill kits will be available to deal with and accidental spillage in and outside the re-fuelling area.

7. Water 7.4 Potential Impacts and Mitigation Measures

7.4.1 Construction Phase

7.4.1.1 Earthworks (Removal of Vegetation Cover, Excavations and Stock Piling)

7.4.1.1.2 Proposed Mitigation Measures

Mitigation by Avoidance:

The key mitigation measure during the construction phase is the avoidance of sensitive aquatic areas where possible. From Figure 7.4 it can be seen that all of the key proposed development areas are significantly away from the delineated buffer zones. Additional mitigation control measures, which are outlined further on in this section, will be undertaken at these locations).

Soil stripping will be confined to footprint of the infrastructural elements within the Proposed Development Site and Haul Route Works i.e. it will be limited to the minimum required.

The large setback distance from sensitive hydrological features (c. 250m to nearest watercourse for Proposed Development Site and c. 25m to River Eighanagh on Haul Route Option 2) means that adequate space is maintained for the proposed drainage mitigation measures (discussed below) to be properly installed and operated effectively. The proposed buffer zone will:

- Avoid physical damage to watercourses, and associated release of sediment;

- Avoid excavations within close proximity to surface watercourses;

- Avoid the entry of suspended sediment from earthworks into watercourses; and,

- Avoid the entry of suspended sediment from the construction phase drainage system into watercourses, achieved in part by ending drain discharge outside the buffer zone and allowing percolation across the vegetation of the buffer zone;

Run-off control and drainage management are key elements in terms of mitigation against impacts on surface water bodies. Two distinct methods will be employed to manage drainage water within the proposed EIA Development. The first method involves ‘keeping clean water clean’ by avoiding disturbance to natural drainage features, minimising any works in or around artificial drainage features, and diverting clean surface water flow around excavations, construction areas and temporary storage areas. The second method involves collecting any drainage waters from works areas within the site that might carry silt or sediment, and nutrients, to route them towards settlement ponds (or stilling ponds) prior to controlled diffuse release over vegetated surfaces. There will be no direct discharges




to surface waters. During the construction phase, all run-off from works areas (i.e. dirty water) will be attenuated and treated to a high quality prior to being released. A schematic of the proposed site drainage management is shown as Figure 7.7 below. A detailed drainage plan showing the layout of the proposed drainage design elements is shown in Volume II Figure 2.13.

Figure 7.7: Schematic of Drainage Concept

Best Practice Mitigation by Design (SUDS principles):

- Source controls for Surface Water:

o Interceptor drains, vee-drains, diversion drains, flume pipes, erosion and velocity control measures such as use of sand bags, oyster bags filled with gravel, filter fabrics, and other similar/equivalent or appropriate systems.

o Small working areas, covering stockpiles, weathering off stockpiles, cessation of works in certain areas or other similar/equivalent or appropriate measures.

- In-Line controls for Surface Water:

o Interceptor drains, vee-drains, oversized swales, erosion and velocity control measures such as check dams, sand bags, oyster bags, straw bales, flow limiters, weirs, baffles, silt bags, silt fences, filter fabrics/membranes (e.g. Sedimats), and collection sumps, temporary sumps/attenuation lagoons, sediment traps, pumping systems, settlement ponds, temporary pumping chambers, or other similar/equivalent or appropriates systems.

- Treatment systems for Surface Water:

o Temporary sumps and attenuation ponds, temporary storage lagoons, sediment traps, and settlement ponds, and proprietary settlement systems such as Siltbuster, and/or other similar/equivalent or appropriate systems.

Water Treatment Train:

If the discharge water from construction areas fails to be of a high quality then a filtration treatment system (such as a ‘siltbuster’ or similar equivalent treatment train (sequence of water treatment processes) will be used to filter and treat all surface discharge water collected in the dirty water drainage system. This will apply for all of the construction phase.




Silt Fences:

Silt fences will be emplaced within drains down-gradient of all construction areas and at the downstream edges of road widening works on the Haul Route Options. Silt fences are effective at removing heavy settleable solids. This will act to prevent entry to watercourses of sand and gravel sized sediment, released from excavation of mineral sub-soils of glacial and glacio-fluvial origin, and entrained in surface water run-off. Inspection and maintenance of these structures during construction phase is critical to their functioning to stated purpose. They will remain in place throughout the entire construction phase. Double silt fences will be emplaced within drains down-gradient of all construction areas.

Silt Bags:

Silt bags will be used where small to medium volumes of water need to be pumped from excavations. As water is pumped through the bag, most of the sediment is retained by the geotextile fabric allowing filtered water to pass through. Silt bags will be used with natural vegetation filters.

Pre-emptive Site Drainage Management:

The works programme for the initial construction stage of the EIA Development and for road widening works for the Haul Route Options, will also take account of weather forecasts, and predicted rainfall in particular. Large excavations and movements of soil/subsoil or vegetation stripping will be suspended or scaled back if heavy rain is forecast. The extent to which works will be scaled back or suspended will relate directly to the amount of rainfall forecast.

Using the safe threshold rainfall values detailed following will allow work to be safely controlled (from a water quality perspective) in the event of forecasting of an impending high intensity rainfall event.

Works will be suspended if forecasting suggests any of the following is likely to occur:

- >10 mm/hr (i.e. high intensity local rainfall events);

- >25 mm in any 24 hour period (heavy frontal rainfall lasting most of the day); or,

- >half the monthly average rainfall in any 7 days duration.

Prior to works being suspended the following control measures should be completed:

- Secure all open excavations;

- Provide temporary or emergency drainage to prevent back-up of surface run-off; and,

- Avoid working during heavy rainfall and a suitable duration after heavy events to ensure drainage systems are not overloaded.

Timing of Site Construction Works:

Construction of the site drainage system and road widening works for Haul Route Options will only be carried out during periods of low rainfall, and therefore minimum run-off rates. This will minimise the risk of entrainment of suspended sediment in surface water run-off, and transport via this pathway to surface watercourses. Construction of the drainage system during this period will also ensure that attenuation features associated with the drainage system will be in place and operational for all subsequent




construction works.

7.4.1.2 Excavation Dewatering and Potential Impacts on Surface Water Quality


Mitigation by Design:

Management of excavation seepages and subsequent treatment prior to discharge into the drainage network will be undertaken as follows:

- Appropriate interceptor drainage, to prevent upslope surface run-off from entering excavations will be put in place;

- If required, pumping of excavation inflows will prevent build up of water in the excavation;

- The interceptor drainage will be discharged to the site constructed drainage system or onto natural vegetated surfaces and not directly to surface waters;

- The pumped water volumes will be discharged via volume and sediment attenuation ponds adjacent to excavation areas, or via specialist treatment systems such as a Siltbuster unit;

- There will be no direct discharge to surface watercourses, and therefore no risk of hydraulic loading or contamination will occur;

- Daily monitoring of excavations by a suitably qualified person will occur during the construction phase. If high levels of seepage inflow occur, excavation work should immediately be stopped and a geotechnical assessment undertaken; and,

- A mobile ‘Siltbuster’ or similar equivalent specialist treatment system will be available on-site for emergencies in order to treat sediment polluted waters from settlement ponds or excavations should they occur. Siltbusters are mobile silt traps that can remove fine particles from water using a proven technology and hydraulic design in a rugged unit. The mobile units are specifically designed for use on construction-sites.

7.4.1.3 Potential Release of Hydrocarbons during Construction and Storage



- Seal/line sub-soil and bedrock at the Proposed Development Site by laying a proprietary geosynthetic clay liner where infrastructure is to be provided directly on top of bedrock or where the thickness of sub-formation overburden is less than 0.6m;

- On site re-fuelling of machinery at the Proposed Development Site and at those areas of construction works associated with the Haul Route Options will be carried out using a mobile double skinned fuel bowser. The fuel bowser, a double-axel custom-built refueling trailer will be re-filled off site, and will be towed around the site by a 4x4 jeep to where machinery is located. The 4x4 jeep will also carry fuel absorbent material and pads in the event of any accidental spillages. There shall not be any refuelling within a 20m buffer of all site drains. The fuel bowser will be parked on a level area in the construction compound when not in use and only designated trained and competent operatives will be authorised to refuel plant on site. Mobile measures such as drip trays and fuel absorbent mats will be used during all refuelling operations;

- Fuels stored at the Proposed Development Site will be minimised. Any storage areas will be bunded appropriately for the fuel storage volume for the time period of the construction. No fuel will be stored at those areas of construction works associated with the Haul Route Options;

- The electrical control building should be bunded appropriately to the




volume of oils likely to be stored, and to prevent leakage of any associated chemicals and to groundwater or surface water. The bunded area will be fitted with a storm drainage system and an appropriate oil interceptor;

- The construction plant used should be regularly inspected for leaks and fitness for purpose; and,

- An emergency plan for the construction phase to deal with accidental spillages will be contained within Environmental Management Plan. Spill kits will be available to deal with accidental spillages at the Proposed Development Site and at the areas of construction works associated with the Haul Route Options.

7.4.1.4 Groundwater and Surface Water Contamination from Wastewater Disposal



- A Wastewater holding tank will be provided at the temporary site compound for the Proposed Development Site, maintained by the providing contractor, and removed from site on completion of the construction works;

- Sewage will be removed twice weekly (or more frequently if required) by a licenced contractor to a designated Wastewater Treatment Plant for treatment and disposal;

- Water supply for the site office and other sanitation will be brought to site;

- No water will be sourced on the site, or discharged to the site.

- No waste water facilities are required at any of the areas where construction work is required associated with the Haul Route Options due to short duration (1-2days) for works at these sites.

7.4.1.5 Release of Cement-Based Products



- At the Proposed Development Site, seal/line sub-soil and bedrock by laying a proprietary geosynthetic clay liner where infrastructure is to be provided directly on top of bedrock or where the thickness of sub-formation overburden is less than 0.6m.

- No batching of wet-cement products will occur at the Proposed Development Site. Ready-mixed supply of wet concrete products and where possible, emplacement of pre-cast elements, will take place;

- Where possible pre-cast elements for culverts and concrete works will be used;

- No concrete will be used at those areas where construction works are required for the Haul Route Options;

- No washing out of any plant used in concrete transport or concreting operations will be allowed at the Proposed Development Site;

- Where concrete is delivered to the Proposed Development Site, only the chute need be cleaned, using the smallest volume of water possible. No discharge of cement contaminated waters to the construction phase drainage system or directly to any artificial drain or watercourse will be allowed. Chute cleaning water is to be tanked and removed from the site to a suitable, non-polluting, discharge location;

- Use weather forecasting to plan dry days for pouring concrete; and,

- Ensure pour site is free of standing water and plastic covers will be ready in case of sudden rainfall event.




7.4.1.6 Potential Impacts on Hydraulic Capacity of Local Watercourses



- No disturbance/production to the Hydraulic Capacity of existing drains shall be carried out.

- Designated working area to be specified so as to limit the extent of activity of plant and machinery.

Mitigation by Design – Proposed Development Site:

The proposed mitigation measures will involve the provision of attenuation ponds as part of a SUDs approach to stormwater management.

Best practice suggests that attenuation ponds will be provided for the difference in pre-development and post-development volume from a 100-year return 24h duration. From Table 7.10 above, the volume of attenuation required is 2,001m3. The drainage layout (Drawing 5279-PL-102, Sheet 1 of 2) shows a total of 11 No. sets of Silt/attenuation ponds. The attenuation ponds shall have an average capacity of 182m3 each, typically 13.5 x 13.5m in area, 1m water depth.

Mitigation by Design – Haul Route Options:

Given the limited scale of constructed works associated with the Haul Route Options, no specific design mitigation measures are proposed.

7.4.1.7 Potential Impacts on Hydrologically Connected Designated Sites


The proposed mitigation measures for protection of surface water quality which will include silt curtains, buffer zones and drainage control measures (i.e. interceptor drains, swales, settlement ponds) will ensure that the quality of run-off from Proposed Development Site and those areas where construction works are required with the Haul Route Options will be very high.

7.4.1.9 Potential Groundwater and Surface Water Impacts due to the Grid Connection Cable Works at Proposed Development Site



- Refuelling will only take place within the designated refuelling area within the temporary compound.

General Best Practice Pollution Prevention Measures will also include:

- No overnight parking of machinery is permitted in this area;

- No concrete truck chute cleaning is permitted in this area;

- Works will not take place at periods of high rainfall, and shall be scaled back or suspended if heavy rain is forecast;

- Plant will travel slowly across bare ground at a maximum of 5km/hr. Bog mats will be employed to protect tracked areas as necessary. Machinery routes will be designated by the main contractor when appointed so that plant and machinery only travel on designated routes to minimise impacts;

- Any excess construction material shall be immediately removed from the area and taken to a spoil storage area; and,

- One or more lines of silt fences shall be placed between the works area and adjacent drains.

Mitigation Measures relating to the use and storage of fuels and chemicals in terms of groundwater protection:

- No maintenance of construction vehicles or plant will take place along the grid connection works areas but will take place at designated areas




such as the temporary compound;

- Fuels or chemicals will only be stored at suitably bunded storage areas;

- The plant used will be regularly inspected for leaks and fitness for purpose;

- Spill kits will be available to deal with accidental spillage in and outside the re-fuelling area; and,

- Adherence to Best Practice Measures in Section 5 of OCEMP.

7.4.1.10 Potential Groundwater and Surface Water Impacts due to the Internal Cable Works at Proposed Development Site



- Avoid physical damage to surface water drains.

Mitigation Measures relating to the use and storage of fuels and chemicals in terms of groundwater protection:

- Re-fuelling will take place at a specific designated re-fuelling area in the wind farm site. This re-fuelling area will be bunded appropriately for the fuel usage volume for the duration of the construction;

- No maintenance of construction vehicles or plant will take place along the internal cabling works areas but will take place at designated areas such as the temporary compound;

- Fuels or chemicals will only be stored at suitably bunded storage areas;

- The plant used will be regularly inspected for leaks and fitness for purpose;

- Spill kits will be available to deal with accidental spillage in and outside the re-fuelling area; and,

- Adherence to Best Practice Measures in Section 5 of OCEMP.

7.4.2 Operational Phase Impacts

7.4.2.1 Replacement of Natural Surface with lower Permeability Surfaces



The operational phase drainage system will be designed in accordance with SUDS principles and will be installed and constructed in conjunction with the road and hardstanding construction work as described below:

- Interceptor drains will be installed up-gradient of all proposed EIA Development infrastructure during the construction phase to collect clean surface run-off, in order to minimise the amount of run-off reaching areas where suspended sediment could become entrained. It will then be directed to areas where it can be re-distributed over the ground by means of a level spreader;

- Swales/road side drains will be used to collect run-off from access roads and turbine hardstanding areas of the site, likely to have entrained suspended sediment, and channel it to settlement ponds for sediment settling;

- Check dams will be maintained along sections of access road drains to intercept silts at source. Check dams will be constructed from a 4/40mm non-friable crushed rock;

- Settlement and attenuation ponds, emplaced downstream of road swale sections and at turbine locations, will buffer volumes of run-off discharging from the drainage system during periods of high rainfall, by retaining water until the storm hydrograph has receded, thus reducing the hydraulic loading to watercourses; and,

- A Drainage Maintenance Plan will be put in place at commencement of the Operational Phase. All drains, silt ponds and attenuation ponds will




be inspected bi-annually and, in addition, following a significant rainfall event (25mm or greater in any 24 hour period). The results of all inspections will be documented and the findings of any inspections will be incorporated into ongoing maintenance works programmes such that any remedial works are completed within a three-month period.

8. Air and Climate 8.6 Mitigation Measures and Residual Effects

8.6.1 Construction Phase Mitigation

The main potential impact during the construction phase of the EIA Development will be from dust nuisance at sensitive receptors close to the site. Good practice site procedures will be followed by the appointed contractor to prevent dirt and dust being transported onto the local road network. Good practice site control measures are likely to include the following:

- Approach roads and construction areas will be cleaned on a regular basis to prevent mud built-up and from migrating around the site and off-site;

- Wheel wash facilities will be provided near the site compound to prevent mud/dirt being transferred from the site to the public road network;

- A mechanised road sweeper will be used at the public road entrance and along the access road to the Killala Business Park if required;

- ‘Damping down’ will be used if dust becomes an issue on any part of the site;

- Vehicles delivering materials to the site will be covered appropriately when transporting materials that could result in dust, e.g. crushed rock or sand;

- Ready-mix concrete will be delivered to site and it is envisaged that no batching of concrete will take place on site;

- Speed restrictions on access tracks will be implemented to reduce the likelihood to dust becoming airborne;

- Public roads along the construction haul route will be inspected regularly and if dirt/mud is identified that could result in dust generation then the road will be cleaned as necessary;

- Weather will be monitored so that during periods of dry weather when dust is likely to become airborne, sporadic damping down of access tracks (and other surfaces as necessary) will be undertaken;

- Stockpiling of materials will be carried out in such a way as to minimise their exposure to wind where possible and damping down will be carried out where needed; and

- A complaints procedure will be implemented on site where complaints will be reported to the site manager, logged and appropriate action taken.

9. Noise 9.5 Mitigation Measures

9.5.1 Construction Noise Mitigation

However, general guidance for controlling construction noise through the use of good practice given in BS 5228 will be followed. During construction of the EIA Development, operations shall be limited to working times incorporated in any planning permission.

9.5.2 Operation Phase Mitigation

A warranty will be sought from the manufacturer of the turbine selected for the EIA Development in order to confirm that an assessment of noise would result in noise levels at all receptor locations being less than or equal to the noise limits set out in this section. The warranty will include the provision




that there will be no clear tonal components audible at any receptor.

10. Shadow Flicker and EMI

10.2.5 Mitigation Measures and Residual Effects (Shadow Flicker

No formal mitigation is proposed at this stage.

In the event that reports or complaints of shadow flicker are received by the Developer/ Site Operator or the Council, and an appropriate investigation confirms an occurrence, initial measures may include more detailed assessment at potentially affected locations. This would involve a line of sight assessment, as well as window sizes, use of rooms and existing natural screening assessments. Should additional screening be required, residents can be consulted on the possibilities of trees being planted and/or blinds or curtains installed. Another option would involve shutting down the turbines at appropriate times. It is possible to use a control system installed as part of the wider turbine control systems to calculate, in real time, whether shadow flicker may affect a property, based on pre-programmed co-ordinates for the properties and wind turbines and the intensity of sunlight, as measured by a device attached to a turbine tower. When the control system calculates that the sunlight is bright enough to cast a shadow, and that a turbine shadow falls on a property, it would automatically shut the turbine down, restarting it when the shadow has moved away from the property.

Overall shadow flicker effects are predicted to be low, and it is proposed that turbines can be programmed to shut down under specific prevailing weather and seasonal conditions to protect residential amenity interests where an impact has been identified.

10.3.4 Mitigation Measures and Residual Effects (EMI)

10.3.4.1 Construction Phase

Devices used during the construction phase of the EIA Development are required by Irish and European law to comply with the EMC Directive 2014/30/EU. Compliance with this directive will mean that the electromagnetic emissions from these devices will not likely cause interference to other equipment.

10.3.4.2 Operation Phase

10.3.5.2.1 Television Reception

Whilst significant effects have not been identified, the Applicant intends to agree a Protocol with RTE to ensure any effects are minimized and /or remediated. Additional mitigation options, such as technical solutions including retuning of receiving equipment or provision of satellite or cable services are available, and commonly used to mitigate these effects from wind farm developments.

11. Landscape and Visual

11.5 Mitigation Measures and Residual Effects

Some of the general mitigation measures that will be undertaken to make the development less intrusive and less eye catching on a localised level include:

- Choice of Blade Arrangement – The current industry standard of a three-blade rotor design, has been adopted in this design;

- Tower Design – The turbine towers are single tapering columns; these are considered more attractive than the lattice structures used in early American designs;

- Turbine Colour – The colour will be industry standard light grey semi-matt finish;

- Sunlight Reflection – The surface coating of the blades will be a semi-matt finish, which is designed to minimise the possible effect of flashing and glinting when rotating blades reflect direct sunlight; and

- Counter Rotation – This occurs where blades on different turbines rotate in opposite directions and are considered to appear disordered. All turbines will only rotate in the same direction to ensure that




counter rotating does not occur.

12. Material Assets - Mitigation measures for the majority of topics covered in the assessment are included in their respective chapters or formed part of the EIA Development design and so are not listed here.

12.9 Air Navigation

12.9.4 Mitigation Measures

Although no significant impacts are predicted, it is standard policy of the IAA Safety Regulation Division to request an Obstruction Survey for wind farms. This Survey is designed to collate data on the height, latitude, longitude, elevation and dimensions of any structures or feature that the IAA deems necessary. An Obstruction Survey will be undertaken at the pre-construction phase in agreement with the IAA.

However, private air traffic, which may not follow designated routes to or from Ireland West or Sligo airports, may use this airspace and it is considered prudent to fix some wind turbines with flashing warning beacons before they are erected. The IAA will be consulted on which turbines require these beacons, the type of beacon and their installation prior to the erection of the turbines. The IAA and the Local Authority will be informed of the coordinates of the as constructed positions of the turbines and the highest point of the turbine

13. Archaeology and Cultural Heritage

13.5 Mitigation Measures and Residual Effects

13.5.1 Construction Phase

The following mitigation measures will be implemented during the construction phase:

- All ground disturbance associated with the construction of the proposed EIA Development are recommended to be monitored by a suitably qualified archaeologist working under license from National Monuments, Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs;

- Should archaeological features, finds or deposits be encountered during monitoring the National Monuments Service and all relevant authorities will be notified immediately. Preservation in-situ or preservation by record (excavation) may be required;

- A temporary fence, will be erected around the recorded monuments MA022:029, MA022:031, MA022:030 and MA022:033 (with a 30m buffer as a minimum) so that they are not impacted by construction traffic. The erection of fencing will be supervised by an archaeologist; and

- Transportation of turbine infrastructure to the site will take due care and diligence when travelling over and under bridges recorded in the National inventory of Architectural Heritage.

14. Traffic and Transport

14.5 Mitigation Measures

- Traffic movements will be limited to 08:00 - 18:00 Monday to Friday and 08:00 – 13:00 on Saturdays with no movements on Sundays or Bank Holidays, unless otherwise agreed in writing with the relevant local authority for example, in the case of abnormal loads which may need to be undertaken at other times. Furthermore, bulk deliveries will be scheduled to avoid peak times around the morning and evening. This will aim to avoid HGV movements arriving to site during peak hours which could have an impact on local residents on their commute/school run. Construction personnel will be encouraged to car-pool, or to travel to site in minibuses;

- Wheel wash equipment will be used at the exit to the site on the access track near the temporary compound to prevent any mud and/or stones being transferred from site to the public highway. All drivers will be required to see that their vehicle is free from dirt and stones prior to




departure from the construction site;

- In addition, any dust generating activities will be minimised where practical during windy conditions, and drivers will adopt driving practices to minimise the creation of dust. Where conditions exist for dust to become friable, techniques such as damping down of the potentially affected areas will be employed;

- Finally, to reduce dust emissions, vehicle containers/loads will be covered during both entrance and egress to the site where required; and

- During the construction phase, clear construction warning signs will be placed on the R314 and on the Mullafarry Road as necessary, which will advise road users of the presence of a construction site and of the likelihood of vehicles entering and exiting the Proposed Development Site. The site entry point will also be appropriately signed. Access to the construction site will be controlled by on site personnel and all visitors will be asked to sign in and out of the site by security / site personnel on entering and exiting the site. All site visitors will undergo a site induction covering Health and Safety issues at the Contractor’s temporary compound and will be required to wear appropriate Personal Protective Equipment (“PPE”) while on-site.

Appendix F.1: Natura Impact Statement

Mitigation measures for provided in the NIS are detailed in Section 5: Biodiversity and Section 7: Water and so are not listed here.

Appendix L: Outline Construction Environmental Management Plan (OCEMP)

5.1 Mitigation Measures

5.1.1 General Procedures

Appropriate induction will be provided to all site workers, including providing key workers with a copy of the CEMP, including what to do in an emergency, and chemical safety data sheets.

The use of task appropriate Personal Protection Equipment (“PPE”) shall be mandatory for all site works, and will include (where necessary) overalls, dust masks, gloves, protective footwear, protective eyewear, and protective hearing equipment.

Records are to be kept of all plant, machines and materials used on site, which are to be maintained at regular intervals.

5.1.2 Storage of Fuels, Oils, and Chemicals

As per Best Practice Guidance (PPGCS005 - Section 3.3), all fuels, oils and chemicals on site must have secondary containment system of a minimum of 110% capacity and will be located more than 50m from any drainage ditch and more than 50m from any watercourse (i.e. outside of the water course buffer).

During construction, all fuels and oils shall be stored in the designated areas only, including mobile bowsers, within the Temporary Construction Compound. If generators are used on site, these shall be bunded (the bund shall be capable of containing a minimum of 110% of the fuel tank’s capacity). The bund shall be kept empty of water.

Where chemicals are required on site, they must be placed in an appropriate bund to prevent ground contamination. All chemicals must be stored in a correctly marked container clearly identifying the contents. Where labels are worn off, then they must have a new label placed on them or the contents transferred to a correctly marked container. All safety data sheets for all chemicals should be filed on site as part of the CEMP.

Appropriate spill kits must be kept and maintained by the Contractor on site to, in the Temporary Construction Compound and in the mobile refuelling vehicle for use in the event of a spillage. These must be made available at




all times to all personnel.

5.1.3 Plant Refuelling During construction, fuel and oil deliveries shall take place within the designated refuelling area within the Temporary Construction Compound, and within the crane hardstand areas only, which are located in an area outside of watercourse buffers (discussed subsequently). The Contractor shall supervise site deliveries to see that the correct amount of material is delivered to the correct tank and that the level is checked prior to refilling to avoid spillage.

Where refuelling of vehicles on site is necessary, the following guidelines will be strictly adhered to:

- Mobile refuelling plant will be filled in a designated area, on an impermeable surface well away from any drains or watercourses;

- A spill kit will be stored (and clearly marked) in the mobile refuelling plant;

- A spill kit will be stored (and clearly marked) near refuelling areas;

- A bunded tank / bowser will be used with capacity of the bund to be a minimum of 110% of the fuel storage capacity;

- Vehicles will never be left unattended during refuelling and drip trays should be located under all static plant vehicles;

- Hoses and valves will be checked regularly for signs of wear, and will be turned off and securely locked when not in use;

- Vehicles will not be left running unnecessarily and low emission fuels will be used where possible; and,

- Diesel pumps and similar equipment will be checked regularly and any accumulated oil removed for appropriate disposal.

5.1.4 Waste Management

Waste management will follow the philosophy of “Reduce, Re-Use and Re-Cycle” as indicated in Figure L.1. Methods to reduce the amount of waste generated in the first instance, together with the re-use and recycling of wastes must be considered. All waste must be stored in designated areas that are isolated from surface drains, prior to removal from site. Contractor’s work areas shall be kept tidy. Burning of waste on site will be prohibited.

Chemical containers, used oil and filters, solvents, paints, electrical items, contaminated materials and hazardous refuse are all classified as “special waste” and as such, must be stored in a bunded area away from watercourses and disposed of by licensed waste contractors in a controlled manner.

The site Contractor has a ‘Duty of Care’ as a producer of waste. Whilst waste is on site it remains under their control until passed to a registered waste carrier with appropriate and valid permits. The waste carrier shall have a waste collection permit issued by the National Waste Collection Office (based in Tullamore in Offaly County Council), and shall take the waste to a similarly licensed disposal facility. The Contractor will see that the permit of the waste contractor collecting the waste is valid and that Appendix 6 of the waste permit is completed. Appendix 6 should state to which site the waste contractor is bringing the waste. The waste contractor should have their valid permit with them at all times. The construction Site Manager will record that the waste permit is valid and that Appendix 6 of this permit states which authorised waste facility the waste is being brought to by the waste contractor.




It is recommended that the contractor check the national waste contractors permit office at www.nwcpo.ie for permitted waste contractors.

A Site Waste Management Plan is available in Appendix C of this report and identified the types of waste which is likely to be generated at the Proposed Development Site and the measures that need to be undertaken to minimise, re-use and recycle it.

5.1.5 Emergencies In the event of a liquid spill occurring on the construction site, the Contractor shall cease work in the vicinity immediately and follow the lines of communication outlined in Appendix B of this report – emergency preparedness and response plan.

Contractor’s trained personnel shall don appropriate PPE and do as follows:

- If spillage is flammable, extinguish all ignition sources;

- Locate the source of the pollution and stop/contain any further flow if possible;

- Immediately deploy the spill kit in accordance with the manufacturer’s instructions;

- Clean up the spill; and,

- All used spill kit materials should be disposed of in the proper manner as outlined in spill summary procedures.

The Site Manager shall contact:

- The Client;

- Environmental Protection Agency (“EPA”) 24 hour emergency incident line 1890 33 55 99;

- Inland Fisheries 24 hour pollution line 1890 34 74 24; and

- Contact shall initially be attempted to be made within 30 minutes of the spill occurring unless it is not possible to do so.

The pollution hotline number shall be referenced in the construction site rules and displayed in the Site Office and in the Emergency preparedness & response plan.

Each Contractor working with controlled substances shall supply appropriate spill kits which shall be kept on site. The spill kits shall be made accessible at all times to all site personnel.

In the event of a fire all personnel must evacuate the site and assemble at the Temporary construction compound or the site entrance, or other designated location. The Site Manager is responsible for calling the Fire Service, who will handle the emergency.

5.2 Management of Earthworks and Drainage

5.2.1 Mitigation Measures

Management & Induction

An Ecological Clerk of Works will undertake a minimum of 1 weekly visit during the construction stage of the EIA Development to see to the successful implementation of the mitigation and enhancement measures which are stated both in the REIS / EIAR and in this report. Particular attention will be payed to the implementation of adequate buffer zones for both water features and badgers.

All site personnel (contractors, sub-contractors and staff) will be made aware of their environmental responsibilities at the site induction prior to being allowed to work on site, and through the production of activity specific method statements outlining environmental requirements for sub-




contractors, which will include environmental emergency response procedures to deal with pollution events, should they occur (refer to Appendix B).

Environmental management actions will be notified to all staff as part of their site induction. Records will be kept by the contractor of their attendance at site inductions.

Buffers at Watercourses

In order to protect sensitive hydrological receptors - exclusion buffers will be applied to the existing drainage channels and the streams near the Proposed Development Site (unless they must be crossed to reach the EIA Development infrastructure). The buffer comprises an offset of 20m in relation to drainage channels (in compliance with published guidance for works in comparable circumstances from Pollution Prevention Guidance PPG5 “Works and maintenance in or near water”) and an offset buffer of 50m in relation to streams and the drainage ditch along the northern boundary of the site which feeds into the Magherabrack stream.

The impositions placed on lands within the buffer zone are as follows:

- There will be no works carried out within 50m of streams or rivers;

- There will be no works carried out within 20m of wet ditches;

- No development of infrastructure, placement of any temporary infrastructure, excepting unavoidable works associated with the access tracks traversing a drainage channel, and grid connection cabling works;

- No unnecessary stripping/removal of vegetation;

- No spoil deposition or stockpiling of excavated material; and,

- No storage or use of chemicals, fuels, or other lubricants.

Management of Surface Water (Natural & Construction Runoff) – Construction Phase, Operation Phase and Decommissioning phase

Specific drainage measures will include the following measures:

- Guidance – Drainage to be constructed on site in line with the relevant legislation and guidance detailed in REIS / EIAR Section 6 and Section 7.

- Existing drainage ditches – To be retained in their existing state and will continue to intercept overland flows.

- Landscaping – Local minor landscaping may be used to provide that runoff is contained within the Proposed Development Site, will be stored and attenuated in open swales or recharged back to ground locally below the swales.

- Site Entrance – A watercourse across the entrance to Killala Business Park is already bridged/culverted and sufficient capacity within the access track footprint will see that no runoff to the public road or this watercourse from the construction of the EIA Development.

- New access tracks – Site tracks shall not be paved, and will be constructed from local stone, to minimise alteration of the habitats on the site and to allow for rapid re-growth on completion of the works. The new access tracks will include roadside drains formed on the upslope side of the track and tracks shall be cross-sloped in order to encourage runoff into these drains.

- Track drainage ditches – To include soakaway pits at intervals along the




ditch to facilitate improved infiltration of surface water runoff to ground.

- Soakaway – A suitably sized soakaway area will also be constructed surrounding the crane hardstands, substation compound and other hardstands to facilitate infiltration of roof runoff to ground (minimising surface water runoff from the site).

- Internal cabling – The trench for cabling shall be back-filled on completion (in general, short sections shall only be open for short periods of time). Within agricultural land, the turf (sod) shall be set aside and reused during reinstatement to assist with rapid vegetation re-establishment. This shall assist in preventing any increase in runoff rates along the cable route.

- Decommissioning Drainage – All SuDs shall remain in place until construction reinstatement and/or decommissioning activities associated with soil disturbance and runoff issues are completed.

- Drainage Ditch Maintenance – The site layout is as such that there will be a minimum of a 20m buffer between the proposed Development and the existing drainage channels within the Proposed Development Site.

- Culvert Installation – The installation of any required culverts along the site access tracks, in order to provide access within the Proposed Development Site over an existing drainage channels will be undertaken in line with the following measures;

• The culvert length will be sufficient that there is no risk of material falling from the new access track into the drain and that pollution prevention and health and safety measures (such as splash fences and safety berm) can be incorporated without the need for further works.

• Work will be undertaken offline or by employing an over-pumping approach.

• In the latter case, the drainage channel will be dammed upstream of the proposed crossing location using sandbags or similar in order to provide a dry working environment. Dammed flows will be pumped out of channel and returned directly to the drain shortly downstream of the works location. Erosion protection shall be placed at the point of pump return. All pumping will be carefully planned, installed and monitored.

• Geotextile silt fences shall be installed adjacent to the drain bank upstream and downstream of the crossing location in order to filter contaminated runoff that may be caused by plant movement associated with the works. A sequence of in-channel geotextile check dams will be installed within the drain channel downstream of the cable crossing location and downstream of the pump-return.

• Over pumping and upstream dams shall be removed. Downstream in-channel filtration check dams shall be retained and renewed as necessary in order to trap sediment until any residual washout of sediment from the exposed excavation has stabilised to a normal (pre-construction) level.

- Temporary Construction Compound/ Car park/ Storage Areas – Additional temporary measures should be implemented to help attenuate increased surface water flows from these areas as they are




likely to have a high silt loading due to excavations, track aggregate and traffic. Temporary swales should be installed on the downslope boundary of the temporary construction compound.

Exposed Ground and Stockpiles

In accordance with BS6031: 2009 Code of Practice for Earth Works, land disturbance will be kept to a minimum and disturbed areas will be stabilised as soon as possible. Soil handling will be undertaken with reference to best practice guidelines available. Soil extracted on site with no certainty about its future use is considered ‘waste’ and guidance is available in this regard (Guidance on the Waste Management (Management of Waste from the Extractive Industries) Regulations 2009). It is recommended that:

- Where feasible all excavated soil/rock will be retained on site;

- Where soil excavated has been contaminated historically this will be disposed of by a licensed waste disposal contractor;

- Soil excavation should be undertaken during dry periods whenever possible;

- The amount of exposed ground and soil stockpiles will be kept to a minimum;

- Stockpiles in place for an extended period of time will be allowed to re-vegetate naturally;

- Any short-term stock piles will be sealed; and

- Silt fences will be used alongside all exposed ground where there is a pollution risk.

The following shall be conducted in relation to soil on site:

- Movement of Materials – This shall be minimised in order to reduce degradation of soil structure and generation of dust.

- Contaminated Materials – Any contaminated materials that are discovered on the site shall be disposed of by a licensed waste disposal contractor.

- Compacted Soil – Any soil that is compacted on the site shall be remediated by way of chisel ploughing or pole forking post construction.

- Verges – grass cover is to be reinstated as much as possible adjacent to access track and hardstand verges in order to maximise bio-retention.

Concrete

Concrete will not be allowed to enter watercourses under any circumstances, and drainage from excavations in which concrete is being poured will not be discharged directly into existing field drains or watercourses without appropriate treatment and consent from the relevant authority. Delivery trucks, tools and equipment will be cleaned at the wheel wash facility located near the entrance or temporary construction compound and within the site boundary.

There will be no use of wet concrete within 20m of drainage ditches at the site, or within 50m of any stream. If required, washing out and cleaning of concrete lorry chutes only will be carried out in a clearly marked contained area in the temporary site compound or at each crane hardstand as far from any drain or watercourses as practical. A wash out pit will be located adjacent to the temporary site compound and/or substation compound for




concrete works in these areas. Lined washout pits will be used to prevent infiltration to groundwater. The location of wash down areas is to be well signposted and wash out at any significant concrete pours will be supervised.

Weather Conditions

Due cognisance should be given to prevailing and predicted weather conditions when planning works on site. Where possible, significant earth moving and wet concrete works should avoid periods of heavy rainfall to minimise pollution risk. Likewise, during very dry weather conditions bowers may be used to water areas to minimise the quantity of dust.

Washing Plant and Machinery

With the exception of concrete lorry chutes which will be washed down into the washout pit(s), plant and machinery will not be washed down on site unless specific containment measures have been established.

Avoiding Soil Compaction

Soil compaction will be limited during construction of the EIA Development through the limiting of machinery movements to designated routes along and adjacent to the access tracks, hardstand and foundation areas, substation compound, temporary construction area, and ancillary works area such as soil deposition and drainage. Once formed, any HGVs visiting the construction site to deliver goods will be restricted to the site access tracks and other hard surfaced areas.

Documents

APPENDIX J: SUMMARY OF PROPOSED MITIGATION AND …...safety authorities and prepare the pre-tender health and safety plan and ensure that a construction phase health and safety plan