Chapter 17 Summary of Mitigation

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TROSTON LOCH WIND FARM

EIA Report – Volume 1 – Main Text

Chapter 17 Summary of Mitigation

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CHAPTER 17

17 SCHEDULE OF MITIGATION ... 17-2

17.1 Introduction ... 17-2

17.2 Schedule of Mitigation ... 17-3

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Chapter 17 Troston Loch Wind Farm

Summary of Mitigation EIA Report

Arcus Consultancy Services Ltd EDF Renewables

Page 17-2 February 2019

17 SCHEDULE OF MITIGATION

17.1 INTRODUCTION

This Chapter of the Environmental Impact Assessment Report (EIA Report) provides a

summary of mitigation measures that have been proposed with the EIA Report to

prevent, reduce or offset the effects associated with the Troston Loch Wind Farm (the

Development).

Mitigation measures have been integral to the design evolution of the Development as

outlined in Chapter 3 Site Design. The overall aim of the design strategy was to

create a wind farm with a cohesive design that relates to the surrounding landscape

whilst taking account of the environmental characteristics of the area in which the

Development is located (the Site), for example priority habitats and key ornithological

species, cultural heritage features and hydrological resources.

Table 17.1 presents a schedule of mitigation measures for the Development listed

according to the relevant environmental topic, which would be applied during the

construction and operation of the Development.

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17.2 SCHEDULE OF MITIGATION

Table 17.1 Schedule of Mitigation

Environmental

Subject Area Mitigation Proposed Timing

Chapter 4 – The

Development Micrositing

A micrositing allowance of 50 metres (m) in all directions is proposed for all infrastructure. This is to allow for a degree of flexibility should unsuitable ground conditions be encountered or in the event of

environmental constraints identified during pre-construction surveys. Any changes will be subject to approval of the Ecological Clerk of Works (ECoW) with specialist archaeological advice as required.

Pre-construction

Construction and Environmental Management Plan

A Construction and Environmental Management Plan (CEMP) will be produced in consultation with the Scottish Ministers, Dumfries and Galloway Council (the Council), Scottish Natural Heritage (SNH) and the Scottish Environment Protection Agency (SEPA).

The CEMP will collate all measures required during construction to avoid and minimise environmental harm, it would include:

• Site induction and training;

• Working hours;

• Enabling works;

• Surface water and drainage management;

• Waste management;

• Wastewater and water supply monitoring and control;

• Oil and chemical delivery and storage;

• Water quality monitoring;

• Ecological protection measures;

• Construction noise management;

• Cultural heritage protection measures;

• Handling of excavated materials;

• Forest and woodland management;

• Reinstatement and restoration;

• Traffic management;

Pre-construction and during construction

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• Environment incident response and reporting;

• Use and extent of borrow pits;

• Method statements and risk assessments;

• Final drawings and details of access tracks; and

• Final drawings and details of turbine foundations.

Contractors will also be required to adhere to the following to minimise environmental effects of the construction process:

• Conditions required under the Consent and deemed planning permission;

• Requirements of statutory consultees including SEPA and SNH;

• Any other relevant mitigation measures identified in the EIA Report; and

• All relevant statutory requirements and published guidelines that reflect ‘good practice’.

The Applicant will require that all contractors follow the requirements of ISO14001 - ‘Environmental Management Systems - Specification and Guidance for Use’, and will provide the following:

• Details of main contractor’s corporate environmental policy;

• Assessment of environmental impacts during construction;

• Procedures and controls for environmental management;

• Environmental monitoring details and reporting systems;

• Schedule of contractual and legislative requirements; and

• Schedule of relevant consents, licences and authorisations.

The CEMP will be prepared in consultation with the relevant statutory bodies including SEPA, SNH and the Council prior to commencement of construction, and performance against the CEMP will be monitored by the Applicant’s Construction Project Manager throughout the construction period.

In addition, the CEMP will typically be supported by the following documents which apply to the construction process:

• Water Protection Plan;

• Peat Management Plan;

• Pollution Prevention Plan;

• Traffic Management Plan;

• Site Waste Management Plan; and

• Restoration Plan.

Chapter 6 – Embedded Mitigation Pre-submission

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Landscape and Visual The layout design of the Development is a vital part of the EIA process and is the stage where the biggest contribution can be made to mitigate potential landscape and visual effects, creating a wind farm which is appropriate for the existing landscape character and visual features of an area.

The design of the Development has evolved as part of an iterative process which has aimed to provide an optimal design in environmental, as well as technical and economic terms. Landscape and visual mitigation measures have been a central consideration in the design process that has evolved throughout the design process.

The design rationale adopted included:

• To ensure that the turbine layout appears as a simple form, which relates to the landscape character of the Site and its surroundings;

• To ensure that the design and layout of the turbines expresses the function of the Development as an energy generator as clearly as possible by avoiding complexity and visual confusion;

• To ensure the turbine layout relates to the scale of the landscape in which it is located;

• To ensure a visually balanced composition of turbines is achieved against the landscape, skyline and other cumulative wind farm developments;

• To respond to the various other environmental and technical constraints identified within the Site;

and

• To take account of relevant national, regional and local policy and guidance.

The proposed turbine layout has been designed to minimise the effect on the surrounding landscape and visual resource. As a consequence, the resulting turbine layout design presents a simple, well balanced image of the Development in the majority of views.

The location and management of construction activities has been carefully considered to minimise landscape and visual effects. Ground disturbance on-site would be restricted as far as practicable and any soil materials excavated would be retained on the site for re-use on areas to be re-vegetated following the construction phase.

The proposed borrow pits, substation, construction compound and tracks are positioned to minimise visual impact. The landform surrounding the Site limits the level of visibility of these infrastructure elements to elevated locations and where visible the design of these has been considered further to ensure they relate to the Site landform as far as possible taking advantage of on-site screening from localised landform and minimising the visual effect of these elements.

Chapter 7 – Ecology Mitigation by Design

Ecological features have been considered at all stages of the Development design, from initial feasibility to final layout. This has helped to avoid or greatly reduce impacts to Important Ecological Features. A critical design consideration has been the avoidance of habitats with high conservation value and groundwater

Pre-submission

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dependency, which has been largely achieved by siting the majority of the Development infrastructure in coniferous plantation and making use of existing forestry tracks.

In line with earlier sections the Applicant has committed to the production of a CEMP to the satisfaction of SNH and other relevant stakeholders, before construction commences which will take into account ecological interests.

Pre-construction

Pre-Construction Surveys

Pre-construction surveys for protected species will be undertaken to provide up-to-date information about the distribution and abundance of the protected species identified in the baseline and will be set out within the CEMP.

Specific surveys have been set out with respect to Bats and Otters, however the pre-construction surveys will cover a wider suite of protected species.

Pre-construction

Bats (Construction)

Construction may disturb two small bat roosts and so mitigation is proposed to avoid the potential for a legal offence. A pre-construction bat roost inspection and activity surveys will be undertaken at the two known roosts. The size and type of roost(s) will determine the need for and scope of mitigation and some options may require a licence from SNH. Given the current roost status, it is anticipated that a programme of sensitive working practices, such as vehicle speed restrictions and limits to night-time working, would provide sufficient safeguards.

Pre-construction and construction

Otters (Construction)

Pre-construction otters surveys will be undertaken to refine the scope of mitigation, which will be

developed in line with SNH good practice. Special measures will be implemented to minimise the potential for habitat fragmentation along the Troston Burn and these will include, but not be limited to:

• Sensitive design of watercourse crossings;

• Construction of the crossings should not take place simultaneously;

• Provision of escape measures from, or cover over, exposed excavations to prevent animal entrapment; and

• All construction work (excluding traffic movements) within 100 m of watercourse crossings must be authorised and, if necessary, supervised by the ECoW.

Fish Fauna and Aquatic Invertebrate Monitoring Plan

A fish fauna and aquatic invertebrate monitoring plan will be produced based on the baseline sampling sites and one additional control site. The suggested monitoring schedule shall cover the construction phase

Pre-construction, construction and post construction.

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and the first two years following completion. The plan will include the following two elements:

• Fish fauna – annual summer survey during construction and in the first two years after completion; and

• Aquatic invertebrates – annual spring/summer survey during construction and in the first two years after completion.

Ecological Clerk of Works

A suitably qualified and experienced ECoW will be appointed to provide ecological and environmental advice during construction, including the monitoring of compliance with the recommendations of this EIA Report and subsequent planning conditions.

Before construction begins the ECoW and project hydrologist will undertake a review of design and drainage plans to inform micro-siting up to 50 m (as specified in Chapter 4 The Development), to minimise impacts to sensitive habitats, and to inform habitat restoration works.

The ECoW will also monitor and advise on the implementation of pollution prevention and good working practices throughout construction to protect both terrestrial and aquatic ecosystems from accidental pollution.

Bats (Operation)

Good practice mitigation measures will be adopted to minimise the risk of bats colliding with operational turbines, in accordance with Natural England published guidance, as adopted by SNH. Turbines will have a 50 m separation distance between blade tips and high-value bat habitats, such as riparian features and forest edges. Although this offset has been included in the design of the Development, it will be maintained throughout the operational life of the Development by ensuring that tree regeneration and restocking does not encroach on the buffer.

Operation

Chapter 8 –

Ornithology Mitigation by Design

The design of the Development included design constraints to minimise the ornithological effects, using the baseline survey data to avoid locating turbines in proximity to any of the more ornithologically sensitive areas.

Specifically, this comprised avoiding locating wind turbines within 800 m of any known active peregrine nest, and within 500 m of any active black grouse lek.

No ornithological mitigation would be required for the operational phase of the Development.

Pre-submission

In line with earlier sections the Applicant has committed to the production of a CEMP to the satisfaction of SNH and other relevant stakeholders, before construction commences which will take into account ornithological interests.

Pre-construction

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Breeding Peregrine

There is a section of site track that lies within 600 m of a regularly-used peregrine nest site. In order to remove the possibility of any disturbance to breeding peregrine all construction works within 600 m of this nest site will be undertaken outside the March-August period.

Construction

Black Grouse

The timing of construction works will also mitigate potential impacts on lekking black grouse, by avoiding works around the hours of dawn and dusk during March-May within 750 m of the lek.

Construction

Construction Phasing

Designated working areas, storage areas and access routes would be identified at the commencement of the construction phase, so that site personnel do not stray close to nest sites. The proposed works will be phased so that access tracks are constructed early in the construction programme. Vehicular access would be restricted to designated routes throughout construction and operation as far as possible, thereby minimising potential disturbance of birds.

Breeding Bird Protection Plan

Several species specially protected under Schedule 1 of the Wildlife and Countryside Act from disturbance during breeding were recorded during the surveys, including goshawk, peregrine, barn owl and common crossbill. It will be essential to ensure that no Schedule 1 species are disturbed during the breeding season, particularly during the construction phase, so a Breeding Bird Protection Plan (BBPP) will be developed and implemented. Further surveys for goshawk, peregrine, barn owl and common crossbill and any other Schedule 1 species will be undertaken to inform the BBPP at fortnightly intervals through the breeding season (March-August) for the construction period. If any nesting Schedule 1 birds were found then potentially disturbing activities would be suspended for the breeding season within an appropriate zone (dependent on the location of the birds and the species involved, to be agreed with SNH and the Council, and following Ruddock and Whitfield 2007). The BBPP will also include measures to ensure the protection of all other nesting birds.

Where works affecting habitats that could be used by nesting birds must take place between March and August (inclusive), they will only be carried out following an on-site check for nesting birds by an

experienced ecologist. If this indicates that no nesting birds are likely to be harmed by the works, then the works will proceed. If nesting birds are found to be present, work will not take place in that area until the adult birds and young have left the nest. A protection zone will be clearly marked around the nest site to prevent accidental disturbance or damage.

Chapter 9 – Geology, Hydrology and Hydrogeology

Construction and Environmental Management Plan (CEMP) and Pollution Prevention Plan (PPP)

Good practice will be followed in all aspects of construction, operation and decommissioning, specifically

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through a Pollution Prevention Plan (PPP), which will be incorporated into a full CEMP, to be agreed with SEPA prior to the construction phase.

The PPP will set out measures to be employed to avoid or mitigate potential effects for all phases of the Development, and will also include an Incident Plan to be followed should a pollution event occur. This plan will be produced following consultation and agreement with SEPA and all appropriate personnel working on the construction site will be trained in its use. The Construction Project Manager will have specific

responsibility for implementation of the PPP.

Method statements will also be applied, which will follow the principles laid out in relevant SEPA Pollution Prevention Guidelines.

Embedded mitigation measures are set out within the draft CEMP (Technical Appendix A9.1), which sets out specific mitigation which relates to this Development. They comprise good practice methods and works that are established and effective measures to which the Applicant will be committed through the deemed planning permission.

The CEMP describes water management measures to control surface water run-off and Pre-construction and construction drain hardstandings and other structures during the construction and operation of the Development. This will form part of a Pollution Prevention Plan (PPP) to be implemented for the Development.

Good practice will be followed in all aspects of construction, operation and decommissioning, specifically through a PPP, which will be incorporated into a full CEMP, to be agreed with SEPA prior to the

construction phase.

The PPP will set out measures to be employed to avoid or mitigate potential effects for all phases of the Development, and will also include an Incident Plan to be followed should a pollution event occur. This plan will be produced following consultation and agreement with SEPA and all appropriate personnel working on the construction site will be trained in its use. The Construction Project Manager will have specific

responsibility for implementation of the PPP.

Peat Management Plan

An iterative design approach was taken for the Development layout to avoid siting infrastructure in deep peat where possible to minimise disturbance of peat soils and associated carbon losses. Further micrositing will be informed by detailed pre-construction ground investigations.

An outline PMP has been produced (Technical Appendix A9.4) which proposes reuses of the excavated peat are in line with the Scottish Renewables and SEPA Guidance, demonstrates that all the excavated peat will be reused on-site. The proposed reuses include the reinstatement of access track verges, cut and fill embankment slopes, reinstatement of turbine hardstandings, reinstatement of borrow pits and general landscape fill. No additional treatment of the peat is anticipated to be required, although methods to

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encourage regeneration of vegetation cover are likely to be required in some areas due to use of catotelmic peat to provide the top layer of reinstatement where there is a deficit of acrotelmic peat.

Methods for handling and storing excavated peat have been described in the Outline PMP to ensure its reuse potential is maximised and any carbon losses are minimised. Monitoring of the reinstated areas will be carried out to ensure that the environmental objectives are realised.

The outline PMP will be updated prior to construction once more detailed site investigation data and detailed engineering designs are available. The temporary peat storage locations will be identified in the updated PMP and will be guided by a geotechnical engineer. The updated PMP will also include detailed method statements and phasing of works, and will be agreed with SEPA and the planning authority prior to construction commencing.

Private Water Supplies

There is potential impact of one private water supply due to potential pollution incidents, erosion and sedimentation. Mitigation outlined in Private Water Supply Risk Assessment (Technical Appendix A9.2) as summarised below and CEMP (Technical Appendix A9.1).

The following mitigation measures will be implemented during the construction of the Development to address potential temporary material changes and ensure the protection of PWS:

• In case of emergency, provision of an alternative potable source during the construction will be made (in the form of a bottled water, water bowser or additional local PWS), if required;

• Adherence to PWS monitoring programme;

• Provision of, and adherence to, Private Water Emergency Response Plan (PWERP).

Should permanent material changes to PWS occur during any phase of the Development, the following mitigation measures will be implemented during the construction of the Development to ensure the protection of PWS:

• Provide an alternative PWS;

• Identify and assess alternate local PWS and connect; and

• Replace and upgrade existing treatment system.

The following checks will be carried out on site to ensure that procedures and measures to prevent pollution incidents are being implemented.

• ‘Good Practice’ is followed;

• Water quality monitoring is conducted at PWS with risk indicated as greater than ‘Negligible’ prior to construction as per PWS Regulations and WQ Regulations;

• A ‘watching brief’ of all excavations is conducted to ensure pipework not damaged;

• Silt fencing is used surrounding watercourses;

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• Silt traps are used downstream of excavations within watercourses and field drains;

• Spill kits are located at the correct locations;

• Spill kits include the correct inventory;

• An Emergency Contacts Notice is prominently displayed within the site accommodation;

• The Private Water Emergency Response Plan is displayed at the site accommodation within the Temporary Construction Compounds; and

• Operatives and sub-contractors have received training in the pollution prevention procedures.

Appropriate monitoring of the pollution prevention procedures will be undertaken by the Site Manager including measures to ensure that they are appropriate and are being adequately implemented.

The Site Manager will carry out a full review of any pollution incidents in order to determine the

effectiveness of the procedures and mitigation measures and the effectiveness of the response procedures and where necessary the will identify any areas where improvement is required.

Chapter 10 – Cultural Heritage and

Archaeology

Archaeological Fencing and Preservation by Record

Known archaeological features have been avoided, where feasible. Two archaeological features have been identified as extant and in close proximity to two turbine locations (Sites 6 and 42), these are common archaeological features of negligible to low sensitivity.

Following pre-construction felling the sites will be fenced off to prevent any accidental disturbance. It is acknowledged that the sites are within the micrositing allowance and could be directly affected. Should impacts be unavoidable due to ground conditions that necessitate micrositing towards the sites, consultation with the Council Archaeologist should occur prior to fence removal to ensure that an appropriate record has been created for the sites prior to any potential damage.

The requirement for, and scope and extent of, any mitigation would be agreed with the Council Archaeologist. The implementation of any agreed mitigation can be secured through an appropriately worded planning condition.

Construction

Chapter 11 – Noise Construction Noise

Construction noise will be limited in duration and confined to working hours as agreed with the Council and can therefore be adequately controlled through planning condition.

The good practice measures detailed below will be implemented to manage the effects of noise during construction operations, and will be required of all contractors:

• Operations shall be limited to times agreed with the Council;

• Deliveries of turbine components, plant and materials by HGV to site shall only take place by designated routes and within times agreed with the Council;

• The site contractors shall be required to employ the best practicable means of reducing noise

Construction

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emissions from plant, machinery and construction activities, as advocated in BS 5228;

• Where practicable, the work programme will be phased, which would help to reduce the combined effects arising from several noisy operations;

• Where necessary and practicable, noise from fixed plant and equipment will be contained within suitable acoustic enclosures or behind acoustic screens;

• All sub-contractors appointed by the main contractor will be formally and legally obliged, and required through contract, to comply with all environmental noise conditions;

• Where practicable, night-time working will not be carried out. Local residents shall be notified in advance of any night-time construction activities likely to generate significant noise levels, e.g., turbine erection; and

• Any plant and equipment normally required for operation at night (23:00 - 07:00), e.g., generators or dewatering pumps, shall be silenced or suitably shielded to ensure that the night- time lower threshold of 45 dB, LAeq,night shall not be exceeded at the nearest noise-sensitive receptors.

Blasting

In the event that stone is required to be extracted from borrow pits by blasting, the following process would be employed to ensure that the effects of blasting noise and vibration on nearby properties are adequately controlled:

Compliance with planning conditions specifying limits to vibration resulting from blasting, restrictions on times of blasting, and a requirement for vibration monitoring;

Trial blasting, using progressively larger charge loads, to establish maximum acceptable charge; and Provision of information on blasting to neighbouring residents.

Construction

Operational Noise

During the development of the layout of the wind turbines, the distance between the turbines and neighbouring properties was maximised as far as practicable, in order to minimise the effects of noise.

Operation

Chapter 12 – Traffic

and Transportation Traffic Management Plan

A Traffic Management Plan (TMP), which will be finalised prior to construction, will detail the selected route, as agreed with the relevant consultees including the Council and Transport Scotland which would then be implemented during the construction phase.

The document would detail the construction related traffic movements, the construction schedule and any necessary traffic management measures.

One potentially significant effect was identified relating to pedestrian amenity at the schools in Carsphairn, Dalmellington and Patna, for which specific measures which would be included within the TMP include the

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following:

• As far as reasonably possible deliveries should be scheduled outside of school opening and closing times;

• Drivers of all delivery vehicles to be made aware during induction of the presence of schools within these settlements and that formal pedestrian crossing facilities are not present; and

• Dalmellington and Carsphairn have part-time 20 mph speed limits which should be in force during school opening and closing times. Drivers to be made aware of this during induction and reminded that strict adherence to these speed limits is a legal requirement.

The TMP will also cover wider aspects in relation to construction related traffic in line with Good Practice and will contain further information regarding transport routes, road upgrades and working hours Chapter 13 – Forestry Wind Farm Forest Plan

Chapter 13 sets out the proposed Wind Farm Forest Plan which described how the existing Forest Plan has been adapted to incorporate the construction and operational of the Development whilst meeting the management objectives of the owner, the criteria of the UK Forestry Standard (UKFS) and the UK Woodland Assurance Standard 4th Edition (UKWAS), under which the woodlands would be managed if certificated. The proposed Wind Farm would be adopted as an approved Forest Plan in support of the operation of the Development.

Pre-construction, construction and operation.

Compensatory Planting

In order to comply with the Scottish Government's Control of Woodland Removal Policy, offsite

compensation planting would be required by the legal agreement attached to any consent. The Applicant is committed to providing appropriate compensation planting. The extent, location and composition of such planting to be agreed with the Forestry Commission Scotland (FCS), taking into account any revision to the felling and restocking plans prior to the commencement of construction.

Pre-construction, construction and operation.

Chapter 14 – Socio-

economics No mitigation measures proposed. N/A

Chapter 15 – Climate

Change Embedded Mitigation

An iterative design approach was taken for the wind farm layout to avoid siting infrastructure in deep peat where possible to minimise disturbance of peat soils and associated carbon losses. Further micro-siting will be informed by detailed pre-construction ground investigations.

Pre-submission

Peat Management

In line with Chapter 9 Geology, Hydrology and Hydrogeology a Peat Management Plan is proposed to ensure that the environmental objectives are realised.

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Maintenance Plans

Other mitigation measures will include the management of wind turbines to maintain operational efficiency during their lifetime. Maintenance plans for wind turbines would be developed to maximise turbine output and efficiency. Key performance indicators to monitor and track operational efficiency would be developed.

Operation

Chapter 16 – Other

Issues (Aviation) Aviation Lighting

The Development will have non-visible aviation lighting as it is located within a military low flying zone. The precise lighting scheme has not been finalised, this will be designed in accordance with the MoD

requirements.

Operation

Radar Mitigation

The predicted impact on the NATS radar will require technical mitigation. The mitigation strategy will be to provide in-fill radar coverage at the affected area to allow blanking of the affected radar. Specifically, the two options that will comprise the mitigation strategy are:

• Provision of a new local in-fill radar at Lowther Hill. The Lowther Hill PSR itself could be blanked, with coverage provided by the new radar and the Glasgow Airport PSR. Impacts on the Great Dun Fell PSR could be blanked or operationally accommodated.

• Blanking the Lowther Hill PSR and Great Dun Fell PSR, utilising in-fill coverage from:

o The Prestwick Terma radar; or

o NATS radar at Glasgow Airport and/or Orchardton.

The Applicant will continue to work closely with NATS in the development of the mitigation strategy.

Operation

Chapter 16 – Other Issues

(Telecommunications)

Telecommunication Interference

In the event that interference which is directly attributable to the Development is experienced, the Applicant will implement a suitable mitigation solution. Effects on telecommunications including television reception are unlikely, and technical solutions are readily available as suitable mitigation measures should adverse effects be present.

Operation