APPLICATION FOR FORESHORE LICENCE FOR MARINE ......Foreshore Application Report 11 August 2016 CeltixConnect 2 Site Investigation Works Job No. 1297 3.0 PROPOSED MARINE SURVEY & SITE

APPLICATION FOR FORESHORE LICENCE

FOR MARINE SURVEY & SITE INVESTIGATION WORKS AT DONABATE, CO. DUBLIN

August 2016

Foreshore Application Report 2 August 2016 CeltixConnect 2 Site Investigation Works Job No. 1297

Contents

1.0 Introduction…………………………………………………………………..p.3

2.0 Planned Survey Route in Irish Waters………………………….……….p.5

3.0 Proposed Marine Survey & Site Investigations………………………p.11

4.0 Survey Equipment Parameters…………………………………...……..p.19

5.0 Mapping……………………………………………………………....……..p.21

6.0 Marine Liaison & Consultations………………………………..……….p.22

7.0 Natura 2000 Sites / Appropriate Assessment……………...…………p.23

Appendices

Appendix 1 Appropriate Assessment Screening Report

Appendix 2 Route Position List

Appendix 3 Drawings


1.0 INTRODUCTION

1.1 Aqua Comms Ltd. is planning to construct a fibre optic cable, CeltixConnect 2,

extending from a landfall at Donabate in Co. Dublin to Blackpool/Lytham St Annes in

Lancashire in the UK.

Figure 1: Schematic of the Planned Network


1.2 Aqua Comms is a provider of bandwidth infrastructure services including dark

fibre, wavelengths and ethernet whose subsea fibre optic networks are designed to meet

the needs of content providers, cloud based networks, data centres, IT companies and

the global media. The company specialises in sub-sea telecoms and owns and operates

the AEConnect transatlantic cable (Killala to New York) and CeltixConnect which runs

from Dublin to Anglesey in the UK.

1.3 This document forms part of an application for a Foreshore Licence for Marine

Survey and Site Investigations. The works will be carried out predominantly by seaborne

electronic equipment (geophysical survey) with some selective sampling of the seabed

(geotechnical survey). Once the results of the survey are obtained detailed route

selection, design and method statements will be developed and a final Route Position

List (RPL) will be defined as part of a further submission for a Foreshore Licence for

installation works.


2.0 PLANNED SURVEY ROUTE IN IRISH WATERS

Inshore

2.1 The general line of the inshore section of the survey route is shown in Figure 2

on Admiralty Chart base. The figure shows the route running due east from Donabate

and then turning to a north-easterly direction to pass between the coastline and Lambay

Island. It then changes course to pass to the north of Lambay on a north-easterly

course. North of Lambay the route changes to a northerly direction so as to cross the

Eirgrid power and fibre optic cables and the Gas Interconnector 1 pipeline at

approximately right angles.

2.2 The route then turns back to a north-easterly direction (See Figure 3) and

crosses the 12 mile limit at approximately the 33km point along the route (KP33).

Figure 2 – Proposed Inshore Survey Route


Offshore

2.3 The general line of the offshore section of the planned survey route is shown in

Figure 2.

2.4 The key Turning Points (TP) for the survey route are shown below in Table 1.

Distances from the High Water Mark are shown as Kilometre Points (KP).

Table 1: Survey Route Turning Points (WGS-84)


Figure 3: Proposed Offshore Survey Route Landfall


2.5 The proposed landfall is at Balcarrick Beach at Donabate in North County Dublin

and the general location is shown in Figure 4.

Figure 4 – Landfall Location on Discovery Map


Landfall Location

2.6 The location of the landfall at Donabate is shown on the 6” to 1 mile Ordnance

Survey map and the 1/2,500 Ordnance Survey map in Figures 5 & 6 respectively.

Figure 5 –Landfall Location on 6” Ordnance Survey Map


Figure 6 –Landfall Location on 1/2,500 Ordnance Survey Map


3.0 PROPOSED MARINE SURVEY & SITE INVESTIGATIONS

3.1 The principal objective of the Marine Survey & Site Investigations is to ascertain

a feasible and safe route for cable system design, deployment, survivability and

subsequent maintenance with due regard for environmental considerations. The survey

will also allow decisions to be made about cable armouring and burial. The survey will

identify all route obstacles and cable hazards and provide detailed information to support

cable route and installation engineering. The site investigations will enable “ground-

truthing” of the seabed along the route.

3.2 The Survey Operations will be broken down into separate but overlapping areas,

with boundaries defined by water depth as specified in the technical requirements

outlined below. These water depth boundaries may be adjusted due to suitability of the

survey vessel(s) and survey gear. The surveys will ensure that there are no gaps or

unsurveyed areas between all of the different survey operations. For the marine route

survey, the sidescan ranges will be limited to those providing the greatest resolution

possible (able to resolve a 0.5m object or better), while following the required minimum

line spacing and overlap. The maximum speeds outlined will be used as guidelines.

Bathymetry data collection will, at minimum, comply with the requirements in this

document or with International Hydrographic Office standards (S44).

3.3 Survey line spacing is to be designed to ensure adequate coverage and overlap

of geophysical measurements.

3.4 For swathe bathymetry, “20% overlap” signifies that adjacent acquisition swathes

within the survey corridor overlap by 20%. For side scan sonar (SSS), 100% overlap

requires two passes of complete coverage over a given area of sea-floor, with the two

passes each ensonifying the sea-floor from opposite directions to ensure targets are

adequately imaged.


3.5 In order to ensure data continuity, the following overlaps between survey regions

are to be established as a minimum;

Landfall Site Survey to Diver Swim Survey – 50m overlap

Diver Swim Survey to Small Boat Survey – 50m overlap

Small Boat Survey to Offshore Survey – 500m overlap

Landfall Site Survey & Site Investigations

3.6 A non-intrusive topographic survey of the beach along the line of the proposed

cable route is required from the carpark to the low water mark.

3.7 Site Investigations at Donabate will consist of;

3 No. Trial Pits on the beach (2.5m depth, excavated and immediately

reinstated by JCB)

Bar probes on the beach (effectively non-intrusive investigation)

Bar probes from the Low Water Line to the 3 metre contour (effectively

non-intrusive investigation)

Diver Swim Survey

3.8 The Diver Swim Survey will extend from the low water line outward to the small

boat survey limits in accordance with the defined overlaps. A diver swim rope with 25m

gradations will be positioned along the route. Dive lines will be configured to provide

representative coverage across the entire survey corridor (nominally spaced at 125m).

3.9 Bathymetry will be measured by diver depth gauge at each 25m gradation.

Geomorphology will be determined by underwater video along the length of the diver

swim rope. The diver video will be undertaken along each line in the survey swathe;

divers will use a dive slate or other clearly written method to indicate Kilometre Point

(KP) and water depth at the specified gradations along the rope.


3.10 Tie lines will be nominally spaced at 125m parallel to shore and will verify primary

survey data within the Diver Swim area. Bathymetry and seabed composition are to be

noted along tie lines. A minimum of 2 tie lines will be performed.

3.11 The Diver Swim Survey will also investigate and identify any obstacles found

during the Small Boat Survey up to safe diving limits. Two spot dives will be considered

part of the standard scope of work.

Survey Area Depth Range Corridor Min. # of Lines

Diver Swim 0 (LAT) to 3m 250m 5

Table 2: Diver Swim Survey Requirements

3.12 The Diver Swim Survey will comply with the requirements of the Underwater

Archaeology Unit of the Department of Arts, Heritage & the Gaeltacht.

Small Boat Survey

3.13 The area extending seaward from the 3m water depth contour and inshore of the

safe working draft limits of the primary survey vessel will be accurately surveyed with a

small craft using Multibeam Echosounder (MBES), sidescan sonar and sub-bottom

profile equipment. Sub-bottom profile equipment will be able to discern the nature and

density of the upper 3 metres of seabed, and will be used on a non-interfering basis with

other sounding systems. Tie lines will be performed to verify primary survey data and will

have a nominal spacing of 10 times the primary line spacing with a minimum of two tie

lines. A minimum of seven survey lines, based upon the Survey RPL, is required.

3.14 Features such as shallow reefs, surge channels, debris fields, archaeological

features or anything that could be a hazard to the cable or installation team will be noted.

General reconnaissance of the survey corridor beyond the planned survey lines and tie

lines may be necessary to describe the seabed as accurately as possible. A diver swim

survey (spot dive) may be required to investigate and identify any obstacles or

archaeological features found during the small boat survey up to safe diving limits. A line


plan showing number of survey lines as a function of depth will be provided prior to start

of survey operations.

Survey Area

Depth Range Corridor Min. # of Lines

Min. Overlap Max. Speed

Small Boat 3m to 15m 500m 7 SSS: 100%

MBES Bathy: 20%

4 knots

Table 3: Small Boat Survey Requirements

Offshore Survey 3.15 A continuous bathymetric swathe (Multibeam Echosounder), along with side scan

sonar imagery and sub-bottom profile will be obtained, centred on the preliminary route

and along all wing lines needed to complete the corridor coverage. A minimum depth

accuracy of 0.5% is required. Sub-bottom equipment will be able to discern the nature

and density of upper 3m of seabed, and is to be used on a non-interfering basis with

other sounding systems. Additional sounding lines may be necessary to develop any

obstacles or archaeological features that may be encountered, and/or to meet the

overlap and corridor requirements.

Survey Area

Depth Range Corridor Min. # of Lines

Min. Overlap Max. Speed

Offshore > 15m 500m 3 SSS: 100%

MBES Bathy:20%

4 knots

Table 4: Offshore Survey Requirements


Seabed Sampling 3.16 Seabed sampling will be required at locations covered by the Small Boat and

Shallow Water Surveys. The proposed sampling locations (23 No.) are shown on the

Drawings 1297-101 & 102 in Appendix 3.

3.17 A minimum of two attempts will be made at each sampling location to acquire a

suitable seabed sample. If an acceptable sample is achieved on the first attempt, there

is no need to perform a second attempt.

3.18 An acceptable sample is defined as;

Grab Sample – recovery of approximately a full bucket of soils. Recovery of

rocks and/or large size granular material will be taken as indication of a hard

seabed and be deemed an acceptable sample.

Gravity Core – recovery of no less than a 2m deep core of soil. If stiff or hard

soils are encountered below 1m of seabed and are clearly indicated in the

sample, a 1m+ soil sample will be deemed acceptable. Any sample site yielding

less than 1m of recovery must be investigated a second time unless there is

obvious damage to the coring equipment indicating a hard or rocky substrate.

CPT – Penetration to the 2m below seabed. Any push resulting in less than 2m

penetration will warrant a second attempt.


Survey Area

Depth Type Avg. Spacing No. of

Samples

Small Boat 3 – 15 m Grab Sampler 1 per 500 m 18

Offshore > 15m Gravity Corer (GC)

or

Cone Penetrometer

(CPT)

Grab Sampler (After GC/CPT

Failure)

1 per 5km

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Table 5: Seabed Sampling Requirements

3.19 The sampling required on the beach at Donabate will involve 3 No. Trial Pits at

50m centres starting seaward of the High Water Mark. The 3 No. Trial Pits will be

excavated, logged, photographed and backfilled in a single intertidal period of less than

1 hour. The trial pits will be backfilled with the original excavated materials in the

sequence in which they are excavated.

3.20 A summary Method Statement for excavation of the Trial Pits is as follows;

3 No. Trail Pits – JCB or equivalent.

– Depth 2.5m.

– Excavate sand and place to one side. Excavate

substrate and place separate from sand. Measure, log

and photograph each Trial Pit.

- Backfill in sequence compacting with bucket of back-hoe

as the backfilling proceeds.


3.21 The bar probes on the beach and out to the 3m contour are simply to prove the

depth of sand, gravel or soft material and are effectively non-intrusive.

3.22 The site investigations in the area from the Low Water Line to the 15m contour

will be undertaken from a small vessel having the appropriate draft.

3.23 The site investigations seaward of the 15m contour will be undertaken from a

larger sea-going vessel.

3.24 The marine survey and site investigations will be undertaken in compliance with

best practice and having regard for the protection of marine mammals.

3.25 The marine survey and site investigations will be undertaken along the route line

shown on the Foreshore Licence Map Drawings. However a 500m wide route corridor is

shown to allow for local diversions in the event of obstructions or other routing

considerations.

3.26 The schedule of Site Investigations is set out in Table 1

Survey Area Depth Type Avg. Spacing

Landfall HWM - LWM Trial Pit 1 per 50 m

Landfall HWM - LWM Bar Probing 1 per 25 m

Diver Swim 0 – 3m Water Depth Bar Probing & Diver 1 per 25 m

Table 6: Site Investigations Schedule


3.27 The overall scope of the Site Investigations is as follows

Trial Pits 3 No. on the beach

Bar Probes 10 No. on the beach

Bar Probes 10 No. from Low Water to the 3.0m contour

Grab Samples 18 No. from the 3m to the 15m contour

Gravity Cores or 5 No. from the 15m contour to the

Cone Penetration Tests 12-Mile Limit

3.28 The mitigation measures prescribed in the Appropriate Assessment Screening

Report (attached as Appendix 1) will be adhered to.


4.0 SURVEY EQUIPMENT PARAMETERS

4.1 The marine surveys will include

Bathymetry

Side Scan Sonar

Sub-Bottom Profiling

Magnetometer

Equipment and Procedures

4.2 The marine survey will be carried out in compliance with the “Code of Practice for

the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters,”

and with the “General Requirements for a Geophysical Survey for Archaeological

Purposes,” and in accordance with the mitigation measures prescribed in the

Appropriate Assessment Screening Report (attached as Appendix 1).

4.3 The survey equipment acoustic properties have the following characteristics;

Equipment Type Frequency

(Energy level in dB re 1 µPa)

Dual Frequency Single Beam Echosounder – Reson Navisound 420

33 and 210kHz (168 – 174)

Dual Frequency Side Scan Sonar - Edgetech 4200 Sidescan Towfish

100 and 400kHz (226 effective)

Sub-bottom Profiler - Geoacoustics 4 x 4 Hull-mounted SBP Pinger

System

3 – 7.5kHz (-225)

4.4 In the case of the Small Boat Survey the survey line spacing will be set at 50m

for the Side Scan Sonar. In deeper water the spacing will increase.


4.5 Specific soft-start procedures (to comply with the “Code of Practice for the

Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters”) will be

developed and incorporated in the project execution plan before mobilisation.

4.6 The duration of noise-generating surveys will be reduced to the minimum

necessary to collect results of sufficient quality.

4.7 The survey will be undertaken by a specialist survey vessel having experience of

marine survey and having approved appropriate survey equipment.

4.8 Details of the survey vessel and of the survey equipment to be used will be made

available prior to commencement of the survey. The data to be provided will include;

Name of vessel

Name of Captain

Name of Client’s Representative

Contact details for the vessel

Details of Multi-Beam Equipment including;

The sound intensity, the frequency of pitch and the tone or bandwidth for the

Echo Sounder, the Side Scan Sonar and the Sub-Bottom Profiler.


5.0 MAPPING

Landfall

5.1 The general location of the Landfall is shown in Figure 5 on a 6 inch OS map.

5.2 The detailed location of the landfall, incorporating the inshore routing and survey

corridor are shown in Figure 6 on a 1/2500 OS map.

5.3 All OS maps are presented as diagrams in this report and are issued true to

scale in the corresponding drawings in Appendix 3.

Site Investigation Corridor

5.4 The site investigation corridor is shown at a width of 100 metres on either side of

the planned centre-line for the inshore area. This width increases to 250metres on either

side of the centre-line (a 500m corridor) beyond the 3 metre contour.

Inshore

5.5 The inshore route of the cable at Donabate is shown in Figure 2 on the Admiralty

Chart base. The map shows the route, key Turning Points, Kilometre Points, and

Sampling Points. This map is included at A3 size in Appendix 3.

Offshore

5.6 The offshore route of the cable in the offshore area is shown in Figure 3 on an

Admiralty Chart base. The map shows the line of the route, key Turning Points,

Kilometre Points, the Sampling Points, and the 12 Mile Limit. This map is included at A3

size in Appendix 3.


6.0 MARINE LIAISON & CONSULTATIONS

Sea Fisheries Protection Agency 6.1 It is proposed to contact the Sea Fisheries Protection Agency (SFPA) to seek

advice regarding the timing of survey works to avoid clashing with spawning periods of

marine fish in the area. This will reduce any potential for noise damage to larval and

juvenile life stages of fish when they are more susceptible to noise damage than adults.

6.2 It is proposed to appoint a Fisheries Liaison Officer for the inshore and offshore

sections of the survey. The appointment of a Fisheries Liaison Officer would have the

purpose of keeping commercial fishermen informed of the survey works including time

lines, dates of sampling and locations of sampling vessels. The Fisheries Liaison Officer

will also inform the survey team of commercial activity and locations of fishing nets or

pots that will be impacted by the survey activities.

6.3 The Sea-Fisheries Protection Authority (SFPA) will be requested to advise on

consultation with the relevant fishermen’s producer organisations on details of the

project.

National Parks & Wildlife Service 6.4 It is proposed to appoint a Marine Mammal Observer to be on board the survey

vessel for the small boat survey.

Irish Coast Guard 6.5 It is proposed to liaise with the Irish Coast Guard to arrange appropriate radio /

nav-text broadcast warnings to advise shipping approaching the survey area.

Marine Notice 6.6 It is proposed to publish a Marine Notice through the Marine Safety Directorate

giving a general description of operations and approximate dates of commencement and

completion.


7.0 NATURA 2000 SITES / APPROPRIATE ASSESSMENT

7.1 There are various Natura 2000 sites in the general area of Donabate and

offshore along the proposed survey route. Accordingly, an Appropriate Assessment

Screening Report was commissioned and this has been carried out by Altemar Ltd. as

part of this application process. The route which has been selected for the marine survey

has no significant impact on the various Natura 2000 sites and a copy of the formal

Appropriate Assessment Survey Report in incorporated in Appendix 1.

7.2 The overall conclusions from the Appropriate Assessment Screening report are

that no significant impact on associated NATURA 2000 sites/species or habitats is

foreseen.


APPENDIX 1

APPROPRIATE ASSESSMENT SCREENING

REPORT

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Appropriate Assessment Screening as required under the European Communities (Birds and Natural Habitats) Regulations 2011 for site

investigations (Foreshore Licence Application) at Donabate, Co. Dublin.

03rd August 2016 Prepared by:

Bryan Deegan (MCIEEM) of Altemar Ltd. On behalf of: McMahon Design & Management Ltd./Aqua Comms

Altemar Ltd., 50 Templecarrig Upper, Delgany, Co. Wicklow. 00-353-1-2010713. [email protected] Directors: Bryan Deegan and Sara Corcoran Company No.427560 VAT No. 9649832U

www.altemar.ie

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Document Control Sheet

Client McMahon Design & Management.

Project Appropriate Assessment Screening as required under the European Communities (Birds and Natural Habitats) Regulations 2011 for site investigations (Foreshore Licence Application) at Donabate, Co. Dublin.

Report Appropriate Assessment Screening

Date 03rd August 2016

Project No: Document Reference: AASCCSI16

Version Author Reviewed Date

Draft 01 Bryan Deegan SC/RR/TMcM 01st August 2016

Draft 02 Bryan Deegan Sara Corcoran 03rd August 2016

Draft 03

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Contents 1. Introduction 3

Background to Altemar Ltd. 4

2. Background to the Appropriate Assessment 5

3. Stages of the Appropriate Assessment 7

4. Screening Stage 8

A) MANAGEMENT OF THE SITE 8

B) DESCRIPTION OF THE PROPOSED PROJECT 8

Site Selection 8

Landfall Location 9

Proposed Marine Survey and Site Investigations 9

Survey Equipment Parameters 15

D) IDENTIFICATION OF NATURA 2000 SITES/SPECIES POTENTIALLY AFFECTED. 16

E) FIELD OBSERVATIONS AT DONABATE, CO. DUBLIN. 45

E) POTENTIAL IMPACT AND THE SIGNIFICANCE OF THE IMPACT 47

F) CUMULATIVE IMPACTS 54

5. Finding of No Significant Effects Report 55

6. References 56

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1. Introduction An Appropriate Assessment is an assessment of the potential effects of a proposed project or plan, on its own, or in combination with other plans or projects, on one or more NATURA 2000 sites (Special Areas of Conservation (SAC) or Special Protection Areas (SPA)). The following Appropriate Assessment (Screening Stage) has been prepared by Altemar Ltd. at the request of McMahon Design & Management Ltd. and Aqua Comms as part of the site investigations application for a Foreshore Licence. The foreshore licence survey relates to the groundtruthing (site investigations) of the potential route of a fibre-optic cable, having a landfall at Donabate, Co. Dublin. As part of an application for a foreshore licence application the Department of Environment, Community and Local Government have requested an Appropriate Assessment screening report on potential impact of site investigations on NATURA 2000 sites. The purpose of this report is to determine the impact, if any, of the proposed site investigations to be carried out as part of the Foreshore Licence application for the landing of the cable, individually or in combination with other plans or projects, on NATURA 2000 sites.

Background to Altemar Ltd.

Since its inception in 2001, Altemar has been delivering ecological and environmental services to a broad range of clients. Operational areas include residential, infrastructural, renewable, oil & gas, private industry, local authorities, EC projects and State/semi-State Departments. Bryan Deegan is the managing director of Altemar. Bryan is an environmental scientist and marine biologist with 20 years’ experience working in Irish terrestrial and aquatic environments, providing services to the State, Semi-State and industry. He has extensive experience in environmental data collation, project management, GIS, habitat mapping, appropriate assessment, environmental impact assessment and in renewable energy. He has also managed environmental aspects of marine cable laying projects including two trans-Atlantic fibre optic cables that made landfall in Ireland in 2015. Bryan Deegan (MCIEEM) holds a MSc in Environmental Science, BSc (Hons.) in Applied Marine Biology, NCEA National Diploma in Applied Aquatic Science and a NCEA National Certificate in Science (Aquaculture). He is also a JNCC approved Marine Mammal Observer and a HSE Part IV & III Commercial Diver. He has carried out over 1800 dives for NPWS in Ireland, habitat mapping and recording species within Irish marine SAC’s.

.

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2. Background to the Appropriate Assessment The Habitats Directive 92/43/EEC (together with the Birds Directive (79/409/EEC)) forms the cornerstone of Europe's nature conservation policy. The directive protects over 1000 animals and plant species and over 200 "habitat types" which are of European importance. In the Directive, Articles 3 to 9 provide the legislative means to protect habitats and species of European Community interest through the establishment and conservation of an EU-wide network of conservation sites (NATURA, 2000). These are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Birds Directive), Article 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect NATURA 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for Appropriate Assessment:

"Any plan or project not directly connected with or necessary to the management of the [NATURA 2000] site but likely to have a significant effect thereon, either individually or in combination with other plans and projects, shall be subjected to appropriate assessment of its implications for the site in view of the site's conservation objectives. In light of the conclusions of the assessment of the implication for the site and subject to the provisions of paragraph 4, the component national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public"

As outlined in the guidance document on Article 6(4) (January 2007): “Appropriate assessments of the implications of the plan or project for the site concerned must precede its approval and take into account the cumulative effects which result from the combination of that plan or project with other plans or projects in view of the site's conservation objectives. This implies that all aspects of the plan or project which can, either individually or in combination with other plans or projects, affect those objectives must be identified in the light of the best scientific knowledge in the field.

Assessment procedures of plans or projects likely to affect NATURA 2000 sites should guarantee full consideration of all elements contributing to the site integrity and to the overall coherence of the network, both in the definition of the baseline conditions and in the stages leading to identification of potential impacts, mitigation measures and residual impacts. These determine what has to be compensated, both in quality and quantity. Regardless of whether the provisions of Article 6(3) are delivered following existing environmental impact assessment procedures or other specific methods, it must be ensured that:

• Article 6(3) assessment results allow full traceability of the decisions eventually made, including the selection of alternatives and any imperative reasons of overriding public interest.

• The assessment should include all elements contributing to the site’s integrity and to the overall coherence of the network as defined in the site’s conservation objectives and Standard Data Form, and be based on best available scientific knowledge in the field. The information required should be updated and could include the following issues:

o Structure and function, and the respective role of the site’s ecological assets;

o Area, representativity and conservation status of the priority and nonpriority habitats in the site;

o Population size, degree of isolation, ecotype, genetic pool, age class structure, and conservation status of species under Annex II of the Habitats Directive or Annex I of the Birds Directive present in the site;

o Role of the site within the biographical region and in the coherence of the NATURA 2000 network; and,

o Any other ecological assets and functions identified in the site.

• It should include a comprehensive identification of all the potential impacts of the plan or project likely to be significant on the site, taking into account cumulative impacts and other impacts likely to arise as a result of the combined action of the plan or project under assessment and other plans or projects.

• The assessment under Article 6(3) applies the best available techniques and methods, to estimate the extent of the effects of the plan or project on the biological integrity of the site(s) likely to be damaged.

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• The assessment provides for the incorporation of the most effective mitigation measures into the plan or project concerned, in order to avoid, reduce or even cancel the negative impacts on the site.

• The characterisation of the biological integrity and the impact assessment should be based on the best possible indicators specific to the NATURA 2000 assets which must also be useful to monitor the plan or project implementation.”

Plans & Projects Plans Plans, as defined by NPWS (2009), include all statutory and non-statutory land use, framework and sectoral plans and strategies to the extent that they have the potential to have significant effects on a NATURA 2000 site. This incorporates ‘plans and programmes’ covered by the SEA Directive 11, and other plans and strategies, including those that are designed or intended to benefit the environment or heritage, such as Heritage and Biodiversity plans, recreation/amenity plans or strategies, and River Basin Management Plans. Project The Commission (EC, 2006) puts the position as follows: “such a definition of project[i.e. definition of ‘project’ from the EIA Directive] is relevant to defining the concept of plan or project as provided for in the Habitats Directive, which, seeks, as does Directive 85/337, to prevent activities which are likely to damage the environment from being authorised without prior assessment of their impact on the environment”, and goes on to say that “the fact that the activity has been carried on periodically for several years on the site concerned and that a licence has to be obtained for it every year does not in itself constitute an obstacle to considering it, at the time of each application, as a distinct plan or project within the meaning of the Habitats Directive”.

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3. Stages of the Appropriate Assessment This Appropriate Assessment was undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the 'Habitats' Directive 92/43/EEC (EC 2001) and the European Commission Guidance 'Managing NATURA 2000 Sites', in addition to the December 2009 publication from the Department of Environment, Heritage and Local Government; ‘Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities.’ In order to comply with the above Guidelines, the Appropriate Assessment has been structured as follows:

1) Screening stage:

• Description of the proposed project;

• Identification of NATURA 2000 sites potentially affected;

• Identification and description of individual and cumulative impacts likely to result from the proposed project;

• Assessment of the significance of the impacts identified above on site integrity. Exclusion of sites where it can be objectively concluded that there will be no significant effects; and,

• Conclusions.

2) Appropriate Assessment Stage (Not relevant to this Appropriate Assessment Screening):

• Description of the NATURA 2000 sites that will be considered further;

• Description of significant impacts on the conservation feature of these sites likely to occur from the project; and,

• Mitigation/Recommendations/Conclusions.

3) Alternative Solutions (Not relevant to this Appropriate Assessment Screening):

If mitigation is possible that enables a risk to be avoided fully, then, subject to other necessary approvals, the project or plan may proceed. If mitigation measures are insufficient, or are not actually practicable and achievable to avoid the risk entirely, then, in the light of a negative assessment, the plan or project may not proceed. A wider search for alternative solutions may need to be considered – Stage 3. 1

4) Imperative Reasons of Overriding Public Interest (IROPI)/Derogation. (Not relevant to this Appropriate Assessment Screening):

Stage 4 is the main derogation process of Article 6(4) which examines whether there are imperative reasons of overriding public interest (IROPI) for allowing a plan or project that will have adverse effects on the integrity of a NATURA 2000 site to proceed in cases where it has been established that no less damaging alternative solution exists. The extra protection measures for Annex I priority habitats come into effect when making the IROPI case.

1 (DoEHLG, 2009) Appropriate Assessment of Plans and projects in Ireland: Guidance for planning authorities.

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4. Screening Stage

a) Management of the Site The plan or project is not directly connected with, or necessary to, the management of NATURA 2000 sites.

b) Description of the Proposed Project Aqua Comms is a provider of bandwidth infrastructure services including dark fibre, wavelengths and ethernet whose subsea fibre optic networks are designed to meet the needs of content providers, cloud based networks, data centres, IT companies and the global media. The company specialises in sub-sea telecoms and owns and operates the AEConnect transatlantic cable (Killala to New York) and CeltixConnect which runs from Dublin to Anglesey in the UK. Aqua Comms Ltd. is planning to construct a fibre optic cable, CeltixConnect 2, extending from a landfall at Donabate in Co. Dublin to Blackpool/Lytham St Annes United Kingdom (Figure 1). This Appropriate Assessment Screening is in relation to Marine Survey and Site Investigation works for the proposed cable only.

Figure 1. Proposed Route of fibre Optic Cable

Site Selection

The project partners have investigated many landfall sites on the east coast of Ireland (and the west coast of the UK) and have taken into account environmental, logistical, infrastructural and engineering factors. Following a desk based and visual review of several sites, the beach at Donabate was chosen as the preferred option. As a result of this selection process site investigations are required to properly assess the suitability of this potential landfall site and cable route.

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The proposed works will be carried out predominantly by seaborne electronic equipment (geophysical survey) with some selective sampling of the seabed (geotechnical survey). Once the results of the survey are obtained detailed route selection, design and method statements will be developed and a final Route Position List (RPL) will be defined as part of a further submission for a Foreshore Licence for installation works which will include an additional assessment as required under the European Communities (Birds and Natural Habitats) Regulations 2011.

Landfall Location

The location of the landfall at Donabate is shown on the 6” to 1 mile Ordnance Survey map and the 1/2,500 Ordnance Survey map in Figure 2.

Figure 2. Proposed Landfall Location on 6” Ordnance Survey Map

Proposed Marine Survey and Site Investigations

The principal objective of the Marine Survey & Site Investigations is to ascertain a feasible and safe route for cable system design, deployment, survivability and subsequent maintenance with due regard for environmental considerations. The survey will also allow decisions to be made about cable armouring and burial. The survey will identify all route obstacles and cable hazards and provide detailed information to support cable route and installation engineering. The site investigations will enable “ground-truthing” of the seabed along the route. The survey operations will be broken down into separate but overlapping areas, with boundaries defined by water depth as specified in the technical requirements outlined below. These water depth boundaries will be adjusted based on the limitations of the survey vessel(s) and survey gear. The surveys will ensure that there are no gaps or unsurveyed areas between the different survey operations. For the marine route survey, the sidescan ranges will be limited to those providing the greatest resolution possible (able to resolve a 0.5m object or better), while following the required minimum line spacing and overlap. The maximum speeds outlined will be used as guidelines. Bathymetry data collection will, at minimum, comply with the requirements in this document or with International Hydrographic Office standards (S44).

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Survey line spacing is to be designed to ensure adequate coverage and overlap of geophysical measurements. For swathe bathymetry, “20% overlap” signifies that adjacent acquisition swathes within the survey corridor overlap by 20%. For side scan sonar (SSS), 100% overlap requires two passes of complete coverage over a given area of sea-floor, with the two passes each ensonifying the sea-floor from opposite directions to ensure targets are adequately imaged. In order to ensure data continuity, the following overlaps between survey regions are to be established as a minimum; Table 1. Overlap of survey Areas:

Survey Overlap

Landfall Site Survey to Diver Swim 50m Diver Swim Survey to Small Boat 50m Small Boat Survey to Offshore 500m

Landfall Site Survey & Site Investigations

A topographic survey of the beach along the line of the proposed cable route is required from the carpark to the low water mark. Site Investigations at Donabate will consist of;

• 3 No. Trial Pits on the beach (2.5m depth by JCB, excavated and immediately reinstated) at 50m centres starting seaward of the High Water Mark. The 3 No. Trial Pits will be excavated, logged, photographed and backfilled in a single intertidal period of less than 1 hour. The trial pits will be backfilled with the original excavated materials in the sequence in which they are excavated.

• Bar probes on the beach and from the Low Water Line to the 3 meter contour The bar probes on the beach and out to the 3m contour are simply to prove the depth of sand, gravel or soft material and are effectively non-intrusive.

Figure 3. Proposed Landfall and trial pit locations

Diver Swim Survey

The Diver Swim Survey will extend from the low water line outward to the small boat survey limits in accordance with the defined overlaps. A diver swim rope with 25m gradations will be positioned along the route. Dive lines will be configured to provide representative coverage across the entire survey corridor (nominally spaced at 125m). Bathymetry will be measured by diver depth gauge at each 25m

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gradation. Geomorphology will be determined by underwater video along the length of the diver swim rope. The diver video will be undertaken along each line in the survey swathe; divers will use a dive slate or other clearly written method to indicate Kilometre Point (KP) and water depth at the specified gradations along the rope. Tie lines will be nominally spaced at 125m parallel to shore and will verify primary survey data within the Diver Swim area. Bathymetry and seabed composition are to be noted along tie lines. A minimum of 2 tie lines will be performed. The Diver Swim Survey will also investigate and identify any obstacles found during the Small Boat Survey up to safe diving limits. Two spot dives will be considered part of the standard scope of work. The Diver Swim Survey will comply with the requirements of the Underwater Archaeology Unit of the Department of Arts, Heritage & the Gaeltacht. Table 2. Diver swim survey requirements

Survey Area Depth Range Corridor Min. # of Lines

Diver Swim 0 (LAT) to 3m 250m 5

Small Boat Survey

The area extending seaward from the 3m water depth contour and inshore of the safe working draft limits of the primary survey vessel will be accurately surveyed with a small craft using Multibeam Echosounder (MBES), sidescan sonar and sub-bottom profile equipment. Sub-bottom profile equipment will be able to discern the nature and density of the upper 3 meters of seabed, and will be used on a non-interfering basis with other sounding systems. Tie lines will be performed to verify primary survey data and will have a nominal spacing of 10 times the primary line spacing with a minimum of two tie lines. A minimum of seven survey lines, based upon the Survey RPL, is required. Features such as shallow reefs, surge channels, debris fields, archaeological features or anything that could be a hazard to the cable or installation team will be noted. General reconnaissance of the survey corridor beyond the planned survey lines and tie lines will be necessary to describe the seabed as accurately as possible. A diver swim survey (spot dive) will be required to investigate and identify any obstacles or archaeological features found during the small boat survey up to safe diving limits. A line plan showing number of survey lines as a function of depth will be provided prior to start of survey operations. The site investigations in the area from the Low Water Line to the 15m contour will be undertaken from a small vessel having the appropriate draft. The site investigations seaward of the 15m contour will be undertaken from a larger sea-going vessel.

Table 3. Small Boat Survey Requirements

Survey Area Depth

Range

Corridor Min. # of Lines Min. Overlap Max. Speed

Small Boat 3m to 15m 500m 7 SSS: 100%

MBES Bathy: 20%

4 knots

Offshore Survey

A continuous bathymetric swathe (Multibeam Echosounder), along with side scan sonar imagery and sub-bottom profile will be obtained, centred on the preliminary route and along all wing lines needed to complete the corridor coverage. A minimum depth accuracy of 0.5% is required. Sub-bottom equipment will be able to discern the nature and density of upper 3m of seabed, and is to be used on a non-interfering basis with other sounding systems. Additional sounding lines will be necessary to develop any obstacles or archaeological features that will be encountered, and/or to meet the overlap and corridor requirements. Table 4. Offshore Survey Requirements

Survey Area Depth Range Corridor Min. # of Lines Min. Overlap Max. Speed

Offshore > 15m 500m 3 SSS: 100%

MBES Bathy:20%

4 knots

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Seabed Sampling

Seabed sampling will be required at locations covered by the Small Boat and Shallow Water Surveys. The proposed sampling locations (23 No.) are shown in Figures 4 & 5. A minimum of two attempts will be made at each sampling location to acquire a suitable seabed sample. If an acceptable sample is achieved on the first attempt, there is no need to perform a second attempt. An acceptable sample is defined as;

• Grab Sample – recovery of approximately a full bucket of soils. Recovery of rocks and/or large size granular material will be taken as indication of a hard seabed and be deemed an acceptable sample.

• Gravity Core – recovery of no less than a 2m deep core of soil. If stiff or hard soils are encountered below 1m of seabed and are clearly indicated in the sample, a 1m+ soil sample will be deemed acceptable. Any sample site yielding less than 1m of recovery must be investigated a second time unless there is obvious damage to the coring equipment indicating a hard or rocky substrate.

• CPT – Penetration to the 2m below seabed. Any push resulting in less than 2m penetration will warrant a second attempt.

Table 5. Seabed Sampling Requirements Survey Area Depth Type Avg. Spacing No. of

Samples

Small Boat 3 - 15 m Grab Sampler 1 per 500 m 18

Offshore > 15m Gravity Corer (GC) or Cone Penetrometer (CPT) Grab Sampler (After GC/CPT

Failure)

1 per 5km 5

The marine survey and site investigations will be undertaken in compliance with best practice and having regard for the protection of marine mammals. The marine survey and site investigations will be undertaken along the route line shown on the Foreshore Licence Map Drawings. However a 500m wide route corridor is shown to allow for local diversions in the event of obstructions or other routing considerations.

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Figure 4. Proposed inshore sampling stations.

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Figure 5. Proposed offshore sampling stations.

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Survey Equipment Parameters

The marine surveys will include

• Bathymetry

• Side Scan Sonar

• Sub-Bottom Profiling

• Magnetometer

Equipment and Procedures

The marine survey will be carried out in compliance with the “Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters” and with the “General Requirements for a Geophysical Survey for Archaeological Purposes”. The survey equipment acoustic properties have the following characteristics; Table 6. Survey Equipment

Equipment Type Frequency (Energy level in dB re 1 µPa)

Dual Frequency Single Beam Echosounder – Reson Navisound 420

33 and 210kHz (168 – 174)

Dual Frequency Side Scan Sonar – Edgetech 4200 Sidescan Towfish

100 and 400kHz (226 effective)

Sub-bottom Profiler – Geoacoustics 4 x 4 Hull-mounted SBP Pinger System

3 – 7.5kHz (-225)

In the case of the Small Boat Survey the survey line spacing will be set at 50m for the Side Scan Sonar. In deeper water the spacing will increase. Specific soft-start procedures (to comply with the “Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters”) will be developed and incorporated in the project execution plan before mobilisation. The duration of noise-generating surveys will be reduced to the minimum necessary to collect results of sufficient quality. The survey will be undertaken by a specialist survey vessel having experience of marine survey and having approved appropriate survey equipment. Details of the survey vessel and of the survey equipment to be used will be made available prior to commencement of the survey. The data to be provided will include; Name of vessel Name of Captain Name of Client’s Representative Contact details for the vessel Details of Multi-Beam Equipment including; The sound intensity, the frequency of pitch and the tone or bandwidth for the Echo Sounder, the Side Scan Sonar and the Sub-Bottom Profiler.

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d) Identification of NATURA 2000 sites/species potentially affected. The following figures show the potential fibre optic cable route in relation to Natura 2000 sites; the Irish territorial waters, and SAC’s (Figure 6), with 15km buffer (Figure 7), inshore elements and SAC’s (Figure 8) and satellite imagery of the landfall in relation to Malahide Estuary SAC (Figure 9), the proposed fibre optic cable route and survey corridor in relation to the Irish territorial waters and SPA’s (Figure 10), 15km buffer and SPA’s (Figure 11) and inshore elements in relation to SPA’s (Figure 12). The position of the offshore sampling sites and SAC’s are seen in Figure 13. The NATURA 2000 sites within 15km of the proposed route and landfall are: Special Areas of Conservation Rockabill to Dalkey Island SAC (cable route passes through this SAC) Malahide Estuary SAC (Landfall within SAC) Rogerstown Estuary SAC (1.8km from cable route) Lambay Island SAC (2.1 km from cable route) Baldoyle Bay SAC (6.6 km from cable route) Ireland’s Eye SAC (7.7 km from cable route) North Dublin Bay SAC (9.8 km from cable route) Howth Head SAC (10.5 km from cable route) Special Protection Areas Rockabill SPA (110m from cable route but is within proposed survey corridor) Rogerstown Estuary SPA (1.2km from cable route) Malahide Estuary SPA (1.3km from landfall) Lambay Island SPA (1.7 km from cable route) Skerries Islands SPA (4.6km from proposed cable route) Baldoyle Bay SPA (6.6 km from cable route) Ireland’s Eye SPA (7.8 km from cable route) North Bull Island SPA(9.8 km from cable route) Howth Head Coast SPA (10.5 km from cable route) South Dublin Bay and River Tolka SPA (13.7km from cable route) Initial screening of these sites can be seen in Table 7. The proposed landfall is also within a proposed Natural Heritage Area (Malahide Estuary pNHA). The closest RAMSAR Site is Broadmeadow Estuary at 1.3km to the south west of the proposed landfall.

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Figure 6. Position of proposed fibre optic cable route and survey corridor in relation to the Irish territorial waters and SAC’s.

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Figure 7. Position of proposed fibre optic cable route, survey corridor (5km, 10km & 15km buffers) in relation to the Irish territorial waters and SAC’s.

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Figure 8. Position of proposed inshore fibre optic cable route, survey corridor (5km & 10km buffers) in relation to the SAC’s.

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Figure 9. Position of proposed inshore fibre optic cable route, landfall and Low Water Mark in relation to the boundaries of Malahide Estuary SAC.

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Figure 10. Position of proposed fibre optic cable route and survey corridor in relation to the Irish territorial waters and SPA’s.

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Figure 11. Position of proposed fibre optic cable route, survey corridor (5km, 10km & 15km buffers) in relation to the Irish territorial waters and SPA’s.

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Figure 12. Position of inshore elements of proposed fibre optic cable route, survey corridor (5km & 10km buffers) in relation to SPA’s.

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Figure 13. Position of proposed cable route and sampling sites in relation to the 10m contour and SAC’s.

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Table 7. Initial screening of Natura 2000 sites within 15km of the proposed cable route and survey.

Special Protection Areas NATURA CODE

NAME Screened In/Out

Details/Reason

IE0004014 Rockabill SPA

Out Conservation Objective: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level. Qualifying Interests A148 Purple Sandpiper (Calidris maritima) A192 Roseate Tern (Sterna dougallii) A193 Common Tern (Sterna hirundo) A194 Arctic Tern (Sterna paradisaea) Potential Impact The proposed cable route is 110m outside this SPA. However, the survey corridor will enter the SPA. No impact on the bird species representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. No impact predicted

IE0004015 Rogerstown Estuary SPA

Out Conservation Objective: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level. Qualifying Interests A043 Greylag Goose (Anser anser) A046 Brent Goose (Branta bernicla hrota) A048 Shelduck (Tadorna tadorna) A056 Shoveler (Anas clypeata) A130 Oystercatcher (Haematopus ostralegus) A137 Ringed Plover (Charadrius hiaticula) A141 Grey Plover (Pluvialis squatarola) A143 Knot (Calidris canutus) A149 Dunlin (Calidris alpina alpine) A156 Black-tailed Godwit (Limosa limosa) A162 Redshank (Tringa tetanus) A999 Wetlands Potential Impact The proposed development site is 1.2km from the Rodgerstown Estuary SPA. No impact on the bird species or Wetlands representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 1.2 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

IE0004025 Malahide Estuary SPA

Out Conservation Objectives: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level.

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Details/Reason

Objective 1: To maintain the favourable conservation condition of the waterbird Special Conservation Interest species listed for Malahide Estuary SPA. Objective 2: To maintain the favourable conservation condition of the wetland habitat at Malahide Estuary SPA as a resource for the regularly -occurring migratory waterbirds that utilise it. Qualifying Interests A005 Great Crested Grebe (Podiceps cristatus) A046 Brent Goose (Branta bernicla hrota) A048 Shelduck (Tadorna tadorna) A054 Pintail (Anas acuta) A067 Goldeneye (Bucephala clangula) A069 Red-breasted Merganser (Mergus serrator) A130 Oystercatcher (Haematopus ostralegus) A140 Golden Plover (Pluvialis apricaria) A141 Grey Plover (Pluvialis squatarola) A143 Knot (Calidris canutus) A149 Dunlin (Calidris alpina alpine) A156 Black-tailed Godwit (Limosa limosa) A157 Bar-tailed Godwit (Limosa lapponica) A162 Redshank (Tringa tetanus) A999 Wetlands Potential Impact The proposed development site is 1.3km from the Malahide Estuary SPA. No impact on the bird species or Wetlands representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 1.3 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

IE0004069 Lambay Island SPA

Out Conservation Objective: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level. Qualifying Interests A009 Fulmar (Fulmarus glacialis) A017 Cormorant (Phalacrocorax carbo) A018 Shag (Phalacrocorax aristotelis) A043 Greylag Goose (Anser anser) A183 Lesser Black-backed Gull (Larus fuscus) A184 Herring Gull (Larus argentatus) A188 Kittiwake (Rissa tridactyla) A199 Guillemot (Uria aalge) A200 Razorbill (Alca torda) A204 Puffin (Fratercula arctica)

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Details/Reason

Potential Impact The proposed development site is 1.7 km from the Lambay Island SPA. No impact on the bird species representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 1.7 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

IE0004122 Skerries Island SPA

Out Conservation Objective: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level. Qualifying Interests A017 Cormorant (Phalacrocorax carbo) A018 Shag (Phalacrocorax aristotelis) A046 Light-bellied Brent Goose (Branta bernicla hrota) A148 Purple Sandpiper (Calidris maritima) A169 Turnstone (Arenaria interpres) A184 Herring Gull (Larus argentatus) Potential Impact The proposed development site is 4.6 km from the Skerries Island SPA. No impact on the bird species representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 1.2 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

IE0004016 Baldoyle Bay SPA

Out Conservation Objectives: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA. Qualifying Interests A046 Brent Goose (Branta bernicla hrota) A048 Shelduck (Tadorna tadorna) A137 Ringed Plover (Charadrius hiaticula) A140 Golden Plover (Pluvialis apricaria) A141 Grey Plover (Pluvialis squatarola) A157 Bar-tailed Godwit (Limosa lapponica) A999 Wetlands.

Potential Impact The proposed survey is 6.6 km from this SPA. No impact on the bird species or Wetlands representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 6.6 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

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Details/Reason

IE0004117 Ireland’s Eye SPA

Out Conservation Objective: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA:

Qualifying Interests A017 Cormorant (Phalacrocorax carbo) A184 Herring Gull (Larus argentatus) A188 Kittiwake (Rissa tridactyla) A199 Guillemot (Uria aalge) A200 Razorbill (Alca torda)

Potential Impact The proposed works are 7.8 km from the Ireland’s Eye SPA. No impact on the bird species or Wetlands representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 7.8 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

IE0004006 North Bull Island SPA

Out Conservation Objective: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level.

Qualifying Interests A046 Light-bellied Brent Goose (Branta bernicla hrota) A048 Shelduck (Tadorna tadorna) A052 Teal (Anas crecca) A054 Pintail (Anas acuta) A056 Shoveler (Anas clypeata) A130 Oystercatcher (Haematopus ostralegus) A140 Golden Plover (Pluvialis apricaria) A141 Grey Plover (Pluvialis squatarola) A143 Knot (Calidris canutus) A144 Sanderling (Calidris alba) A149 Dunlin (Calidris alpina alpine) A156 Black-tailed Godwit (Limosa limosa) A157 Bar-tailed Godwit (Limosa lapponica) A160 Curlew (Numenius arquata) A162 Redshank (Tringa tetanus) A169 Turnstone (Arenaria interpres) A179 Black-headed Gull (Chroicocephalus ridibundus) A999 Wetlands Potential Impact The proposed works are 9.8 km from the North Bull Island SPA on the southern side of the Howth Head peninsula. No impact on the bird species or Wetlands representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 9.8 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. No impact predicted

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Details/Reason

IE0004113 Howth Head Coast SPA

Out Conservation Objective: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA Qualifying Interests A188 Kittiwake (Rissa tridactyla) Potential Impact The proposed works are 10.5 km from the Howth Head Coast SPA. No impact on the qualifying interests of this SPA is foreseen. No impact on the Kittiwake which represents the qualifying interest of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 10.5 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina. . No impact predicted

IE0004024 South Dublin Bay and River Tolka Estuary SPA

Out Conservation Objective: The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level.

Qualifying Interests Light-bellied Brent Goose (Branta bernicla hrota) Oystercatcher (Haematopus ostralegus) Ringed Plover (Charadrius hiaticula) Grey Plover (Pluvialis squatarola) Knot (Calidris canutus) Sanderling (Calidris alba) Dunlin (Calidris alpina) Bar-tailed Godwit (Limosa lapponica) Redshank (Tringa totanus) Black-headed Gull (Croicocephalus ridibundus) Roseate Tern (Sterna dougallii) Common Tern (Sterna hirundo) Arctic Tern (Sterna paradisaea) Wetlands & Waterbirds

Potential Impact The works are located 13.7 km from the South Dublin Bay and River Tolka Estuary SPA. No impact on the bird species or Wetlands representing the qualifying interests of this SPA is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 13.7 km from the SPA in an area that has regular boat traffic with the close proximity to Malahide Marina.

No impact predicted

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Special Areas of Conservation NATURA CODE


Details/Reason

IE0003000 Rockabill to Dalkey Island SAC

IN Conservation Objectives: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected.

Qualifying Interests 1170 Reefs 1351 Harbour porpoise Phocoena phocoena

Potential Impact The proposed survey route is within this SAC which has been designated for Reef and harbour porpoise.

Further Information is Required on the Distribution and Status of Conservation Objectives to assess potential impact. (see additional information following this table)

IE0000205 Malahide Estuary SAC

IN Conservation Objectives: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected.

Qualifying Interests and targets 1140 Mudflats and sandflats not covered by seawater at low tide. 1310 Salicornia and other annuals colonising mud and sand 1320 Spartina swards (Spartinion maritimae) As outlined in NPWS (2013) it not be necessary to assess the likely effects of plans or projects against this Annex I habitat at this site. 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1410 Mediterranean salt meadows (Juncetalia maritimi) 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes).

Potential Impact The landfall and site investigations are within this SAC.

Further Information is Required on the Distribution and Status of Conservation Objectives to assess potential impact. (see additional information following this table)

IE0000208 Rogerstown Estuary SAC

Out Conservation Objectives: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected.

Qualifying Interests 1130 Estuaries 1140 Mudflats and sandflats not covered by seawater at low tide 1310 Salicornia and other annuals colonising mud and sand 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1410 Mediterranean salt meadows (Juncetalia maritimi) 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes)

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Potential Impact The development site is located within a residential area 1.8km m from the SAC. No impact the qualifying interests of this SAC is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 1.8 km from the SAC in an area that has regular boat traffic with the close proximity to Malahide Marina.

No Impact Predicted.

IE000204 Lambay SAC Out Conservation Objectives: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected.

Qualifying Interests 1170 Reefs 1230 Vegetated sea cliffs of the Atlantic and Baltic coasts 1364 Grey Seal (Halichoerus grypus) 1365 Common Seal (Phoca vitulina)

Potential Impact The proposed works are located 2.1 km from this SAC. No impact the qualifying interests of this SAC is foreseen, due limited nature of the survey in both area and temporal extent. Seals that are resident in this SAC may be in the vicinity of the proposed survey. The “Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters” will be complied with at all stages of the project. All operations will be a minimum of 2.1 km from the SAC in an area that has regular boat traffic with the close proximity to Malahide Marina.

No impact predicted IE0000199 Baldoyle Bay

SAC Out Qualifying Interests

Salicornia and other annuals colonising mud and sand (1310) Atlantic salt meadows (Glauco - Puccinellietalia maritimae) (1330) Mediterranean salt meadows (Juncetalia maritimi)(MSM) (1410) The following habitats were recorded during the Coastal Monitoring Project (Ryle et al., 2009) but they are not listed in the qualifying interests for the site: Annual vegetation of drift lines (1210) Embryonic shifting dunes (2110) Shifting dunes along the shoreline with Ammophila arenaria (white dunes) (2120) Fixed coastal dunes with herbaceous vegetation (grey dunes) (2130) Humid dune slacks (2190) Potential Impact The proposed works are located 6.6 km from this SAC. No impact the qualifying interests of this SAC is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 2.1 km from the SAC. No impact predicted

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IE0002193 Ireland's Eye SAC

Out Conservation Objectives: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected. Features of Interest 1220 Perennial vegetation of stony banks 1230 Vegetated sea cliffs of the Atlantic and Baltic coasts Potential Impact The proposed works are located 7.7 km from this SAC. No impact the qualifying interests of this SAC is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 7.7 km from the SAC. No impact predicted

IE0000206 North Dublin Bay SAC

Out Conservation Objectives: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected. Features of Interest 1140 Mudflats and sandflats not covered by seawater at low tide 1210 Annual vegetation of drift lines 1310 Salicornia and other annuals colonising mud and sand 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1395 Petalwort Petalophyllum ralfsii 1410 Mediterranean salt meadows (Juncetalia maritimi) 2110 Embryonic shifting dunes 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes) 2190 Humid dune slacks Potential Impact The proposed works are located 9.8 km from this SAC. No impact the qualifying interests of this SAC is foreseen, due limited nature of the survey in both area and temporal extent. All operations will be a minimum of 9.8 km from the SAC. No impact predicted

IE0000202 Howth Head SAC

Out Conservation Objectives To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected. Qualifying Interests (1230) Vegetated sea cliffs of the Atlantic and Baltic coasts (4030) European dry heaths Potential Impact The proposed works are located 10.5 km from this SAC. No impact the qualifying interests of this SAC is foreseen, due limited nature of the survey in both area and temporal extent. No impact predicted

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Conservation Objectives and overall status of relevant species and habitats Malahide Estuary SAC (IE0000205)

Malahide Estuary SAC is designated for a range of coastal habitats including saltmarshes and sand dunes. The following five coastal habitats are included in the qualifying interests for the site (* denotes a priority habitat):

⋅ 1140 Mudflats and sandflats not covered by seawater at low tide

⋅ 1310 Salicornia and other annuals colonising mud and sand

⋅ 1320 Spartina swards (Spartinion maritimae)

⋅ 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

⋅ 1410 Mediterranean salt meadows (Juncetalia maritimi)

⋅ 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes)

⋅ 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes)* The distributions of these habitats within the SAC in relation to the proposed fibre-optic cable route are seen in Figures 14-17. As can be seen from these figures the proposed fibre optic cable route in not in the vicinity of Saltmarsh (Figure 14) or Sand dune (Figure 15) habitats. However, it is within the habitat “Mudflats and sandflats not covered by sea water at low tide” (Figure 16) comprised of a “Fine sand with oligochaetes, amphipods, bivalves and polychaetes community complex” (Figure 17). As outlined in the marine habitats supporting document “this community complex occurs along the eastern boundary of the site from the Martello Tower at Balcarrick in the north to Portmarnock in the south. The sediment of this community complex is largely that of fine sand (ranging from 74% to 88.9%) with negligible amounts of coarse material (<4%). The complex is distinguished by the oligochaete Tubificoides benedii, the crustacean Bathyporeia guilliamsoniana, the bivalve Angulus tenuis and the polychaetes Nephtys cirrosa, Hediste diversicolor, Scoloplos armiger and Scolelepis squamata, all of which occur in moderate abundances here”. Distinguishing species of the Fine sand with oligochaetes, amphipods, bivalves and polychaetes community complex are Tubificoides benedii, Hediste diversicolor, Bathyporeia guilliamsoniana, Scoloplos armiger, Angulus tenuis, Scolelepis squamata and Nephtys cirrosa. In NPWS (2013a) a technical clarification is provided in relation to specific conservation objectives and targets for Annex I habitats to facilitate the appropriate assessment process: Objective: To maintain the favourable conservation condition of Mudflats and sandflats not covered by seawater at low tide in Malahide Estuary SAC, which is defined by the following list of attributes and targets. “Target 1: The permanent habitat area is stable or increasing, subject to natural processes. This target refers to activities or operations that propose to permanently remove habitat from a site, thereby reducing the permanent amount of habitat area. It does not refer to long or short term disturbance of the biology of a site. Early consultation or scoping with the Department in advance of formal application is advisable for such proposals.

Target 2: Maintain the extent of the Zostera-dominated community and Mytilus-dominated community complex, subject to natural processes. 2 The Zostera-dominated community and Mytilus-dominated community complex are considered to be keystone communities that are of considerable importance to the overall ecology and biodiversity of a habitat by virtue of its physical complexity, e.g. the former community serves as important nursery grounds for commercial and non-commercial species while both provide important food sources for a number of bird species.

Any significant anthropogenic disturbance to the extent of this community should be avoided.

2 Note: Both species communities are seen within the Estuary and not out on the open coast (Figure 17)

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An interpolation of the likely distribution of these community types are provided in figure 2. The areas given below are based on spatial interpolation and therefore should be considered indicative:

- Zostera-dominated community – 5ha,

- Mytilus-dominated community complex- 4ha

Target 3: Conserve the high quality of the Zostera-dominated community, subject to natural processes. It is important to ensure the quality as well as the extent of Zostera-dominated communities is conserved. For example, percent coverage can provide an indication of the habitat quality as well as giving information on the habitat complexity and refuge capability; all important components in maintaining the structural and functional integrity of the habitat. Target 4: Conserve the high quality of the Mytilus edulis-dominated community complex, subject to natural processes. Every effort should be made to avoid any death to living Mytilus edulis.

Any significant anthropogenic disturbance to the quality (e.g. living individual/m2) of the community should be avoided.

Target 5: Conserve the following community types in a natural condition: Fine sand with oligochaetes, amphipods, bivalves and polychaetes community complex; Estuarine sandy mud with Chironomidae and Hediste diversicolor community complex; and Sand to muddy sand with Peringia ulvae, Tubificoides benedii and Cerastoderma edule community complex. The estimated areas of the communities within the Mudflats and sandflats not covered by seawater at low tide habitat given below are based on spatial interpolation and therefore should be considered indicative: - Fine sand with oligochaetes, amphipods, bivalves and polychaetes community complex – 126ha - Estuarine sandy mud with Chironomidae and Hediste diversicolor community complex – 7ha - Sand to muddy sand with Peringia ulvae, Tubificoides benedii and Cerastoderma edule community complex – 169ha Significant continuous or ongoing disturbance of communities should not exceed an approximate area of 15% of the interpolated area of each community type, at which point an inter-Departmental management review is recommended prior to further licensing of such activities. Proposed activities or operations that cause significant disturbance to communities but may not necessarily represent a continuous or ongoing source of disturbance over time and space may be assessed in a context-specific manner giving due consideration to the proposed nature and scale of activities during the reporting cycle and the particular resilience of the receiving habitat in combination with other activities within the designated site.” It is also stated in the Conservation objectives of this SAC that the objective in relation to Mudflats and sandflats not covered by seawater at low tide is “to maintain the favourable conservation condition of Mudflats and sandflats not covered by seawater at low tide in Malahide Estuary SAC” including Conserving “the following community types in a natural condition: Fine sand with oligochaetes, amphipods, bivalves and polychaetes community complex; Estuarine sandy mud with Chironomidae and Hediste diversicolor community complex; and Sand to muddy sand with Peringia ulvae, Tubificoides benedii and Cerastoderma edule community complex.” Conclusion Habitats of conservation importance are located in the vicinity of the proposed site investigations. The potential impact of these works on each of the Conservation Objectives is assessed in detail in Section E) (Potential impact and the significance of the impact) on p47.

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Figure 14. Position of proposed cable route in relation to saltmarsh habitats in Malahide Estuary SAC.

Proposed cable route

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Figure 15. Position of proposed cable route in relation to sand dune habitats in Malahide Estuary SAC.


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Figure 16. Position of proposed cable route in relation to Mudflats and sandflats not covered by sea water at low tide in Malahide Estuary SAC.


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Figure 17. Position of proposed cable route in relation to marine communities in Malahide Estuary SAC.


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Conservation Objectives and overall status of relevant species and habitats Rockabill to Dalkey SAC (IE0003000) Phocoena Phocoena (Harbour porpoise) As stated in NPWS (2013b) “this small toothed cetacean species (from the mammal Order Cetacea - whales, dolphins and porpoises) occurs in estuarine, coastal and offshore waters in which it carries out breeding, foraging, resting, social activity and other life history functions. Its distribution extends predominantly throughout continental shelf waters and the species may range over many hundreds or thousands of kilometres. As air-breathing mammals, harbour porpoises must return to the water surface to breathe but they are otherwise wholly aquatic. Individual porpoises of all ages use sound as their primary sensory tool in order to navigate, communicate, avoid predators, or locate and facilitate the capture of prey under water. Group sizes tend to be small (i.e. in single figures, more commonly 2 to 3 individuals) although larger aggregations may occasionally be recorded, particularly in the summer months. Harbour porpoise breed annually in Ireland, predominantly during the months of May to September. The principal calving period in Irish waters is thought to occur in the months of May and June, although it may extend throughout the summer months and into early autumn. Newborn calves are weaned before they are one year old. Mating commonly occurs several weeks after the calving season. The occurrence of harbour porpoises within a prescribed marine area can be estimated using visual observation and passive acoustic methods in order to deliver an assessment of community or population size (i.e. relative abundance or absolute abundance), density and distribution. The size, community structure and distribution or habitat use of harbour porpoise inhabiting Rockabill to Dalkey Island SAC are not fully understood. In acknowledging limitations in the understanding of aquatic habitat use by the species within the site, it should be noted that all suitable aquatic habitat (Figure 18) is considered relevant to the species range and ecological requirements at the site and is therefore of potential use by harbour porpoises. Survey effort targeting the 2008 summer-autumn season delivered initial estimates of 0.54-6.93 animals per km2 within the northern half of the site (overall estimate across four surveys: 2.03 individuals per km2, N=211±47 individuals, 95% Confidence Intervals: 137-327, Coefficient of Variation=0.23) and 0.48-2.05 animals per km2 within the southern half of the site, including outer Dublin Bay (overall estimate across four surveys: 1.19 individuals per km2, N=138±33 individuals, 95% Confidence Intervals: 86-221, Coefficient of Variation=0.24). While the numbers of harbour porpoise encountered during any survey within the site are variable, additional acoustic data plus casual and effort-related sighting rates from coastal observation stations are significant for the east coast of Ireland and, comparatively high group sizes (>5 individuals) have been recorded from this area. The species is present at the site in all seasons, while important cohorts within the harbour porpoise community such as adults juveniles and newborn calves have also been recorded within the site, including during the calving/breeding season. Harbour porpoise is a successful aquatic predator that feeds on a wide variety of fish, cephalopod and crustacean species occurring in the water column or close to the seabed. Dive depths in excess of 200m have been recorded for the species. Foraging areas for harbour porpoise are often associated with areas of strong tidal current and associated eddies; therefore the occurrence of porpoises close to shore or adjacent to islands and prominent headlands is commonly reported. However gaps remain in the knowledge of the species foraging ecology within Rockabill to Dalkey Island SAC and the available data may be biased toward particular locations due to the nature of survey effort and opportunistic reports from a range of sources. No detailed information is currently available on individual or group movements by harbour porpoise within or into and out of the site, nor is it known whether individuals or groups of the species demonstrate any faithfulness to the site (i.e. site fidelity or residency). Nevertheless, the consistent annual and seasonal occurrence of the species at the site, its occurrence during the calving/breeding period and density/population estimates available to date all indicate the importance of this coastal site for the species.

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Figure 18. Distribution of Harbour Porpoise in Rockabill to Dalkey SAC.

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According to Berrow & O’Brien (2013) who carried out six surveys in Rockabill to Dalkey Island SAC between July and September 2013, estimates in Rockabill to Dalkey Island SAC ranged from 1.13 porpoises per km2 to a maximum of 2.61, with an overall density of 1.44±0.09 porpoises per km2 with a very low CV of 0.06. Harbour porpoise abundance for Rockabill to Dalkey Island SAC was around 400 individuals (391±25 with 95% CI of 344- 445). The proportion of young harbour porpoises (i.e., juveniles +calves) recorded on survey days ranged from c. 4-19% of all animals seen and was c. 7% overall using the combined dataset. The proportion of calves recorded on each survey ranged from 0 to c. 8% of all animals seen and was c. 2% overall using the combined dataset. The following technical clarification is provided in relation to specific conservation objectives and targets for Annex II species to facilitate the appropriate assessment process (NPWS, 2013b): Harbour Porpoise Objective: To maintain the favourable conservation condition of harbour porpoise in Rockabill to Dalkey Island SAC, which is defined by the following list of attributes and targets Target 1 Species range within the site should not be restricted by artificial barriers to site use. This target may be considered relevant to proposed activities or operations that will result in the permanent exclusion of harbour porpoise from part of its range within the site, or will permanently prevent access for the species to suitable habitat therein. It does not refer to short-term or temporary restriction of access or range. Early consultation or scoping with the Department in advance of formal application is advisable for proposals that are likely to result in permanent exclusion. Target 2 Human activities should occur at levels that do not adversely affect the harbour porpoise community at the site. Proposed activities or operations should not introduce man-made energy (e.g. aerial or underwater noise, light or thermal energy) at levels that could result in a significant negative impact on individuals and/or the community of harbour porpoise within the site. This refers to the aquatic habitats used by the species in addition to important natural behaviours during the species annual cycle. This target also relates to proposed activities or operations that may result in the deterioration of key resources (e.g. water quality, feeding, etc) upon which harbour porpoises depend. In the absence of complete knowledge on the species ecological requirements in this site, such considerations should be assessed where appropriate on a case-by-case basis. Proposed activities or operations should not cause death or injury to individuals to an extent that may ultimately affect the harbour porpoise community at the site. Conclusion Species of importance are located in the vicinity of the proposed site investigations. The potential impact of these works on each of the Conservation Objectives is assessed in detail in Section E) (Potential impact and the significance of the impact) on p47.

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Reef Within the Rockabill to Dalkey Island SAC two community types are recorded within the Annex I habitat, namely Intertidal reef community complex and Subtidal reef community complex (Figures 19 & 20). Intertidal reef community complex This reef community complex is recorded on the islands within this site and on the south coast of Howth. The exposure regime of the complex ranges from exposed to moderately exposed reef (Figure 19). Exposed reef is recorded on the east side of Dalkey Island, on the east and southern shores of Ireland’s Eye and on all shores of Rockabill and the Muglins. Moderately exposed reef occurs on the western shores of Dalkey and at Howth and Ireland’s Eye. The substrate here is that of flat and sloping bedrock; around Rockabill cobbles and boulders occur on bedrock. Vertical cliff faces are found on the north and northeast shores of Ireland’s Eye; steep shorelines are a feature of Rockabill, Muglins and the eastern shore of Dalkey Island. The species associated with this community complex include the fucoids Fucus serratus, F. vesiculosus, F. spiralis, Ascophyllum nodosum and Pelvetia canaliculata, the barnacle Semibalanus balanoides and the bivalve Mytilus edulis. In the more exposed areas Semibalanus balanoides and Mytilus edulis dominate while in the more moderately exposed areas it is the fucoid species that are more abundant. The gastropods Patella vulgata and Littorina sp. are also recorded here. In all area the kelp species Laminaria digitata is recorded at the low water mark. Species associated with the Intertidal reef community complex include Fucus serratus, Fucus spiralis Fucus vesiculosus, Semibalanus balanoides, Ascophyllum nodosum, Mytilus edulis, Pelvetia canaliculata, Patella vulgata, Laminaria digitata and Littorina sp. Subtidal reef community complex. This community complex is recorded off the islands within the site and also off the coast between Lambay Island and Rush Village (Figure 19). The exposure regime here ranges from moderately exposed reef at the Muglins to exposed reef over the remainder of the site. The substrate ranges from that of flat and sloping bedrock, to bedrock with boulders and also a mosaic of cobbles and boulders. Vertical rock walls occur on the north and east of Ireland’s Eye and to the east of Lambay Island where they give way to sloping bedrock at c.20m. In the northern reaches of the site, at Rockabill and Ireland’s Eye, areas of both sediment scouring and a thin veneer of silt were observed on the reefs; the veneer of silt was also recorded at Lambay Island. In the south of the site, strong currents were experienced in the channel between Dalkey Island and the Muglins. In the shallow reaches of this community complex (<10m) a sparse covering of the kelp species Laminaria hyperborea occurs with an undercover of red algal species including Hypoglossum hypoglossoides, Brongniartella byssoides, Membranoptera alata, Phycodrys rubens and Delesseria sanguinea. In deeper water (>10m) the anemone Alcyonium digitatum occurs in moderate abundances and Metridium senile also being recorded here. Faunal crusts of bryozoans such as Flustra foliacea and Chartella papyracea and hydroids including Nemertesia antennina are recorded in deeper water (>20m) along with the ascidian Aplidium punctum. The asteroid Asterias rubens is recorded throughout the site while the barnacle Balanus crenatus, the echinoderms Echinus esculentus and Antedon bifida also occur here. In general, it was noted that where the reef was subjected to the effects of sediment, either through scouring or settlement of silt, low numbers of species and individuals occurred. Conclusion Habitats of conservation importance are located in the vicinity of the proposed site investigations. The potential impact of these works on each of the Conservation Objectives is assessed in detail in Section E) (Potential impact and the significance of the impact) on p47.

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Figure 19. Conservation Objectives-Marine community types in Rockabill to Dalkey SAC.

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Figure 20. Distribution of Reef in Rockabill to Dalkey SAC.

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E) Field Observations at Donabate, Co. Dublin.

Figure 9: Satellite image of the Ross Strand Area During fieldwork, only those features relevant to the proposed site investigations for the fibre optic cable, the potential cumulative effects in relation the installation of the fibre-optic and surrounding impacts that may have an adverse effect on the integrity of NATURA 2000 sites, have been considered. An adverse effect on integrity is likely to be one that prevents the site from making the same contribution to favourable conservation status for the relevant features as it did at the time of designation; ‘integrity’ being defined by the European Commission (2000) as relating to the reasons for the site’s designation:

“The integrity of a site is the coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and / or populations of species for which the site is or will be classified”

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During our field observations, we had particular regard to any sign of the above potential impacts on the SAC in which the landfall site and cable route are located. A walk over assessment of the proposed route in the intertidal, including trial pit locations was carried out by Bryan Deegan (Altemar Ltd.) on the 2nd July 2016.

The location of the proposed landfall is a popular Blue Flag beach (Balcarrick) located near Donabate, Co. Dublin. Despite the showery conditions on site the beach was relatively busy. The proposed cable route is beside the main access to the beach via the Martello Tower and The Waterside House Hotel. The route follows the main sandy shore and avoids the rocky outcrop and boulders to the north. The upper shore is made up of fine sand and no drift lines were present. However, a considerable amount of detached filamentous red algae and Enteromorpha

lactuca was present on the midshore. No anoxic sediment was noted in the vicinity of the algae. Occasional casts of juvenile Arenicola marina were seen on the lower shore. No Zostera sp. or Mytilus edulis were noted on the route of the proposed fibre optic cable.

Proposed Route of fibre-optic cable

Detached algae on the mid-shore

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E) Potential impact and the significance of the impact Cetaceans All cetaceans are listed under Annex IV of the Habitats Directive, which means that they are protected wherever they occur. Bottle-nosed Dolphin and Harbour Porpoise are also listed under Annex II of the Directive. Annex II species require that core areas of their habitat are designated as sites of Community importance i.e. SAC’s. Rockabill to Dalkey SAC has been designated for Harbour Porpoise. Cetaceans have been recorded in near the proposed survey out to and beyond the 12nm limit (Figure 21). The proposed survey would be expected to impact on cetaceans primarily through the emission of noise due to the vessel and acoustics from survey equipment including multibeam. As outlined by O’Brien (2005), “sound travels 4.5 times faster in water than in air and low frequency sounds travel farther underwater than high frequency sounds. Multi-beam can be defined as Low frequency (<1 kHz), Mid-frequency (1-10 kHz) and High Frequency (>10 kHz). The hearing ranges and sensitivity of marine mammals differ from one species to another depending on their audiogram. For example, harbour porpoises are sensitive from 3 kHz to 130 kHz, with peak sensitivity at 125-130 kHz, and bottlenose dolphins from 5-110 kHz, with peak sensitivity at 40 and 60-116 kHz (Southall et al., 2007). Common seals are sensitive 4-45 kHz (peak sensitivity at 32 kHz) and grey seals 8-40 kHz. Humans are sensitive only to frequencies from 20 Hz to 16-18kHz but with peak sensitivity from 2-4 kHz. Most small cetaceans, excluding harbour porpoise, have an auditory bandwidth of 150 HZ to – 160 kHz, while harbour porpoise to frequencies within 200 Hz to 180 kHz. Pinnipeds in water are thought to have an auditory bandwidth of between of 75 Hz to 75 kHz and from 75 Hz to 30 kHz in air (Southall et al. 2007).” The cetacean species observed along the route of the proposed marine survey are mainly mid-frequency and high frequency cetaceans. Southall et al. (2007) outlined in their publication Marine Mammal Noise Exposure Criteria: Initial Scientific Recommendations that for discrete noise events such as multi-beam, for mid-frequency and high frequency cetaceans maximum peak pressure level of 230 dB re 1 uPa and a maximum received sound pressure level of 198 dB re 1 uPa2-s (Table 14) Table 14. Southall et al. (2007) Proposed injury criteria for individual marine mammals exposed to “discrete” noise events (either single or multiple exposures within a 24-h period).

The proposed survey equipment and the noise frequency emissions are seen in Table 15. The high frequencies emitted from the equipment (210 kHz and 400 kHz) are above the auditory range of the mid frequency but within the hearing range of high frequency cetaceans observed and on the proposed cable route (Tables 15 & 16).

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Table 15. Proposed survey equipment.

The 100 kHz (Edgetech 4200 Sidescan towfish) and 33 kHz (Reson Navisound 420mid-frequencies of) emit mid-range frequencies within the hearing ranges of small cetaceans (and seals). The Geoacoustics 4x4 hull mounted sub-bottom profiler Pinger (3-7.5kHz) emits low frequency noise, within the auditory range of harbor porpoise and the lower detection range of dolphins. The Reson Navisound 420 (168-174 dB) emits noise below the acceptable received source level (db) and should not adversely affect cetaceans. As the Geoacoustics Sub-bottom Profiler and Edgetech 4200 Sidescan towfish emit noise of 225 dB (re 1 uPa2) at 4-7.5k Hz and 226 dB (re 1 uPa2) at 11 kHz, which is above the 198 (re 1 uPa2) proposed injury levels indicated by Southall et al (2007), negative impacts may be foreseen if cetaceans are close enough to the equipment to receive sound levels above this indicative threshold. Table 16. Marine Mammal Functional Hearing Groups and Estimated Functional Hearing Ranges Proposed by Southall et al. (2007)

Lurton (2016) modelled the sound field radiated by multibeam echosounders for acoustical impact assessment. He stated that “considering the injury criteria, the results illustrate that injury hazards are possible only at very short distances from the source: e.g. about 5 m for SPL and 12 m for SEL in the case of a 240-dB source level, considering cetaceans. For behavioural response criteria, the corresponding values are 9 m and 70 m.” The survey would comply with the DoEHLG’s Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters3 . These guidelines require a 1000m distance which would be deemed adequate to mitigate the negative impacts of the proposed survey. In addition, cetaceans in the vicinity of the vessel during start up procedures would be given ample time to leave the site with the soft start procedures outlined in the guidelines.

3 http://www.npws.ie/sites/default/files/general/Underwater%20sound%20guidance_Jan%202014.pdf

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Figure 21. Distribution of Cetacean sightings (IWDG sightings scheme)and SAC’s within 12nm limit and proximity to the proposed cable route.

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Figure 22. Distribution of Cetacean sightings during Q1 (IWDG sightings scheme) and SAC’s within 12nm limit and proximity to the proposed cable route.

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The potential impact and the significance of the impact of the activity in combination with the other plans and projects for each of the conservation objectives in the screened NATURA 2000 sites are seen in the tables below:

Malahide SAC (IE0000205)

Qualifying Interest Impact and Significance

[1310] Salicornia and other annuals colonizing mud and sand

This habitat does not occur in the vicinity of the proposed site investigations. The proposed site investigations will not impact on this habitat. No Impact Predicted.

[1330] Atlantic salt meadows (Glauco‐ Puccinellietalia maritimae)


[1410] Mediterranean salt meadows (Juncetalia maritimi)


[2120] Shifting dunes along the shoreline with Ammophila arenaria ("white dunes")


[2130] Fixed coastal dunes with herbaceous vegetation ("grey dunes")


[1320] Spartina swards (Spartinion maritimae)

“Spartina swards (Spartinion maritimae) was originally listed as a qualifying Annex I habitat for Malahide Estuary SAC due to historical records of two rare forms of cordgrass–small cordgrass (Spartina maritima) and Townsend’s cordgrass (S . x townsendii.). However, Preston et al. (2002) considers both forms to be alien. In addition, all stands of cordgrass in Ireland are now regarded as common cordgrass (S. anglica) (McCorry et al., 2003; McCorry and Ryle, 2009). As a consequence, a conservation objective has not been prepared for this habitat. It will therefore not be necessary to assess the likely effects of plans or projects against this Annex I habitat at this site.” No Impact Predicted.

[1140] Mudflats and sandflats not covered by seawater at low tide

This habitat does occur in the vicinity of the proposed site investigations. The proposed site investigations are located at the northern end of the SAC on a blue flag beach within an area of Mudflats and sandflats not covered by seawater at low tide which undergoes significant disturbance. The site investigations will involve the placement of a machinery and personnel on shore for bar probes and digging of three trial pits. Bar probes will cause localised disturbance to the sediment and may result in mortality of a small number of infauna but this is not deemed to be significant. The movement of machinery on the shore may result in temporary localised compression of sediments during one tidal cycle. The extent of disturbance along the 300m track is approximately 300m2 (0.03ha). Trial pits should be dug within this track. The total area of this habitat on site is 311ha (NPWS,

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2013) and temporary disturbance represents less than 0.01% of the habitat. The proposed works will not alter the extent of the permanent habitat area. The area is outside areas of Zostera sp. and Mytilus edulis. Neither species was noted during the site visit. The proposed route is within the area noted as “Fine sand with oligochaetes, amphipods, bivalves and polychaetes community complex” and it is noted that a conservation objective it to “conserve the community type in a natural condition”. The proposed works will not alter the longterm ecology or “natural condition” of the site in this area that is already exposed to footfall as a result of the blue flag beach. Although no impacts are foreseen on the conservation objectives of the SAC mitigation measures are proposed to reduce the footprint of the works No Impact Predicted.

Rockabill to Dalkey Island SAC (IE0003000)


[1170] Reefs

Based on the areas identified in (NPWS 2013) intertidal or subtidal reef habitat would not be expected to occur in the vicinity of the proposed site investigations. The proposed route would was initially screened to purposely avoid reef areas so that the cable can be buried sufficiently. However, the purpose of site investigations is to assess the route for burial suitability and areas of subtidal reef may be encountered. If present, the site investigations may cause minor localised disturbance in the reef areas to the extent of area of the sampling equipment. It would be expected that this would be in a similar in nature to effects of a small boat anchor on the seabed. The proposed site investigations would not impact on the distribution or the permanent area occupied by reef and will not impact on the integrity of this habitat within this SAC. No Significant Impact Predicted.

[1351] Harbour porpoise (Phocoena phocoena)

This species could occur in the vicinity of the proposed site investigations. The proposed site investigations will pass through this SAC and the survey length within the SAC will be 12.6km. The proposed works will not result in the species range within the site being restricted by artificial barriers to site use. Proposed activities or operations should not introduce man-made energy (e.g. aerial or underwater noise, light or thermal energy) at levels that could result in a significant negative impact on individuals and/or the community of harbour porpoise within the site. This refers to the aquatic habitats used by the species in addition to important natural behaviours during the species annual cycle. Proposed activities or operations should not cause death or injury to individuals to an extent that may ultimately affect the harbour porpoise community at the site.

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The proposed survey would be carried out in Q1 2017. As outlined in NPWS (2013b) the species is present at the site in all seasons and breed annually, predominantly during the months of May to September. The principal calving period in Irish waters is thought to occur in the months of May and June, although it may extend throughout the summer months and into early autumn. Newborn calves are weaned before they are one year old. Mating commonly occurs several weeks after the calving season. Therefore the proposed survey will be outside the main breeding season for harbour porpoise. The survey would comply with the DoEHLG’s Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters As a result it is concluded that the Human activities proposed will occur at levels that do not adversely affect the harbour porpoise community at the site. No Significant Impact Predicted.

Mitigation Measures

1. Under no circumstance should seals hauled out in the area be disturbed such that they enter the water. This is unlikely, as this area is not recognised as a haul out area.

2. All site investigations should not take place if brent geese or other birds of conservation interest are

present in the immediate area. If roosting birds are present on the uppershore, the survey should be postponed until the birds depart, without provocation.

3. Drift lines if present should be avoided by machinery.

4. The bucket of the digger should have teeth, so as to minimize scraping of metal against

rock/boulders, if these are found to be present.

5. The trial pits should be dug on a receding tide. This is to ensure all operations are done on one tidal cycle and should be completed before an incoming tide when many of the birds return to feed and infauna are exposed to a minimum amount of disturbance.

6. Trial pits should be dug within the tracks of disturbance caused by machinery. Machinery should exit the beach on the same tracks that it entered the beach.

7. The sand layer should be treated as a separate layer and stored on the surface separately to ensure the

integrity of the sandflat upon completion of the site investigation.

8. Images should be taken of the process and upon completion for inspection.

9. Cetaceans: The survey would comply with the DoEHLG’s Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters . These guidelines require a 1000m distance which would be deemed adequate to mitigate the negative impacts of the proposed survey. In addition, cetaceans in the vicinity of the vessel during start up procedures would be given ample time to leave the site with the soft start procedures outlined in the guidelines.

54

F) Cumulative Impacts Disturbance Donabate (Balcarrick) strand is a popular Blue Flag beach only 22km from Dublin City Centre. The average daily visitor numbers to the beach during the bathing season is approximately 600 (Bathing Water Profile). The beach is used for walking, swimming and canoeing. The underwater acoustic noise emitted during site investigations involving boat traffic would not be thought to be higher than normal acoustic levels on a day to day basis in this area as the site is located near the Malahide Designated Shellfish Area and Malahide Marina, which has 350 fully serviced berths and can accommodate vessels up to 75 metres l.o.a. and 4 metres draught. Fibre-optic Cable Laying If the site investigations prove to be positive the proposed laying of the fibre optic cable will need to be assessed and considered. This will be dealt with in the main lay permissions including requirements under the European Communities (Birds and Natural Habitats) Regulations 2011.

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5. Finding of No Significant Effects Report

Details of project Name and Location of the NATURA 2000 site Special Areas of Conservation

1) Rockabill to Dalkey Island SAC (cable route passes through this SAC) 2) Malahide Estuary SAC (Landfall within SAC) 3) Rodgerstown Estuary SAC (1.8km from cable route) 4) Lambay Island SAC (2.1 km from cable route) 5) Baldoyle Bay SAC (6.6 km from cable route) 6) Ireland’s Eye SAC (7.7 km from cable route) 7) North Dublin Bay SAC (9.8 km from cable route) 8) Howth Head SAC (10.5 km from cable route) Special Protection Areas 1) Rockabill SPA (110m from cable route but is within proposed survey corridor) 2) Rogerstown Estuary SPA (1.2km from cable route) 3) Malahide Estuary SPA (1.3km from landfall) 4) Lambay Island SPA (1.7 km from cable route) 5) Skerries Islands SPA (4.6km from cable route) 6) Baldoyle Bay SPA (6.6 km from cable route) 7) Ireland’s Eye SPA (7.8 km from cable route) 8) North Bull Island SPA(9.8 km from cable route) 9) Howth Head Coast SPA (10.5 km from cable route) 10) South Dublin Bay and River Tolka SPA (13.7km from cable route)

Description of the Project Appropriate Assessment Screening for site investigations (Foreshore Licence Application) for AquaComms fibre-optic cable landing in Donabate, Co. Dublin.

Is the Project directly connected with the management of the NATURA 2000 site?

No

Details of any other projects or plans that together with this project could affect the Natura 2000 site

None

The assessment of significant effects Describe how the project is likely to affect the NATURA 2000 site

Temporary compaction and disturbance of sediment (300m2) within Malahide Estuary SAC and introduction of acoustic noise into Rockabill to Dalkey SAC.

Response to consultation N/A Data collected to carry out the assessment Who carried out the assessment Altemar Ltd. Sources of data NPWS website, standard data form, conservation

objectives data, field survey of the site and references outlined in the AA Screening Report.

Explain why the effects are not considered significant

Deemed to be not a significant effect due to the minor and limited temporal nature of the site investigations. Minor disturbance may occur but mitigation measures are proposed.

Level of assessment completed Stage 1 Screening Where can full results be accessed and reviewed National Parks and Wildlife Service Overall conclusions No significant impact on associated NATURA 2000 sites/species or habitats is foreseen.

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6. References The following references were used in the preparation of this AA screening report.

1. Department of Environment Heritage and Local Government Circular NPW 1/10 and PSSP 2/10 on Appropriate Assessment under Article 6 of the Habitats Directive – Guidance for Planning Authorities March 2010.

2. Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities,

Department of the Environment, Heritage and Local Government 2009; http://www.npws.ie/publications/archive/NPWS_2009_AA_Guidance.pdf

3. Managing NATURA 2000 Sites: the provisions of Article 6 of the Habitats Directive

92/43/EEC, European Commission 2000; http://ec.europa.eu/environment/nature/Natura2000/management/docs/art6/provision_of_art6_en.pdf

4. Assessment of Plans and Projects Significantly Affecting NATURA 2000 Sites: Methodological

guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC; http://ec.europa.eu/environment/nature/Natura2000management/docs/art6/Natura_2000_assess_en.pdf

5. Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC – Clarification of

the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission; http://ec.europa.eu/environment/nature/Natura2000/management/docs/art6/guidance_art6_4_en.pdf

6. Guidance document on the implementation of the birds and habitats directive in estuaries and

coastal zones with particular attention to port development and dredging; http://ec.europa.eu/environment/nature/Natura2000/management/docs/guidance_doc.pdf

7. The Status of EU Protected Habitats and Species in Ireland. http://www.npws.ie/publications/euconservationstatus/NPWS_2007_Conservation_Status_Report.pdf

8. NPWS (2013) Conservation Objectives: Baldoyle Bay SPA 004016. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

9. NPWS (2012). Conservation Objectives: Baldoyle Bay SAC 000199. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

10. NPWS (2012b). Baldoyle Bay SAC (site code 199)Conservation objectives supporting document -coastal habitats

11. NPWS (2015) Conservation objectives for Ireland's Eye SPA [004117]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht.

12. NPWS (2013) Conservation Objectives: Rogerstown Estuary SPA 004015. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

13. NPWS (2015) Conservation objectives for Howth Head Coast SPA [004113]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht.

14. NPWS (2015) Conservation Objectives: North Bull Island SPA 004006. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

15. NPWS (2013) Conservation Objectives: Malahide Estuary SPA 004025. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

16. NPWS (2015) Conservation objectives for Howth Head SAC [000202]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht.

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17. NPWS (2015) Conservation objectives for Ireland's Eye SAC [002193]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht.

18. NPWS (2013) Conservation Objectives: Malahide Estuary SAC 000205. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

19. NPWS (2013) Conservation Objectives: North Dublin Bay SAC 000206. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

20. NPWS (2013) Conservation Objectives: Rockabill to Dalkey Island SAC 003000. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

21. NPWS (2013b) Rockabill to Dalkey Island SAC (site code: 3000)Conservation objectives supporting document. -Marine Habitats and Species Version 1

22. NPWS (2013) Conservation Objectives: Rogerstown Estuary SAC 000208. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

23. Berrow, S.D. and O’Brien, J. (2013). Harbour porpoise SAC survey 2013. Report to the National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. Irish Whale and Dolphin Group. pp. 37.

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Appendix I. pNHA,NHA and Ramsar sites within 5 km of the fibre-optic cable route.


APPENDIX 2

ROUTE POSITION LIST

Celtix Connect 2 RPL - Inshore UK Blackpool Option

30-06-16

Latitude Longitude

TP0 53° 28.667'N 6° 7.022'W

TP1 53° 28.569'N 6° 6.829'W

TP2 53° 28.563'N 6° 4.898'W

TP3 53° 29.500'N 6° 4.126'W

TP4 53° 30.612'N 6° 3.409'W

TP5 53° 31.699'N 6° 0.102'W

TP6 53° 33.489'N 6° 0.310'W

TP7 53° 33.834'N 5° 56.452'W

TP8 53° 35.308'N 5° 50.892'W

TP9 53° 45.640'N 5° 20.056'W

TP10 53° 45.240'N 5° 17.966'W

TP11 53° 45.755'N 5° 12.975'W

TP12 53° 51.424'N 4° 55.983'W

TP13 53° 50.451'N 4° 40.293'W

TP14 53° 49.197'N 4° 25.626'W

TP15 53° 48.158'N 4° 10.252'W

TP16 53° 46.955'N 3° 52.017'W

TP17 53° 46.955'N 3° 46.326'W

TP18 53° 45.802'N 3° 42.180'W

TP19 53° 44.772'N 3° 37.880'W

TP20 53° 44.474'N 3° 35.827'W

TP21 53° 44.329'N 3° 26.035'W

TP22 53° 44.490'N 3° 22.807'W

TP23 53° 45.004'N 3° 22.441'W

TP24 53° 45.002'N 3° 14.930'W

TP25 53° 45.002'N 3° 13.426'W

TP26 53° 45.230'N 3° 7.848'W

TP27 53° 46.522'N 3° 3.449'W

Position (WGS-84)


APPENDIX 3

DRAWINGS

1297-101 FORESHORE LICENCE MAP 1

OFFSHORE SECTION

1297-102 FORESHORE LICENCE MAP 2

INSHORE SECTION

1297-103 SITE LOCATION MAP 1

Documents

APPLICATION FOR FORESHORE LICENCE FOR MARINE ......Foreshore Application Report 11 August 2016 CeltixConnect 2 Site Investigation Works Job No. 1297 3.0 PROPOSED MARINE SURVEY & SITE