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Environmental
Impact Statement
JJK Renewables
Grugganskeagh Wind Farm, County Down
2016
JJK Renewables
1/11/2016
i
Table of Contents
List of Figures..........................................................................................................................iii
Introduction..............................................................................................................................1
Purpose of the Report............................................................................................................1
Area Considered within the EIA.............................................................................................2
Project Description..................................................................................................................5
Planning Application Site and Associated Lands ..................................................................5
Land Ownership.....................................................................................................................6
Purpose of the Development .................................................................................................6
Proposed Windfarm Layout ................................................................................................... 7
Detail of Recommended Turbines ......................................................................................... 7
Life Cycle of the Site ..............................................................................................................8
Environmental Description.....................................................................................................9
Geography of the Proposed Site ...........................................................................................9
Current and Historical Landscape Usage of the Site ............................................................9
Land use in the Wider Area of Study...................................................................................10
Anticipated Environmental Impacts and Mitigation ..........................................................12
Anticipated Environmental Impacts .....................................................................................12
Measures to Minimise Impacts ............................................................................................14
Proposed Mitigation Strategies............................................................................................ 15
Analysis of Alternatives.........................................................................................................17
Environmental Monitoring Programme...............................................................................19
Environmental Management Plan........................................................................................19
Additional Studies .................................................................................................................21
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Public Consultation ..............................................................................................................21
Health, Safety and Environmental Management.................................................................21
Project Benefits and Analysis ..............................................................................................22
Executive Summary and Conclusion ..................................................................................23
Introduction...........................................................................................................................23
Environmental Interactions ..................................................................................................23
Conclusion............................................................................................................................25
Disclosure of Consultants Engaged.................................................................................... 27
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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List of Figures
Figure 1 Map illustrating the proposed site and the location of each individual Enercon
turbine. .......................................................................................................................................3
Figure 2 A 1:3km (kilometre) scale map showing the Grugganskeagh windfarm location and
surrounding towns, including Hilltown and Mayobridge............................................................4
Figure 3 Access point at Mullaghgarriff Road ..........................................................................5
Figure 4 The Enercon E53 turbine, as proposed by JJK Renewables. ...................................7
Figure 5 Table showing whether or not monitoring is required during different phases of the
windfarm proposal at Grugganskeagh ....................................................................................20
Figure 6 The buzzard. This species was considered during the proposal.............................24
1
Introduction
Purpose of the Report
This Environmental Impact Assessment (EIA) has been produced by JJK Consultants with a
view to assess the potential impact of the proposed windfarm on 3.2 square kilometres of
land that is 500 metres south east of the Mullaghariff Road in the town of Grugganskeagh.
Grugganskeagh is approximately four miles south east of Hilltown in County Down, Northern
Ireland. The site itself falls within the jurisdiction of the Newry and Mourne councils. This
report is associated with the full planning application made by JJK Consultants which
includes the construction of the following:
 20 Enercon E-53 turbines (each 100 metres in height),
 Concrete foundations and surround for each turbine,
 Improvements to access routes for haulage along the Mullaghariff Road,
 Substation and control building,
 Temporary construction compound (including car parking),
 Five kilometres of internal tracks on site.
The EIA is being produced in order to comply with the EU Directive, 2011/92/EU, which was
established on 13 December 2011. This directive has since been converted to fit within a
local context for Northern Ireland in the form of Planning (Environmental Impact
Assessment) Regulations (Northern Ireland, 2012). These regulations became active on 13
March 2012 and supersede any and all previous EIA regulations for the region.
The purpose of this EIA report is to ensure that the windfarm is constructed with the
consideration of environmental responsibility being at the forefront of the list of priorities,
thus ensuring cultural, environmental and social impacts are as minimal as possible. As
such, mitigation strategies for any foreseen issues are included alongside a holistic view of
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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the project’s lifecycle being considered including construction, operational and
decommissioning phases.
Area Considered within the EIA
The site of the windfarm as proposed in the planning application will be 3.2 square
kilometres (km²; Figure 1) however it is appreciated that the area that falls under the
applicants control will be much larger (Figure 2). Resultantly, some of these areas have also
required inclusion in the EIA where relevant, for the most part the land included is the area
immediately associated with the windfarm site and associated infrastructure and access
routes.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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As mentioned, Figure 1 shows the location of each individual turbine along the chosen
plateaux area of the Mournes at Grugganskeagh. A number of alternative sites were
suggested and considered during the application. For example, a proposed site on the top of
the Mournes was rejected largely due to access restrictions despite the site being the
windiest of all considered.
Figure 1 Map illustratingthe proposed site and the locationof eachindividual Enercon turbine (See Key).
Key
= Plateaux
= 1 Enercon turbine
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Normal practice dictated that spacing between each Enercon E53 was to be at least three
times the size of the rotor diameter. In the case of Grugganskeagh, each turbine has a rotor
diameter of 52.9 metres, meaning that spacing between each is to be at least 158.7 metres.
This is the spacing that JJK Renewables propose.
Figure 2 A 1:3km (kilometre) scale mapshowingthe Grugganskeagh windfarm location and surrounding towns, including
Hilltown and Mayobridge. Source:http://irish.gridreferencefinder.com/
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Project Description
Planning Application Site and Associated Lands
The planned site is positioned four kilometres south west of Hilltown in the townlands of
Grugganskeagh, Gruggandoo and Mullaghgarve. The site is positioned west of the
Rostrevor Road (B25) and 500 metres south east of the Mullaghariff Road. The closest
settlement to the site is Hilltown, with the surrounding land being sparsely populated and
predominantly used for agriculture. The Mullaghariff Road is the proposed access route for
the site (Figure 3).
The planned site itself includes mainly pastureland transitioning into moorland, bog and
exposed bedrock as altitude increases. The land is divided by a combination of wire fence,
dry stone walls and hedgerows. The main land use is that of sheep grazing.
Figure 3 Access point at MullaghgarriffRoad
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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The site is positioned on a plateau of land at 310 metres above sea level in the western
foothills of the Mourne Mountains. Continuing eastwards from the site altitude continues to
increase to 364 metres above sea level at Slieve Roe. To the north and west the land drops
into the Leitrim river valley and Newry basins respectively.
Land Ownership
All of the land involved in the proposed development is privately owned and an agreement
has been reached with the landowners and various stakeholders regarding how the
development will proceed and how they will be compensated for the use of their land.
Purpose of the Development
The development will help Northern Ireland meet its commitment to the reduction of
emissions to 20 per cent below 1990 levels by 2020 as well as the Assembly’s commitment
to generating 40 per cent of Northern Ireland’s energy via renewable means in the same
time frame.
Additionally, the site will deliver the following benefits to Northern Ireland:
 Displacement of 89,500 tonnes of carbon dioxide (CO2) per year,
 The powering of approximately 50,000 homes per year,
 The generation of £16.3 million in the 25-year life span,
 Input of £10 million into the local economy though employment,
 Increased energy security for local regions,
 Improvement of local infrastructure.
The site is in accordance with policy as it advocates:
 The selection of appropriate sites rather than a comparison between sites,
 Proceeding with projects which will aid in meeting policy targets,
 Projects which deliver benefits at both the local and regional scales.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Proposed Windfarm Layout
Constituent elements of the windfarm:
 20 individual turbines with 40-50 metre buffer zone between each model (Figure 4),
 Access tracks on site connecting the turbines,
 Electricity substation,
 Temporary soil deposition areas and construction compound (limited to construction
phase only),
 Reinforced access routes over waterways,
 Grid connection (to be established and designed by Northern Ireland Electricity),
 Entry and exit off the Mullaghgarriff Road.
Detail of Recommended Turbines
The turbines recommended for use on this site are Enercon E53 turbines (Figure 4), the
same as are used in many other similar projects across the United Kingdom. These turbines
have a hub height of 75 metres and are 100 metres tall with the addition of the length of the
blades and a total blade diameter of 52.9 metres. With an output of 800kW, each of the
turbines are operational in wind speeds from 2.5-34m/s
(metres per second) with their peak output at 12m/s and
have a predicted lifecycle of 25 years. The turbines will be
mounted on a reinforced concrete foundation with an area
of 15x15 metres to a depth of 5 metres as per the norm for
such cases. The foundations will be circular in shape and
feature a support element for the turbine which will be
bolted in place. Upon the decommissioning of the site the
foundations can be dismantled and removed with the
remaining holes being refilled with soil.
Figure 4 The EnerconE53 turbine, as proposed by JJK
Renewables. Source:http://cdu-kirchlinteln.de/cdu-fuer-
sozial-vertraegliche-windkraftnutzung
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Life Cycle of the Site
The construction phase of the site is expected to take 12-18 months and will be conducted
by a contracted engineering company. Any timescales and estimates are subject to weather
and economic variables. The site is expected to last for 25 years with regular maintenance,
and will be decommissioned following this period.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Environmental Description
Geography of the Proposed Site
The proposed site is located on the western periphery of the Mourne Mountains in County
Down, Northern Ireland, at an elevation of 360 metres above sea level. The site itself is
located on a plateaux area at Grugganskeagh, which is exposed in nature with significant
grass cover and exposed granite rock which would be attributed to the retreat of glacial ice
following the Midlandian glacial maxima. There are also areas of shallow peat bog, acid
grassland and wet heath on the site. The site is positioned with the main body of the Mourne
Mountains immediately to the east/south east, while on all other sides the landscape slopes
down from the site into the basins of the Newry, Knockbarragh and Leitrim rivers.
Current and Historical Landscape Usage of the Site
The proposed site lies in an area where the lower slopes are dedicated to agricultural
grazing, mainly of sheep, while the upland areas are predominantly bog and peat land areas
which are more open in format. The land is divided using dry stone walls in the traditional
manner; with hedgerows (mainly hawthorn in variety) also being incorporated on the lower
reaches of the slopes. Access to the fields is mainly gained by single track lanes flanked by
hedgerows and/or hedgerows which extend to provide access to the majority, but not the
entirety of the site area.
The exposed nature of the site contributing to the limited vegetation results in the area
hosting no form of commercial forestry or woodland areas. Only a sporadic covering of ash,
and hawthorn trees are present with hedgerows being the only vegetation of note which is
subject to any management strategies.
The Mullaghgarriff Road is the main access route to the site. This is a small, quiet country
road with little traffic in a moderate state of repair and a small number of individual dwellings
on it. Other roads in close proximity to the site include the Rostrevor Road, Yellow Road,
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Lower Knockbarragh Road and Coyle’s Hill Road, all of which are minor routes and host few
dwellings.
Land use in the Wider Area of Study
Due to the nature of a site with such a scale being positioned at elevation there must be a
consideration for the surrounding area and the manner in which such a development may
have an influence in a wider context. This is recommended by ‘SNH Visual Representation
of Wind Farms 2014’ where, for a site the scale of which we are proposing, a 20-35
kilometre radius should be considered in an application.
The application is for an area close to the Mourne Mountains which includes six mountains
over 700 metres high, as well as a number of lakes, dams and reservoirs. The area also
plays host to a range of peat land and bog environments. Also included are forest parks at
Kilbroney and Tullymore, alongside a number of commercial forestry sites of conifers.
Tourism is a dominant feature in the area with will-walkers, campers, day trippers and rock
climbers availing of the mountain environment. Approximately 1,300 acres of land in the area
is under National Trust management and the region features heavily in the Draft Tourism
Strategy for Northern Ireland until 2020. The Mournes also hold ‘Area of Outstanding Natural
Beauty’ (AONB) status and features picturesque landmarks such as the Mourne Wall and a
number of marked trails which are popular with tourists.
Within a 10 kilometre radius of the site the total human population is approximately 14,500
according to the 2011 census. The majority of these people live in the villages of Rostrevor,
Rathfriland, Mayobridge, Hilltown and the town of Warrenpoint. These rural settlements are
mainly constituted of detached houses, bungalows and cottages positioned in close
proximity to the roads, with larger farms being located slightly further away from the major
highways. All of the settlements exist in the lowland regions and there is little to no
development on the more elevated areas. There are also a notable number of isolated
derelict or abandoned houses in the area.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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The settlements and majority of people in the area inhabit areas close to the following major
roads:
 A25 Newry Road,
 B27 Kilkeel Road,
 B25 Rostrevor Road,
 B180 Bryansfort Road,
 B8 Hilltown Road.
The area is also serviced by the more minor Mullaghgarriff, Yellow, Lower Knockbarragh and
Leitrim roads.
All of the areas within the wider area of study, as defined by the 35 kilometre radius, fall into
the medium to high sensitivity bracket with regards landscape sensitivity to a possible visual
impact according to the NIEA (Northern Ireland Environment Agency) Sensitivity Scale as
defined in SPG Wind Energy Development in Northern Ireland’s Landscape (2010).
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Anticipated Environmental Impacts and Mitigation
Anticipated Environmental Impacts
The general approach of quantifying the environmental impacts associated with such a
project is based on the nature and sensitivity of the involved species and environment. The
main parties considered with regards the environmental impacts of the project are species
habitats, bats, badgers, smooth newts and the Irish Hare (Lepus timidus hibernicus).
During the Construction Phase
 There will be a direct removal of habitats in the immediate site area due to the
introduction of infrastructure such as the access routes, waste disposal areas,
construction compounds and the turbines themselves. The habitats concerned are
mainly shallow peat bog, acid grassland and wet heath. The total area concerned
with this level of environmental degradation is 3.2km². This impact will also be more
permanent in nature than other impacts associated with the construction phase. A
considerable amount of grassland will be effected, however this land is mostly semi-
improved, and only a small proportion is unimproved and making the transition to wet
heath
 There will be a small degree of contamination of waterways due to the mobilisation of
soil and debris. The total impact from this will be minimal due to the limited nature of
the fisheries in the watercourses associated with the affected area
 Lower air quality and further habitat impacts from increases in heavy machinery and
traffic
 The majority of damage likely to influence the badger population is likely to be
associated with the construction phase of the wind farm. Badger setts may be
vulnerable to damage during construction if the activity is in their immediate vicinity,
as the level of ground disturbance may cause collapse and destabilisation of tunnels.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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The increased traffic may also lead to an increased number of badger deaths from
traffic associated incidents
 The resident bat population will also be exposed to some potentially adverse
impacts, namely habitat fragmentation. This issue will be of a very small magnitude
due to the nature of vegetation on site. The lack of apparent roosting sites means
there will be no discernible loss of roosting sites for the local bat population
 There will be minimal impact on smooth newt populations as there is only one body
of water which could host the species and it will be unaffected by the construction
 The Irish Hare will experience localised disturbance on a temporary basis which will
yield negligible population impacts
 Salmon species may be impacted by declines in water quality associated with ground
disturbance and subsequent entrainment of particulate matter into water
 Accumulation of sediment on riverbeds may inhibit spawning of some salmon due to
eggs becoming smothered. This can impact invertebrate species in similar ways
 Navigation of fish through the drainage network may be impacted by the temporary
obstruction of channels in the application area. This is of particular relevance in
Ghann River which will have temporary crossing points constructed on it.
During the Operational Phase
 Habitats will experience no additional impacts
 Badgers will experience no negative impacts from the wind farm as maintenance
work is not foreseen to contribute any additional disturbance
 Bats may experience issues with potential collisions with the rotor blades due to a
change in air pressure associated with the moving blades. The site generally
experiences low bat activity and most activity are located near significant natural
features as opposed to open, standalone areas such as the wind farm site proposed
by JJK Consultants. Only Leisler’s bats are at significant risk from the turbines due to
their particular behavioural patterns. All other species are at no or low levels of risk
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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 Irish Hare are at no additional risk
 Smooth newts are at no additional risk
 There may be impacts to a trout stock in the Ghann River tributaries associated with
the site. This is due to the crossing points that are scheduled to be constructed in this
location which could impede the migration of the fish. If unmitigated this could
develop into a considerable issue.
During the Decommissioning Phase
The same impacts will be experienced as during construction phase, with the exception of
the impacts associated with the presence of the construction compound.
Measures to Minimise Impacts
During the Construction Phase
 The wind farm has been strategically designed to avoid intrusion into the active peat
environments present on site. The supporting infrastructure present during
construction will be positioned so as to totally avoid all pockets of fen or mire habitats
 Habitat enhancement for Irish hare should serve to compensate for the small scale
disturbance the species will experience
 Planting trees and implementing hedge reinstatement should serve to reduce any
negative impacts on the resident bat population.
During the Operational Phase
To try and prevent excessive bat casualties from collision with rotor blades there is a 50m
buffer zone between each turbine, as per common practice. Care has been given to ensure
turbines are sufficiently far from any habitat features likely to host high levels of bat activity.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Proposed Mitigation Strategies
During the Construction Phase
Ecology
 Areas containing particularly sensitive habitats will be clearly demarcated and it will
be a priority to avoid intrusion into the protected zones. A similar strategy will be
employed to mitigate against damage to badger setts
 Materials for components such as roads and foundations will be selected according
to the degree of compatibility with the existing soil and groundwater characteristics
 An ecological consultant will be employed during the construction phase to ensure
environmental objectives are met
 A sustainable drainage system will be established around the construction zone to
ensure minimal groundwater or watercourse contamination
 Any hedges removed during the construction phase will be reinstated using the
original component species, and new hedge will be planted along the Mullaghgarriff
Road to aid in habitat enhancement for bats.
Fisheries
 Reductions in the impact of particulate matter in run-off include 50 metre buffer zones
around aquatic areas, the inclusion of check-dams and drainage systems which treat
any surface run-off from the site
 Water quality will be monitored
 Main construction activities likely to cause wholesale soil disturbance will be limited
to outside salmon spawning season.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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During the Operational Phase
Habitats
 Habitat enhancement measures will be utilised to mitigate against any potential
damage to the resident species. This should offset the damage of the permanent loss
of some habitats
 The 50 metre buffer zone between turbines is the main form of mitigation against
harming bat populations, as well as the height of the turbines being out of the
common flightpath of many species.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Analysis of Alternatives
Schedule 4, Item 2 of the 2012 EIA Regulations places a requirement on the provision of
main alternatives considered and the reasoning behind the deciding on a particular site.
There are thus a number of sections to be considered.
1) ‘Do nothing’ Approach – To simply do nothing is an unacceptable alternative
to developing the proposed wind farm for a plethora of reasons. Firstly there
is an ever-pressing need to achieve the UN, EU and regional level targets on
the reduction of greenhouse gases and the increased proportion of energy to
be produced by renewable means. Without windfarms such as the one
proposed by JJK Consultants at Grugganskeagh, these targets would almost
certainly fail to be met. To do nothing may be counter-productive from a
planning point of view as it may well pressurise authorities to pass other
possibly less appropriate sites in an effort to satisfy government targets.
2) Site Selection – The suitability of the site was assessed using a combination
of background desk-based research and site visits. An analysis of a
particular criteria identified how appropriate the site selection was and
identified were possible limitations:
 Wind resource – Proposed site has an excellent wind resource
evident from data collected prior to application
 Grid connection - There will be future gird connection
availability and capacity in the vicinity of the site
 Proximity to dwellings – The site is an appropriate distance to
neighbouring dwellings
 Area of land available - There is a large area within the
controlled lands, allowing for the avoidance of sensitive
ecological and archaeological areas identified through the EIA
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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 Site access – The site has suitable access
 Topography – Site topography is appropriate for the proposed
development
 Nature conservation designations and ecological impacts –
Addressed in the environmental/ecological interaction section
of this report
 Land use designations - Addressed in the
environmental/ecological interaction section of this report
 Location of archaeological and cultural heritage features -
Addressed in the environmental/ecological interaction section
of this report
 Telecommunications/aviation interests - Addressed in the
environmental/ecological interaction section of this report
3) Evolution of Alternative Design – The design of the application has been
evolved in such a way that it seeks to minimise environmental detriment
whilst maximising the production of renewable energy. This was achieved
through the assessment of an originally larger area of the mountain to find
the most appropriate location for the development given the criteria and
where the development could be accommodated. For example, placing the
turbines close to the summit of the mountain would maximise energy
production but vastly increase visual impacts of the application and thus a
compromise was settled upon.
Alternative renewable technologies at present do not have the same potential to generate
green energy in the immediate future as onshore wind. Major hydroelectric developments
and offshore wind farms are not currently at the stage where the energy they could
potentially generate would be beneficial in meeting current legislated targets.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Environmental Monitoring Programme
Environmental Management Plan
The proposed windfarm at Grugganskeagh is to consist of 20 standalone turbines that
are each approximately 100 metres high along the periphery of the Mourne Mountains;
an Area of Outstanding Natural Beauty (AONB). Due to the large-scale nature of the
windfarm it is imperative that, following approval, an Environmental Management Plan
(EMP) is introduced in order to monitor and mitigate the effects of the construction on the
various aspects that are to be affected by the proposal. These aspects include ecology,
transport and tourism, which are highly considered throughout the proposal due to their
fragile temperament. Throughout the EMP a list of environmental objectives will be
drawn up so that targets can be met throughout the proposal, providing a professional
organisational structure during both the construction and operational phases. This will
continue periodically throughout the life cycle of the windfarm right up until the
decommissioning phase in 25 years. Therefore the Environmental Management Plan is
to monitor and mitigate both the short and long-term effects of the windfarm proposal on
surrounding environment and ecology.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Table 1 below summarizes aspects affected by the proposed windfarm and indicates
whether or not monitoring is required during the construction, operational and
decommissioning phase:
Key:
Y = Monitoring and management is required during this phase
N = Monitoring and management is not required during this phase.
A scheduled programme of surveys is required in order to ensure negative impacts have not
exceeded previously predicted levels and should be carried out by the appropriately qualified
professionals and subcontractors commissioned to do so. These surveys should take place
in continued liaison with all stakeholder groups of the application.
Monitoring required during:
Construction Phase Operational Phase Decommissioning
Phase
Ecology (Flora and
Fauna)
Y Y Y
Fisheries Y N Y
Avian Ecology Y Y N
Water and Geology
Environment
Y N Y
Transport, Access and
Haulage
Y N Y
Noise Y Y Y
Shadow Flicker N Y N
Tourism Y Y Y
Telecommunications and
Aviation
N Y N
Electromagnetic Fields N Y N
Figure 5 Table showing whether or not monitoringis required duringdifferent phases of the windfarm proposal at
Grugganskeagh
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Additional Studies
Public Consultation
Planning applications were all published using the appropriate avenues including all local
newspapers and relevant government websites. A consultation evening was advertised and
held in a local community centre where members of the public could voice their concern, if
any, and receive information regarding the application.
The consultation draft of the Strategic Planning Policy Statement (SPPS) was published and
underwent a public consultation period. The SPPS provides a shorter, simpler, strategic
policy framework that provides clarity and certainty for all users of the reformed planning
system. The SPPS consolidates 20 separate pieces of planning policy to a single statement
and heralds a new approach to the preparation of regional planning policy.
Health, Safety and Environmental Management
It is the responsibility of the developer to appoint a Construction Design Management (CDM)
coordinator and a principle contractor in keeping with CDM regulations prior to the
commencement of construction. The CDM coordinator will oversee the collection and
distribution of pre-construction information, usually as part of the tendering process. The
principal contractor is responsible for preparing the Construction Phase Plan (CPP) which
covers all aspects of Health and Safety for the project. This construction phase plan will
include procedure for incident reporting, contingency planning and monitoring. Audits will
occur regularly in coincidence with key construction phases also. Additionally, the plan will
include maintenance emergency service vehicles and will require the contractor to liaise with
emergency services prior to commencing work as well as ensuring access to emergency
vehicles from this point until completion of the construction phase.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
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Project Benefits and Analysis
There is a multitude of potential benefits associated with the application, none more so
evident than the overall environmental benefits. The generation of electricity from a
renewable, clean source will reduce the need for conventional fossil fuels to be burnt and
thus will directly contribute to the improvement of air quality regionally. This proposed
development has the potential to power approximately 50,000 homes, reducing local
electricity costs. 89,500 tonnes of carbon dioxide will be displaced simultaneously. This
equates to the removal 67,523 cars from the roads in the North of Ireland.
Aside from benefits the environment, the proposed project will have profound benefits for
Northern Ireland’s economy. For example, 56 per cent of the total proposed expenditure
over the 25 year life span of the project is to be retained within the Northern Irish economy.
Local direct and indirect benefits during the construction phase will include:
 The purchase and supply of aggregates, concrete and steel,
 Construction contracts for the construction of turbine bases,
 Erection of substation building,
 Civils contracts for electrical engineering associated with the grid connection,
 Accommodation,
 Day-to-day supplies for contractors,
 Transportation of turbine components.
Over the 25 year project life, the estimated total (direct and indirect) benefits from the
ongoing operation of the development equates to a total of 312 jobs, £8.98 million of total
wages and £21.93 million of total GVA (gross value added). Each turbine requires £1.4
million per year to run, meaning that yearly running totals will equate to £28 million. Whilst
costs are also going to be incurred during the implementation of the project on elements
such as licenses and payroll, the environmental and monetary benefits, as mentioned above,
are to massively outweigh these running costs in both the immediate and long term.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
23
ExecutiveSummary and Conclusion
Introduction
The proposed windfarm has been assessed in accordance with the EU Directive,
2011/92/EU, which was established on 13 December 2011. This legislative act has since
been modified to fit within a local context for Northern Ireland, thus becoming relevant for the
Environmental Impact Assessment by JJK Renewables at Grugganskeagh.
Environmental Interactions
Ecology (flora and fauna):
The impact of the proposal on terrestrial flora and fauna is considered to be minimal and of
low impact at all stages. One anomaly would be wet heath present at the proposed site,
which is expected to be the recipient of moderate impact during the construction phase.
However, these impacts are easily mitigated against via restoration or management of
existing habitats. Additionally, the infrastructure at Mullaghgarriff Road is an area that has
previously been cleared of vegetation, therefore requiring minimal disturbance to native
vegetation.
Fisheries:
The windfarm proposal is to have a negligible impact on surrounding fisheries. Impacts, if
any, would likely occur as a result of ground disturbance during the early construction phase.
This has the potential to obscure trout movements through river courses as a result of the
introduction of artificial stream crossings. A surface water management plan is ready to
mitigate against this.
Avian Ecology:
From an overall standpoint, there are to be no significant impacts on relevant, local bird
species such as buzzards and ravens (Figure 5), both of which are highly coveted by the
RSPB (Royal Society for the Protection of Birds). Included in the proposal are 500 metre
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
24
buffer zones, with special consideration given to
ensuring that there is no overlap between the
project area and bird roosting sites. Furthermore,
a 12-month field survey is to be undertaken to
determine the baseline numbers of birds present
during an annual cycle in order to provide data on
the distribution and movements of these birds.
Water and Geology Environment:
Underlying geology of the proposed site at
Grugganskeagh comprises mainly alluvium with
granite bedrock. The site is upstream of an area of a significant groundwater body, but does
not lie in the catchment of any significant rivers. Potential impacts on hydrology have been
identified and mitigation strategies are to be implemented accordingly.
Transport, Access and Haulage:
Any increase in traffic in the area will be short term as it is immediately limited to the
construction phase. Traffic levels will be similar during the decommissioning phase in 25
years, but traffic will be minimal during the operational phase. Traffic will also be regulated
by designated policy guidelines. Construction materials are to be sourced locally as part of a
mitigation strategy to minimise traffic at the site. Also as part of this mitigation strategy is a
proposed widening of roads as part of a traffic management and road construction plan,
where installation will be carried out in stages. Local residents will also be given warning of
arrangements through mediums such as local newspapers.
Noise:
As part of the proposal, an assessment is to be conducted according to the Assessment and
Rating of Noise from Windfarms Protocol 1996 and associated good practice guidelines. The
Figure 6 The buzzard. This species was considered during the
proposal. Source:
https://www.rspb.org.uk/discoverandenjoynature/discoverandle
arn/birdguide/name/b/buzzard/
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
25
site also complies with EU legislation regarding turbine location. Noise cannot be completely
mitigated against during the most intensive period of the construction phase, however the
impact will be short term and will result in an overall benefit to residents in the long term
which outweigh these short-term impacts. Work to reduce noise will be managed as much as
practicable.
Shadow Flicker:
In a worst case scenario, a limited number of nearby properties will experience shadow
flicker. These levels are, however, within designated guidelines. To avoid these effects,
mitigation measures have been integrated into the site design with regard to colour and
finish of the Enercon E-53 turbines. Turbines may also be programmed to shut down in the
event of likely shadow flicker.
Tourism:
The proposed 20-turbine site at Grugganskeagh is not visible from 80 per cent of the Mourne
Mountains. Any views in the remaining view shed are moderate to no impact, thus indicating
that the tourism industry will not suffer as a result of an accepted proposal. This is because
the proposed site is located far from popular tourist destinations of the Mournes that people
travel far distances to visit.
Archaeology and Cultural Heritage:
There is a moderate risk of visual impact on neighbouring recorded Iron Age burial sites, but
there are no direct impacts anticipated with the proposed Grugganskeagh site.
Conclusion
The European Union (EU) has set legally binding targets for the production of 20 per cent of
EU energy consumption to come from renewable sources and for a reduction of greenhouse
gas emissions to 20 per cent below 1990 levels by the end of 2020. The windfarm proposal
at Grugganskeagh by JJK Renewables can act as an ideal component in helping Northern
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
26
Ireland contribute to reaching these targets in the designated time. The project itself provides
an environmentally sustainable alternative to the unsustainable burning of fossil fuels and,
as noted, no significant environmental or ecological impacts have been identified.
It is concluded by JJK Renewables that the project at Grugganskeagh is justified when all
components throughout this EIS are considered. The best possible turbine specification is to
be used at the windfarm and this enables and 800 kilowatt output of renewable energy to
Northern Ireland’s existing power generation capacity, among many other benefits that were
identified as primary objectives. These include indirect benefits of the windfarm such as the
boosting of the employment sector that is going to provide the local population with jobs.
Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty)
27
Disclosure ofConsultants Engaged
Professor Ian W. Montgomery, Queen’s University Belfast
Professor Ian Montgomery, a Professor of Animal Ecology at Queen’s University Belfast,
acted as majority stakeholder throughout the windfarm proposal and Environmental Impact
Assessment (EIA) at Grugganskeagh. Prof. Montgomery actively participated in decisions on
the planning and management of the windfarm from the scoping stage to the reviewing
stage, while simultaneously providing great expertise and local knowledge that are vital
ingredients for effective environmental assessment. Below is a brief résumé that highlights
the value of the aforementioned as a majority stakeholder:
 Over 150 publications and reports that include over 100 peer-reviewed journals and
edited collections,
 Total research grant income exceeding £3.5M,
 Successful supervision of 46 PhD students,
 Past Head of School of Biological Sciences at Queen’s University Belfast (1995-
2010),
 Established Quercus (2003-2008); a focus for the development of expertise in
conservation science within Northern Ireland. Now a director.

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MSc_Env_Impact_Assess

  • 1. 0 Environmental Impact Statement JJK Renewables Grugganskeagh Wind Farm, County Down 2016 JJK Renewables 1/11/2016
  • 2. i Table of Contents List of Figures..........................................................................................................................iii Introduction..............................................................................................................................1 Purpose of the Report............................................................................................................1 Area Considered within the EIA.............................................................................................2 Project Description..................................................................................................................5 Planning Application Site and Associated Lands ..................................................................5 Land Ownership.....................................................................................................................6 Purpose of the Development .................................................................................................6 Proposed Windfarm Layout ................................................................................................... 7 Detail of Recommended Turbines ......................................................................................... 7 Life Cycle of the Site ..............................................................................................................8 Environmental Description.....................................................................................................9 Geography of the Proposed Site ...........................................................................................9 Current and Historical Landscape Usage of the Site ............................................................9 Land use in the Wider Area of Study...................................................................................10 Anticipated Environmental Impacts and Mitigation ..........................................................12 Anticipated Environmental Impacts .....................................................................................12 Measures to Minimise Impacts ............................................................................................14 Proposed Mitigation Strategies............................................................................................ 15 Analysis of Alternatives.........................................................................................................17 Environmental Monitoring Programme...............................................................................19 Environmental Management Plan........................................................................................19 Additional Studies .................................................................................................................21
  • 3. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) ii Public Consultation ..............................................................................................................21 Health, Safety and Environmental Management.................................................................21 Project Benefits and Analysis ..............................................................................................22 Executive Summary and Conclusion ..................................................................................23 Introduction...........................................................................................................................23 Environmental Interactions ..................................................................................................23 Conclusion............................................................................................................................25 Disclosure of Consultants Engaged.................................................................................... 27
  • 4. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) iii List of Figures Figure 1 Map illustrating the proposed site and the location of each individual Enercon turbine. .......................................................................................................................................3 Figure 2 A 1:3km (kilometre) scale map showing the Grugganskeagh windfarm location and surrounding towns, including Hilltown and Mayobridge............................................................4 Figure 3 Access point at Mullaghgarriff Road ..........................................................................5 Figure 4 The Enercon E53 turbine, as proposed by JJK Renewables. ...................................7 Figure 5 Table showing whether or not monitoring is required during different phases of the windfarm proposal at Grugganskeagh ....................................................................................20 Figure 6 The buzzard. This species was considered during the proposal.............................24
  • 5. 1 Introduction Purpose of the Report This Environmental Impact Assessment (EIA) has been produced by JJK Consultants with a view to assess the potential impact of the proposed windfarm on 3.2 square kilometres of land that is 500 metres south east of the Mullaghariff Road in the town of Grugganskeagh. Grugganskeagh is approximately four miles south east of Hilltown in County Down, Northern Ireland. The site itself falls within the jurisdiction of the Newry and Mourne councils. This report is associated with the full planning application made by JJK Consultants which includes the construction of the following:  20 Enercon E-53 turbines (each 100 metres in height),  Concrete foundations and surround for each turbine,  Improvements to access routes for haulage along the Mullaghariff Road,  Substation and control building,  Temporary construction compound (including car parking),  Five kilometres of internal tracks on site. The EIA is being produced in order to comply with the EU Directive, 2011/92/EU, which was established on 13 December 2011. This directive has since been converted to fit within a local context for Northern Ireland in the form of Planning (Environmental Impact Assessment) Regulations (Northern Ireland, 2012). These regulations became active on 13 March 2012 and supersede any and all previous EIA regulations for the region. The purpose of this EIA report is to ensure that the windfarm is constructed with the consideration of environmental responsibility being at the forefront of the list of priorities, thus ensuring cultural, environmental and social impacts are as minimal as possible. As such, mitigation strategies for any foreseen issues are included alongside a holistic view of
  • 6. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 2 the project’s lifecycle being considered including construction, operational and decommissioning phases. Area Considered within the EIA The site of the windfarm as proposed in the planning application will be 3.2 square kilometres (km²; Figure 1) however it is appreciated that the area that falls under the applicants control will be much larger (Figure 2). Resultantly, some of these areas have also required inclusion in the EIA where relevant, for the most part the land included is the area immediately associated with the windfarm site and associated infrastructure and access routes.
  • 7. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 3 As mentioned, Figure 1 shows the location of each individual turbine along the chosen plateaux area of the Mournes at Grugganskeagh. A number of alternative sites were suggested and considered during the application. For example, a proposed site on the top of the Mournes was rejected largely due to access restrictions despite the site being the windiest of all considered. Figure 1 Map illustratingthe proposed site and the locationof eachindividual Enercon turbine (See Key). Key = Plateaux = 1 Enercon turbine
  • 8. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 4 Normal practice dictated that spacing between each Enercon E53 was to be at least three times the size of the rotor diameter. In the case of Grugganskeagh, each turbine has a rotor diameter of 52.9 metres, meaning that spacing between each is to be at least 158.7 metres. This is the spacing that JJK Renewables propose. Figure 2 A 1:3km (kilometre) scale mapshowingthe Grugganskeagh windfarm location and surrounding towns, including Hilltown and Mayobridge. Source:http://irish.gridreferencefinder.com/
  • 9. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 5 Project Description Planning Application Site and Associated Lands The planned site is positioned four kilometres south west of Hilltown in the townlands of Grugganskeagh, Gruggandoo and Mullaghgarve. The site is positioned west of the Rostrevor Road (B25) and 500 metres south east of the Mullaghariff Road. The closest settlement to the site is Hilltown, with the surrounding land being sparsely populated and predominantly used for agriculture. The Mullaghariff Road is the proposed access route for the site (Figure 3). The planned site itself includes mainly pastureland transitioning into moorland, bog and exposed bedrock as altitude increases. The land is divided by a combination of wire fence, dry stone walls and hedgerows. The main land use is that of sheep grazing. Figure 3 Access point at MullaghgarriffRoad
  • 10. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 6 The site is positioned on a plateau of land at 310 metres above sea level in the western foothills of the Mourne Mountains. Continuing eastwards from the site altitude continues to increase to 364 metres above sea level at Slieve Roe. To the north and west the land drops into the Leitrim river valley and Newry basins respectively. Land Ownership All of the land involved in the proposed development is privately owned and an agreement has been reached with the landowners and various stakeholders regarding how the development will proceed and how they will be compensated for the use of their land. Purpose of the Development The development will help Northern Ireland meet its commitment to the reduction of emissions to 20 per cent below 1990 levels by 2020 as well as the Assembly’s commitment to generating 40 per cent of Northern Ireland’s energy via renewable means in the same time frame. Additionally, the site will deliver the following benefits to Northern Ireland:  Displacement of 89,500 tonnes of carbon dioxide (CO2) per year,  The powering of approximately 50,000 homes per year,  The generation of £16.3 million in the 25-year life span,  Input of £10 million into the local economy though employment,  Increased energy security for local regions,  Improvement of local infrastructure. The site is in accordance with policy as it advocates:  The selection of appropriate sites rather than a comparison between sites,  Proceeding with projects which will aid in meeting policy targets,  Projects which deliver benefits at both the local and regional scales.
  • 11. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 7 Proposed Windfarm Layout Constituent elements of the windfarm:  20 individual turbines with 40-50 metre buffer zone between each model (Figure 4),  Access tracks on site connecting the turbines,  Electricity substation,  Temporary soil deposition areas and construction compound (limited to construction phase only),  Reinforced access routes over waterways,  Grid connection (to be established and designed by Northern Ireland Electricity),  Entry and exit off the Mullaghgarriff Road. Detail of Recommended Turbines The turbines recommended for use on this site are Enercon E53 turbines (Figure 4), the same as are used in many other similar projects across the United Kingdom. These turbines have a hub height of 75 metres and are 100 metres tall with the addition of the length of the blades and a total blade diameter of 52.9 metres. With an output of 800kW, each of the turbines are operational in wind speeds from 2.5-34m/s (metres per second) with their peak output at 12m/s and have a predicted lifecycle of 25 years. The turbines will be mounted on a reinforced concrete foundation with an area of 15x15 metres to a depth of 5 metres as per the norm for such cases. The foundations will be circular in shape and feature a support element for the turbine which will be bolted in place. Upon the decommissioning of the site the foundations can be dismantled and removed with the remaining holes being refilled with soil. Figure 4 The EnerconE53 turbine, as proposed by JJK Renewables. Source:http://cdu-kirchlinteln.de/cdu-fuer- sozial-vertraegliche-windkraftnutzung
  • 12. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 8 Life Cycle of the Site The construction phase of the site is expected to take 12-18 months and will be conducted by a contracted engineering company. Any timescales and estimates are subject to weather and economic variables. The site is expected to last for 25 years with regular maintenance, and will be decommissioned following this period.
  • 13. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 9 Environmental Description Geography of the Proposed Site The proposed site is located on the western periphery of the Mourne Mountains in County Down, Northern Ireland, at an elevation of 360 metres above sea level. The site itself is located on a plateaux area at Grugganskeagh, which is exposed in nature with significant grass cover and exposed granite rock which would be attributed to the retreat of glacial ice following the Midlandian glacial maxima. There are also areas of shallow peat bog, acid grassland and wet heath on the site. The site is positioned with the main body of the Mourne Mountains immediately to the east/south east, while on all other sides the landscape slopes down from the site into the basins of the Newry, Knockbarragh and Leitrim rivers. Current and Historical Landscape Usage of the Site The proposed site lies in an area where the lower slopes are dedicated to agricultural grazing, mainly of sheep, while the upland areas are predominantly bog and peat land areas which are more open in format. The land is divided using dry stone walls in the traditional manner; with hedgerows (mainly hawthorn in variety) also being incorporated on the lower reaches of the slopes. Access to the fields is mainly gained by single track lanes flanked by hedgerows and/or hedgerows which extend to provide access to the majority, but not the entirety of the site area. The exposed nature of the site contributing to the limited vegetation results in the area hosting no form of commercial forestry or woodland areas. Only a sporadic covering of ash, and hawthorn trees are present with hedgerows being the only vegetation of note which is subject to any management strategies. The Mullaghgarriff Road is the main access route to the site. This is a small, quiet country road with little traffic in a moderate state of repair and a small number of individual dwellings on it. Other roads in close proximity to the site include the Rostrevor Road, Yellow Road,
  • 14. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 10 Lower Knockbarragh Road and Coyle’s Hill Road, all of which are minor routes and host few dwellings. Land use in the Wider Area of Study Due to the nature of a site with such a scale being positioned at elevation there must be a consideration for the surrounding area and the manner in which such a development may have an influence in a wider context. This is recommended by ‘SNH Visual Representation of Wind Farms 2014’ where, for a site the scale of which we are proposing, a 20-35 kilometre radius should be considered in an application. The application is for an area close to the Mourne Mountains which includes six mountains over 700 metres high, as well as a number of lakes, dams and reservoirs. The area also plays host to a range of peat land and bog environments. Also included are forest parks at Kilbroney and Tullymore, alongside a number of commercial forestry sites of conifers. Tourism is a dominant feature in the area with will-walkers, campers, day trippers and rock climbers availing of the mountain environment. Approximately 1,300 acres of land in the area is under National Trust management and the region features heavily in the Draft Tourism Strategy for Northern Ireland until 2020. The Mournes also hold ‘Area of Outstanding Natural Beauty’ (AONB) status and features picturesque landmarks such as the Mourne Wall and a number of marked trails which are popular with tourists. Within a 10 kilometre radius of the site the total human population is approximately 14,500 according to the 2011 census. The majority of these people live in the villages of Rostrevor, Rathfriland, Mayobridge, Hilltown and the town of Warrenpoint. These rural settlements are mainly constituted of detached houses, bungalows and cottages positioned in close proximity to the roads, with larger farms being located slightly further away from the major highways. All of the settlements exist in the lowland regions and there is little to no development on the more elevated areas. There are also a notable number of isolated derelict or abandoned houses in the area.
  • 15. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 11 The settlements and majority of people in the area inhabit areas close to the following major roads:  A25 Newry Road,  B27 Kilkeel Road,  B25 Rostrevor Road,  B180 Bryansfort Road,  B8 Hilltown Road. The area is also serviced by the more minor Mullaghgarriff, Yellow, Lower Knockbarragh and Leitrim roads. All of the areas within the wider area of study, as defined by the 35 kilometre radius, fall into the medium to high sensitivity bracket with regards landscape sensitivity to a possible visual impact according to the NIEA (Northern Ireland Environment Agency) Sensitivity Scale as defined in SPG Wind Energy Development in Northern Ireland’s Landscape (2010).
  • 16. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 12 Anticipated Environmental Impacts and Mitigation Anticipated Environmental Impacts The general approach of quantifying the environmental impacts associated with such a project is based on the nature and sensitivity of the involved species and environment. The main parties considered with regards the environmental impacts of the project are species habitats, bats, badgers, smooth newts and the Irish Hare (Lepus timidus hibernicus). During the Construction Phase  There will be a direct removal of habitats in the immediate site area due to the introduction of infrastructure such as the access routes, waste disposal areas, construction compounds and the turbines themselves. The habitats concerned are mainly shallow peat bog, acid grassland and wet heath. The total area concerned with this level of environmental degradation is 3.2km². This impact will also be more permanent in nature than other impacts associated with the construction phase. A considerable amount of grassland will be effected, however this land is mostly semi- improved, and only a small proportion is unimproved and making the transition to wet heath  There will be a small degree of contamination of waterways due to the mobilisation of soil and debris. The total impact from this will be minimal due to the limited nature of the fisheries in the watercourses associated with the affected area  Lower air quality and further habitat impacts from increases in heavy machinery and traffic  The majority of damage likely to influence the badger population is likely to be associated with the construction phase of the wind farm. Badger setts may be vulnerable to damage during construction if the activity is in their immediate vicinity, as the level of ground disturbance may cause collapse and destabilisation of tunnels.
  • 17. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 13 The increased traffic may also lead to an increased number of badger deaths from traffic associated incidents  The resident bat population will also be exposed to some potentially adverse impacts, namely habitat fragmentation. This issue will be of a very small magnitude due to the nature of vegetation on site. The lack of apparent roosting sites means there will be no discernible loss of roosting sites for the local bat population  There will be minimal impact on smooth newt populations as there is only one body of water which could host the species and it will be unaffected by the construction  The Irish Hare will experience localised disturbance on a temporary basis which will yield negligible population impacts  Salmon species may be impacted by declines in water quality associated with ground disturbance and subsequent entrainment of particulate matter into water  Accumulation of sediment on riverbeds may inhibit spawning of some salmon due to eggs becoming smothered. This can impact invertebrate species in similar ways  Navigation of fish through the drainage network may be impacted by the temporary obstruction of channels in the application area. This is of particular relevance in Ghann River which will have temporary crossing points constructed on it. During the Operational Phase  Habitats will experience no additional impacts  Badgers will experience no negative impacts from the wind farm as maintenance work is not foreseen to contribute any additional disturbance  Bats may experience issues with potential collisions with the rotor blades due to a change in air pressure associated with the moving blades. The site generally experiences low bat activity and most activity are located near significant natural features as opposed to open, standalone areas such as the wind farm site proposed by JJK Consultants. Only Leisler’s bats are at significant risk from the turbines due to their particular behavioural patterns. All other species are at no or low levels of risk
  • 18. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 14  Irish Hare are at no additional risk  Smooth newts are at no additional risk  There may be impacts to a trout stock in the Ghann River tributaries associated with the site. This is due to the crossing points that are scheduled to be constructed in this location which could impede the migration of the fish. If unmitigated this could develop into a considerable issue. During the Decommissioning Phase The same impacts will be experienced as during construction phase, with the exception of the impacts associated with the presence of the construction compound. Measures to Minimise Impacts During the Construction Phase  The wind farm has been strategically designed to avoid intrusion into the active peat environments present on site. The supporting infrastructure present during construction will be positioned so as to totally avoid all pockets of fen or mire habitats  Habitat enhancement for Irish hare should serve to compensate for the small scale disturbance the species will experience  Planting trees and implementing hedge reinstatement should serve to reduce any negative impacts on the resident bat population. During the Operational Phase To try and prevent excessive bat casualties from collision with rotor blades there is a 50m buffer zone between each turbine, as per common practice. Care has been given to ensure turbines are sufficiently far from any habitat features likely to host high levels of bat activity.
  • 19. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 15 Proposed Mitigation Strategies During the Construction Phase Ecology  Areas containing particularly sensitive habitats will be clearly demarcated and it will be a priority to avoid intrusion into the protected zones. A similar strategy will be employed to mitigate against damage to badger setts  Materials for components such as roads and foundations will be selected according to the degree of compatibility with the existing soil and groundwater characteristics  An ecological consultant will be employed during the construction phase to ensure environmental objectives are met  A sustainable drainage system will be established around the construction zone to ensure minimal groundwater or watercourse contamination  Any hedges removed during the construction phase will be reinstated using the original component species, and new hedge will be planted along the Mullaghgarriff Road to aid in habitat enhancement for bats. Fisheries  Reductions in the impact of particulate matter in run-off include 50 metre buffer zones around aquatic areas, the inclusion of check-dams and drainage systems which treat any surface run-off from the site  Water quality will be monitored  Main construction activities likely to cause wholesale soil disturbance will be limited to outside salmon spawning season.
  • 20. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 16 During the Operational Phase Habitats  Habitat enhancement measures will be utilised to mitigate against any potential damage to the resident species. This should offset the damage of the permanent loss of some habitats  The 50 metre buffer zone between turbines is the main form of mitigation against harming bat populations, as well as the height of the turbines being out of the common flightpath of many species.
  • 21. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 17 Analysis of Alternatives Schedule 4, Item 2 of the 2012 EIA Regulations places a requirement on the provision of main alternatives considered and the reasoning behind the deciding on a particular site. There are thus a number of sections to be considered. 1) ‘Do nothing’ Approach – To simply do nothing is an unacceptable alternative to developing the proposed wind farm for a plethora of reasons. Firstly there is an ever-pressing need to achieve the UN, EU and regional level targets on the reduction of greenhouse gases and the increased proportion of energy to be produced by renewable means. Without windfarms such as the one proposed by JJK Consultants at Grugganskeagh, these targets would almost certainly fail to be met. To do nothing may be counter-productive from a planning point of view as it may well pressurise authorities to pass other possibly less appropriate sites in an effort to satisfy government targets. 2) Site Selection – The suitability of the site was assessed using a combination of background desk-based research and site visits. An analysis of a particular criteria identified how appropriate the site selection was and identified were possible limitations:  Wind resource – Proposed site has an excellent wind resource evident from data collected prior to application  Grid connection - There will be future gird connection availability and capacity in the vicinity of the site  Proximity to dwellings – The site is an appropriate distance to neighbouring dwellings  Area of land available - There is a large area within the controlled lands, allowing for the avoidance of sensitive ecological and archaeological areas identified through the EIA
  • 22. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 18  Site access – The site has suitable access  Topography – Site topography is appropriate for the proposed development  Nature conservation designations and ecological impacts – Addressed in the environmental/ecological interaction section of this report  Land use designations - Addressed in the environmental/ecological interaction section of this report  Location of archaeological and cultural heritage features - Addressed in the environmental/ecological interaction section of this report  Telecommunications/aviation interests - Addressed in the environmental/ecological interaction section of this report 3) Evolution of Alternative Design – The design of the application has been evolved in such a way that it seeks to minimise environmental detriment whilst maximising the production of renewable energy. This was achieved through the assessment of an originally larger area of the mountain to find the most appropriate location for the development given the criteria and where the development could be accommodated. For example, placing the turbines close to the summit of the mountain would maximise energy production but vastly increase visual impacts of the application and thus a compromise was settled upon. Alternative renewable technologies at present do not have the same potential to generate green energy in the immediate future as onshore wind. Major hydroelectric developments and offshore wind farms are not currently at the stage where the energy they could potentially generate would be beneficial in meeting current legislated targets.
  • 23. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 19 Environmental Monitoring Programme Environmental Management Plan The proposed windfarm at Grugganskeagh is to consist of 20 standalone turbines that are each approximately 100 metres high along the periphery of the Mourne Mountains; an Area of Outstanding Natural Beauty (AONB). Due to the large-scale nature of the windfarm it is imperative that, following approval, an Environmental Management Plan (EMP) is introduced in order to monitor and mitigate the effects of the construction on the various aspects that are to be affected by the proposal. These aspects include ecology, transport and tourism, which are highly considered throughout the proposal due to their fragile temperament. Throughout the EMP a list of environmental objectives will be drawn up so that targets can be met throughout the proposal, providing a professional organisational structure during both the construction and operational phases. This will continue periodically throughout the life cycle of the windfarm right up until the decommissioning phase in 25 years. Therefore the Environmental Management Plan is to monitor and mitigate both the short and long-term effects of the windfarm proposal on surrounding environment and ecology.
  • 24. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 20 Table 1 below summarizes aspects affected by the proposed windfarm and indicates whether or not monitoring is required during the construction, operational and decommissioning phase: Key: Y = Monitoring and management is required during this phase N = Monitoring and management is not required during this phase. A scheduled programme of surveys is required in order to ensure negative impacts have not exceeded previously predicted levels and should be carried out by the appropriately qualified professionals and subcontractors commissioned to do so. These surveys should take place in continued liaison with all stakeholder groups of the application. Monitoring required during: Construction Phase Operational Phase Decommissioning Phase Ecology (Flora and Fauna) Y Y Y Fisheries Y N Y Avian Ecology Y Y N Water and Geology Environment Y N Y Transport, Access and Haulage Y N Y Noise Y Y Y Shadow Flicker N Y N Tourism Y Y Y Telecommunications and Aviation N Y N Electromagnetic Fields N Y N Figure 5 Table showing whether or not monitoringis required duringdifferent phases of the windfarm proposal at Grugganskeagh
  • 25. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 21 Additional Studies Public Consultation Planning applications were all published using the appropriate avenues including all local newspapers and relevant government websites. A consultation evening was advertised and held in a local community centre where members of the public could voice their concern, if any, and receive information regarding the application. The consultation draft of the Strategic Planning Policy Statement (SPPS) was published and underwent a public consultation period. The SPPS provides a shorter, simpler, strategic policy framework that provides clarity and certainty for all users of the reformed planning system. The SPPS consolidates 20 separate pieces of planning policy to a single statement and heralds a new approach to the preparation of regional planning policy. Health, Safety and Environmental Management It is the responsibility of the developer to appoint a Construction Design Management (CDM) coordinator and a principle contractor in keeping with CDM regulations prior to the commencement of construction. The CDM coordinator will oversee the collection and distribution of pre-construction information, usually as part of the tendering process. The principal contractor is responsible for preparing the Construction Phase Plan (CPP) which covers all aspects of Health and Safety for the project. This construction phase plan will include procedure for incident reporting, contingency planning and monitoring. Audits will occur regularly in coincidence with key construction phases also. Additionally, the plan will include maintenance emergency service vehicles and will require the contractor to liaise with emergency services prior to commencing work as well as ensuring access to emergency vehicles from this point until completion of the construction phase.
  • 26. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 22 Project Benefits and Analysis There is a multitude of potential benefits associated with the application, none more so evident than the overall environmental benefits. The generation of electricity from a renewable, clean source will reduce the need for conventional fossil fuels to be burnt and thus will directly contribute to the improvement of air quality regionally. This proposed development has the potential to power approximately 50,000 homes, reducing local electricity costs. 89,500 tonnes of carbon dioxide will be displaced simultaneously. This equates to the removal 67,523 cars from the roads in the North of Ireland. Aside from benefits the environment, the proposed project will have profound benefits for Northern Ireland’s economy. For example, 56 per cent of the total proposed expenditure over the 25 year life span of the project is to be retained within the Northern Irish economy. Local direct and indirect benefits during the construction phase will include:  The purchase and supply of aggregates, concrete and steel,  Construction contracts for the construction of turbine bases,  Erection of substation building,  Civils contracts for electrical engineering associated with the grid connection,  Accommodation,  Day-to-day supplies for contractors,  Transportation of turbine components. Over the 25 year project life, the estimated total (direct and indirect) benefits from the ongoing operation of the development equates to a total of 312 jobs, £8.98 million of total wages and £21.93 million of total GVA (gross value added). Each turbine requires £1.4 million per year to run, meaning that yearly running totals will equate to £28 million. Whilst costs are also going to be incurred during the implementation of the project on elements such as licenses and payroll, the environmental and monetary benefits, as mentioned above, are to massively outweigh these running costs in both the immediate and long term.
  • 27. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 23 ExecutiveSummary and Conclusion Introduction The proposed windfarm has been assessed in accordance with the EU Directive, 2011/92/EU, which was established on 13 December 2011. This legislative act has since been modified to fit within a local context for Northern Ireland, thus becoming relevant for the Environmental Impact Assessment by JJK Renewables at Grugganskeagh. Environmental Interactions Ecology (flora and fauna): The impact of the proposal on terrestrial flora and fauna is considered to be minimal and of low impact at all stages. One anomaly would be wet heath present at the proposed site, which is expected to be the recipient of moderate impact during the construction phase. However, these impacts are easily mitigated against via restoration or management of existing habitats. Additionally, the infrastructure at Mullaghgarriff Road is an area that has previously been cleared of vegetation, therefore requiring minimal disturbance to native vegetation. Fisheries: The windfarm proposal is to have a negligible impact on surrounding fisheries. Impacts, if any, would likely occur as a result of ground disturbance during the early construction phase. This has the potential to obscure trout movements through river courses as a result of the introduction of artificial stream crossings. A surface water management plan is ready to mitigate against this. Avian Ecology: From an overall standpoint, there are to be no significant impacts on relevant, local bird species such as buzzards and ravens (Figure 5), both of which are highly coveted by the RSPB (Royal Society for the Protection of Birds). Included in the proposal are 500 metre
  • 28. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 24 buffer zones, with special consideration given to ensuring that there is no overlap between the project area and bird roosting sites. Furthermore, a 12-month field survey is to be undertaken to determine the baseline numbers of birds present during an annual cycle in order to provide data on the distribution and movements of these birds. Water and Geology Environment: Underlying geology of the proposed site at Grugganskeagh comprises mainly alluvium with granite bedrock. The site is upstream of an area of a significant groundwater body, but does not lie in the catchment of any significant rivers. Potential impacts on hydrology have been identified and mitigation strategies are to be implemented accordingly. Transport, Access and Haulage: Any increase in traffic in the area will be short term as it is immediately limited to the construction phase. Traffic levels will be similar during the decommissioning phase in 25 years, but traffic will be minimal during the operational phase. Traffic will also be regulated by designated policy guidelines. Construction materials are to be sourced locally as part of a mitigation strategy to minimise traffic at the site. Also as part of this mitigation strategy is a proposed widening of roads as part of a traffic management and road construction plan, where installation will be carried out in stages. Local residents will also be given warning of arrangements through mediums such as local newspapers. Noise: As part of the proposal, an assessment is to be conducted according to the Assessment and Rating of Noise from Windfarms Protocol 1996 and associated good practice guidelines. The Figure 6 The buzzard. This species was considered during the proposal. Source: https://www.rspb.org.uk/discoverandenjoynature/discoverandle arn/birdguide/name/b/buzzard/
  • 29. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 25 site also complies with EU legislation regarding turbine location. Noise cannot be completely mitigated against during the most intensive period of the construction phase, however the impact will be short term and will result in an overall benefit to residents in the long term which outweigh these short-term impacts. Work to reduce noise will be managed as much as practicable. Shadow Flicker: In a worst case scenario, a limited number of nearby properties will experience shadow flicker. These levels are, however, within designated guidelines. To avoid these effects, mitigation measures have been integrated into the site design with regard to colour and finish of the Enercon E-53 turbines. Turbines may also be programmed to shut down in the event of likely shadow flicker. Tourism: The proposed 20-turbine site at Grugganskeagh is not visible from 80 per cent of the Mourne Mountains. Any views in the remaining view shed are moderate to no impact, thus indicating that the tourism industry will not suffer as a result of an accepted proposal. This is because the proposed site is located far from popular tourist destinations of the Mournes that people travel far distances to visit. Archaeology and Cultural Heritage: There is a moderate risk of visual impact on neighbouring recorded Iron Age burial sites, but there are no direct impacts anticipated with the proposed Grugganskeagh site. Conclusion The European Union (EU) has set legally binding targets for the production of 20 per cent of EU energy consumption to come from renewable sources and for a reduction of greenhouse gas emissions to 20 per cent below 1990 levels by the end of 2020. The windfarm proposal at Grugganskeagh by JJK Renewables can act as an ideal component in helping Northern
  • 30. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 26 Ireland contribute to reaching these targets in the designated time. The project itself provides an environmentally sustainable alternative to the unsustainable burning of fossil fuels and, as noted, no significant environmental or ecological impacts have been identified. It is concluded by JJK Renewables that the project at Grugganskeagh is justified when all components throughout this EIS are considered. The best possible turbine specification is to be used at the windfarm and this enables and 800 kilowatt output of renewable energy to Northern Ireland’s existing power generation capacity, among many other benefits that were identified as primary objectives. These include indirect benefits of the windfarm such as the boosting of the employment sector that is going to provide the local population with jobs.
  • 31. Environmental Impact Statement (EIS) JJK Renew ables (John Gallogly, Johnny Reaney & Kelan McCafferty) 27 Disclosure ofConsultants Engaged Professor Ian W. Montgomery, Queen’s University Belfast Professor Ian Montgomery, a Professor of Animal Ecology at Queen’s University Belfast, acted as majority stakeholder throughout the windfarm proposal and Environmental Impact Assessment (EIA) at Grugganskeagh. Prof. Montgomery actively participated in decisions on the planning and management of the windfarm from the scoping stage to the reviewing stage, while simultaneously providing great expertise and local knowledge that are vital ingredients for effective environmental assessment. Below is a brief résumé that highlights the value of the aforementioned as a majority stakeholder:  Over 150 publications and reports that include over 100 peer-reviewed journals and edited collections,  Total research grant income exceeding £3.5M,  Successful supervision of 46 PhD students,  Past Head of School of Biological Sciences at Queen’s University Belfast (1995- 2010),  Established Quercus (2003-2008); a focus for the development of expertise in conservation science within Northern Ireland. Now a director.