5. CONSULTATION 5.1. Introduction 5.2. The consultation process 5.3. List of consultees 5.4. Key issues raised by consultees 5.5. Analysis of key issues 5.6. Scope of the Environmental Impact Assessment

5. CONSULTATION

5.1. Introduction

This chapter describes the consultation process that was undertaken throughout the various stages of the EIA process and provides a summary of the key issues raised by consultees. It also includes relevant responses from consultations that were undertaken as part of the Stage 1 Scoping Report. Consultation is a key and fundamental part of the EIA process.

5.2. The consultation process

The consultation process serves to:

• ensure that statutory consultees and other bodies with a particular interest in the environment within the area of the scheme are informed of the proposal and provided with an opportunity to comment;
• obtain baseline information regarding existing environmental site conditions;
• establish key environmental issues and identify potential impacts to be considered during the EIA;
• identify those issues which are likely to require more detailed study and those which can be justifiably excluded from further assessment; and
• provide a means of identifying the most appropriate methods of impact assessment.

Although consultation is an important part of the EIA process, it may continue in an iterative manner throughout the detailed planning and design stages of the project.

All consultees were contacted by letter, originally by Jacobs Babtie in 2003, informing them of the details of the proposed development and requesting that they provide any specific baseline information that they may hold or any comments they may have concerning the proposed scheme. The information requested was tailored specifically for each consultee and was based on the consultations undertaken at the previous stages of assessment. A plan of the proposed bridge replacement designs and realignment accompanied the letter. A further consultation was conducted by Scotland TranServ in November 2006 to determine if any new environmental issues had developed since the initial consultations by Jacobs Babtie.

5.3. List of consultees

Consultations were undertaken with the statutory and non-statutory bodies detailed in Table 5.1.

Table 5.1 Organisations, businesses and people consulted.

Consultee	Contacted by Jacobs Babtie	Contacted by Scotland TranServ
Argyll and Bute Council	X
Ballachulish Community Council	X	X
Bridge of Orchy	X
Freight Transport Association		X
Glencoe Cottages	X
Glencoe and Glen Etive Community Council	X
Health and Safety Executive	X
Historic Scotland	X	X
Highland Council *	X	X
Highlands and Islands Fire Brigade		X
Highlands of Scotland Tourist Board	X
Lochaber Mountain Access Group	X	X
Mountaineering Council of Scotland	X	X
National Trust for Scotland	X	X
Nevis Range Development Company	X	X
Paths for all Partnership		X
Police		X
Road Haulage Association		X
Ramblers Association		X
Royal Society for the Protection of Birds	X	X
Scottish Ambulance Service		X
Scottish Canoe Association	X
Scottish Environment Protection Agency	X	X
Scottish Executive Environment and Rural Affairs Department	X	X
Scottish Natural Heritage	X	X
Scottish Ornithologists' Club		X
Scottish Water	X
Scottish Wildlife Trust	X	X
Scottish Youth Hostel Association	X
Scotways		X
SUSTRANS		X
Tay District Salmon Fisheries Board		X

* More than one division/group was consulted within the organisation.

5.4. Key issues raised by consultees

The key issues raised by individual consultees are identified in Table 5.2. The issues are categorised under the relevant ES chapter, where appropriate. The following consultees either had no comment or did not respond to the consultation: Road Haulage Association, Ramblers Association, Police, Scottish Ornithological Club, Scotways, Tay District Salmon Fisheries Board, SUSTRANS, Freight Transport Association, Highlands and Islands Fire Brigade, Scottish Ambulance Service, Argyll and Bute Council, Bridge of Orchy, Glencoe Cottages, Glencoe and Glen Etive Community Council, Scottish Canoe Association and Scottish Wildlife Trust.

5.5. Analysis of key issues

The main environmental issues arising from the consultation exercise are summarised below and are sub-divided according to the relevant chapter headings of the ES. Due to the format of the scoping report, the majority of consultation feedback from the Jacobs Babtie Consultation is general and refers to all seven bridge replacement schemes, so some issues were not directly relevant to Ba Bridge.

5.5.1. Land use

Health and Safety Executive

• Confirmed that there are no major hazard sites, pipelines or explosive sites listed in their records within the vicinity of the proposals. Hazardous installations have therefore been scoped out.

5.5.2. Geology and Soils

Highland Council

• There are no details of known or potentially contaminated land in the vicinity of the proposals within the Highland Council area. Contaminated land has therefore been scoped out.

5.5.3. Road drainage and the water environment

Scottish Environment Protection Agency (SEPA)

• Advised that water quality status must be maintained; erosion, sedimentation and discolouration prevention measures are implemented. Schemes should be designed to avoid crossing watercourses, and to bridge watercourses which cannot be avoided.

Scottish Water

• Confirm that no schemes affect Scottish Water’s services.

5.5.4. Ecology and nature conservation

SNH

• Concern of potential impact on the protected species of freshwater invertebrate as a result of sedimentation arising from in-river construction works.

Highland Council

• The study should include a detailed assessment of ecological areas and habitats, an evaluation of impact of the works on these sites or habitats mitigation measures to address areas of concern identified and reinstatement measures relative to all areas of disturbance.

National Trust for Scotland

• NTS would like to see, a strict commitment to removing, storing and replacing turves in situ.
• In any restoration works, only species native to the glen should be used in seed mixes.

RSPB

• A pair of black Throated Divers attempt to nest by Loch Ba most years but usually fail due to disturbance from fishermen. Any work at the bridge should be carried out in such a way as to avoid pollution to the loch and, if possible, done outwith the period May to July, inclusive, to minimise disturbance. The response from the RSPB in November 2006 stated, however, that they were unaware of any bird species of particular conservation concern.

SEPA

• SEPA request that habitat and species surveys are carried out at appropriate times of the year by appropriately qualified and experienced personnel, and suitability of timing needs to be considered within the ES.

Table 5.2 Scoping matrix of key consultee issues with the 2006 responses having credence over earlier responses.

Consultee	Land Use	Geology / Soils	Hydrodynamics, water quality	Ecology & Nature Conservation	Landscape and visual	Cultural Heritage	Air Quality **	Traffic Noise & Vibration **	Pedestrians, Others & Community	Vehicle Travellers	Disruption due to Construction	Policies and Plans
Ballachulish Community Council					•					•	•
Health and Safety Executive	•										•
Highland Council*		•		•	•	•			•	•		•
Highlands of Scotland Tourist Board											•
Lochaber Mountain Access Group											•
Mountaineering Council of Scotland					•				•		•
National Trust for Scotland*			•	•	•	•			•	•	•
Nevis Range Development Company											•
Paths for All Partnership									•
Royal Society for the Protection of Birds				•							•
Scottish Environment Protection Agency			•	•							•
Scottish Executive Development Department			•									•
Scottish Natural Heritage*				•	•						•
Scottish Water			•

** No issues raised, therefore scoped out.

5.5.5. Landscape and visual issues

SNH

• Key viewpoints should be agreed with SNH and photos of the existing landscape, together with visualisations of the proposed development, produced for each viewpoint. Viewpoints should be identified relevant to road users, walkers and climbers. Consideration should be given to changeable light levels, both by day and seasonally. A plan showing the zone of visual influence is also recommended;
• Reference should be made to the NSA description, SNH’s Landscape Character Assessment for Lochaber, SNH’s Policy Statement on Wildness in Scotland’s Countryside and the Glencoe and Rannoch Moor Landscape Study (Cobham Resource Consultants 1991);
• Request that details of the following are provided:
• design and materials of the bridges and any associated structures – both temporary and permanent and not only individually, but also collectively in terms of standard styles;
• signage, barriers and lighting. Where these are required they should be grouped and located with regard to the enjoyment of the surrounding landscape;
• drainage;
• extent and treatment of verges;
• treatment of existing parking areas;
• work area limits;
• off-site requirements;
• maintenance regimes;
• storage and re-use of materials; and
• temporary roads and tracks.
• In order to minimise the impact of the works on the landscape, the proposals should include:
• a method statement to cover scenarios which may be encountered during construction and which may affect the end product;
• a set of principles that would be adhered to in the design and execution of the works; and
• a landscape restoration plan for each bridge development, with a clear set of objectives and methodology for achieving them.

NTS

• Stressed that the landscape of Rannoch Moor is of national significance and it is felt that any bridge design and consequential road realignments should take this into consideration and be of the highest possible standard;
• The current series of bridges make up a suite of similarly designed structures that fit well within a semi-natural landscape. This is seen as being desirable and should be used as a principle for their replacement.

Highland Council

• Both Glen Coe and Rannoch Moor are areas of extreme national importance in terms of their landscape and nature conservation values;
• It is recommended that features such as parapets should be finished in natural stone, the colour of which should be akin to that found within the area;
• The Landscape and Visual appraisal should include the following:
• establish and outline methodology for assessing the said works in the context of the NSA designation for Glen Coe and Rannoch Moor and their impact on their intrinsic qualities;
• description and evaluation of existing landscape characteristics and features of the sites in relationship and importance to the National Scenic Areas;
• assessment of all works including temporary accesses, storage/compound areas, lighting, noise etc and their impact on the wider landscape setting;
• preparation and visualisations of the bridges from key viewpoints, to be agreed with the Planning Authority from the road network for passive users and for recreational users from hill tops etc.

Mountaineering Council of Scotland

• Recommend that the bridges faced off with local stone so that they blend into the landscape, possibly this could arise from additional rock cuttings associated with the schemes.

Ballachulish and Glencoe Community Council

• The Community Council would assume that any replacement bridges are of similar finished appearance to the current ones, although accept that the construction method may differ to achieve the loadings required.

5.5.6. Cultural heritage

Historic Scotland

• Historic Scotland are content that this proposal raises no significant issues and have no further comments to offer.

Highland Council

• "There are no archaeological sites in the area and the potential for unrecorded/buried remains to survive is considered to be low. I do not feel that there is a need to include a chapter on Cultural Heritage in the Environmental Statement."

National Trust for Scotland (NTS)

• It is recommended that a review be undertaken of the Sites and Monuments Records held by RCAHMS, HC or NTS to realise the possibility of such issues. Such sites could then be usefully included in report figures. NTS would argue that any impact statements which do not include a review of this information will at best be incomplete.
• NTS support the undertaking of field evaluations as it should not be presumed that the information held by NTS, HC or RCAHMS is complete. In particular, the potential of damage/destruction is not just at the places of work themselves, but also at the site huts, store areas, etc.

5.5.7. Air quality

None raised.

5.5.8. Traffic noise and vibration

None raised.

5.5.9. Pedestrians, cyclists, equestrians and community effects

Highland Council

• It is pivotal that pedestrian and public access within all of the areas of proposed workings is safeguarded and where possible improved upon;
• Expressed concern on the part of several tourism businesses in the area, with regard to disruption of traffic at all sites during the works. Pointed out that the A82 is a vital year round tourism route and that any major diversion or disruptions will have a serious impact on the local economy.

Mountaineering Council of Scotland

• Wish to see adequate space for pedestrians on the road bridges and don’t want to see walkers having to run on the road itself in order to cross the bridges.

Natural Trust of Scotland

• Address safety issues of people often having to squeeze flat against the parapets as traffic passes by, often large vehicles at high speed. Traffic calming measures should also be addressed.

5.5.10. Vehicle travellers

Highland Council

• That the road be widened at the bridge location to at least 6m wide carriageway with reasonable footpath.

Ballachulish & Glencoe Community Council

• Note and support the suggestion that the replacement bridges be widened for safety reasons.

National Trust for Scotland (NTS)

• That all measures possible, including traffic calming, should be taken to reduce vehicle speeds.

5.5.11. Disruption due to construction

Land use impacts

Highlands of Scotland Tourist Board

• Expressed concern on the part of several tourism businesses in the area, with regard to disruption to traffic at all sites during the works. Point out that the A82 is a vital year round tourism route and that any major diversion or disruptions will have a serious impact on the local economy. Request that the Scoping Study include full consultation with the business community.

Nevis Range Development Company

• Many of NRDC Plc’s customers are day visitors who use the A82 to get to the ski area and visitor attraction north of Fort William, and NRDC Plc are concerned about the financial implications of having the A82 either closed or seriously restricted at key periods. Some of the key periods for NRDC Plc include weekends in January and February.

Traffic and access impacts

Ballachulish & Glencoe Community Council

Disruption during construction works is of concern to the community council, and whilst they appreciate the works are necessary, they very much welcome suggestions and proposals as to how any disruption could be kept to a minimum.

Mountaineering Council for Scotland (MCoS)

• During the period when road works, and maybe road closures, are taking place in Glencoe, the MCoS will be happy to carry news of this work on its website. This would convey the news to a significant section of the mountaineering community and could help to reduce frustration if walkers and climbers were already aware of the potential delays.

Geology

None

Water quality

Scottish Environment Protection Agency (SEPA)

• One of SEPA’s key interests in relation to this type of project is pollution prevention measures during the period of construction/demolition and ongoing pollution prevention measures thereafter.

Ecology and nature conservation

National Trust for Scotland (NTS)

• NTS would like to see, a strict commitment to removing, storing and replacing turves in situ.
• In any restoration works, only species native to the glen should be used in seed mixes.

Royal Society for the Protection of Birds (RSPB)

• The only specific concern of the RSPB is with regard to Loch Ba. A pair of Black Throated Divers attempts to nest by the loch most years but usually fail due to disturbance. Any work at the bridge here should be carried out in such a way as to avoid pollution to the loch and, if possible, done outwith the period May to July, inclusive, to minimise disturbance.

Scottish Natural Heritage (SNH)

• Once detailed plans are available, a notice of intent to carry out potentially damaging operations within the SSSIs will need to be submitted to SNH. SNH’s written consent will be required before work within the SSSI commences.

Visual impacts

Scottish Natural Heritage (SNH)

• In order to minimise the impact of the works on the landscape, the proposals should include:
• a method statement to cover scenarios which may be encountered during construction and which may affect the end product;
• a set of principles that would be adhered to in the design and execution of the works; and
• a landscape restoration plan for each bridge development, with a clear set of objectives and methodology for achieving them.

Cultural heritage

Historic Scotland

• See section 5.5.6

Air quality

None

Traffic Noise and vibration

None

Health and safety

Health and Safety Executive

The works should not include measures which would conflict with the requirements of the Health and Safety at Work Act 1974 and its relevant statutory provisions.

Policies and plans

Scottish Executive Development Department

• At the National level, planning policy guidance has been produced by SEDD as statements of government policy on nationally important land use and planning matters (National Planning Policy Guidance (NPPGs)) and to provide advice on best practice (Planning Advice Notes (PANs)).

5.6. Scope of the Environmental Impact Assessment

Throughout the development of options and the detailing of the preferred option, the scope of issues requiring environmental assessment has been constantly revisited. This has resulted in certain issues being 'scoped out' i.e. it has not been deemed necessary to be considered further. This section lists these issues which have been scoped 'in' or 'out' of the Stage 3 EIA and discusses the justification for not considering them further. Table 5.3 summarises issues scoped 'in' and 'out' for further assessment.

Table 5.3 Summary of issues scoped 'in' and 'out’

Issue	Scoping of Issue for Further Assessment	Reason for scoping in/out
Land use	OUT	No significant impacts to land use.
Geology and soils	IN	Small area of disturbance to substrate and geological resources.
Water quality and hydrogeology	IN	Bridge crosses a sensitive water course.
Ecology and nature conservation	IN	Surrounding area is of high natural heritage value.
Landscape	IN	New elements will be introduced to sensitive area.
Visual issues	IN	New elements will be introduced to sensitive area.
Cultural heritage	OUT	Unrecorded archaeological features are unlikely to be found on site because the area would have been heavily disturbed during the original construction of the A82 and Ba Bridge. This has been confirmed through consultation.
Air quality	OUT	The scheme will not result in a change in traffic conditions on the bridge during the operational phase, so no increase in air pollution is anticipated.
Traffic noise and vibration	OUT	The scheme will not result in a change in traffic conditions on the bridge during the operational phase, so no increase in noise or vibration is expected, thus no impact to the nearest receptor, which is five miles away.
Pedestrians, cyclists and community effects	OUT	The scheme will improve the situation for pedestrians and cyclists by the inclusion of a footway and wider bridge.
Vehicle travellers	OUT	On-line bridge replacement.
Disruption due to Construction	IN	10 – 12 month construction in sensitive area.
Policies and Plans	IN	Slight impact.

The issues of Land use, Cultural Heritage, Air Quality and Traffic Noise and Vibration, Pedestrians, Cyclists and Community Effects, and Vehicle Travellers during operation have all been scoped out as their impacts will either not change from the current situation or improve once the scheme is in operation. However, these issues have been considered further in Chapter 10 – Disruption Due to Construction.