Description of main environmental impacts and proposed mitigation

Air quality

Construction activities associated with the proposed works have the potential to temporarily cause local air quality impacts. The main sources are likely to be dust generated by excavation and breaking out, and emissions from transportation of materials, the presence of construction traffic and vehicles idling. As a result, there is potential for dust, particulate matter, and exhaust emissions to be emitted to the atmosphere. However, taking into account the nature and scale of the works and the following mitigation measures, the risk of significant impacts to air are considered to be low.

Ancillary plant, vehicles and non-road mobile machinery (NRMM) will have been regularly maintained, paying attention to the integrity of exhaust systems. These will also be switched off when stationary to prevent exhaust emissions (e.g., there will be no idling vehicles).
Cutting, grinding, and sawing equipment (if required) will be fitted or used in conjunction with suitable dust suppression techniques e.g., local exhaust ventilation system that fits directly onto tools.
Regular monitoring (e.g., by engineer or Clerk of Works) will take place when activities generating air pollution are occurring. In the unlikely event that unacceptable levels of air pollution are emanating from the site, the operation will, where practicable, be modified and re-checked to verify that the corrective action has been effective. Actions to be considered include: (a) minimizing cutting and grinding on-site, (b) reducing the operating hours, (c) changing the method of working, etc.
All delivery vehicles carrying material with dust potential will be covered when travelling to or leaving site, preventing the spread of dust beyond the work area.
Material stockpiles will be reduced as far as is reasonably practicable by using a ‘just in time’ delivery system. All material will also be stored on made ground.
Any stockpiled material on site will be monitored daily to ensure no risks of dust emissions exists.
Materials will be removed from site as soon as is practicable.
Good housekeeping will be employed throughout the works.

With the above mitigation measures in place, it is anticipated that any air quality effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this Record of Determination (RoD).

Cultural heritage

It is assessed that the planned works will not adversely impact any nearby sites of cultural heritage interest as the works are not located within the footprint or direct proximity to any designated or undesignated cultural heritage sites. While the historic military road forms part of the current carriageway and nearby excavation is required, it does not hold statutory protection and any installations to prevent further erosion are likely to have a net positive effect on this asset. The following mitigation measures will be included in the site environmental management plan (SEMP) to address any potentially unforeseen impacts on cultural heritage during construction:

If there are any unexpected archaeological finds, works will stop temporarily in the vicinity, the area will be cordoned off, and a member of the BEAR Environment team will be contacted for advice. Historic Environment Scotland will be consulted as required.
Laydown areas will be sensitively located (i.e. on areas of hard standing) to avoid areas of cultural heritage interest.
There will be no storage of plant, materials or equipment against buildings, bridges, walls or fences.

With the above mitigation measures in place, it is anticipated that any cultural heritage effects associated with the proposed scheme are unlikely to be significant. This receptor is not considered further in this RoD.

Landscape and visual effects

There will be a short-term impact on the landscape character and visual amenity of the site as a result of the presence of construction plant, vehicles, and TM.

The works are predicted to have a negligible adverse impact on the landscape character during construction and minor adverse effect once constructed. Some embankment stabilisation is already in place along nearby sections of the watercourse, and the proposed new embankment stabilisation will not be visible from the road due to the elevated position of the carriageway. The LLTNP authority have been previously consulted for works in the RaBT area and requested that if any vehicle access is required off road that this should be micro-sited where possible to avoid more sensitive habitat areas.

Notification of these new works has been given to LLTNP, who commented that they were happy with the scheme design as the rock bags are more malleable and can achieve a more organic shape and tie in with the natural river bends. Their only recommendation was to include a follow up date to check on the re-seeding progress on the bank to check if any additional seeding is required.

Works will be carried out in line with good practice measures for managing the construction environment as outlined in the SEMP as follows:

Throughout all stages of the works, the site will be kept clean and tidy, with materials, equipment, plant and wastes appropriately stored, minimising the landscape and visual effects.
Upon completion of the works, the bank will be re-seeded, and a follow-up inspection will be carried out by BEAR operatives to check if the topsoil and re-seeding was successful or if follow up works are required to help this process.
Works will avoid encroaching on land and areas where work is not required or not permitted. This includes general works, storage of equipment/containers and parking.
The site will be left clean and tidy following construction.
Mitigation measures described in the Biodiversity section will be followed to reduce potential impacts on the landscape.

With the above mitigation measures in place, it is anticipated that any landscape and visual effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this RoD.

Biodiversity

The scheme is located 760m south of Glen Etive and Glen Fyne SPA. As such, an HRA was carried out and concluded that no potential for Likely Significant Effects would occur on the qualifying feature of the SPA due to the distance between the site, intervening topography and lack of nesting or foraging habitat in proximity to works.

Due to the scheme being located within the Beinn an Lochain SSSI; NatureScot was consulted and it was concluded that the SSSI’s features would not be negatively impacted by the proposed works and that no further consultation or SSSI consent was required.

During works, activities undertaken on site have the potential to result in adverse impacts on species that may be active within proximity of the proposed works. However, no further ecological surveys or licensing is required at this stage. No vegetation clearance is currently planned as part of works however if the scope of works is updated to include significant vegetation clearance during the breeding season (March-August inclusive) then a nesting bird check will be carried out 48hrs prior to works; if nesting birds are found during the pre-works check, consultation with NatureScot will be carried out and a licence will be sought if advised by NatureScot. If required, all conditions of any licences will be adhered to. Further measures to be included in the SEMP are as follows:

If significant vegetation clearance is added to the scope of works, then a 48hr pre-works nesting bird check will be required.
Site personnel will remain vigilant for the presence of protected species throughout the works period. Should a protected species be noted during construction, works will temporarily halt, until such time that the species has sufficiently moved on.
Measures to be implemented to protect the aquatic environment are detailed in the Road Drainage and Water Environment section below.
Tracking of machinery through watercourses will not be permitted.
No discharges into any watercourses or drainage systems will be permitted.
All construction operatives will be briefed through toolbox talks prior to works commencing. The talks will specifically cover ecology, field signs of protected species, and legislation. Briefings will be clear and unambiguous, with all staff informed to stop works where a concern is raised. Works will not recommence until advice from an appropriately qualified ecologist is sought and appropriate mitigation is in place, where required.
A ‘soft start’ will be implemented on site each day. This will involve switching on vehicles and checking under/around vehicles and the immediate works area for mammals prior to works commencing to ensure none are present and that there is a gradual increase in noise.
Any excavations, exposed pipes/drains, or areas where an animal could become trapped (e.g. storage containers) will be covered over when not in use, at the end of each shift, and following completion of the works to avoid animals falling in and becoming trapped.
If fencing is utilised at any point during the works, a gap of 200mm from ground level must be provided, allowing free passage for mammals and preventing entrapment.
If an active bird nest is found in the vicinity of works, all works within 30m of the nest will stop until the BEAR Scotland Environment Team can provide advice. Consultation with NatureScot may be required out and a licence will be sought if advised by NatureScot. If required, all conditions of any licences will be adhered to.

There is potential for temporary, indirect impacts on fish during construction due to mobilisation of sediment as a result of construction works. With the following mitigation in place, impacts are not anticipated to be significant:

The dry working area will be restricted to the minimum size possible to safely allow access for embankment works; this will only be a partial dry working area, with water continuing to flow downstream around it and allow fish passage.
Fish rescue will be conducted before any dry working areas are installed. The Argyll Fisheries Trust have been contacted to provide this service, if this is not possible another suitably qualified sub-contractor will be confirmed.
Mitigation measures described in the Road Drainage and the Water Environment Section will be followed to minimise potential impacts on the water environment.
Pollution prevention measures will be in place for the duration of construction.

The proposed works will result in some loss of habitats which are ubiquitous in the wider area. Therefore, the loss of small areas of these habitats compared to the wider area is not expected to be significant. During the operational phase, the works are not expected to significantly impact surrounding habitats as no on-going activities or maintenance of the embankment is expected.

The following mitigation measures will be adhered to during construction to ensure potential impacts on habitats are not significant and minimised where possible:

Construction methods will take place sensitively to reduce as far as possible encroachment of plant and machinery on habitats outside of the work footprint.
Material storage areas and site compound will be sited sensitively to avoid requirement for further land take. Where practical, this will be in existing hardstanding areas on level ground.
Mitigation measures described in the Road Drainage and the Water Environment Section will be followed to minimise potential impacts on the water environment.
Mitigation measures described in the Geology and Soils Section will be followed to minimise potential impacts on habitats.

Taking into account the nature and scale of the works and the good site practice mitigation measures which will be adopted during the works, it is anticipated that any biodiversity effects associated with the proposed works will not be significant. This receptor is not considered further in this RoD.

Geology and soils

The scheme is not located within a GCRS. Works will entail stabilisation works to the embankment, with only soil at failing areas of embankment to be excavated to make space for rock bags. As such, any impacts to local soils/geology are limited, and excavations will be carried out with good practice measures detailed in the SEMP as follows:

Excavated soil and rock will be stored in a designated area on level ground where practicable.
If the soil is to be re-used on site, then it will be wetted (if necessary) during periods of dry weather to prevent drying out.
Upon completion of the works, any damage to the local landscape (i.e. damage to grass verges) will be reinstated as much as is practicable.
Mitigation measures to prevent contamination of soils through loss of containment are discussed in the Water Section.
Mitigation measures described in the Biodiversity Section will be followed to reduce potential impacts on soils.
Multiple handling of soil derived from excavations will be minimised. The extent and duration of exposed soil will be kept to the minimum required for works.

With the above mitigation measures in place, it is anticipated that any geology and soils effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this RoD.

Material assets and waste

During construction, there will be a temporary impact as a result of material consumption and waste production. However, materials will be sourced locally where possible and the following mitigation measures will be put in place:

Materials will be sourced from recycled origins as far as reasonably practicable within design specifications.
Care will be taken to order the correct quantity of required materials to prevent the disposal of unused materials.
Where possible, minimal packaging will be requested on required deliveries to reduce unnecessary waste and production of packaging materials.

Provided the following mitigation measures are followed during works, impacts during construction are not anticipated to be significant:

The waste hierarchy (Reduce, Reuse, Recycle and Dispose) will be employed throughout the construction works.
Bulk material will be delivered to site without packaging where possible.
Suppliers will be requested to minimise all packaging where possible.
Care will be taken to only order the correct quantity of required materials, preventing disposal of unused materials.
Materials will be reutilised where possible.
Facilities on site will be provided in a designated area to enable the correct segregation of waste, maximising recycling on site. These will be clearly marked and labelled.
Wastes not suitable for recycling will be sent to landfill or special waste treatment facilities, depending on the nature of the waste.
All waste stored on site will be adequately protected against the elements.
All appropriate waste documentation will be present on-site and be available for inspection.
All wastes and unused materials will be removed from site in a safe manner by a licensed waste carrier upon completion of the works. The appointed waste carrier will have a valid SEPA waste carrier registration, a copy of which will be retained by BEAR Scotland. A copy of the waste transfer is also to be provided to BEAR Scotland as early as practicably feasible and retained.
During the site induction, all staff will be informed that littering will not be tolerated. Staff are also encouraged to collect any litter seen on site.
Where applicable, all temporary signage will be removed from site on completion of the works.
All hazardous material will be stored in line with the Road Drainage & Water Environment section.
A copy of the duty of care paperwork will be provided and filed appropriately in accordance with the Code of Practice (as made under Section 34 of Environmental Protection Act 1990 as amended).
Any contaminated ground as a result of the works will be removed and transferred off site as special waste.
Any special waste (if generated) will be removed from site by a licenced waste carrier. Special waste will not be mixed with general waste and/or other recyclables.

With the above mitigation measures in place, it is anticipated that any material assets and waste effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this RoD.

Noise and vibration

No commercial or residential properties are located within 300m of the works, and any impact to passing vehicles/NMUs on the A83 will be highly limited. Refer to the Biodiversity section for relevant assessment on protected species.

With the implementation of the following mitigation, noise and vibration impacts during the construction phase are not predicted to be significant:

The best practicable means, as defined in Section 72 of the Control of Pollution Act 1974 and BS5228-1:2009+A1:2014 Code of Practice for Noise and Vibration Control on Construction and Open Sites, will always be employed to reduce noise to a minimum.
Where possible, inherently quiet plant will be selected for construction works.
All plant, machinery and tools will be well maintained, including parts relating to noise minimisation.
All plant, machinery, and vehicles will be switched off when not in use.
Where ancillary plant such as generators are required, they will be positioned so to cause minimum noise disturbance.
Movement of plant onto and around the site will have regard to minimising noise and will not be left running if not required for immediate use.
All plant will be operated in a mode that minimises noise emissions and must have been maintained regularly to comply with relevant national and international standards.

With the above mitigation measures in place, it is anticipated that any noise and vibration effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this RoD.

Population and human health

During construction, activities undertaken on site may have temporary adverse impacts on vehicle travellers and NMUs as a result of construction presence, and associated delays due to TM measures. Road users will be informed of works through a media release, which will provide details of construction dates and times.

No significant congestion issues are noted during the proposed construction hours; however increased journey times may occur. These works will be scheduled to reduce overlap in TM restrictions at RaBT approximately 1.3km south of works.

It is anticipated that there will be a residual beneficial impact on safety for users of the trunk road at this location on completion of works due to reduction in the risk of embankment failure at this section.

With the following mitigation measures in place, the risk of significant impacts on population and human health is considered to be low:

Any changes of schedule (e.g. change from daytime works to nightworks) will be communicated to travelling public throughout the programme.
Appropriate provisions / measures will be implemented within the TM to allow the safe passage of NMUs of all abilities through the site (if required).
Journey planning information will be available for drivers online at the trafficscotland.org website. Journey planning information will also be available for drivers online through BEAR’s social media platforms.

With the above mitigation measures in place, it is anticipated that any population and human health effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this RoD.

Road drainage and the water environment

There is potential for temporary impacts on the water environment due to operation of plant within and within proximity to watercourses and/or drainage systems, which may lead to potential changes in water quality from pollution events (either by accidental spillage of sediments, particulate matter, chemicals, fuels or by mobilisation of these in surface water caused by rain). Standard procedures and conditions are in place to mitigate impacts on the water environment, as listed below.

Bank reinforcement works will be carried out at four localised areas (each section between 18-25m in length) using rock bags and rip rap (rock armour) to reinstate and stabilise the eroded sections of bank over a total length of approximately 83m. As such an Environmental Authorisations (Scotland) Regulations (EASR) Permit application for ‘Bank works more than 50m’ has been submitted to SEPA and will be confirmed prior to works commencing; a copy of this permit will be retained on site, and all conditions will be followed throughout the duration of works. The pre-application consultation with SEPA in March 2025 confirmed that grey bank reinforcements were considered suitable at this location due to topographical constraints on the alternative green bank options usually encouraged by SEPA.

A dry working area will be utilised for the works using appropriate bunding/damming, with exact method yet to be confirmed. Experience gained from BEAR maintenance schemes elsewhere on the network has shown that where standard good working practice is adopted (e.g., adherence to SEPA good practice guidance, utilisation of drain covers or similar, etc.), water quality is protected.

Provided the following mitigation measures are adhered to throughout the works, impacts during the construction phase are not predicted to be significant:

All conditions of the EASR Permit will be adhered to, and a copy of this permit will be retained on site at all times.
All conditions of the EASR Water General Binding Rules (GBRs) (specifically GBR9 which relates to ‘operating vehicles, plant or machinery in or near any surface water or wetland’) will be adhered to during the works, full details of which will be included in the SEMP.
Standard working practices to comply with EASR 2018 for works in or near water will be detailed in the SEMP and adhered to on site.
In-stream works will be carried out within a dry working area. The contractor is responsible for designing and implementing the dry working area and will provide a method statement for review prior to works commencing. This may involve partially damming the watercourse and over-pumping through the site.
Dry working area will be regularly inspected to ensure efficiency.
Rip rap rock armour will be washed off site prior to installation to remove fine sediments.
A toolbox talk on silt and sediment containment will be delivered to all site staff as part of the site induction.
No discharges into any watercourses or drainage systems will be permitted. Appropriate containment measures will be in place to prevent any loss of construction materials into the water environment.
An Environmental Clerk of Works (ECoW) will be present during various stages of works.
Fish rescue will be conducted by an appropriately qualified sub-contracted ecologist before any dry working areas are installed to minimise impact on the ecology of the watercourse.
All plant and equipment will be regularly inspected for any signs of damage and leaks. A checklist will be present to make sure that the checks have been carried out.
All on-site activities will operate in accordance with relevant SEPA Guidance for Pollution Prevention (GPPs).
All hazardous material utilised on site is required to undergo assessment under the Control of Substances Hazardous to Health (COSHH) Regulations 2002. These assessment(s) will contain a section on environment which highlights any precautions and mitigation requirements for storage.
All hazardous material will be stored in line with COSHH data within a designated COSHH storage area at least 10m from watercourses, drains, or waterbodies. Oils and chemicals will be stored in appropriately bunded storage cabinets. The COSHH store will be locked with only appropriate personnel having access and an inventory register being maintained.
The designated storage area will be on impermeable ground and fully bunded.
Where applicable and practicable, bio-degradable hydraulic fluids and oils will be utilised in machinery.
Where fuel is stored on site and refuelling actives are undertaken, the following will apply:
Only suitably bunded fuel bowser(s) or tank(s) in line with GBRs as detailed in the EASR will be utilised on site.
The fuel bowser(s) and/or tank(s) will be stored at least 10m away from any watercourses, waterbodies or drains and away from being struck by plant and machinery.
All distribution and fuelling nozzles will be fitted with a shut-off valve.
All refuelling activities will be undertaken in a designated site with a drip tray positioned underneath the nozzles when not in use.
All fuel containers and nozzles will be secured, for example with a lock when not in use.
All staff undertaking refuelling actives will be appropriately trained and undertake these activities in line with site refuelling procedures.
During refuelling of smaller mobile plant, a funnel and drip trays will be used.
Spill kits will be quickly accessible to capture any spills should they occur.
The ground / stone around the site of a spill will be removed, double-bagged and taken off site as special waste.
Generators and static plant may have the potential to leak fuel and/or other hydrocarbons and will have bunding with a capacity of 110%. If these are not available, then drip trays with a capacity of 110% will be placed beneath the equipment.
An incident response (contingency) plan will be put in place to reduce the risk from pollution incidents or accidental spillages. All necessary containment equipment, including suitable spill kits (for oil and chemicals) will be available on site, quickly accessible if needed, and staff trained in their use.
All spills will be logged and reported. In the event of any spills into the water environment, all works will stop, and the incident reported to the project manager and the BEAR Scotland Environment Team. SEPA will be informed of any such incident as soon as possible using the SEPA Pollution Hotline.
Mitigation detailed in Biodiversity Section will be strictly adhered to.

With the above mitigation measures in place, it is anticipated that any road drainage and the water environment effects associated with the proposed works are unlikely to be significant. This receptor is not considered further in this RoD.

Climate

During the works there is potential for impacts as a result of the emission of greenhouse gases through the use of equipment, vehicles, material use and production and transportation of materials and wastes. However, considering the nature, short-term duration, size and scale of the scheme, and the mitigation detailed below, the risk of significant impacts to climate are considered to be low.

Proposed climate mitigation measures:

BEAR Scotland will adhere to their Carbon Management Policy.
Local contractors and suppliers will be used as far as practicable to reduce fuel use and greenhouse gas emitted as part of the works.
Where possible, materials will be sourced locally and any waste which cannot be re-used or remain on-site will be disposed at local landfill, to reduce greenhouse gas emissions associated with materials movement.

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