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 cold milling in preparation of carriageway resurfacing, as well as exhaust emissions from ancillary plant and vehicles. 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 quality are considered to be low.

A water-assisted dust sweeper will sweep the carriageway after dust-generating activities, and waste will be contained and removed from site as soon as is practicable.
Materials that have a potential to produce dust will be removed from site as soon as possible, and vehicles that remove waste from site will have sheeted covers.
Ancillary plant, vehicles, and non-road mobile machinery (NRMM) will have been regularly maintained, paying attention to the integrity of exhaust systems.
Ancillary plant, vehicles and NRMM will 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., 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) minimising cutting and grinding on-site, (b) reducing 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 the 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 work.

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).

Landscape and visual effects

Works lie within the Cairngorms National Park. The National Park Authority will be notified prior to the works commencing.

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.

However, people, ancillary plant, vehicles, NRMM and materials are restricted to areas of made/engineered ground on the A889, and construction works are programmed to be of short duration, undertaken at night on a rolling programme. No change to land use, or to the designation features of the CNP, will occur as a result of the works. As such, the visual impact of the works will be minimal. Upon completion of the works, no residual impacts are anticipated e.g., when complete the visual appearance will remain largely unaffected, with a renewed road surface being the only discernible change.

In addition, the following mitigation measures will be put in place during works:

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 as much as possible.
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.
Where applicable, upon completion of the works, any damage to the local landscape will be reinstated as much as is practicable.
The site will be left clean and tidy following construction.

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 proposed works lie within 2km of the River Spey SAC, Drumochter Hills SAC and Drumochter Hills SPA. The existing BEAR Scotland ‘Roads and Bridges Maintenance Activities within the Drumochter Hills, River Spey and River Spey-Insh Marshes European Sies, Highland Region HRA (June 2023)’ produced by BEAR Scotland to assess ecological connectivity of maintenance activities on the River Spey SAC and Drumochter Hills SAC/SPA includes resurfacing works, such as those proposed at A889 North of Crubenmore Junction. As such, potential impacts of the proposed works have already been assessed and no further HRA is required for this scheme.

The HRA concluded that there would be no Likely Significant Effects (LSE) on the qualifying features of the River Spey SAC based on the following factors:

No works will take place within the boundary of the SAC and no in-water works are required
Given the minor and localised nature of the works, the lack of requirement for in-water works, and adherence to standard good practice measures for pollution prevention, no risk of significant pollution impacts (to watercourses or associated feeding grounds) was identified.
Although the works will result in a temporary (localised) increase in noise, this is unlikely to significantly affect the qualifying features of the SAC due to the transient nature of the works, the mobile nature of the qualifying species and the ample alternative foraging habitat in the remainder of the SAC away from the works.
Mammals within the vicinity of the trunk road are likely to be habituated to existing levels of noise and activity due to traffic, and the proposed resurfacing works are unlikely to result in significantly higher levels of noise than baseline levels.
Although night works will require artificial lighting, the works will be transient, and lighting will be directed in a way to avoid light spillage within the surrounding environment.
Works will not promote the known negative pressures on the various designated features.

The HRA concluded that there would be no LSE on the qualifying features of the Drumochter Hills SAC (included assessment of features of Drumochter Hills SSSI (montane assemblage, vascular plant assemblage, fluvial geomorphology of Scotland) as a component of the SAC for completeness) based on the following factors:

No works will take place within the boundary of the SAC/SSSI, and no in-water works are required; as such no direct impacts on the qualifying features will occur.
Standard working practices include robust containment measures to prevent pollution events.

The HRA concluded that there would be no LSE on the qualifying features of the Drumochter Hills SPA based on the following factors:

No works will take place within the boundary of the SPA/SSSI; as such no direct impacts on the qualifying breeding bird species (mortality or nest destruction due to construction vehicles, habitat loss) will occur.
Given the minor and localised nature of the works, the lack of requirement for in-water works, and adherence to standard good practice measures for pollution prevention, no risk of significant pollution impacts (to watercourses or associated feeding grounds) was identified.
Bird species that are within proximity to the works are likely to be habituated to the traffic noise, and the proposed resurfacing works are unlikely to result in significantly higher levels of noise that baseline levels.

The habitat surrounding the works indicates the potential for presence of protected species. Activities undertaken on site could potentially have a temporary adverse impact on biodiversity in the area as a result of an increased vehicle presence and the potential for disturbance to protected species and pollution of habitats. However, works are restricted to the A889 carriageway and the number of construction vehicles and construction operatives required onsite is low given the scale and scope of works. In addition, any species in the area are likely to be accustomed to noise and visual disturbance pertaining to vehicle movements on the A889 and the scheme is of short duration. The potential for significant species disturbance within the area of likely construction disturbance is therefore considered to be low.

Pollution controls and good practice measures to reduce impacts of works on the local environment will be detailed in the SEMP and adhered to on site. Therefore, with the following mitigation measures in place, the risk of significant impacts on biodiversity are considered to be low:

No in-water works will be permitted. Works will be strictly limited to areas required for access and to carry out the works. Unnecessary encroachment onto terrestrial or aquatic areas will not be tolerated.
All construction operatives will be briefed through toolbox talks prior to works commencing, which will be included in the SEMP. The toolbox talks will provide information on the legislation, general ecology, and best practice measures for relevant protected species.
Site personnel will remain vigilant for the presence of recorded and unrecorded instances of invasive plants or injurious weeds in road verges throughout the works period; should any be identified in working areas, no works will take place within 7m of these areas until the BEAR Scotland Environment Team can provide further advice on additional mitigation measures.
Site personnel will remain vigilant for the presence of any protected species, throughout the works period. Should a protected species be noted during construction, works will temporarily halt until the species has sufficiently moved on. Any sightings of protected species will be reported to the BEAR Scotland Environmental Team.
Artificial lighting will be directed away from areas of woodland and waterbodies as far as is safe and reasonably practicable.
If an active bird nest (e.g., eggs or young present, adult sitting on nest) is identified on site, all works within 30m of the nest will stop until the BEAR Scotland NW Environment Team can provide advice.
A ‘soft-start’ will be implemented on site each day. This will involve switching on vehicles and checking under/around vehicles and the immediate work 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 will be provided, allowing free passage for mammals and preventing entrapment.

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.

Material assets and waste

There is potential for impacts as a result of resource depletion through use and transportation of new materials. 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 shall be requested on required deliveries to reduce unnecessary waste and production of packaging materials.

There is potential for impacts during works as a result of the improper storage or disposal of waste. The following mitigation measures will be put in place:

The waste hierarchy (Reduce, Reuse, Recycle and Dispose) will be employed throughout the construction works.
The subcontractor will adhere to waste management legislation and ensure they comply with their Duty of Care.
Containment measures will be in place to prevent debris or pollutants from entering the surrounding environment.
All road planings will be managed in accordance with SEPA Position Statement WAS-G-DEF-07 (LRWA 3) and recycled in line with SEPA Guidance WAS-G-DEF-05 on End-of-Waste for Recycled Aggregates.
All wastes and unused materials will be removed from site in a safe and legal 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 provided to and retained by BEAR Scotland as early as possible.
All appropriate waste documentation will be present on site and be available for inspection. A copy of the Duty of Care paperwork shall be produced and filed appropriately in accordance with the Code of Practice (as made under Section 34 of Environmental Protection Act 1990 as amended).
If any presence of coal tar is discovered the following process will be followed:
- Any coal tar contaminated road planings will be classified as Special Waste.
- Special waste consignment notes (SWCN) will be obtained from SEPA to allow the movement of the contaminated planings.
- Coal tar contaminated road planings will be transported by a registered waste carrier to an appropriate waste recovery facility.
- SEPA will be notified at least 72 hours before (and no longer than one month before) Special Waste leaving site.
Re-use and recycling of waste will be encouraged, and the subcontractor will be required to fully outline their plans and provide documentary evidence for waste arising from the works (e.g., waste carrier’s licence, transfer notes, and waste exemption certificates).
Staff will be informed that littering will not be tolerated. Staff will be encouraged to collect any litter seen on site.
Where applicable, all temporary signage will be removed from site on completion of the works.

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

Construction activities associated with the proposed scheme have the potential to cause noise and vibration impacts through the use of equipment and construction vehicles for the proposed activities. However, the works are not located within a CNMA or CQA and the proximity of road space suggests that residents within the local area will have a degree of tolerance to noise and disturbance. Works will be completed over 6 nights on a rolling programme, with the aim being to complete the noisiest work by 23:00. Works with the potential to induce worst-case scenario noise and vibration will also be intermittent, temporary, transient and short-lived.

The road surface is in a poor condition, with a series of defects. Replacing the life-expired surface course affords the benefits of a reduction in mid-to-high frequency traffic noise and a reduction in ground vibrations. As a result, upon completion of the work, noise associated with the movement of vehicles on the trunk road should decrease post construction.

The following mitigation measures will be put in place:

Local residents which are affected by the works will be notified in advance of the works, likely by a letter drop, which will contain details of the proposed timings and duration of the works, in addition to contact details for the Site Supervisor.
The Environmental Health Officer (EHO) from Highland Council will be notified of the works.
The Best Practicable Means, as defined in Section 72 of the Control of Pollution Act 1874, will be employed at all times to reduce noise to a minimum. On-site construction tasks will be programmed to be as efficient as possible, with a view to limiting noise disruption to local sensitive receptors.
Where possible and where works will take place within 300m of residential properties and other sensitive receptors, the noisiest work operations (e.g., cold milling, using breakers (jackhammers), chipping hammers, use of rollers, etc.) will be completed before 23:00.
All site personnel will be fully briefed in advance of works regarding the need to minimise noise during works and of the site-specific sensitivities.
Drop heights from vehicles and NRMM will be kept to a minimum to minimise noise when unloading.
All plant, machinery and vehicles will be switched off when not in use.
All plant will be operated in such a way that minimises noise emissions and will have been maintained regularly to the appropriate standards.
Where fitted, and where permitted under Health and Safety requirements, white noise reversing alarms will be utilised during construction.
Where ancillary plant such as generators are required, they will be positioned so as to cause minimum noise disturbance. Where deemed necessary, acoustic screens will be utilised.

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 have the potential to have temporary adverse impacts on local residents, vehicle travellers, and NMUs. Although the works require two-way temporary traffic lights and a convoy system, the TM will take place at night when traffic count is at its lowest and no significant congestion issues are noted during the proposed construction hours. In the event of local access restrictions to residential properties, access will be granted as requested. Access to any NMU facilities which lie within 300m of the scheme, will be maintained.

A cluster of approximately five residential properties is found within 300m of the scheme. The nearest of which lies approximately 175m southeast from the works with limited visual an acoustic screening. Works are being undertaken at night, therefore, there is potential for a level of disturbance from noise, vibration and the additional construction lighting.

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

Notification will be issued to local residents and local public transport operators prior to commencement of the works, advising of any proposed works and expected restrictions.
The works schedule and any changes to this will be communicated to local residents prior to and throughout the programme.
Given the proximity of residential properties to the scheme extents, the Toolbox Talk TTN-042 ‘Being a Good Neighbour’ will be briefed prior to the works commencing.
Construction lighting will consider the need to avoid illuminating surrounding environment and properties to avoid a nuisance at night, and non-essential lighting will be switched off at night.
Local access will be granted as required.
Appropriate provisions / measures shall be implemented within the traffic management to allow the safe passage of NMUs of all abilities through the site.
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).

No in-water works will take place and there is no requirement for the abstraction or transfers of water from, or discharges to, a waterbody. As such, the potential for a direct pollution incident within a waterbody is unlikely. 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.

The works may result in potential direct or indirect effects on surrounding waterbodies. The following mitigation measures will be put in place to reduce the risk of pollution incidents as a result of works:

No work has been identified that would require entering any surface waterbodies. If such a need were identified onsite, BEAR Scotland’s Environmental Team will be contacted (before the works commence) to allow consideration of potential environmental effects.
Standard working practices to comply with The Environmental Authorisations (Scotland) Regulations 2018 (EASR) for works in or near water will be detailed in the SEMP and adhered to on site.
No discharges into any watercourses or drainage systems are permitted. Appropriate containment measures must be in place to prevent any loss of construction materials into the water environment.
Appropriate measures will be implemented during resurfacing operations to limit the potential for wastes (i.e. road planings) and materials (i.e. new asphalt) to enter any gullies present on site. On completion of resurfacing operations, any gullies present on site will be visually checked to ensure they have not become blocked as a result of the scheme.
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 will be reported to the project manager and the BEAR Scotland Environmental Team. SEPA will be informed of any such incident as soon as possible using the SEPA Pollution Hotline.
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.
Storage of hazardous material, oil and fuel containers will be distanced more than 10m away from any watercourses.
If required, a designated refuelling area will be identified. Fuel bowsers will be stored on an impermeable area and be fully bunded. This will be distanced more than 10m from any watercourses.
During refuelling of smaller mobile plant, a funnel will be used, and drip trays will be in place. Care will be taken to reduce the chance of spillages. Spill kits will be quickly accessible to capture any spills should they occur. The ground/stone around the site of a spill shall be removed, double bagged and taken off site as special contaminated 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 bunded then drip trays shall also be supplied beneath the equipment with a capacity of 110%.

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 such as 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 its Carbon Management Policy.
All mitigation measures detailed within ‘Air Quality’ and ‘Material Assets and Waste’ will be adhered to.
The works will utilise the use of Warm Mix Asphalt (WMA) for binder layer in favour of Hot Mix Asphalt (HMA).
Local contractors and suppliers will be used as far as is practicable to reduce fuel use and greenhouse gases emitted as part of the works.
Where possible, materials will be sourced locally to reduce greenhouse gas emissions associated with materials movement, and waste will be disposed at local landfill, where required.

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

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