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 the works, and emissions from transportation of material, the presence of construction traffic and vehicles idling. Activities undertaken on site may cause dust and particulate matter 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 the air 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.
Good housekeeping will be employed throughout the work.
Concrete bags will remain closed when not in use to prevent cast off to the surrounding environment.

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

The scheme lies wholly within the Cairngorms NP; as such, the Cairngorms NP Authority has been notified of the works and no additional mitigation measures were recommended.

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 will be restricted to areas of made/engineered ground on the A9, and construction works are programmed to be of short duration, undertaken during the day on a rolling programme. As such, the visual impact of the works will be minimal.

Upon completion of the works, no significant residual impacts are anticipated. The visual appearance will remain largely unaffected, with a renewed VRS system and the addition of new VRS to fill existing gaps being the only discernible change. The proposed VRS will be in keeping with the existing/replaced street furniture, and as such, any visible change is considered to be negligible.

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 shall 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

No European sites (i.e. SPAs, SACs or Ramsar sites) are located within 2km of, or hold ecological connectivity to, the scheme extents. Additionally, there are no SSSIs, LNCSs or LNRs designated for biodiversity within 300m of the scheme.

Activities undertaken on site could potentially have a temporary adverse impact on biodiversity that may be present in the area as a result of an increased vehicle presence and the potential for disturbance to protected species and pollution of habitats. However, no protected species resting places were identified during the ECS. However, it was noted in the ECS that the surrounding habitat is suitable for nesting birds, the risk of disturbance is considered to be low due to the existing noise levels and visual disturbance associated with traffic on the A9. However, no vegetation clearance is required as part of the works, and as such, a pre-work nesting bird check is not required.

The works are restricted to the central reserve of the A9 carriageway, which is already subject to high levels of noise and disturbance due to traffic, and noise produced during works is not expected to differ significantly from baseline conditions. In addition, any species in the area are likely to be accustomed to noise and visual disturbance pertaining to vehicle movements on the A9. The scheme is of short duration (30 days) and will be undertaken on a rolling programme during daylight hours. The potential for significant species disturbance within the area of likely construction disturbance is therefore considered to be low.

The NBN Atlas did not record any injurious weeds or INNS within the scheme extent; however, the injurious weed common ragwort was recorded on AMPS within the scheme extent. This will be managed as per the NW Landscape Management plan and disposed of accordingly if required. Works are restricted to the central reservation of the A9 trunk road and should any injurious weed or INNS be identified within the works area, relevant mitigation measures to prevent spread will be detailed within the SEMP and followed on site.

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:

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 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 (if required) 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.
Personnel will remain vigilant for the presence of INNS or injurious weeds in road verges throughout the works period. Should any INNS be identified in working areas, works will be restricted to a 7m buffer of any growth where reasonably practicable.
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.

Geology and soils

The scheme is not located within a geological SSSI. However, the scheme is located approximately 20m south of the Glen Garry SSSI and is located within the A9 Road Cuttings and River Garry Gorge GCRS. Although the works will entail minor excavation, this will be on engineered ground within the central reservation of the A9 carriageway. NatureScot was consulted as a precaution via the Informed Decision online tool, which confirmed that SSSI consent is not required for the works to proceed within close proximity to Glen Garry SSSI.

Although the risk of impacts on geology and soils is considered to be low due to the location of works on engineered ground, the following measures will be implemented and will be carried out with good practice measures detailed in the SEMP as follows:

Excavations will be restricted to the engineered ground of the A9 carriageway, and all machinery will operate from road level without entering ground outside the man-made surface of the A9.
Excavated material will be kept to a minimum and reused and/or redistributed within the scheme extents.
Multiple handling of excavated soil will be minimised.
Upon completion of the works, any damage to the local landscape will be reinstated as much as is practicable.
Mitigation measures to prevent contamination of soils through loss of containment will be strictly adhered to.
The parking of machinery/vehicles and storage of equipment on verges will be minimised as far as is reasonably practicable.
All relevant soil management toolbox talks will be included in the SEMP and sediment control measures will be in place to prevent soil erosion and loss of containment.
Additional pollution prevention measures as outlined in the ‘Road drainage and the water environment’ section will be adhered to during construction.

With the above mitigation measures in place, it is anticipated that any geology and soil effects associated with the proposed works are unlikely to 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 will 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.
As the scheme’s cost exceeds £350,000 a Site Waste Management Plan (SWMP) will be produced.
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 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 will be produced and filed appropriately in accordance with the Code of Practice (as made under Section 34 of Environmental Protection Act 1990 as amended).
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, the works are scheduled to commence within typical working hours (08:00 – 18:00, Monday – Friday) and the proximity of road space suggests that residents within the local area will have a degree of tolerance to noise and disturbance. Works with the potential to induce worst-case scenario noise and vibration will also be intermittent, temporary, transient and short-lived.

The following mitigation measures will be put in place:

Local residents that are likely to be 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 Best Practicable Means, as defined in Section 72 of the Control of Pollution Act 1974, 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.
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. The works will take place during the day, when traffic count is likely to be at its highest. However, the A9 will not be fully closed during the works. There will be a single lane closure on both sides of the carriageway and works will avoid the weekend. In the event of local access restrictions to residential properties, access will be granted as requested. Access to NMU facilities which lie within 300m of the scheme will be maintained.

Approximately three residential properties are within 300m of the scheme. The nearest residential property lies 30m south of the scheme; however, visual and acoustic screening is provided by intervening woodland, and the works will take place during daytime hours.

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.
Any changes of schedule will be communicated to local residents and public transport operators 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.
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 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).

Under the Environmental Authorisations (Scotland) Regulations 2018 (EASR), the proposed road drainage works are classed as an activity that does not require authorisation. There is no requirement for the abstraction or transfers of water from, or discharges to, a waterbody and standard good practice measures will be in place to prevent pollution or loss of containment to the surrounding environment. 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 following measures will be put in place to reduce the risk of pollution incidents as a result of works:

Standard working practices to comply with 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 will be permitted. Appropriate containment measures will be in place to prevent any loss of construction materials into the water environment.
Concrete batching will be carried out on an impermeable surface at least 10m away from drains, water bodies and any open drainage facilities but as close to the works as possible to prevent any spills, drips, etc into open ground.
Any concrete wash-out will be contained and removed off-site for appropriate treatment/disposal. Disposal of wash water into waterbodies or road drainage will not be permitted.
Pollution prevention measures (e.g., plant nappies, bunding) will be in place to manage concrete (including any wash water) and prevent escape to the watercourse.
Cement powder, concrete retarding and concrete curing agents (if required) will be stored in areas away from roadside gullies and any open drainage facilities, with liquids being stored in a suitable bund or storage container.
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 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 bunded then drip trays will 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 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 its Carbon Management Policy.
All mitigation measures detailed within ‘Air Quality’ and ‘Material Assets and Waste’ will be adhered to.
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 to reduce greenhouse gas emissions associated with materials movement, and waste will be disposed at local facilities, 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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