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. 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.
- 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
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 A9, and construction works are programmed to be of short duration, undertaken at night 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 e.g., when complete the visual appearance will remain largely unaffected, with a renewed VRS system being the only discernible change. This VRS change 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
The Inner Moray Firth SPA and Ramsar lie approximately 2.15km south from the scheme and the Moray Firth SPA lies approximately 2.5km south from the scheme. Due to ecological connectivity between the scheme and the designated sites, a HRA Proforma was produced. The HRA concluded that there was no potential for the proposed works to result in Likely Significant Effects (LSE) on the qualifying features of the Inner Moray Firth SPA / Ramsar or the Moray Firth SPA based on the following factors:
- No works will take place within the boundary of either SPA or Ramsar and no in-water works are required; as such, no direct impacts (e.g., habitat loss) will occur.
- Given the minor and localised nature of the works, the lack of requirement for in-water works, and adherence to 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 Moray Firth SPA or Inner Moray Firth SPA due to the transient nature of the works and distance from the scheme.
- Although night works will require some artificial lighting, the works will be transient, and lighting will be directed in a way to avoid light spillage within the surrounding environment.
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, works are restricted to the A9 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 A9 and the scheme is of short duration (4 to 6 weeks) and will be undertaken on a rolling programme. The potential for significant species disturbance within the area of likely construction disturbance is therefore considered to be low.
One area of long-established (of plantation origin) woodland is located within 300m of the scheme; however, no tree felling is planned for the works.
Transport Scotland’s AMPS identified rosebay willowherb and giant hogweed within the scheme extent. Rosebay willowherb an invasive native perennial plant will be managed as per NW Landscape Management plan and disposed of accordingly if required. Giant hogweed growth was identified to be present within the verge of the southbound (SB) carriageway layby located 400m north from Glackmore Farm. Works are restricted to be within the central reservation of the A9 trunk road and lie approximately 15m west from the identified giant hogweed growth. Should any INNS be identified within the works area, relevant mitigation measures to prevent spread will be followed, as will be detailed within the SEMP.
Pollution controls and good practice measures to reduce impacts of works on the local environment will be detailed in the Site Environment Management Plan (SEMP) and adhered to on site. Any protected species in the area are likely to be accustomed to road noise on the A9 and the scheme is of relatively short duration. 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 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 (where 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 GCRS or geological SSSI. Although the works will entail minor excavation, this will be on engineered ground. In addition, any excavations 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 grass 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 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 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 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 on a rolling programme during night-time working hours, 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 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 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 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.
- Where possible and where works will take place within 300m of residential properties and other sensitive receptors, the noisiest work operations 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. The A9 will not be fully closed during the works, the single lane closure on both sides of the carriageway 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 NMU facilities which lie within 300m of the scheme, will be maintained and the works are being undertaken at night when footfall and cyclist count is at its lowest.
Several residential properties are found within 300m of the scheme. The nearest residential property lies 30m west from the scheme with minimal screening present and given that the works are being undertaken at night, there is potential for 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.
- 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.
- 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 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.
However, 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) (as amended) 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, any open drainage facilities and trees (roots absorb water) 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 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, any open drainage facilities, and trees, 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.