64 Comments for Lillebælt:
1. To the extent possible, it is recommended that the pipeline routing and pipe laying method be chosen based on a criterion of least possible environmental impact, including impact on any
NOVANA measuring stations. However, this is also implied in section 7.1 on mitigation measures, where it specifies e.g. that “It should be attempted for the pipeline to be established outside the coastal eelgrass and stone reef areas south of Fænø, which will only lead to impact on these habitat types by the landfalls on the Funen and Jutland side and thus a smaller part of the total areas with eelgrass and stone reefs in the survey corridor.”
As the environmental impact report was prepared against the background of the actual project, using the construction within the stated project area as the starting point, Energinet does not see any grounds for preparing an addendum to the environmental impact assessment.
Energinet can confirm that the pipeline is not routed through the eelgrass areas south of Fænø.
The Danish Energy Agency would also like to point out that Energinet, under the terms set, must ensure that the pipeline is set up outside of the eelgrass and stone reef areas near to the coast south of Fænø in a way that minimises impact as much as possible.
65 2. The Danish Environmental Protection Agency would like to be notified when work is being carried out in Lillebælt (Little Belt), so that this can be taken into consideration when the NOVANA monitoring programme is underway.
This can be accommodated. The Danish Energy Agency
points out that is a condition of the approval that
Energinet must abide by the demands of the
Environmental Protection Agency relating to how the project is carried out and its operation.
66 3. The environmental impact assessment highlights the current ecological and chemical conditions in the affected bodies of water with regard to the body-of-water-plans Environmental GIS. There is not, however, any reference to the actual environmental target criteria (classes between quality thresholds) for the respective quality elements, which is why the view is taken that there is insufficient support for the opinion that the project does not adversely affect conditions and does not prevent the target of sound ecological and chemical conditions from being met. For this reason, the overall view taken appears too general in relation to the plans for the bodies of water (6.15.3.1.3) and does not assess any adverse effect.
The plans for the bodies of water were evaluated against the background of descriptions and assessments of the impact on the sea bed and sediment spread, benthic flora and fauna etc. in other sections of the report.
Furthermore, the sediment’s contents have been described and evaluated in terms of nutrients and environmentally dangerous substances.
No nutrients or environmentally dangerous substances will be supplied to the body of water during the project. In other words, the only impact on the quality elements will be the purely mechanical impact on the sea bed when digging/setting up the gas pipeline, plus the indirect effect that swirling sediment with a certain nutrient and environmentally dangerous substance content may have by releasing sediment-bound nutrients and environmentally dangerous substances. For Lillebælt, it is also about what impact any dredging of excess sediment would have.
Against the background of figures from the Danish Nature Agency’s investigations, it was decided that the sediment has modest nutrient and environmentally dangerous substances content. After the application for dredging work was submitted to the Danish Environmental Protection Agency, the Agency subsequently also decided that the sediment is so pure that there would be no need to take sediment samples for analysis purposes.
Against that background, NIRAS, who are Energinet’s advisor, decided that the aforementioned descriptions and assessments already sufficiently highlight the impact from the project on the targets in the plans for the bodies of water, and as such that a more detailed review of the quality elements in relation to the
environmental target criteria would be unnecessary.
As far as the wording is concerned, i.e. that the project will not adversely affect conditions in the bodies of water, NIRAS takes the view that the decision implies that the project has no significant impact on the plans for the bodies of water. If it had been decided that the project would have adverse effects, i.e. such that classifications for the body of water would be downgraded on one or more of the parameters, this would have been deemed a considerable impact.
The Danish Energy Agency has no more comments on this issue.
67 4. In connection with the above, it must also be pointed out that the plans for the bodies of water’ assessment of benthic
invertebrates as a quality element is done using the Danish Quality Index (DKI), which is why the environmental impact assessment’s assessment of the benthic fauna appears general.
The Danish Quality Index (DKI) can only be applied to soft benthic fauna collected using a set methodology (certain number of samples using certain methods). This is necessary in order to gain a quantitative result that can be used in a certain calculation. No benthic fauna samples were taken in connection with Baltic Pipe, because it was decided that it would be enough to describe the existing soft benthic fauna population in the project area based on data from a nearby monitoring station, as shown in figure 6.17 of the report (station no LBBR0017 - the Danish Environmental Protection Agency) and investigations in N2000 habitat area no 96, in Lillebælt just south of the project area.
Field studies in relation to Baltic Pipe mainly focused on securing that the most sensitive habitat types (eelgrass and reefs/hard seabed areas) were mapped precisely, as they are the most complex and sensitive habitats to impact with the longest recovery time.
In hard bed habitats (hard benthic bottom/stone reef), qualitative lists of species (observed species) were compiled together with an overall quantitative description (individuals, common, predominant) of the species observed. It is not possible to create a DKI index based on this data.
Section 6, bed flora and fauna, describes loss of habitat, covering the sea bed with sediment and spread of sediment, as well as other disruption of the species living on the sea bed, as a result of the Baltic Pipe
The Danish Energy Agency has no more comments on this issue.
project. A description and assessment of the re-establishment and restoration process for the different types of nature in the project area, and for recolonisation of the flora and fauna, are provided.
Against this background, NIRAS decided that the impact of the benthic invertebrates from the project has been highlighted sufficiently to be able to assess the impact in relation to the quality element in the plans for the bodies of water.
68 5. The impact from environmentally dangerous substances (EDS) is assessed in the environmental impact assessment if environmental quality standards are stipulated by law and action levels are given in the dredging guidelines. The latter are applied when assessing dredging and do not in themselves constitute criteria under which the targets from the Water Framework Directive and Marine Strategy Framework Directive are to be set. One suggestion may be to include criteria/threshold values for EDS, to be applied under the auspices of OSPAR and HELCOM.
As described in the report, the project will not introduce any environmentally dangerous substances (EDS) to body of water. The description of the sediment’s EDS content reflected the Danish Nature Agency’s
monitoring of EDS in the area, and comparing this with the action levels in the dredging guidelines will ensure that the sediment’s EDS content does not exceed the average background level, which itself is not expected to have any effect, according to the Danish Environmental Protection Agency website. There are no direct sources of EDS close to the project area (direct discharges, ports etc.) As the project in itself will not introduce any EDS to the body of water, the level of contamination affecting the sediment is not expected to change. After the application for dredging work was submitted to the Danish Environmental Protection Agency, the Agency also decided that the sediment is so pure that there would be no need to take sediment samples for analysis purposes.
Any impact that may occur will be from EDS potentially released to the aqueous phase from the swirling sediment. As described in the report, this impact will be short-term and, against the background of the hard-bed content of EDS in the sediment, limited in scope.
Against this backdrop, NIRAS decided that the EDS impact of the project has been highlighted sufficiently – including an adequate description of the sediment’s EDS content.
The Danish Energy Agency has no more comments on this issue.