MARINE SURVEY OFFICE
Marine Survey Office,
Abbey View House
Ballyshannon,
Donegal,
Ireland.
Memorandum to
Attention
Fax No
From
No of Pages
Date
Reference
Tel: 353-071-9822400
E.C & LG Foreshore Division
Ann Banville
6199408
Nick Cantwell
1
13 February 2016
FS6492
America Europe Connect Subsea Fiber
optic cable. Co. Mayo.
CC
Ann /
Having reviewed the Marine Environmental report for the proposed development, I am
satisfied that all reasonable steps have been considered to minimise disruption to marine
navigation.
In support of this it is imperative that as much warning is given to shipping interests as
possible. This should be by means of a Marine Notices issued by the Irish Maritime
Administration and a notice in a locally read newspaper.
These notices should provide information on commencement and completion dates, the
nature of the work and a clear statement referring to marine safety broadcasts as arranged
with the Irish Coast Guard.
In view of the above this office raises no objections.
Yours faithfully
____________________
N.W.Cantwell (Capt.)
Nautical Surveyor
MARINE INSTITUTE
Marine Institute Comments on the foreshore licence application by America
Europe Connect Ltd for the installation of a subsea fibre optic cable on the
foreshore, with landfall at Ross village in Killala Bay, Co. Mayo (FS006942)
America Europe Connect Ltd has submitted an application to for a Foreshore Licence to facilitate the
installation of a subsea fibre optic cable on the foreshore. The works are part of a project involving
the installation of a subsea fibre optic cable system, 5,250km in length, extending from Long Island
in the USA to Ireland with landfall at Ross village in Killala Bay, Co. Mayo. It is intended that the
subsea cable would be linked via an on-shore cable network in Ireland with further high capacity
links to the UK and mainland Europe.
The proposed cable route on the foreshore is shown on Drawing No. 1251-207 submitted by the
applicant, entitled “Foreshore Licence Map”, dated 29/02/2015. Details are also shown on:
 Drawing No. 1251-204, entitled “Mainlay Offshore Route”, dated 16/02/2015
 Drawing No. 1251-205, entitled “Mainlay Inshore Route”, dated 16/02/2015
 Drawing No. 1251-206, entitled “Mainlay Landfall ”, dated 16/02/2015
A pre-lay grapnel run, to clear debris from the seabed along the installation route, is proposed prior
to cable installation. This is standard practice. The swathe width of the grapnel is < 1m and impacts
on the seabed are considered to be minimal and not significant. All debris recovered from the
seabed will be stored on board the vessel used to carry out the pre-lay grapnel run and will be
disposed of onshore.
Cable Installation
Inshore
Beach Manhole
A Beach Manhole is to be constructed onshore at the existing hard stand area at Ross Strand. The
manhole will be 3m x 2m x 2m and is to be constructed in reinforced concrete. It is anticipated that
construction time would be in the order of 1 week.
A section of duct will be installed at a depth of 1.5m from the Beach Manhole to the top of the
slipway. The existing macadam surface will be saw-cut, the trench will be excavated, the duct will be
installed and the trench will be backfilled immediately. The macadam surface will be reinstated on
completion of the backfill. It is anticipated that these work would take 2 days to complete.
Shore End
The shore end operation will involve the excavation of the trench on the beach at Ross Village. It will
commence with removal of the stones forming part of the upper shore, as necessary and storing
these to one side. The excavation of the trench will be carried out from the slipway to the LWM. It
will continue until the target depth of 1.5m is achieved in the sediment. A short section of duct will
be placed beneath the storm beach.
Cable installation will be carried out by a cable ship, or shallow water vessel, stationing offshore near
its minimum working depth. A messenger line will be hauled ashore and a winch, located near the
Beach Manhole will pull the cable through the pre-installed duct and into the manhole. The cable
will then be lowered into the excavated trench and the trench backfilled. Any disturbed areas of the
beach landing will be restored to their original pre-construction condition. The cable installation
element of the works is generally completed in one tidal cycle.
It is also intended to install and an “ocean ground bed” on the beach at Ross Village. The ocean
ground bed is a set of electrodes which provides the return path for the electrical circuit that powers
the repeaters in the submarine cable system. The ocean ground bed is typically buried at least 2m
below beach level and is effectively a 6m long trench that would be backfilled and reinstated in one
tidal cycle. The Ocean Ground Bed will be buried in the beach adjacent to the cable
It is intended that the above works would be carried out in August 2015
Main Cable Lay
It is intended to use a single cable ship, one of TE SubCom R-Class cable ships, to lay the cable: On
arrival at the Pre Lay Shore End cable position, the streamed cable end on an anchor is retrieved by
the cable vessel, either by use of divers or grappling, and the shore end recovered to make a joint to
the main system cable onboard. The jointing process takes approximately 18-24 hours to complete
including tests of the cable system, through to the terminal station, once the joint is complete.
During the main lay and ploughing operations there are two methods associated with the cable
laying:
 Cable burial – where the cable is required to be buried to protect it from potential threats in
depths less than 1500m.
 Surface laying – where the submarine cable is laid onto the surface of the seabed. This
procedure is carried out in water where the cable cannot, or is not required to, be buried
(e.g. at cable/pipeline crossings or in areas where the seabed is too hard for the burial tool
and at depths greater than 1500m)
The target burial depth for the America-Europe Connect cable system is 1.5 metres for main lay
Operations
Post Lay Inspection
Following the main lay operations, a post-lay inspection and burial programme may be carried out in
certain areas to inspect the proper laying and burial of the cable in the seabed. The amount and
locations of the buried cable to be inspected will be determined based on the performance of the
main lay operations. In the areas requiring post lay burial, a separate Remotely Operated Vehicle
(ROV) is utilised. The ROV typically uses a jetting tool to bury the cable to the required depth.
It is anticipated that the cable lay operation would be completed within a 2 week period.
On the basis of the information provided by the applicant the Marine Institute is of the view that
considering the nature, scale, location and duration of the proposed works impacts on the marine
environment are not likely to be significant. There are no licenced aquaculture site along, or
adjacent to the proposed cable route. The nearest licenced aquaculture site is circa 2.5Km south of
the proposed landfall site at Ross Village and the Marine Institute is of the view that there would be
no impact on aquaculture activities as a result of the proposed works.
The Marine Institute has no objections to a licence being granted.
It is recommended that the following Conditions should be attached to any licence that may be
granted:
1. The Licensee shall use that part of the Foreshore the subject matter of this licence for the
purposes as outlined in the application and for no other purposes whatsoever.
2. The Licensee shall notify the Department of the Environment, Community and Local
Government at least 14 days in advance of the commencement of the works on the
foreshore.
3. The cable shall be installed as detailed in the submitted “Planning Report: February 2015”
unless otherwise approved by the Department of the Environment, Community and Local
Government.
4. The Licensee shall be fully compliant with the requirements set out in the “Guidance to
Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters”
(January 2014) in respect of the cable installation activity on the foreshore.
5. The mitigation measures set out in documented entitled “ Marine and Intertidal Ecological
Impact Assessment for the American-Europe Connect Ltd. trans-Atlantic fibre optic cable
landing in Killala Bay, Co. Mayo (Supplement Appendix to NIS)” dated 16th February 2015
shall be implemented in full
6. A chart and a route position list detailing the “as laid location” of the cable shall be provided
to the Department of the Environment, Community and Local Government on completion of
the works
Dr. Terry McMahon
02 April 2015
INLAND FISHERIES IRELAND
Re: DECLG file ref FS6492 Foreshore Application by America Europe Connect Ltd, for a
lease/licence under the Foreshore Acts for the installation of subsea fibre optic cable at
Ross Beach, Killala, Co. Mayo.
Request for observations from Ms. Ann Banville (DECLG) dated 18.3.2015
Overview:
A predecessor application for foreshore licence from Emerald Networks Ltd. For site
investigations on the site was granted on 8.5.2014 (FS 6280). The current applicant indicates
that these works have been completed.
Can DECLG Foreshore confirm that there is a legal link between the previous application for
site investigations (Emerald networks Ltd.) and the current application (America Europe
Connect Ltd.)?
The works is scheduled to take two weeks, commencing in August 2015
Works plan:
 Pre-lay grapnel run by boat – track to be 1m wide – along the proposed cable-lay
route. Debris clearance and debris disposal to landfill

Trenching on the beach and down to low-water line will be by excavator, with a
target burial depth of 1.5 m. Following cable insertion into trench, backfilling with
parent material will take place immediately and digging of sections will occur within
tidal cycles

Ocean Ground Bed - An ocean ground bed is required on the beach at Ross Village.
The ocean ground bed is a set of electrodes which provides the return path for the
electrical circuit that powers the repeaters (amplifiers) in the submarine cable
system. The ocean ground bed is typically buried at least 2m below beach level. The
plan dimensions of the ground bed will be 6m in length and 1m in width –it is
effectively a 6m long trench and it will be backfilled and reinstated in one tidal cycle –
can the applicant provide some brief clarification on this “Ocean Ground Bed”,
please for IFI. If it is a set of electrodes, is it encased in some way? Are there cables
in- and out- of it and is electric charge being conveyed? Is a 2 m burial depth
adequate to provide safety to the installation and to beach users?

Seaward of low water the cable will be laid on the sea bed and buried to depth via
water jetting

At greater depths – cut-off point not specified – the cable will either (a) be laid on
the sea bed, where burial is not required or (b) be trenched into the seabed via a
plough mechanism
Documentation provided identifies the very low likely levels of impact from the cables in
regard to electrical, heat or magnetic discharges into the aquatic environment and, hence,
potential for adverse impact to aquatic organisms.
IFI comment and observations:
The documentation provided gives a clear picture of the proposed survey methods. IFI
concurs with the outcome of the Appropriate Assessment / Screening process, in regard to
no impact.
The present applicant conferred with IFI in regard to fisheries issues.
The proposed timing of works - April 2015 – was identified by IFI as an important time for
salmon smolt migration to sea and glass eel migration into freshwater. In addition, this time
period would cover the upstream migration of adult sea lamprey, designated for the R. Moy
SAC, into freshwater to spawn.
The timing of proposed cable laying and trenching etc has now been changed to August
2015.
This August timing could also pose some issues for out-migrating adult silver eel. IFI
indicated the importance of dark periods and of flood flows in stimulating the silver eel outmigration. The applicant has indicated the need to lay cable in calm conditions and this
should prevent a clash of interests here.
It was indicated by IFI that: “Consultation and prior notification is required in relation to the
cable lay and Inland Fisheries Ireland. Procedures must be put in place to ensure no damage
or disturbance to vulnerable fish stocks, particularly salmon and eels, results from the
proposed operation. IFI request a copy of these procedures prior to works commencing. IFI
also request one weeks’ notice prior to works commencing on the site.”
James J. King (IFI R&D); John Conneely & Aisling Donegan (IFI Western RBD, Ballina)
Inland Fisheries Ireland
7.4.2015
DEPARTMENT OF AGRICULTRE FOOD AND MARINE
Your Ref: FS 6492
Our Ref: FW/13/12
Re:
Foreshore Licence Application on behalf of America Europe Connect Ltd in respect of the
installation of a subsea fibre optic cable at Ross Beach, Killala, Co. Mayo.
Dear Ann,
Further to your letter dated 18th March 2015, below find observations from this Department.
There are no licenced aquaculture sites along, or adjacent to, the proposed cable route. The nearest
licenced aquaculture site is located circa. 2.5km south of the proposed landfall location at Ross
Village. Given that here are no licenced aquaculture sites along, or adjacent to, the proposed route
for the cable the Department is of the view that the proposed works will have no impact on
aquaculture activity in the area.
There may be some interaction with fishing activity along the proposed cable route during the
installation phase but this will be limited in scale and duration and such interaction will not be
significant.
Given the location, nature and scale of the proposed works the Department is of the view that there
will be no significant impacts on the marine environment in the area and will not interfere with
other legitimate users of the area.
On the basis of the above, the Department has no objection to a licence being granted.
Yours sincerely,
Deirdre O’Flynn
______________________________
Deirdre O’Flynn,
Aquaculture & Foreshore Management Division,
National Seafood Cente,
Clonakilty,
Co Cork.
DEPARTMENT OF ARTS, HERITAGE AND THE GAELTACHT
Re: Foreshore Licence Application by America Europe Connect Ltd in respect of the installation of a
proposed subsea fibre optic cable at Ross Beach, Killala Bay
Archaeology
Underwater Archaeology
Reference is made to the archaeological assessment report submitted to this office relating to the
above proposed development.
The archaeological assessment report for the proposed America-Europe fibre optic cable is totally
inadequate and contains insufficient information for this Department to make an informed decision
regarding the impact of the development on known or potential archaeology. This Department
requests that the following information be supplied in advance of any foreshore licence being
granted.
Section 4.3 of the Marine Archaeological Assessment Report is totally inadequate and the shipwreck
data shall be analysed again in light of the comments below and a report shall be resubmitted to this
department for review. Section 4.3 states that none of the wrecks recorded in the shipwreck
Inventory are “located along the cable route corridor”. This is incorrect and there is the potential for
numerous wrecks to be located along the cable route. The Shipwreck Inventory of Ireland Database
(SIID) lists over 50 wrecks for Killala Bay, any number of which may be located buried beneath the
sand within the cable corridor. Also, the proposed cable route runs through or adjacent to the Killala
Bar where there are several shipwrecks recorded in SIID. The archaeological assessment has failed to
highlight that there is the potential for these wrecks to be located within the cable corridor at the
Killala Bar. It should be noted that all wrecks over 100 years are subject to statutory protection
under section 3 of the National Monuments (Amendment) Act, 1987. Should this development
proceed it is possible that material of archaeological significance may be impacted by the proposed
cable works.
Page 13, section 4.5 of the Marine archaeological assessment states that the depth of sediment is
“not conducive for the preservation of archaeological material”. Further detail is required on the
nature of the sediment cover over the length of the proposed cable route. The interpretation maps
of the geophysical data lists vast areas of loose sand in many places along with mega-ripples in other
areas. Loose sand, mega-ripples and areas of gravel have the potential to contain archaeological
material. If there is evidence that this type of seabed does not have the potential to contain
archaeological material it should be supplied to this office for review. Has there being an assessment
of the sub-bottom data gathered during the geophysical surveys? If so, a copy of this assessment
should be forwarded to this office for review.
The section on the archaeological assessment of the geophysical survey is totally inadequate. This
section shall be resubmitted with the following information:
 A detailed description of the equipment used to carry out each survey, the methodologies
employed to carry the surveys including a list of personnel involved in doing the work.
 High resolution maps showing the track lines of the sidescan, magnetometer, sub-bottom
profiler and bathymetric surveys.
 An overview of the quality of the survey carried out including any gaps in the data and
coverage achieved.




A detailed archaeological assessment and interpretation of each of the datasets and a list of
all anomalies identified along with their locational details, written descriptions and images
where appropriate.
High resolution maps shall be supplied showing the location of the anomalies and the
proposed cable route.
A copy of the archaeological assessment report of the geophysical data and any other
assessment reports on the geophysics.
A copy of all the raw data from the geophysical surveys shall be forwarded to the
Underwater Archaeology Unit for review.
It appears from the geophysical survey interpretation maps that there is a significant shortfall
between the end of the area surveyed for the cable corridor and the high water mark? If this is the
case, details are required as to why this area was not surveyed and why it was not highlighted in the
archaeological assessment that there is a significant gap in the data. Has there being any
archaeological assessment of this area of shortfall? If not, it is required that a geophysical and/or
dive survey, as described below, shall be carried out of this area in advance of the foreshore licence
being granted.
An archaeological assessment of the multibeam data gathered by INFOMAR and the Irish National
Seabed Survey has not been assessed as part of this archaeological assessment. The multibeam data
should be assessed by an archaeologist experienced in marine geophysics and a report should be
submitted to this office for review.
An intertidal and metal detection survey was not carried out of the proposed landfall of the cable. It
is recommended that an intertidal survey and metal detection survey shall be carried out of the
proposed landfall site out to the low water mark. Both surveys shall be licensed under the National
Monuments Acts 1930-2004. These surveys should be carried out in advance of a foreshore licence
being granted.
Intertidal, Metal Detection, Geophysical and Dive Survey shall be carried out as follows;
1. The applicant is required to engage the services of a suitably qualified archaeologist to carry out
an intertidal and metal detection survey of the proposed landfall site. An archaeological dive
assessment and/or geophysical survey shall be carried out of any area of the cable corridor,
which was not assessed during the initial geophysical survey and carried out by suitably qualified
underwater archaeologist.
2. The intertidal, metal detection, geophysical and dive surveys shall be licensed under the
National Monuments Acts 1930-2004
3. Having completed the work, a detailed Underwater Archaeological Impact Assessment (UAIA)
Report shall be submitted to this Department for review as Further Information.
4. Where archaeological material/features are shown to be present, preservation in situ,
avoidance, preservation by record (archaeological excavation) or archaeological monitoring may
be required.
5. The applicant shall be prepared to be advised by the Department of Arts, Heritage & the
Gaeltacht in this regard.
It is recommended that the requested archaeological assessment be carried out in advance of the
foreshore licence being granted. This will enable this Department and the Foreshore Section to
formulate an informed archaeological recommendation before a decision is made with regard to the
granting of the foreshore licence. It shall be borne in mind that, once this Further Information has
been reviewed by this Department, further archaeological mitigation may be required such as more
detailed underwater archaeological assessment, avoidance, preservation by record (archaeological
excavation) or archaeological monitoring. The applicant shall be prepared to be advised by the
Department of Arts, Heritage & the Gaeltacht in this regard.
Officers from this department are available to meet to discuss the above if required.
Nature Conservation
Marine Science and Biodiversity
This Department would recommend that the cable laying operations would be analogous in certain
situations to dredging in terms of noise output. For this reason the mitigating measures proposed in
the circulated Environmental Report must be applied in full. In addition the proponents may find
“Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters”
(available to download from: http://www.npws.ie/marine/bestpracticeguidelines/) a useful
reference.
Le meas
Muiris Ó Conchúir
Manager, Development Applications Unit (DAU)
Bainisteoir, Aonad um Iarratais Forbartha
Department of Arts, Heritage and the Gaeltacht
An Roinn Ealaíon, Oidhreachta agus Gaeltachta
Newtown Road, Wexford
Br an Bhaile Nua, Loch Garman
T: 053-911 7387 (direct/díreach)
Reception/Fáiltiú: 053-911 7500