Location of Sampling Points and the Farragh Proteins Facility at Crossdoney (Copyright Google 2011)

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Location of Lough Oughter and Associated Loughs SAC (Copyright Google 2011)

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Location of Lough Oughter SPA (Copyright Google 2011)

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Location of Lough Oughter and Associated Loughs pNHA (Copyright Google 2011)

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EPA Export 29-03-2012:04:03:16 Appendix 5.2 Biological Water Quality Monitoring Data

Indicator Group Taxon Number Group A 0 (Very sensitive) Absent Group B 4 (Moderately sensitive) Cased Tricoptera (Caddisfly) Limniphilidae 2 Plecoptera (Stonefly) Leuctra 2 Group C 169 (Moderately tolerant) Ephemeroptera (Mayfly) Baetis rhodani 2 Uncased Tricoptera (Caddisfly) Polycentropidae 3 Amphipoda (Shrimp) Gammarus duebeni 101 Diptera (Winged Fly) Chironomidae 31 Tipulidae 3 Coleoptera (Beetles) Elminthidae 13 Halipidae 2 Gastropods (Snails) Viviparus 1 Group D 17 (Very tolerant) Isopoda (Lice) For inspection purposes only. Consent Asellusof copyright aquaticusowner required for any other use. 8

Hirudnea (Leeches) Glossiphonidae 3 Bivalves Sphaeridae 6 Group E (Most tolerant) Absent

Total Abundance 191 Q Value 3-4 Berger-Parker Diversity 1.89

Results from the Biological Water Quality Monitoring of Station 2 (d/s of Farragh Proteins) 27/04/2011

EPA Export 29-03-2012:04:03:16 Appendix 5.3 NPWS Site Synopsis

NPWS Site Synopsis of Lough Oughter And Associated Loughs SAC

Site Code: 000007

Lough Oughter and its associated loughs occupy much of the lowland drumlin belt in north and central Cavan between Upper Lough Erne, Killeshandra and Cavan town. The site is a maze of waterways, islands, small lakes and peninsulas including some 90 inter-drumlin lakes and 14 basins in the course of the Erne River. The area lies on Silurian and Ordovician strata with Carboniferous limestone immediately surrounding.

This site is a candidate Special Area of Conservation for natural eutrophic lakes and bog woodland, two habitats listed on Annex I of the E.U. Habitats Directive and for the otter, a species listed on Annex II of the same Directive. The site also contains areas of dry woodland, marsh, reedbed and wet pasture.

Drainage within the area is inefficient and the water levels prone to natural fluctuation as a result. The regularly flooded areas still accommodate a variety of specialist plant species such as Amphibious Bistort (Polygonum amphibium) and Marsh Foxtail ( Alopecurus geniculatus) , as well as rarer species such as Needle Spike-Rush ( Eleocharis acicularis) and Lesser Marshwort (Apium inundatum) .

The lakes and basins are shallow, and the water well mixed and nutrient rich (eutrophic). The aquatic flora is varied with several pondweed species such as Bluntleaved Pondweed (Potamogeton obtusifolius ), Shining Pondweed ( Potamogeton lucens ), Broad-leaved Pondweed (Potamogeton natans ), Reddish Pondweed ( Potamogeton alpinus ) and Various-leaved Pondweed ( Potamogeton gramineus ). Typical in the zone of aquatic plants are Yellow Water- lily ( Nuphar lutea ), Canadian Pondweed For inspection( Elodea purposes canadensis only. ), Mare’s Tail ( Hippuris vulgaris ), Consent of copyright owner required for any other use. Water Milfoil ( Myriophyllum spicatum ), Brooklime ( Veronica beccabunga ), Water Dropwort (Oenanthe spp .) and Starwort ( Callitriche sp .). The aquatic community includes species of limited distribution in Ireland such as the Duckweed species Lemna gibba and Spirodela polyrhiza.

Around much of the shoreline there are well developed swamp and marsh communities, typically with a zone of Bulrush ( Schoenoplectus lacustris ) in front of a zone of Common Reed (Phragmites australis ) which is in turn backed by a more species rich zone of sedges, grasses and herbs, particularly Bottle Sedge ( Carex rostrata ), Common Sedge ( Carex nigra ), Creeping Bent ( Agrostis stolonifera ), Meadowsweet ( Filipendula ulmaria ), Marsh Helleborine ( Epipactis palustris ), Water Plantain ( Alisma plantago-aquatica ), Rough Horsetail ( Equisetum hyemale ), Water Horsetail ( Equisetum fluviatile) and Wild Angelica ( Angelica sylvestris ). Less widespread species also occur on the wet lake margins; species such as Water Dock ( Rumex hydrolapathum ), Greater Water-parsnip ( Sium latifolium ), Cowbane ( Cicuta virosa ), Tufted Sedge ( Carex elata ), Water Soldier ( Stratioites aloides ), Arrowhead ( Sagittaria sagittifolia ), Flowering Rush (Butomus umbellatus ) and Greater Spearwort ( Ranunculus lingua ) may be locally prominent.

EPA Export 29-03-2012:04:03:16 There are many variations on this typical zonation of sheltered shores with species such as Reedmace (Typha spp.), Branched Bur-Reed ( Sparganium erectum) and Reed Canary-grass (Phalaris arundinacea ) gaining local prominence. More exposed shores lack the extensive swamp zones, here smaller species such as Common Spike Rush ( Eleocharis palustris ) can be found.

Level, wet pastures tend to be dominated by Creeping Bent ( Agrostis stolonifera) and Rush species ( Juncus sp .) with a scattering of marshland and wet grassland plants such as Marsh Marigold ( Caltha palustris), Water Forget-me-not (Myosotis scorpiodes) and Yellow Iris ( Iris pseudacorus). Soft Rush ( Juncus effusus) is most abundant with frequent Hard Rush ( Juncus inflexus ) and Sharp-Flowered Rush ( Juncus acutiflorus) and less widespread Conglomerate Rush (Juncus conglomeratus ) also occurring .

Where a general lack of grazing pressure or a particular slope has allowed it, deciduous woodland has re-established itself behind the reedbeds. Two species of Willow ( Salix caprea and Salix cinerea ) are common constituents along with Alder ( Alnus glutinosa ), Downy Birch (Betula pubescens ), Hazel ( Corylus avellana ) and Hawthorn ( Crataegus monogyna ). Along submerged margins Alder and Willow are most commonly found with a flooded understorey typically containing Reed Canarygrass, Meadow Sweet, Yellow Flag and in places Tufted Sedge (Carex elata ) and Greater Tussock Sedge ( Carex paniculata ). Downy Birch occurs along lake edges and also forms stands of wet woodland on cutover bog with varying degrees of wet and dry peat. Purple Moor-grass ( Molinia caerulea), Marsh Cinquefoil ( Potentilla palustris) and Bog Moss ( Sphagnum sp.) occur in areas with pools and dry areas . Where there is dry peat, Bracken (Pteridium aquilinum ), Bramble ( Rubus fruticosus agg.) and Gorse ( Ulex sp.) occur under the Birch canopy. Birch dominated wood is also found in association with Ling Heather ( Calluna vulgaris ) bog.

In areas of wet bog with good Sphagnum cover, bog woodland has developed. Downy Birch

characterises this habitat; other typical species For inspection include purposes only. Purple Moor-grass ( Molinia caerulea ) and Consent of copyright owner required for any other use. Bottle Sedge ( Carex rostrata ).

Dry broad-leaved woodland is characterised by Ash (Fraxinus excelsior ), Hazel, Holly ( Ilex aquifolium) and Oak ( Quercus spp. ), while shrubs include Blackthorn ( Prunus spinosa ), Spindle (Euonymus europaeus) and Guelder Rose ( Viburnum opulus ). The Red Data Book species Bird Cherry ( Prunus padus ) has also been recorded from the site. The clayey soils have a characteristic flora, including Wood Avens ( Geum urbanum), Wood Sorrel ( Oxalis acetosella ), Primrose ( Primula vulgaris ), Herb Robert (G eranium robertianum ) and Wood Sedge ( Carex sylvatica).

The site supports a substantial population of water birds including internationally important numbers of Whooper Swan (average peak 231) and nationally important numbers of Tufted Duck (average peak 247) and Cormorant (average peak 130) as well as important numbers of species such as Greenland White-fronted Goose, Great Crested Grebe, Wigeon, Teal and Pochard. Lapwing, Snipe and Golden Plover also utilise the wet grassland areas. Wildfowl Sanctuaries exist at Inchin Lough, Derrygid Lough, Farnham Lough, Derrybrick Lough,

EPA Export 29-03-2012:04:03:16 Derrinishbeg Lough and Annagh Lough. Part of the site is designated an SPA under the EU Birds Directive.

Otter, a species listed on Annex II of the E.U. Habitats Directive occurs at the site. Irish Hare has also been recorded. Both of these species are listed in the Irish Red Data Book and are legally protected under the Wildlife Act 1976.

The main threats to the quality of the site are water polluting activities such as run-off from fertiliser and slurry application and sewage discharge which have raised the nutrient status of some lakes to hypertrophic. Housing and boating developments are on the increase, adjacent to and within the site respectively. There is also significant fishing and shooting pressure on and around the lakes. Increased afforestation has resulted in some loss of wetland habitat and also loss of feeding ground for wintering birds such as Greenland White-fronted Geese.

The Lough Oughter area contains important examples of two habitats listed on Annex I of the E.U. Habitats Directive and supports a population of the Annex II species, otter. The site as a whole is the best inland example of a flooded drumlin landscape in Ireland and has many rich and varied biological communities. Nowhere else in the country does such an intimate mixture of land and water occur over a comparable area, and many of the species of wetland plants, some considered quite commonplace in Lough Oughter and its associated loughs, are infrequent elsewhere.

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EPA Export 29-03-2012:04:03:16 SITE NAME: LOUGH OUGHTER SPA

SITE CODE: 004049

Lough Oughter is a medium-sized lake that extends over a wide area. Its situation in submerged drumlin country accounts for the extremely ramified nature of its basin. The main feeders to the lake are the River Erne and the Annalee River. These flow over relatively insoluble rock (Ordovician and Silurian strata) so that the lake water is only moderately hard, despite the fact that most of the immediate surroundings are of Carboniferous limestone. Lough Oughter is a shallow lake (maximum depth 10 m) and is considered to be a naturally eutrophic system. Since the 1970s the lake has, however, shown clear signs of organic enrichment and has most recently been classified as being hypertrophic (though chlorophyll levels have dropped markedly in recent years).

The lakes have a well-developed aquatic flora, with a range of pondweeds ( Potamogeton spp.) and such species as Yellow Water-lily ( Nuphar lutea ), Canadian Pondweed ( Elodea canadensis ), Mare’s-tail ( Hippuris vulgaris ), Spiked Water-milfoil ( Myriophyllum spicatum ) and Water- starwort ( Callitriche sp.). The aquatic community includes species of limited distribution in Ireland such as the duckweeds, Fat Duckweed ( Lemna gibba ) and Greater Duckweed ( Spirodela polyrhiza ). Around much of the shoreline there are well developed swamp and marsh communities, typically with a zone of Common Clubrush ( Scirpus lacustris ) in front of a zone of Common Reed ( Phragmites australis ) which is in turn backed by a more species-rich zone of sedges, grasses and herbs. In places, wet woodland is well-developed at the lake margins. This is mainly of willows ( Salix caprea and S. cinerea ), along with Alder ( Alnus glutinosa ), Downy Birch ( Betula pubescens ) and Hazel ( Corylus avellana ).

Lough Oughter is of importance for a range of wintering waterfowl. Of particular note is an internationally important population of Whooper Swan (302) that is based in the area and which

uses the lakes as a roost - all figures are For inspection average purposes peaks only. for the 5 seasons 1995/96-1999/00. A Consent of copyright owner required for any other use. population of Greenland White-fronted Goose (67) of regional importance also roosts on the lakes and feeds mainly on nearby improved grassland. The site supports nationally important wintering populations of four species, i.e. Great Crested Grebe (92), Mute Swan (128), Wigeon (910) and Goldeneye (123). Other species which occur regularly include Teal (225), Mallard (341), Pochard (60), Tufted Duck (160), Lapwing (523), Curlew (95), Little Grebe (9), Cormorant (83) and Black-headed Gull (357).

Lough Oughter is at the centre of the breeding range of the Great Crested Grebe in Ireland and the site supports in excess of 10% of the estimated national breeding total (115 individuals in 1986-88). A small colony of Common Tern occurs, with 10 pairs on Farnham Lough in 1995.

Otter, a species that is listed on Annex II of the E.U. Habitats Directive, occurs at the site.

Lough Oughter is a very nutrient-enriched lake and numbers of wintering wildfowl, especially diving duck, are likely to be depressed due to the enriched conditions. Water pollution is likely to remain a problem in the near future. Recreational and wildfowling activities currently cause some disturbance to the birds and any increase in such activities would be of concern. Increased

EPA Export 29-03-2012:04:03:16 afforestation in surrounding areas could result in the loss of feeding habitat for wintering birds such as Whooper Swan and Greenland White-fronted Goose.

The Lough Oughter SPA is of importance for both wintering and breeding birds. Of particular note is the internationally important population of Whooper Swan that is based in the area. The site also supports nationally important populations of a further four wintering species. The site is of especial importance for one of the highest breeding concentrations of Great Crested Grebe in the country. Of note is that three of the species which occur regularly are listed on Annex I of the E.U. Birds Directive, i.e. Whooper Swan, Greenland White-fronted Goose and Common Tern.

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EPA Export 29-03-2012:04:03:16

Whitehill Environmental

Noreen McLoughlin, MSc Environmental Consultant Whitehill Edgeworthstown Co. Longford [email protected] (087) 4127248 / (043) 6672775

FARRAGH PROTEINS

A STAGE 1 SCREENING REPORT TO INFORM THE APPROPRIATE ASSESSMENT

IN LINE W ITH THE REQUIREMENTS OF ART ICLE 6(3) OF THE EU HABITATS DIRECTIVE

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Prepared on Behalf of

Farragh Proteins Crossdoney Co. Cavan

June 2011

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TABLE OF CONTENTS

TABLE OF CONTENTS ______II 1 INTRODUCTION ______1 1.1 Background ...... 1 1.2 Regulatory Context ...... 4 2 METHODOLOGY ______7 2.1 Desktop Consultation ...... 7 2.2 Appropriate Assessment ...... 7 2.3 Field Based Studies ...... 10 3 RECEIVING ENVIRONMENT ______12 3.1 The River Erne ...... 12 3.2 Receiving Water Quality ...... 12 4 SCREENING ______15 4.1 Description of The Proposed Project ...... 15 4.2 Identification of Natura 2000 Sites Potentially Affected ...... 18 4.3 Identification of Potential Impacts and Effects ...... 21 4.4 Mitigation Measures ...... 23 4.5 Overall Assessment ...... 24 4.6 Finding of No Significant Effects ...... 25 APPENDIX I WATER QUALITY DATA ______27 APPENDIX II NPWS SITE SYNOPSIS ______28 APPENDIX III REFERENCES & FURTHER READING ______33

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1 INTRODUCTION

1.1 BACKGROUND This report is an Appropriate Assessment Screening (Stage 1 AA) of the proposed developments at Farragh Proteins, Crossdoney, Co. Cavan was undertaken by Consultant Ecologist Noreen McLoughlin, MSc of Whitehill Environmental. This report assesses the likely impacts, if any, of the current and future activities of Farragh Proteins on areas that have been designated under the EU Habitats and Birds Directions (the Natura 2000 network). Effects upon both habitats and species are considered.

This screening process is in accordance with the requirements of the EU Habitats Directive (Directive 92/43/EC).

The EPA Circular L8/08 includes a screening methodology in the form of a flow diagram for determining whether an Appropriate Assessment should be undertaken for works involving water services projects. This flow diagram was followed and based on the location of the waste water treatment plant at Crossdoney, it was determined that an Appropriate Assessment was necessary. This methodology and the steps taken in following this flow diagram are illustrated in Figures 1 and 2.

This report should be read along with Chapter 5 of the EIS – Flora and Fauna.

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Figure 1 – Circular L8/08 Screening Flowchart

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1. Is the development in a nature conservation site?

2a. (If the development involves a surface water abstraction/discharge:) Is the development in the surface water catchment of a nature conservation site (or part of such a site)?

Yes – Lough Oughter and Associated Loughs SAC, SPA, pNHA

3. Are the qualifying habitats and species of the site water dependent?

Yes

5. Is there a WFD sub-basin plan for the site or its protected habitats/species?

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ASSESS IMPACTS – APPROPRIATE ASSSESSMENT MUST BE CARRIED OUT

Figure 2 – Flow Diagram for the Farragh Proteins Application, based on the L8 / 08 Circular

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1.2 REGULATORY CONTEXT 1.2.1 Relevant Legalisation The Birds Directive (Council Directive 79/409/EEC) implies that particular protection is given to sites (Special Protection Areas) which support certain bird species listed in Annex I of the Directive and that surveys of development sites should consider the status of such species.

The EU Habitats Directive (92/43/EEC) gives protection to sites (Special Areas of Conservation) which support particular habitats and species listed in annexes to this directive. Articles 6(3) and 6(4) of this Directive call for the undertaking of an Appropriate Assessment for plans and projects likely to have an effect on designated sites. This is explained in greater detail in the following section.

The Wildlife Act 1976 (and its amendment of 2000) provides protection to most wild birds and animals. Interference with such species can only occur under licence. Under the act it is an offence to “wilfully interfere with or destroy the breeding place or resting place of any protected wild animal”. The basic designation for wildlife is the Natural Heritage Area (NHA). This is an area considered important for the habitats present or which holds species of plants and animals whose habitat needs protection. Under the Wildlife Amendment Act (2000) NHA’s are legally protected from damage.

The Water Framework Directive (WFD) (2000/60/EC), which came into force in December 2000, establishes a framework for community action in the field of water policy. The WFD was transposed into Irish law by the European Communities (Water Policy) Regulations 2003 (S.I. 722 of 2003). The WFD rationalises and updates existing legislation and provides for water management on the basis of River Basin Districts (RBDs). RBDs are essentially administrative areas for coordinated water management and are comprised of multiple river basins (or catchments), with cross-border For inspection basins purposes (i only..e. those covering the territory of more than Consent of copyright owner required for any other use. one Member State) assigned to an international RBD. The aim of the WFD is to ensure that waters achieve at least good status by 2015 and that status doesn’t deteriorate in any waters. The definition of good status has been set out in the Surface Water Regulations 2009 (S.I. 272/2009).

1.2.2 Appropriate Assessment and the Habitats Directive Directive 92/43/EEC on the Conservation of Natural Habitats and Wild Fauna and Flora – the ‘Habitats Directive’ - provides legal protection for habitats and species of European importance. Article 2 of the Directive requires the maintenance or restoration of habitats and species of European Community interest, at a favourable conservation status. Articles 3 - 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as Natura 2000 . Natura 2000 sites are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Conservation of Wild Birds Directive (79/409/EEC).

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Articles 6(3) and 6(4) of the Habitats Directive sets out the decision-making tests for plans or projects affecting Natura 2000 sites. Article 6(3) establishes the requirement for Appropriate Assessment:

“Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.”

Article 6(4) deals with the steps that should be taken when it is determined, as a result of appropriate assessment, that a plan/project will adversely affect a European site. Issues dealing with alternative solutions, imperative reasons of overriding public interest and compensatory measures need to be addressed in this case.

Article 6(4) states:

“If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member States shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, For inspection purposes only. Consent of copyright owner required for any other use. to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.”

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1.2.3 The Appropriate Assessment Process The aim of the Appropriate Assessment process is to assess the implications of the proposal in respect of a site’s conservation objectives.

Appropriate Assessment is an assessment of the potential effects of a proposed plan - ‘in combination’ with other plans and projects - on one or more European sites. The ‘Appropriate Assessment’ itself is a statement which must be made by the competent authority which says whether the plan affects the integrity of a European site. The actual process of determining whether or not the plan will affect the site is also commonly referred to as ‘Appropriate Assessment’.

If adverse impacts on the site cannot be avoided, then mitigation measures should be applied during the Appropriate Assessment process to the point where no adverse impacts on the site remain (European Commission, 2000, 2001).

The conclusions of the appropriate assessment report should enable the competent authority to ascertain whether the proposal would adversely affect the integrity of the site (European Commission, 2000, 2001).

Under the terms of the directive (European Commission, 2000, 2001), consent can only be granted for a project if, as a result of the appropriate assessment either (a) it is concluded that the integrity of the site will not be adversely affected, or (b) where an adverse effect is anticipated, there is shown to be an absence of alternative solutions, and there exists imperative reasons of overriding public interest for the project should go ahead.

The competent authority is required to complete the Appropriate Assessment in consultation with the National Parks and Wildlife Service (NPWS).

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2 METHODOLOGY

2.1 DESKTOP CONSULTATION A review of areas designated (or being considered for designation) for nature conservation was carried out by consulting the website of the National Parks and Wildlife Service (NPWS). These included Special Areas of Conservation, Special Protection Areas for birds (both internationally important) and proposed Natural Heritage Areas (of national importance). Technical files and previous reports prepared by Farragh Proteins as part of their IPPC Licence (2007) were also reviewed as part of the current assessment. These included the IPPC application document and supporting information such as maps and discharge locations and emission parameters. A range of additional sources of information including scientific reports produced by, and information on the websites of the EPA, NPWS, National Biodiversity Data Centre, Cavan County Council and other agencies were also reviewed and a consultation letter was sent to the NPWS regional office. A full bibliography of information sources reviewed is given in the references section. Ordinance Survey Maps and OS aerial photographs were also reviewed during the desk assessment.

2.2 APPROPRIATE ASSESSMENT This report has been prepared with reference to the following documents:

• Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6 (3) and (4) of the Habitats Directive 92/43/EC (European Communities, 2002);

• Managing Natura 2000 sites: the provisions of Article of the ‘Habitats Directive’ 92/43/EC;

• Circular L8/08 ‘Water Services For inspection Investment purposes only. and Rural Water Programmes – Protection Consent of copyright owner required for any other use. of Natural Heritage and National Monuments’ Department of Environment, Heritage and Local Government, 2008 (See Figure 1) ; and

• Notes on Appropriate Assessment for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. 684 of 2007) Environmental Protection Agency ( www.epa.ie ).

The EC Guidance sets out a number of principles as to how to approach decision making during the process. The primary one is ‘the precautionary principle’ which requires that the conservation objectives of Natura 2000 should prevail where there is uncertainty.

When considering the precautionary principle, the emphasis for assessment should be on objectively demonstrating with supporting evidence that:

There will be no significant effects on a Natura 2000 site;

There will be no adverse effects on the integrity of a Natura 2000 site;

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There is an absence of alternatives to the project or plan that is likely to have an adverse effect to the integrity of a Natura 2000 site; and

There are compensation measures that maintain or enhance the overall coherence of Natura 2000.

This translates into a four stage process to assess the impacts, on a designated site or species, of a policy or proposal.

The EC Guidance states that “each stage determines whether a further stage in the process is required”. Consequently, the Council may not need to proceed through all four stages in undertaking the Appropriate Assessment.

The four stage process is:

1. Stage 1 - Screening

2. Stage 2 - Appropriate Assessment

3. Stage 3 - Assessment of alternative solutions

4. Stage 4 - Assessment where no alternative solutions exist and where adverse impacts remain (i.e. Compensatory Measures)

In complying with the obligations set out in Articles 6(3) and following the guidelines described above, this appropriate assessment has been structured as a stage by stage approach as follows:

1. Screening Stage

• Description of the proposed project. For inspection purposes only. Consent of copyright owner required for any other use.

• Identification of the Natura 2000 sites potentially affected.

• Identification and description of individual and cumulative impacts likely to result from the project.

• Assessment of the significance of the impacts identified above on site integrity. Exclusion of sites where it can be objectively concluded that there will be no significant effects.

2. Appropriate Assessment Stage

Appropriate Assessment should address the potential of the project to adversely affect the integrity of the site, with respect to its conservation objectives. An adverse effect on integrity is likely to be one that prevents the site from making the same contribution to favourable conservation status for the relevant features as it did at the time of designation.

‘Integrity’ is defined by the European Commission (2000) as relating to the reasons for the site’s designation:

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“The integrity of a site is the coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and / or populations of species for which the site is or will be classified”

Assessment of the effects of the project on the integrity of the site follows the following steps:

Describe the proposed plan/project;

Collate information about the European Site and set out the conservation objectives of the site;

Describe how the project or plan, in combination with other projects/plans, will affect the European Site, its key species and key habitat, and how the overall integrity of the site is likely to be affected; and

Describe what mitigation measures are to be introduced to avoid or reduce the adverse effects on the integrity of the site. Acknowledge uncertainties and any gaps in information.

The Habitats Directive promotes a hierarchy of avoidance, mitigation and compensatory measures. First the project should aim to avoid any negative impacts on European sites by identifying possible impacts early in the planning stage and designing the project in order to avoid such impacts. Second, mitigation measures should be applied if necessary during the appropriate assessment process to the point where no adverse impacts on the site remain. If the project is still likely to result in adverse effects and no further practicable mitigation is possible, then it is rejected. If no alternative solutions are identified and the project is required for imperative reasons of overriding public interest under Article 6(4) of the Habitats Directive. Then compensation measures are required for any remaining adverse effects.

For inspection purposes only. 3. Identifying AlternativeConsent Solutions of copyright owner required for any other use.

This stage examines alternative ways of implementing the project or plan that, where possible, avoid any adverse impacts on the integrity of the Natura 2000 site.

4. When there are No Alternative Solutions

For sites that host priority habitats and species, it is necessary to consider whether or not there are human health or safety considerations or environmental benefits flowing from the project or plan. If such considerations do exist, then it will be necessary to carry out the Stage Four assessments of compensatory measures. If no such considerations exist, then establish whether there are other imperative reasons of overriding public interest (IROPI) before carrying out the Stage Four assessments. Where IROPI exist, an assessment to consider whether compensatory measures will or will not effectively offset the damage to the site will be necessary before the project or plan can proceed.

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2.3 FIELD BASED STUDIES 2.3.1 Water Quality Sampling Biological water quality assessment was carried out at one location on the River Erne and this was downstream of the Farragh Proteins effluent discharge point. Information on the biological water quality upstream of the facility was obtained from recent EPA data (Bellahillan Bridge 2010). The locations of both sampling locations are shown in Table 1 and illustrated in Figure 3.

Station No. Location NGR Location 1 (EPA) ~1k m u/s of discharge H 3556 0152 2 ~ 700m d/s of discharge H 3584 0269 Discharge Point H 3609 0229 Table 1 – Stations Sampled as Part of this Assessment Fieldwork including biological sampling was carried out on 27 th April 2011. Weather conditions on this day were dry, calm and sunny.

The sample at Station No. 2 was taken with a Freshwater Biological Association approved hand held sweep net with a mesh diameter of 500 µm. The normal protocol for a biological water quality sample is to take a two minute kick sample and stone wash from a suitable riffle site. However, there were no suitable riffle sites found on any section of the Erne downstream of Farragh Proteins and at all points observed it was deep and slow with a high deposition of silt along the banks. Instead of the standard kick sample a sweep sample was taken along the bank. The sample was retained in plastic containers at the sampling site. Mud and debris were removed from each sample by sieving under running water through a 500 µm sieve. The samples were then live sorted for a period of 30 minutes in a white tray under a bench lamp. All macro-invertebrates were counted and identified to the appropriate taxonomic level. Based on the relative For inspection abundance purposes only. of indicator species, a biotic index (Q Consent of copyright owner required for any other use. rating) was determined for the sites in accordance with the biological assessment procedure used by the Environmental Protection Agency. However, as the conditions of the river were not suitable to a proper Q assessment, it should be kept in mind that the Q rating obtained is not a true reflection of the ecological status of the river.

In addition to the biological rating, a simple diversity index called the Berger-Parker Diversity Index was calculated for each site. This index has the formulae

D = N max / N

Where N max is the number of individuals of the most abundant taxon and N is the total abundance of all individuals in the sample. With this diversity index, the value decreases with increased diversity. The reciprocal is therefore used so that an increase in the value of the index accompanies an increase in measured diversity.

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Figure 3 – Location of Sampling Points and the Farragh Proteins Facility at Crossdoney (copyright Google Maps)

For inspection purposes only. Consent of copyright owner required for any other use.

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3 RECEIVING ENVIRONMENT

Farragh Proteins is located in the townland of Monery Upper, Crossdoney, Co. Cavan. It is located approximately 2km north-west of Crossdoney village, on a local road that is just off the Ballananagh to Killeshandra Road. The rendering plant is situated adjacent to the River Erne on predominately soil of gley origin. The surrounding land is mostly agricultural and there are many drains running through the land towards the River Erne.

3.1 THE RIVER ERNE The River Erne rises in Beaghy Lough, two miles south of Stradone in County Cavan and it flows for 64 miles through Lough Gowna, Lough Oughter and Upper and Lower Lough Erne to the sea at Ballyshannon, County Donegal. For 30 miles it is difficult to distinguish the river as it meanders its way through interconnected lakes nestling among the drumlin hills of Cavan and south Fermanagh. The river is 120 kilometres long and is very popular for fly fishing for trout and salmon, with a number of fisheries along both the river itself and its tributaries (Source: www.irelandflyfishing.com).

The site of the proposed development is adjacent to the River Erne, at a point where the river is approximately 10 metres wide. At this point it is extremely deep and slow flowing. The River Erne at this location is designated as a proposed Natural Heritage Area (Lough Oughter and Associated Loughs, pNHA 000007) and a Special Protection Area (SPA 004049). Approximately 200 meters downstream of the proposed development site, the River Erne is also designated as a Special Area of Conservation (SAC 000007).

3.2 RECEIVING WATER QUALITY 3.2.1 Biological Water Quality Monitoring The EPA have been monitoring the biological water quality of the River Erne at Bellahillan Bridge since 1971. When monitoring For inspection commenced, purposes only. ecological status of the river at this point Consent of copyright owner required for any other use. was high (Q5) and between then and 2004, water quality at this station fluctuated between good and high ecological status. In the 2007 and 2010 results, water quality had decreased to a Q3-4, i.e., moderate status. This status falls below the requirements of the EU Water Framework Directive.

The results from the biological water quality monitoring of the EPA at Bellahillan Bridge and from the sample taken as part of this assessment are summarised in Table 2. These are described in the paragraphs below whilst a full list of the species found is presented in Appendix I.

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Station Location Q Rating Status No.1 ~ 1km u/s of discharge Q3-4 Moderate 2 ~ 700m d/s of discharge Q3-4 Moderate

Table 2 – Summary of Findings of the Biological Water Quality Assessment

Results taken as part of this assessment indicated that there seems to be no deterioration in ecological status of the River Erne downstream of the Farragh Proteins WWTP discharge point.

The sample from station 2 (downstream) was dominated by the water louse Asellus aquaticus, a group D organism which is fairly tolerant of organic pollution. However, overall Group C taxa dominated the sample and these organisms are more sensitive to organic pollution. Group C taxa recorded included the water shrimp Gammarus, gastropods from the Ancyclidae and Hydrobidae families, midge larve from the Chironomidae and mayflies from the Ecdyonuridae and Caenidae families. Group B taxa (relatively sensitive to organic pollution) were also represented in small numbers by cased caddis larvae from the Limniphilidae and Glossosomatidae families. Given the relative abundance of the indicator species and bearing in mind the sampling methodology used and the conditions of the river, a Q rating of 3-4 was assigned to this point of the River Erne. A full list of results from this sample is given in Appendix I.

According to the Water Matters website ( www.wfdireland.ie ), the website which relates information pertaining to the implementation of the Water Framework Directive in Ireland, the section of the River Erne (IE_NW_36_1746) within the area of interest to this study is categorised as being at risk with an overall objective of restoring it to good status by the year 2121. The overall Q status for this section of the river has been described as moderate and For inspection purposes only. this fits in with the findings Consentof this of copyrightstudy. owner The required general for any physio-chemicalother use. status of the river in this section is classed as good. Overall, models and research suggest that this section of the River Erne is most at risk from diffuse rather than point sources. In line with the European Communities Environmental Objectives (Surface Waters) Regulations 2009 (S.I. no. 272 of 2009) measures to restore this river to good status will have to be given effect by December 2015.

3.2.2 Assimilative Capacity As part of the current application, Rowan Engineering Consultants were contracted to carry out a waste assimilative capacity (WAC) study on behalf of Farragh Proteins on the River Erne adjacent to their Wastewater Treatment This WAC was carried out in accordance with the following legislation and guidelines:

• WSTG – ‘Guidance to Application for a Licences to Discharge to Surface Waters’

• European Communities Environmental Objectives (Surface Waters) Regulations 2009

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The analysis carried out on the River Erne consisted of a combination of samples and analysis by the EPA, Cavan County Council and Rowan Engineering Consultants Ltd. It determined to identify the potential effects that discharge from the facility could have on the water quality of the River Erne.

The waste assimilative capacity of a river at any particular location may be defined as the maximum quantity of waste water which may be discharged under set conditions of river flow that does not lead to any significant decrease in water quality and which does not harm aquatic life or humans who consume the water.

The assimilative capacity of rivers can be calculated to determine if the river can absorb the wastewater discharge and still comply with relevant legislation and water quality objectives. The parameters that were used when calculating the assimilative capacity of the River Erne as part of this study included biological oxygen demand (BOD), ammonia and ortho-phosphate..

Assimilative capacity calculations are based on mass balance, which looks at the natural self- purification capacity of a stream/river to assimilative a waste discharge. Based on the calculations, the total amount of waste water (and quality) which can be discharged into receiving waters without deteriorating the existing/future water quality can be determined.

-1 The Waste Assimilative Capacity for BOD (WAC) = (C max -Cback ) x F 95 x86.4 kg BOD day

Where C max = Maximum permissible concentration

Cback = Background concentration (upstream) th 3 F95 = 95 percentile flow (m /s)

86.4 = Conversion Factor

For inspection purposes only. Consent of copyright owner required for any other use. (Gray, N. 2005)

Therefore, the parameters required for this assessment include the flow rate of the river, the discharge flow rate from the wastewater treatment plant into the river, the concentration of the parameter in the discharge and the current water quality parameters from upstream of the proposed point of discharge.

Rowan Engineering Consultants Ltd has calculated the assimilative capacity of the River Erne for BOD, ortho-phosphate and ammonia. These calculations showed that the proposed effluent to be discharged from the Farragh Proteins WWTP is within the assimilative capacities for all the above parameters. Therefore, the impact upon the River Erne from this discharge would be negligible.

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4 SCREENING

4.1 DESCRIPTION OF THE PROPOSED PROJECT The processing of animal by-products commenced at the site of Farragh Proteins in Crossdoney, Co. Cavan in c.1951. It has been licensed by the EPA as a Category 3 (low risk) meat rendering plant since 2004 (Licence Reg. No. P0025-04 ) and since then it has been collecting and processing raw material derived from this category. The facility operates 24 hours a day, 6 days a week.

Buildings on site include a production area, loading area, raw material intake area, a boiler house, housing for the thermal oxidisation unit, laboratory building, changing area, work shop with stores area, a canteen and the main office block. The entire factory is within a bunded area.

Since January 2005 there has been substantial investment on the site. The facility has been upgraded to become a modern production plant, which has incorporated the best technology available into each operation on the site. This saw the implementation of a more energy efficient production system and improvements in pollution abatement systems.

Production process requires the operation of on-site services including:

• The waste water treatment system

• The thermal oxidiser and steam boiler

• The biofilter odour abatement system

Farragh Proteins has recently expressed their intention to apply for planning permission to Cavan County Council for the developments described below at their facility at Crossdoney. For inspection purposes only. Consent of copyright owner required for any other use. Description of Proposed Development

The new upgraded plant will be located within the confines of the existing site (2.4 HA). The proposed site layout plan is included in Appendix 2.1. There will be modest infrastructure change to the existing facility given that the fact the plant has existing capacity for 125,000 MT per annum. The upgraded rendering plant is designed to incorporate the latest in technologies to maximise efficiencies in environmental protection, energy, water, handling and waste management. It is proposed to increase the capacity at Farragh Proteins from 78,840 MT/annum to 125,000 MT annually.

Farragh Proteins are seeking planning permission from Cavan County Council for the following:

1. To increase in the raw material intake tonnage from 216 MT/day (existing EPA licence condition) to 125,000 MT per annum.

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2. Process modification to wet rendering on the CAT 3 line. – ‘DAFF Method 7’ and to

install an evaporator on the CAT 3 line to reduce fuel consumption and CO 2 emissions.

3. To replace 2 No. existing boilers with a single boiler.

4. To install two new bio-filters (No. 4 and No. 5).

5. To increase final treated effluent volume from 240m3/day to 340m 3/day and to construct an additional aeration and balance tank to meet proposed Emission Limit Values for the final treated effluent.

Rationale for The Proposed Development

1. An increase in the raw material intake tonnage from 216 MT/day (EPA licence condition) to 125,000 MT per annum

Due to the nature of the rendering business it is difficult to negotiate raw material intake on a daily intake figure (current IPPC licence max of 216 MT/day). Farragh Proteins operate around their customers from which they receive raw material from e.g. they have to remove the trailers from the slaughter houses when they are full and bring them to be processed. Some customer plants may have more material to be collected on one day than another. The rationale for the proposed increase in intake tonnage includes:

• The plant has the current capacity to accept and process 125,000MT of raw material per annum;

• Economies of scale will result in efficiencies and increased competitiveness and will assist in ensuring the economic viability of the existing plant;

For inspection purposes only. • Consent of copyright owner required for any other use. Assist in sustaining the business and allied industries in the area and assist in reducing transport costs and associated emission for agri-food sector;

• The proposed development will secure and create jobs in the area.

2. Process modification to wet rendering on Cat 3 line & installation of an evaporator on the Cat 3 line

Farragh proteins are driving to improve its efficiency by introducing a wet rendering process on the Category 3 line. The advantages of wet rendering are improving efficiency and environmental impacts of the process. It involves more gentle rendering as the oil and water are removed pre the drying process. This prevents high volatile fats beings created which cause odour. The reduced energy requirements in the dryers reduce fuel (40%) and CO 2 emissions. This process also retains quality enhancement of the products. There will be also reduced nutrient loading of the WWTP as the condensate produced by the evaporator will be a better quality (weaker influent for the WWTP), however the volume of condensate will increase. The move to wet rendering will guarantee the production of quality meals and oils.

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As part of the upgrading existing high pressure presses and decanters will be decommissioned in the main process building.

3. Replace 2 No. existing boilers with a single boiler.

It is proposed to upgrade the existing steam generation plant by replacing the existing 2 No. boilers with a single larger capacity high efficiency boiler. The proposed boiler will be situated adjacent to the front of the main process building. The proposed new boiler will be used as abatement for the treatment for the non condensable gases generated in the plant when the thermal oxidiser is down.

The benefits of this proposal include:

• Improved efficiency of fuel usage;

• Better control on steam production;

• Better quality steam will be produced;

• The replacement of 2 No. fuel handling systems with a single system;

• Replace 2 No. boiler emission points with a single emission point;

• Reduced CO 2 emissions.

The existing boilers will be decommissioned and sold.

4. To install two new biofilters (No. 4 and No. 5)

It is proposed to increase the volume of air extracted from the process building by the construction of an additional biofilter For inspection (No. purposes 4). Thonly.is additional biofilter will be capable of 3 Consent of copyright owner required for any other use. treating 40,000 m /hr of process air. Furthermore, it is proposed to construct an additional biofilter (No. 5) for the proposed new balance tank at the WWTP. The biofilter (No. 5) will capable of treating 10,000 m 3/hr of air from the new balance tank.

5. To increase final treated effluent volume from 240m3/day to 340m 3/day and install an additional aeration tank at the WWTP

As result of the above process change air emissions will be condensed increasing the quantity of liquid effluent from 240m 3/day to 340m 3/day which will be transferred to the WWTP. It should be noted that the nutrient loading of the condensate will be lower than the existing effluent. The extra effluent produced will be compensated by reduced CO 2 emissions and fuel saving (c. 40%).

It is intended to install an additional aeration tank and Balance Tank (each 1,000 m 3) at the existing WWTP. These are to be installed to ensure that there is sufficient aeration and storage capacity for the additional condensate. The new tanks will also ensure that the proposed Emission Limit Values for the proposed treated effluent are met. More details are provided in Chapter 7 of the EIS (Water).

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4.2 IDENTIFICATION OF NATURA 2000 SITES POTENTIALLY AFFECTED It was concluded that there would be only one Natura 2000 site (although it has three separate designations) potentially affected by the proposed development at Farragh Proteins. This site is Lough Oughter and Associated Loughs and it is designated as a Special Area of Conservation (SAC) and Special Protection Area (SPA). It is also a proposed Natural Heritage Area (pNHA). The boundaries of the SAC and the SPA differ in this area and a summary of the information is presented in Table 3. Information in relation to the boundary of the proposed Natural Heritage Area (pNHA) is also presented. Maps of these designated areas in relation to the Farragh Proteins Facility are illustrated in Figures 4, 5 and 6.

Site Code Designation Closest Location to Development Site

00007 SAC 165m downstream of the WWTP discharge point

004049 SPA Adjacent to the Proposed Development Site

000007 pNHA Adjacent to the Proposed Development Site

Table 3 - Summary of the Natura 2000 Location Information Lough Oughter and Associated Loughs SAC occupy much of the lowland drumlin belt in north and central Cavan between Upper Lough Erne, Killeshandra and Cavan town. The site is a maze of waterways, islands, small lakes and peninsulas including some 90 inter-drumlin lakes and 14 basins in the course of the Erne River. The site has been designated for the protection of natural eutrophic lakes and bog woodland, two habitats listed in Annex I of the E.U. Habitats Directive. In addition, the site contains areas of dry woodland, marsh, reedbed and wet pasture. The full NPWS site description for this SAC can be read in Appendix II.

The NPWS qualifying interests of the Lough Oughter SAC are: For inspection purposes only. Consent of copyright owner required for any other use. • Natural euthrophic lakes with Magnopotamion or Hydrocharition-type vegetation

• Bog woodland

Lough Oughter has also been designated for the protection of the otter Lutra lutra, a species that is listed in Annex II of the Habitats Directive. Information available from the website of the National Biodiversity Data Centre confirms the presence of the otter in this particular area (recorded at 100m resolution) and this information was obtained from various studies on the distribution of the otter such as the Atlas of Mammals in Ireland 2010 – 2015 (National Biodiersity Data Centre, 2010).

The River Erne in this section is also a known habitat for the freshwater crayfish (Austropotamobius pallipes), which is a species listed I Annex II of the EU Habitats Directive. There are several records for this protected species in this section of the River Erne (NPWS, pers comm.).

The Lough Oughter site has also been designated as an SPA for the protection of certain bird species. It is an important site for a range of wintering wildfowl, including whooper swan,

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great-crested grebe, mute swan, wigeon and goldeneye. Kingfisher ( Alcedo atthis) are also known to occur along the River Erne and this bird species is listed in Annex I of the Birds Directive. The full NPWS site description for this SPA can also be read in Appendix II.

The National Biodiversity Data Centre has recorded for badgers Meles meles in the area. It is also likely that hares Lepus timidus hibernicus occur locally. Records for the occurrence of bats in the area are very sparse but this is probably due to lack of recording effort. It is likely that species such as the common pipistrelle Pipistrellus pipistrellus , the soprano pipistrelle Pipistrellus pygmaeus and Daubenton’s Bat Myotis daubentonii occur in this area.

Figure 4 – Location of Lough Oughter and Associated Loughs SAC For inspection purposes only. Consent of copyright owner required for any other use.

Figure 5 – Location of Lough Oughter SPA

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Figure 6 – Location of Lough Oughter and Associated Loughs pNHA

For inspection purposes only. Consent of copyright owner required for any other use.

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4.3 IDENTIFICATION OF POTENTIAL IMPACTS AND EFFECTS Following consultation with the National Parks and Wildlife Service, the Development Applications Unit of the Department of Arts, Heritage and the Gaeltacht expressed the following concerns about some potential impacts:

• Deterioration of the water quality in the River Erne and downstream in Lough Oughter resulting from the pollution from trade effluents from the development;

• Deterioration of the water quality in the River Erne and downstream in Lough Oughter resulting from the pollution from surface water run-off during site preparation and construction;

• Damage / destruction to riparian habitats and riverbank vegetation.

This section provides a screening exercise to establish whether the above impacts of the proposed developments at Farragh Proteins are likely to occur and whether or not they are significant.

4.3.1 Direct Impacts Direct environmental impacts are those impacts which directly affect a specific area. These impacts can include land take and loss, direct discharges to water etc.

If this proposed development is allowed to proceed, there will be no habitat loss, habitat fragmentation, resource abstraction or land take from any area that is designated as an SPA, SAC or pNHA. The outlet pipe from the WWTP already exists and will not need modification. There will be no alteration or disturbance to the river bank or any riparian habitats. There will be no disturbance to or loss of any habitats that are currently used by species such as the otter, bats, kingfisher or other birds listed in Annex II of the Birds Directive. For inspection purposes only. Consent of copyright owner required for any other use.

The final treated effluent from the Farragh Proteins waste water treatment plant will be discharged directly into the Lough Oughter and Associated Loughs SPA and pNHA and upstream of the SAC. Calculations have shown that this effluent discharge is within the assimilative capacity of the River Erne and therefore there should be no deterioration in water quality in the River Erne or downstream in the Lough Oughter area. Therefore, any negative impacts on designated areas and species (such as the crayfish) will be negligible.

During the construction and operational phase there is the potential for silt laden or hydrocarbons to enter the storm water collection system. The storm water drains lead directly to the River Erne and so any negative impacts upon it could directly affect this designated site.

Particularly, during construction phase, it is possible that this drain will receive run off that will result in pollution and an increase in siltation in the drain and this could have a moderately negative impact upon the River Erne. An increase in the siltation levels of the river could result in the smothering of fish eggs, an increase in the mortality rate in fishes of all ages, a reduction in the amount of food available for fish and the creation of impediments

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to the movement of fish. Pollution of the water with hydrocarbons , cement and concrete during the construction phase of this proposed development could also have a significant negative effect on the fish and aquatic invertebrate populations. However, if proper mitigation measures are taken during the construction phase of this development (see Section 4.4), then the potential for this to occur will be significantly reduced.

4.3.2 Indirect Impacts Indirect (or secondary) impacts are defined as effects that are “caused by and result from the activity although they are later in time or further removed in distance, but still reasonably foreseeable” (Bowers-Marriott, 1997). Indirect impacts would include air or noise emissions that occur some distance away from a particular site, but which still have the potential to impact negatively on a site, e.g., a reduction in air quality could affect sensitive plant or animals some distance away from the point of emission.

Emissions to the atmosphere from the current activities on the site include ammonia, amines, hydrogen sulphide and mercaptans from the woodchip bio-filter and oxides of sulphur, NO x and particulates from the TEAP (Thermal Exhaust Air Purification) unit and the boiler. In data from 2009 and 2010 presented by Farragh Proteins to the EPA in their Annual Environmental Report it was shown that the mass emissions of each of these parameters was well within their emission limit values as set out in the Farragh Proteins IPCC license. The replacement of the existing boilers with a more efficient one will result in a further decrease in these emissions. The installation of two additional biofilters will only moderately increase emissions from the site. Therefore, it is extremely unlikely that these emissions will have any indirect negative impacts upon any protected habitats or species.

4.3.3 Cumulative Impacts Cumulative impacts or effects are changes in the environment that result from numerous human-induced, small-scale alterations. Cumulative impacts can be thought of as occurring For inspection purposes only. Consent of copyright owner required for any other use. through two main pathways: first; through persistent additions or losses of the same materials or resource, and second,-through the compounding effects as a result of the coming together of two or more effects (Bowers-Marriott, 1997).

The River Erne is suffering from the effects of eutrophication along its entire length and this is most likely due to run-off from diffuse agricultural sources. This type of run-off is hard to control. However, the discharge from the waste water treatment plant at Farragh Proteins currently and at proposed future levels remains within the assimilative capacity of the river, therefore at current operation standards the cumulative impacts can be described as negligible.

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4.4 MITIGATION MEASURES To minimise the impacts of the development on the River Erne, the following mitigation measures should be implemented:

• The developer should ensure that any excavated topsoil be disposed of responsibly. Its disposal should not lead to the loss or damage of any natural or semi-natural habitats elsewhere.

• Low intensity lighting should be used on all boundaries. This will reduce the impact of any new lighting scheme on local bat populations.

• Any timbers used during new builds should not be treated with chlorinated hydrocarbons where possible as this is toxic to mammals, including any bats that could potentially use the eves as suitable roosting sites. Pyrethroid insecticides with low mammalian toxicity can be used as a substitute.

• Strict controls of erosion, sediment generation and other pollutants associated with the construction process should be implemented, including the provision of attenuation measures, silt traps and geotextile curtains to reduce and intercept sediment release into drains that run adjacent to the site.

• Fuels, oils, greases and hydraulic fluids must be stored in bunded compounds well away from drains. Refuelling of machinery, etc., should be carried out in bunded areas.

• Oil interceptors should be fitted on the storm water system.

• There must be no disturbance to the river bank or and riparian habitats along the River Erne. For inspection purposes only. Consent of copyright owner required for any other use. • Run off from machine service and concrete mixing areas must not enter the drains.

• Stockpile areas for sands and gravel should be kept to a minimum size, well away from the drains.

• The principles of Sustainable Urban Drainage Systems (SUDS) should be adhered to on site at all phases of construction and operation.

• The site should continue to undertake any required storm water and treated effluent monitoring as required by the sites existing/proposed reviewed EPA IPPC licence to demonstrate compliance to relevant standards or ELV’s.

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4.5 OVERALL ASSESSMENT Using the information gathered as part of this report along with an analysis of the information produced by Farragh Proteins, Rowan Engineering Consultants and the EPA, it was concluded that the current and future operation of Farragh Proteins, Crossdoney will have no impacts (direct, indirect, cumulative) upon the integrity or the conservation objectives of the Lough Oughter and Associated Loughs SAC, SPA or pNHA, its habitats or its designated species. Therefore, full appropriate assessment of this application is not necessary and Stage 2 of the process will not be undertaken.

However, it is recommended that the mitigation measures included in this document are followed and that continuous chemical monitoring of the River Erne be continued both upstream and downstream of the discharge points.

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4.6 FINDING OF NO SIGNIFICANT EFFECTS Finding of No Significant Effects Report Matrix Name of project Farragh Proteins planning application to Cavan County Council

Name and location of Natura 2000 site The Lough Oughter and Associated Loughs SAC & SPA

Description of project See Section 4.1

Is the project directly connected with or No necessary to the management of the site?

Are there other projects or plans that See Section 4.3.3. for discussion of together with project being assessed could cumulative effects affect the site?

The Assessment of Significance of Effects Describe how the project is likely to affect See Section 4.3 on discussion of possible the Natura 2000 site impacts

Explain why these effects are not Discharge to the Natura 2000 site is well considered significant within the assimilative capacity of the River Erne. Also, the mitigation measures outlined in Section 4.4 will reduce the possibility of any significant negative effects on the site

List of agencies consulted Letter to the National Parks and Wildlife Service

Response to consultation For inspection purposesYes only. Consent of copyright owner required for any other use. Data Collected to Carry out the Assessment Who carried out the Sources of data Level of Where can the full assessment assessment results of the completed assessment be accessed and viewed Noreen McLoughlin, Field work, NPWS, Stage 1 Full results included MSC, MIEEM. EPA, National Appropriate Consultant Ecologist Biodiversity Data Assessment Centre, Rowan Overall Conclusion

It can be concluded objectively that there are not likely to be any significant effects on Lough Oughter and Associated Loughs SAC or SPA.

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APPENDIX I WATER QUALITY DATA

Indicator Group Taxon Number Group A 0 (Very sensitive) Absent

Group B 4 (Moderately sensitive) Cased Tricoptera (Caddisfly) Limniphilidae 2

Plecoptera (Stonefly) Leuctra 2

Group C 169 (Moderately tolerant) Ephemeroptera (Mayfly) Baetis rhodani 2

Uncased Tricoptera (Caddisfly) Polycentropidae 3

Amphipoda (Shrimp) Gammarus duebeni 101

Diptera (Winged Fly) Chironomidae 31 Tipulidae 3

Coleo ptera (Beetles) Elminthidae 13 Halipidae 2

Gastropods (Snails) For inspection purposes only. Consent of copyright Viviparus owner required for any other use. 1

Group D 17 (Very tolerant) Isopoda (Lice) Asellus aquaticus 8

Hirudnea (Leeches) Glossiphonidae 3

Bivalves Sphaeridae 6

Group E (Most tolerant) Absent

Total Abundance 191 Q Value 3-4 Berger-Parker Diversity 1.89 Index Results from the Biological Water Quality Monitoring of Station 2 (d/s of Farragh Proteins)

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APPENDIX II NPWS SITE SYNOPSIS

NPWS Site Synopsis of Lough Oughter And Associated Loughs SAC

Site Code: 000007

Drainage within the area is inefficient and the water levels prone to natural fluctuation as a result. The regularly flooded areas still accommodate a variety of specialist plant species such as Amphibious Bistort (Polygonum amphibium) and Marsh Foxtail (Alopecurus geniculatus) , as well as rarer species such as Needle Spike-Rush (Eleocharis acicularis) and Lesser Marshwort ( Apium inundatum) .

The lakes and basins are shallow, and the water well mixed and nutrient rich (eutrophic). The aquatic flora is varied with several pondweed species such as Bluntleaved Pondweed ( Potamogeton obtusifolius ), Shining Pondweed (Potamogeton lucens ), Broad-leaved Pondweed ( Potamogeton natans ), Reddish Pondweed ( Potamogeton alpinus ) and Various-leaved Pondweed ( Potamogeton gramineus ). Typical in the zone of aquatic plants are Yellow Water-lily ( Nuphar lutea ), Canadian Pondweed ( Elodea canadensis ), Mare’s Tail ( Hippuris vulgaris ), Water Milfoil ( Myriophyllum spicatum For inspection), purposes Brooklime only. ( Veronica beccabunga ), Water Consent of copyright owner required for any other use. Dropwort ( Oenanthe spp .) and Starwort ( Callitriche sp .). The aquatic community includes species of limited distribution in Ireland such as the Duckweed species Lemna gibba and Spirodela polyrhiza.

Around much of the shoreline there are well developed swamp and marsh communities, typically with a zone of Bulrush ( Schoenoplectus lacustris ) in front of a zone of Common Reed ( Phragmites australis ) which is in turn backed by a more species rich zone of sedges, grasses and herbs, particularly Bottle Sedge ( Carex rostrata ), Common Sedge ( Carex nigra ), Creeping Bent ( Agrostis stolonifera ), Meadowsweet ( Filipendula ulmaria ), Marsh Helleborine ( Epipactis palustris ), Water Plantain ( Alisma plantago-aquatica ), Rough Horsetail ( Equisetum hyemale ), Water Horsetail ( Equisetum fluviatile) and Wild Angelica ( Angelica sylvestris ). Less widespread species also occur on the wet lake margins; species such as Water Dock (Rumex hydrolapathum ), Greater Water-parsnip ( Sium latifolium ), Cowbane ( Cicuta virosa ), Tufted Sedge ( Carex elata ), Water Soldier ( Stratioites aloides ), Arrowhead (Sagittaria sagittifolia ), Flowering Rush ( Butomus umbellatus ) and Greater Spearwort (Ranunculus lingua ) may be locally prominent.

There are many variations on this typical zonation of sheltered shores with species such as Reedmace ( Typha spp.), Branched Bur-Reed ( Sparganium erectum) and

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Reed Canary-grass ( Phalaris arundinacea ) gaining local prominence. More exposed shores lack the extensive swamp zones, here smaller species such as Common Spike Rush ( Eleocharis palustris ) can be found.

Level, wet pastures tend to be dominated by Creeping Bent ( Agrostis stolonifera) and Rush species ( Juncus sp .) with a scattering of marshland and wet grassland plants such as Marsh Marigold ( Caltha palustris), Water Forget-me-not (Myosotis scorpiodes) and Yellow Iris ( Iris pseudacorus). Soft Rush ( Juncus effusus) is most abundant with frequent Hard Rush ( Juncus inflexus ) and Sharp-Flowered Rush (Juncus acutiflorus) and less widespread Conglomerate Rush ( Juncus conglomeratus ) also occurring .

Where a general lack of grazing pressure or a particular slope has allowed it, deciduous woodland has re-established itself behind the reedbeds. Two species of Willow ( Salix caprea and Salix cinerea ) are common constituents along with Alder (Alnus glutinosa ), Downy Birch ( Betula pubescens ), Hazel ( Corylus avellana ) and Hawthorn ( Crataegus monogyna ). Along submerged margins Alder and Willow are most commonly found with a flooded understorey typically containing Reed Canarygrass, Meadow Sweet, Yellow Flag and in places Tufted Sedge ( Carex elata ) and Greater Tussock Sedge ( Carex paniculata ). Downy Birch occurs along lake edges and also forms stands of wet woodland on cutover bog with varying degrees of wet and dry peat. Purple Moor-grass ( Molinia caerulea), Marsh Cinquefoil ( Potentilla palustris) and Bog Moss ( Sphagnum sp.) occur in areas with pools and dry areas . Where there is dry peat, Bracken ( Pteridium aquilinum ), Bramble ( Rubus fruticosus agg.) and Gorse ( Ulex sp.) occur under the Birch canopy. Birch dominated wood is also found in association with Ling Heather ( Calluna vulgaris ) bog.

In areas of wet bog with good Sphagnum cover, bog woodland has developed. Downy Birch characterises this habitat; other typical species include Purple Moor- grass ( Molinia caerulea ) and Bottle Sedge ( Carex rostrata ).

Dry broad-leaved woodland is characterised by Ash (Fraxinus excelsior ), Hazel, Holly For inspection purposes only. (Ilex aquifolium) and OakConsent ( Quercus of copyright spp. owner ),required while for any shrubs other use. include Blackthorn ( Prunus spinosa ), Spindle ( Euonymus europaeus) and Guelder Rose ( Viburnum opulus ). The Red Data Book species Bird Cherry ( Prunus padus ) has also been recorded from the site. The clayey soils have a characteristic flora, including Wood Avens ( Geum urbanum), Wood Sorrel ( Oxalis acetosella ), Primrose ( Primula vulgaris ), Herb Robert (G eranium robertianum ) and Wood Sedge ( Carex sylvatica).

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27.11.2002

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SITE NAME: LOUGH OUGHTER SPA SITE CODE: 004049

The lakes have a well-developed aquatic flora, with a range of pondweeds (Potamogeton spp.) and such species as Yellow Water-lily ( Nuphar lutea ), Canadian Pondweed ( Elodea canadensis ), Mare’s-tail ( Hippuris vulgaris ), Spiked Water-milfoil (Myriophyllum spicatum ) and Water-starwort ( Callitriche sp.). The aquatic community includes species of limited distribution in Ireland such as the duckweeds, Fat Duckweed ( Lemna gibba ) and Greater Duckweed ( Spirodela polyrhiza ). Around much of the shoreline there are well developed swamp and marsh communities, typically with a zone of Common Clubrush ( Scirpus lacustris ) in front of a zone of Common Reed ( Phragmites australis ) which is in turn backed by a more species-rich zone of sedges, grasses and herbs. In places, wet woodland is well-developed at the lake margins. This is mainly of willows ( Salix caprea and S. cinerea ), along with Alder (Alnus glutinosa ), Downy Birch ( Betula pubescens ) and Hazel ( Corylus avellana ).

Lough Oughter is of importance for a range of wintering waterfowl. Of particular note is an internationally important population of Whooper Swan (302) that is based in the area and which uses the lakes as a roost - all figures are average peaks for the 5 seasons 1995/96-1999/00. A population of Greenland White-fronted Goose (67) of regional importance also roosts on the lakes and feeds mainly on nearby improved For inspection purposes only. grassland. The site supportsConsent of copyright nationally owner required important for any other wuse.intering populations of four species, i.e. Great Crested Grebe (92), Mute Swan (128), Wigeon (910) and Goldeneye (123). Other species which occur regularly include Teal (225), Mallard (341), Pochard (60), Tufted Duck (160), Lapwing (523), Curlew (95), Little Grebe (9), Cormorant (83) and Black-headed Gull (357).

Otter, a species that is listed on Annex II of the E.U. Habitats Directive, occurs at the site.

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APPENDIX III REFERENCES & FURTHER READING

Bailey, M. & Rochford, J . (2006) Otter survey of Ireland 2004 / 2005. Irish Wildlife Manuals No. 23. National Parks & Wildlife Service. DoEHLG.

Bowers Marriott, B . (1997) Practical Guide to Environmental Impact Assessment: A Practical Guide. Published by McGraw-Hill Professional, 1997, 320 pp.

Crowe, O . (2005) Irelands Wetlands and their Waterbirds: Status and Distribution. Birdwatch Ireland, Newcastle, Co Wicklow.

Department of the Environment, Heritage and Local Government (2009) Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities.

Dwyer , (2000) Protecting Nature in Ireland, The NGO Special Areas of Conservation Shadow List. Published by the Irish Peatland Conservation Council, Dublin.

EPA (2001) Parameters of Water Quality - Interpretation and Standards. Environmental Protection Agency, Ireland.

EPA (2002 ) Guidelines on the Information to be contained in Environmental Impact Statements . Environmental Protection Agency, Ireland.

EPA (2003) Advice Notes on Current Practice in the Preparation of Environmental Impact Statements . EPA, Wexford, Ireland.

Fossit, J.A . (2000) A Guide to Habitats in Ireland . The Heritage Council, Kilkenny.

Gilbert, G; Gibbons D. W. & Evans J. (1998) Bird Monitoring Methods – a Manual of

Techniques for Key UK Species . Royal For inspection Society purposes Protection only. Birds (RSPB). Consent of copyright owner required for any other use.

Hayden, T. & Harrington, R. (2000) Exploring Irish Mammals. Dúchas the Heritage Service, Town House Dublin.

Heath, M-F. & Evans, M-I. eds. (2000) Important Bird Areas in Europe: Priority Sites for Conservation. 1: Northern Europe . Cambridge UK: BirdLife International (BirdLife Conservation Series No. 8).

Hunt, ]; Derwin, J; Coveney, J. & Newton, S. (2000) Important Bird Areas in Europe: Priority sites/or conservation. 1 : (pp 365 – 416) in Heath M.F. and Evans, M.I., eds. Cambridge UK: BirdLife International (BirdLife Conservation Series No. 8).

Institute of Environmental Assessment (1995) Guidelines for Baseline Ecological Assessment . Institute of Environmental Assessment, Great Britain.

IUCN (2003) Red List of Threatened Species . International Council for Conservation of Nature and Natural Resources.

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Lynas P; Newton, S.F. and Robinson, J.A. (2007). The Status of Birds in Ireland: An Analysis of Conservation Concern 2008-2013. Irish Birds, 8:149-167.

Mullarney, K; Svensson, L; Zetterstrom, D. & Grant, P.J . (1999) Collins Bird Guide . HarperCollins, London.

Natura Environmental Consultants (2005) Draft Habitat Survey Guidelines: A Standard Methodology for Habitat Survey and Mapping in Ireland. The Heritage Council, Kilkenny.

NPWS (2009) Otter Threat Response Plan 2009 – 2011. National Parks & Wildlife Service. DoEHLG.

NRA (2004) Guidelines for Assessment of Ecological Impacts of National Road Schemes. National Roads Authority, Dublin.

Newton, S; Donaghy, A; Allen, D. & Gibbons, D. (1999) Birds of Conservation Concern in Ireland . Irish Birds 6(3), 333–344.

Rowan, T & Lynch, J. (2011) Assimilation Capacity Study of River Erne to Accept Proposed Treated Emissions from Farragh Proteins. Rowan Engineering Consultants, Navan, Co. Meath.

Whilde, A . (1993) Threatened Mammals, Birds, Amphibians and Fish in Ireland. Irish Red Data Book 2: Vertebrates. HMSO, Belfast.

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