Appropriate Assessment Report

Alexandra Basin Redevelopment Project (FS005699)

Project Description

In July 2015 Dublin Port Company submitted an application, accompanied by an Environmental Impact Statement (EIS), and a Natura Impact Statement (NIS) for a foreshore lease / licence to carry out works on the foreshore as part of the Alexandra Basin Redevelopment Project (ABR).

Planning permission for the Project was granted by An Bord Pleanala, subject to 16 No. Conditions, in June 2015. (Bord Pleanala Reference Number: 29N.PA0034)

The ABR Project comprises three main elements:

1. Works at Alexandra Basin West: which includes construction of new quays and jetties, remediation and reuse of contaminated sediments in the basin, capital dredging to deepen the basin and to achieve depths of -10m Chart Datum (CD) at the new berths.

2. Infilling of the Basin at Berths 52 & 53 and construction of a new river berth with a double tiered Ro-Ro ramp.

3. Deepening of the fairway and approach to Dublin Port to increase the depth from - 7.8m CD to -10.0m CD.

It is noted, however, that the disposal of dredged material at sea requires a Dumping at Sea Permit from the EPA. The proposed disposal of dredge spoil at this site as part of Alexandra Basin Redevelopment Project is the subject of an application for a Dumping at Sea permit to the EPA. (EPA Ref S0024-01) and the effect of this activity on designated Natura 2000 site will be considered by the EPA as part of the Dumping at Sea Permit determination process.

It is proposed that the following works will be carried.

Alexandra Basin:  The infilling of Graving Dock No.2  The excavation and restoration of Graving Dock No.1.  The removal of infill material  The relocation of the ore concentrates loading system within Alexandra Basin West  The relocation of double deck ramp No.4 to new river berth at Berths Nos. 52/53

The demolition of:

 The bulk jetty  A section of North Wall Quay Extension

 Five control rooms/buildings/oil bunds  A floating ramp on the Liffey side of North wall Quay Extension  A lead-in jetty at Graving Dock No.2 within the Basin

The construction of:

 New quay walls at North Wall Quay Extension (937m in length) including a rounded eastern end using salvaged stone material from demolished sections of quay.  Moving and reconstruction of existing light house to the east end of revised North Wall Quay Extension  Refurbishment of existing quay walls along Ocean Pier (approximately 555m in length)  Refurbishment of existing quay walls along Alexandra Quay West (approximately 400m in length)  Extension of Alexandra Quay West (130m in length)  Construction of new quay wall along Crossberth Quay (approximately 250m in length)  New 273m long Ro-Ro jetty and provision of three Ro-Ro ramps  Interpretative glazed pavilions (36sq.m.) on the W of the reconfigured North Wall Quay Extension and the presentation of a salvaged historic concrete block from the demolished section of the quay

The dredging of:

 470,000m3 of contaminated material to a depth of -10.0m Chart Datum (CD) over an area of 19.4Ha within the redeveloped Alexandra Basin and its subsequent remediation.

Conservation works to the existing pump house and to retained sections of North Wall Quay Extension

Berths 52 and 53

The demolition of:  Existing Berths 52 and 53  Jetty at Berth 52  Concrete Dolphin at Berth 53

The construction of :

 A new 300m quay wall at Berth 52 / 53  A new 75m mooring jetty for New Berth 52  New 40m long mooring jetty to extend existing Berth 49 (50m long)

 The infilling of the Terminal 5 Ro-Ro basin (circa 4.565 Ha)

 The raising of existing levels by 1.4m over an area of 9.5 Hab.m.

 Dredging of new river berth to -10m CD

Liffey Channel

 Construction of a marina protection structure to a height of +7.0m CD and a length of 220m on the South side of the River channel.

 Dredging of the shipping channel to a depth of -10m CD from a point 55m to the East of the East Link Bridge to a location in the vicinity of Dublin Bay a total distance of 10.3Km

 It is envisaged that stabilisation works will be required to the Great South Wall to negate any impact from the channel dredging and realignment. These works will include the placement of additional rock armour to protect the existing rock armour slopes around the Bull lighthouse which prevents any undermining of the existing structure. Also, the steepened dredge side slopes of the navigation channel will be stabilised at this location using concrete mattresses

Drawings:

The location and details of works on the foreshore are shown in the following Drawings submitted by the applicant:  Drawing No. IBM0569-FS-001, “Overall Site Layout on A3”, Rev A , dated 19/11/2014  Drawing No. IBM0569-FS-002, “Site Location Maps, Rev A, , dated 19/11/2014  Drawing No. IBM0569-FS-003, “Site Location of Alexandra Basin, Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-004, “Site Location at New Berth 52” Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-005, “Dublin Port Company Lease Areas Showing Proposed Works” Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-006, “Demolition Plan At Alexandra Basin ” Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-007, “Demolition Plan At New Berth 52 ” Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-008, “Proposed General Arrangement Alexandra Basin Sheet 1,” Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-009, “Proposed General Arrangement Alexandra Basin Sheet 2,” Rev A, dated 19/11/2014  Drawing No. IBM0569-FS-0010, “Proposed General Arrangement Alexandra Basin Sheet 2,” Rev A, dated 19/11/2014

 Drawing No. IBM0569-FS-0011, “Proposed General Arrangement At New Berth 52,” dated 19/11/2014  Drawing No. IBM0569-FS-0012, “Proposed Sections at Alexandra Basin Sheet 1”, dated 19/11/2014  Drawing No. IBM0569-FS-0013, “Proposed Sections at Alexandra Basin Sheet 2”, dated 19/11/2014  Drawing No. IBM0569-FS-0014, “Proposed Sections at New Berth 52”, dated 19/11/2014  Drawing No. IBM0569-FS-0015, “Proposed Marina Layout and Section”, dated 19/11/2014  Drawing No. IBM0569-FS-0016, “Proposed Channel Works at New Berth 52 and Great South Wall”, dated 19/11/2014  Drawing No. IBM0569-FS-0017, “Channel Works at New Berth 52 and Great South Wall Typical Sections”, dated 19/11/2014  Drawing No. IBM0569-FS-0018, “Site Location Plan with Co-ordinates”, dated 19/11/2014  Drawing No. IBM0569-FS-0019, “Permanent Structures at Alexandra Basin”, dated 19/11/2014  Drawing No. IBM0569-FS-0020, “Permanent Structures and drilling at Berth 52”, dated 19/11/2014  Drawing No. IBM0566-FS-0021, “Foreshore Ownership at Alexandra Basin”, dated 19/11/2014  Drawing No. IBM0569-FS-0022, “Foreshore Ownership at Berth 52”, dated 19/11/2014

Phasing of the works

Construction Works

The construction activities are divided between two primary work streams:  the civil engineering works required to facilitate the creation of deep berths and enclose Berths 52 / 53 and  dredging of the main channel and of Alexandra Basin West.

These civil engineering works are broken into three distinct, sequential phases, largely determined by port operational requirements. It is anticipated that each of the three phases will last between 18 and 24 months, overlapping to give construction duration of 36 - 47months.

Phase 1

It is envisaged that the following works will be undertaken during Phase 1:

 Construction of new quay walls and the reconfiguring of existing loading facilities within the North West corner of Alexandra Basin West  Demolition of existing vessel loading jetties and plant  Re-fronting of Ocean Pier

 Construction of the new berths on Crossberth Quay  Relocation of customers from existing Berths 52 / 53 to Crossberth Quay berths

The anticipated form of construction for the quay walls within Alexandra Basin West will comprise a steel combi-wall. This will consist of sheet piles extending between intermittent king piles. It is anticipated that the primary piles of the new quay walls will be installed to depths ranging between -20m ODM and -35m ODM, with the final depths depending on the local ground conditions and proximity to the standard dredge depth. In areas of relatively shallow bedrock the piles will be cored into the rock as required to achieve overall stability of the quay structure and to sustain any imposed loads. Intermediate sheet piles forming quay walls will be installed to depths in excess of the standard dredge depth to protect against undermining and loss of material from behind the quay wall. The final design and construction depth of intermediate sheet piles will be determined by local material properties but will extend beyond the dredge depth by 2-4m. The quay wall will be tied to a sheet piled anchor wall or a reinforced concrete anchor beam, depending on the proximity of existing structures/operations to the quay side. The berthing face to the quay structure will be formed by the installation of a reinforced concrete capping beam. Fenders will be fixed to the concrete capping beam to provide a suitable berthing face. The deck behind the combi-wall quay will be reinstated to tie-in with the existing surfacing and deck levels.

The form of construction for the 273m long Ro-Ro jetty proposed for Alexandra Basin will be an open pile structure, constructed using a series of piled mooring dolphins, which will be connected using a steel walkway structure.

Phase2

It is envisaged that Phase 2 will include the following works:  Closure of Berths 52 / 53  Construction of New Berth 52 (river berth)  Re-fronting of Alexandra Quay West  Dredging of Alexandra Basin West  Treatment of dredge material and infilling of Graving Dock No. 2 and Berths 52 / 53

It is anticipated that a cellular cofferdam form of construction will be used to close off Berth 52/53 from the main navigation channel. The existing bed level along the proposed line of the quay will be excavated to the required level. The cells will then be constructed sequentially from the East side of the Berth using interlocking sheet piles and filled with suitable granular material. The cells will be constructed using piling plant, initially operating from the existing revetment and then from the preceding cell in turn once completed.

Fenders will be mounted on the Southern face of the cofferdams to provide a berthing face for the proposed multi-purpose berth. Associated mooring and berthing dolphins will be installed to the East of the Berth to stabilise the existing revetment for dredging operations. The form of construction for the mooring jetties proposed at Berth 52 / 53 and Berth 49 will be an open pile structure, constructed using a series of piled mooring dolphins, which will be connected using a steel walkway structure. A two tier concrete approach structure with piled bridge supports is also

5 required to provide access to ramp No. 4 from the new river berth quay. Reinforced concrete dolphin structures will also be required to facilitate the installation of ramp No.4 from Alexandra Basin.

Phase 3

It is envisaged that Phase 3 will involve the:  Installation of a new marina wall on the Southern Side of the channel at Poolbeg marina  Deconstruction, re-fronting and conservation of the North Wall Quay Extension

In order to minimise potential impact of the channel dredging or the alterations to the North Wall Quay Extension on the Poolbeg Marina, it is proposed to construct a 220m long surge protection/retaining wall, with a new floating pontoon along the edge of navigation channel at Poolbeg Marina. This structure would also serve to protect vessels moored in the marina from the wash produced by vessels manoeuvring in the vicinity of North Wall Quay Extension. It is envisaged that the form of construction used will be a steel combi-wall. The proposed wall will be designed to facilitate possible future dredging to -12.0m CD.

It is also intended to remove an area of approximately 2.2 hectares from the existing North Wall Quay Extension and carry out the re-fronting of the existing masonry walls with a steel combi- wall structure to facilitate dredging to -10.0m CD (and possible future dredging to -15.0m CD). The anticipated form of construction for these quay walls will also comprise a steel combi-wall with a reinforced concrete capping beam.

Dredging

It is intended that approximately 6,370,000m3 of sediments will be dredged in order to permit access to Alexandra Basin and provide sufficient water depths for vessels in Alexandra Basin at all stages of the tide.

The following works are proposed: • Dredging of Alexandra Basin to -10.0m CD • Dredging of the Liffey Channel to -10.0m CD from the East Link Bridge to the Dublin Bay Buoy.

It is intended that circa 5,400,000m3 of uncontaminated dredged material from the main channel will be transported and disposed of at the licensed Burford Bank offshore disposal site. It is envisaged that the dredging of uncontaminated material will be carried out during winter months only (October to March). The channel dredging will be undertaken over a period of six winter seasons, commencing at the channel mouth and continuing westwards into the port. During each dredging campaign each portion of the channel will be dredged to the required depth along one side, maintaining an open shipping lane at all times. Once completed, the opposite side of the channel will be dredged to depth, with the shipping lane changed to the newly dredged section. The marine sediments from the outer channel, comprising mainly fine sands, between the North Bull Wall / Great South Wall and the Dublin Bay Buoy will be dredged using a Trailer Suction Hopper Dredger, or equivalent. The dredger will transport the material directly to the licensed

6 sea disposal site. Inside the Port’s walls, the bed material changes to silts, sands and gravel. This section of the channel will be dredged to the required design depths by an excavator which will operate from a floating pontoon. The dredged material will be loaded into barges and transported directly to the licensed sea disposal site. Dredging of circa 500,000m3 of slight/moderately contaminated silty material adjacent to the North Wall Quay Extension and the entrance to Alexandra Basin West will be undertaken in conjunction with the dredging of gravels from the main channel. The slight/moderately contaminated silts deposited at the dump site will be overlaid (capped) with the dredged gravels.

Disposal of dredged material to the dump site at the Burford Bank is the subject of an application for a Dumping at Sea permit to the EPA. (EPA Ref S0024-01)

Treatment and re-use of contaminated material dredged from the Alexandra Basin

Dredging of circa 470,000m3 of contaminated material from within the Alexandra Basin West will be undertaken using a floating pontoon with an excavator mounted clamshell bucket adapted for environmental dredging in order to minimise the disturbance and escape of material at the seabed and during removal through the water column. A silt curtain will be utilised around the dredger whilst the dredging of contaminated material is ongoing. It is envisaged that the dredging of the contaminated sediments will not be seasonally dependent. This dredged material will be loaded onto barges to be transported to the treatment facility at Berth 52/53. The rate of dredging within Alexandra Basin West will be determined by the rate of treatment of the dredged material.

It is estimated that the main channel dredging could be completed, given favourable conditions, within six years. There is the requirement to have the North Wall Quay Extension and the Marina Wall works completed prior to undertaking the dredging of the channel adjacent to these works.

The contaminated dredged material recovered from Alexandra Basin will be transported by barge to a treatment facility adjacent to Berth 52 / 53. It will be stabilised and modified to improve the engineering properties of the material, to allow its re-use as fill material. The treatment process proposed for the contaminated material is discussed in Section 11 of the EIS.

It is proposed to fill the basin at Berth 52 / 53 with circa 519,000m3 of treated dredge material to provide open storage space and a new river berth at the port entrance. It is also proposed to raise the surface levels at the marshalling area adjacent to the infilled basin at Berth 52 / 53 by approximately 1.4m. The material will be treated and placed in Berth 52 / 53 to tie in with the proposed reclamation levels for the area adjacent to the basin.

It is also proposed to seal and fill Graving Dock No. 2 at Alexandra Basin West to provide space for open hardstanding space for storage/parking and approximately 55,000m3 of treated material will be required for these works. The treated material will be transported from the treatment facility at Berth 52/53 to the Graving Dock No. 2 by trucks along the internal port road network. The graving dock will be filled with treated material and capped with crushed material to tie in with the surrounding surface levels. A layer of sand and a geotextile material will be placed in

7 the graving dock, prior to the infilling, to act as a separation layer. This will facilitate future reversal of the infilling works if required.

The proposed treatment of the contaminated material is the subject of a separate application, to the EPA, by Dublin Port Company for an Industrial Emissions Licence (EPA Ref No 10022-01)

Natura 2000 Considerations

The application was accompanied by a Natura Impact Statement (NIS). The NIS provides a description of the project, the project location and identifies the Natura 2000 sites within a 15Km radius of the project. The NIS provides an initial screening assessment of these sites (22 in total) and, based on the screening methodology outlined, identifies a total of 5 Natura 2000 sites that could potentially to be affected by the proposed development and which require further assessment. The NIS predicts the potential effect on the Conservation Objectives of these sites and where potential effects are predicted presents mitigation measures. In-combination effects with other plans and projects are also identified.

On the basis of the information provided in the NIS and associated document it is considered that the sufficient data and information has been provided to allow for an Appropriate Assessment of the proposed development to be carried out.

Natura 2000 sites

As noted above the NIS provided details of the Screening Assessment carried out by the applicant. This assessment, based on distance from the project location, the potential of a “source – pathway – receptor” and consideration of the qualifying interests / features and the specific conservation objectives of the sites, concluded that the project could potentially effect 5 of Natura sites. These sites include:

 North Dublin Bay SAC (Site Code 000206),  North Bull Island SPA (Site Code 004006),  South Dublin Bay and River Tolka SPA (Site Code 004024),  South Dublin Bay SAC (Site Code 000210)  Rockabill to Dalkey Island SAC (Site Code 003000),

The remainder of the 22 sites examined were “screened out” were not considered further.

It is considered that the approach and screening method adopted was appropriate and the conclusion is reasonable.

North Dublin Bay SAC (Site Code 000206),

This site covers the inner part of north Dublin Bay, the seaward boundary extending from the Bull Wall lighthouse across to the Martello Tower at Howth Head. The North Bull Island is the focal point of this site.

The Conservation Objectives for this site are1

 To maintain the favourable conservation condition of Mudflats and sandflats not covered by seawater at low tide in North Dublin Bay SAC  To restore the favourable conservation condition of Annual vegetation of drift lines in North Dublin Bay SAC  To restore the favourable conservation condition of Salicornia and other annuals colonizing mud and sand in North Dublin Bay SAC  To maintain the favourable conservation condition of Atlantic salt meadows (Glauco- Puccinellietalia maritimae) in North Dublin Bay SAC  To maintain the favourable conservation condition of Mediterranean salt meadows  (Juncetalia maritimi) in North Dublin Bay SAC  To restore the favourable conservation condition of Embryonic shifting dunes in North  Dublin Bay SAC,  To restore the favourable conservation condition of Shifting dunes along the shoreline with Ammophila arenaria ('white dunes') in North Dublin Bay SAC,  To restore the favourable conservation condition of Fixed coastal dunes with herbaceous vegetation ('grey dunes') in North Dublin Bay SAC,  To restore the favourable conservation condition of Humid dune slacks in North Dublin Bay SAC,  To maintain the favourable conservation condition of Petalwort in North Dublin Bay SAC

No works will occur within this site and therefore there will be no direct impact on any habitats within the designated site. There will be no direct loss of habitat or species, habitat or species fragmentation will not occur and there will be no direct impact on to key habitats or species.

Some of the of the qualifying features of North Bay Dublin Bay SAC, including embryonic shifting dunes, Shifting dunes along the shoreline with Ammophila arenaria (white dunes), fixed coastal dunes with herbaceous vegetation (grey dunes), humid dune slacks, Pettlewort (Petalophyllum ralfsii) are above the high water mark. There is, therefore, no effects pathway that could compromise the conservation objectives of these features.

On the basis of the outputs of the modelling studies presented in the EIS the MLVC is of the view that significant impacts / alterations to coastal processes are not considered likely. Similarly, significant deposition of sediments in sensitive locations with the Dublin Bay area is also not considered likely. It can be concluded therefore that significant effects on the qualifying features of the SAC are not likely as a result of the dredging and associated activity.

Considering the nature and location of the proposed development, the MLVC is of the view that project is not likely to have long term significant effects on water quality or sediment quality in

1 NPWS (2013) Conservation Objectives: North Dublin Bay SAC 000206. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 9

North Bay Dublin Bay SAC provided that all mitigation measures in the EIS, NIS and associated documents are implemented in full.

North Bull Island SPA (Site Code 004006),

This site covers all of the inner part of north Dublin Bay, with the seaward boundary extending from the Bull Wall lighthouse across to Drumleck Point at Howth Head. The North Bull Island sand spit is a relatively recent depositional feature, formed as a result of improvements to Dublin Port during the 18th and 19th centuries. It is almost 5 km long and 1 km wide and runs parallel to the coast between Clontarf and Sutton. The North Bull Island SPA is an excellent example of an estuarine complex and is one of the top sites in Ireland for wintering waterfowl. It is of international importance on account of both the total number of waterfowl and the individual populations of Lightbellied Brent Goose, Black-tailed Godwit and Bar-tailed Godwit that use it. Also of significance is the regular presence of several species that are listed on Annex I of the E.U. Birds Directive, notably Golden Plover and Bar-tailed Godwit, but also Ruff and Short- eared Owl.

The Conservation Objectives for this site are2

 To maintain the favourable conservation condition of Light-bellied Brent Goose in North Bull Island SPA  To maintain the favourable conservation condition of Shelduck in North Bull Island SPA  To maintain the favourable conservation condition of Teal in North Bull Island SPA,  To maintain the favourable conservation condition of Pintail in North Bull Island SPA  To maintain the favourable conservation condition of Shoveler in North Bull Island SPA  To maintain the favourable conservation condition of Oystercatcher in North Bull Island SPA,  To maintain the favourable conservation condition of Golden Plover in North Bull Island SPA,  To maintain the favourable conservation condition of Grey Plover in North Bull Island SPA  To maintain the favourable conservation condition of Knot in North Bull Island SPA  To maintain the favourable conservation condition of Sanderling in North Bull Island SPA  To maintain the favourable conservation condition of Dunlin in North Bull Island SPA,  To maintain the favourable conservation condition of Black-tailed Godwit in North Bull Island SPA  To maintain the favourable conservation condition of Bar-tailed Godwit in North Bull Island SPA,  To maintain the favourable conservation condition of Curlew in North Bull Island SPA  To maintain the favourable conservation condition of Redshank in North Bull Island SPA

2 NPWS (2015) Conservation Objectives: North Bull Island SPA 004006. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 10

 To maintain the favourable conservation condition of Turnstone in North Bull Island SPA  To maintain the favourable conservation condition of Black-headed Gull in North Bull Island SPA,  To maintain the favourable conservation condition of the wetland habitat in North Bull Island SPA as a resource for the regularly occurring migratory waterbirds that utilise it.

On the basis of the outputs of the modelling studies presented in the EIS the MLVC is of the view that significant impacts / alterations to coastal processes are not considered likely. Similarly, significant deposition of sediments in sensitive locations with the Dublin Bay area is also not considered likely. It can be concluded therefore that significant effects on the habitats within this SPA are not likely as a result of the dredging and associated activity.

Considering the nature and location of the proposed development, the MLVC is of the view that project is not likely to have long term significant effects on water quality or sediment quality in North Bull Island SPA provided that all mitigation measures in the EIS, NIS and associated documents are implemented in full.

Considering the nature and location of the proposed development, the MLVC is of the view that project is not likely to result in significant disturbance to bird species listed as qualifying interest of the SPA as a result of noise producing works e.g. piling, dredging.

There will be no significant impact on wetland habitats and habitat or species fragmentation will not occur as a result of the proposed works on the foreshore. No areas of intertidal mudflats, saltmarsh or habitats of a similar nature are located in the work areas and no loss of potential feeding area for waterbirds will occur

Provided that all mitigation measures in the EIS, NIS and associated documents are implemented in full significant effects on the Conservation Objectives of the North Bull Island SPA are not considered likely.

South Dublin Bay and River Tolka SPA (Site Code 004024),

The South Dublin Bay and River Tolka Estuary SPA comprises a substantial part of Dublin Bay. It includes the intertidal area between the River Liffey and Dun Laoghaire, and the estuary of the River Tolka to the north of the River Liffey, as well as Booterstown Marsh. A portion of the shallow marine waters of the bay is also included.

The Conservation Objectives for this site are3  To maintain the favourable conservation condition of Light-bellied Brent Goose in South Dublin Bay and River Tolka Estuary SPA  To maintain the favourable conservation condition of Oystercatcher in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Ringed Plover in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Knot in South Dublin Bay and River Tolka Estuary SPA  To maintain the favourable conservation condition of Sanderling in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Dunlin in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Bar-tailed Godwit in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Redshank in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Black-headed Gull in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Roseate Tern in South Dublin Bay and River Tolka Estuary SPA,  To maintain the favourable conservation condition of Common Tern in South Dublin Bay and River Tolka Estuary SPA  To maintain the favourable conservation condition of Arctic Tern in South Dublin Bay and River Tolka Estuary SPA  To maintain the favourable conservation condition of the wetland habitat in South Dublin Bay and River Tolka Estuary SPA as a resource for the regularly occurring migratory waterbirds that utilise it.

On the basis of the outputs of the modelling studies presented in the EIS the MLVC is of the view that significant impacts / alterations to coastal processes are not considered likely. Similarly, significant deposition of sediments in sensitive locations with the Dublin Bay area is also not considered likely. It can be concluded therefore that significant effects on the habitats within this SPA are not likely as a result of the dredging and associated activity.

Considering the nature and location of the proposed development, the MLVC is of the view that project is not likely to have long term significant effects on water quality or sediment quality in

3 NPWS (2015) Conservation Objectives: South Dublin Bay and River Tolka Estuary SPA 004024. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 12

SPA provided that all mitigation measures in the EIS, NIS and associated documents are implemented in full.

Provided that all mitigation measures in the EIS, NIS and associated documents are implemented in full significant effects on the Conservation Objectives of the South Dublin Bay and River Tolka SPA are not considered likely.

South Dublin Bay SAC (Site Code 000210)

This site lies south of the River Liffey in Co. Dublin, and extends from the South Wall to the west pier at Dun Laoghaire. It is an intertidal site with extensive areas of sand and mudflats. The sediments are predominantly sands but grade to sandy muds near the shore at Merrion Gates. The main channel which drains the area is Cockle Lake.

The Conservation Objectives for this site are4:

 To maintain the favourable conservation condition of Mudflats and sandflats not covered by seawater at low tide in South Dublin Bay SAC

Considering the nature and location of the proposed development, the MLVC is of the view that project is not likely to have long term significant effects on water quality or sediment quality in South Dublin Bay SAC provided that all mitigation measures in the EIS, NIS and associated documents are implemented in full.

4 NPWS (2013) Conservation Objectives: South Dublin Bay SAC 000210. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 13

Rockabill to Dalkey Island SAC (Site Code 003000)

This site includes a range of dynamic inshore and coastal waters in the western Irish Sea. These include sandy and muddy seabed, reefs, sandbanks and islands. This site extends southwards, in a strip approximately 7 km wide and 40 km in length, from Rockabill, running adjacent to Howth Head, and crosses Dublin Bay to Frazer Bank in south Co. Dublin. The site encompasses Dalkey, Muglins and Rockabill islands. The total area of the site is circa 27, 316ha

The area represents a key habitat for the Annex II species Harbour Porpoise within the Irish Sea. Common Seal and Grey Seal ae also present. Bottle-nosed Dolphins and a number of other marine mammals including Minke, Fin and Killer Whales and Risso’s and Common Dolphins have been recorded in this area.

The site is also selected due to the occurrence of reefs which are found fringing offshore islands along the Dublin coast. These Reefs are subject to strong tidal currents with an abundant supply of suspended matter resulting in good representation of filter feeding fauna such as sponges, anemones and echinoderms.

The Conservation Objectives for this site are5

 To maintain the favourable conservation condition of Reefs in Rockabill to Dalkey Island SAC,  To maintain the favourable conservation condition of Harbour porpoise in Rockabill to Dalkey Island SAC

The proposed capital dredging works in the eastern most section of the c.10km approach channel to the port extends in into the western portion this SAC. This area equates to circa 0.25% of the total area of the SAC and the impacts of the disturbance to the seabed are not considered significant.

There are no reef habitats located with the proposed dredging area and therefore this activity will not have a direct impact on reef habitat within the SAC and no species or habitat fragmentation will occur in this habitat. On the basis of the outputs of the modelling studies presented in the EIS the MLVC is of the view that significant impacts / alterations to coastal processes are not considered likely. Similarly, significant deposition of sediments in sensitive locations with the Dublin Bay area is also not considered likely. It can be concluded therefore that significant effects on the reef habitats within the SAC are not likely as a result of the dredging and associated activity. Within the SAC the proposed area to be dredged is not considered an important cetacean foraging area and therefore any displacement resulting from impacts on available prey are unlikely and not considered significant

The dredging and other noise producing works e.g. piling activity could result in the disturbance of Harbour porpoise, as well as other marine mammals, in the area. It is considered that full compliance with the requirements set out in the “Guidance to Manage the Risk to Marine Mammals from

5 NPWS (2013) Conservation Objectives: Rockabill to Dalkey Island SAC 003000. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht 14

Man-made Sound Sources in Irish Waters” (January 2014) and full implementation of the mitigation measures set out in the EIS and NIS will minimise and mitigate any such interactions with Harbour porpoises and other marine mammal species.

In combination / cumulative impacts

The NIS considered potential cumulative impacts of the proposed Alexandra Basin Redevelopment Project and existing and planned developments in the area. In this regard a total of 10 projects were considered and assessed. These projects were identified as part of the Dublin Port Masterplan’s Strategic Natura Impact Statement. Potential impacts arising from the ESB 220kV replacement crossing of the River Liffey and decommissioning of existing cable was also considered.

The NIS concluded that no significant in combination / cumulative impacts were likely on marine mammals, bird populations, benthic habitats and species or other sensitive habitats. The only project identified which could potentially have in combination / cumulative impacts was the “Dublin Array” project involving the installation of wind turbines on the Kish Bank. Potential impacts on Harbour Porpoises resulting from noise associated with piling of wind turbine foundations was considered. It was concluded, however, that such impacts were not likely given that the proposed time scales of both projects do not overlap.

It is noted that potential in combination / cumulative impacts with the proposed Dun Laoghaire Harbour Cruise Berth project have not been considered. This project is currently under consideration by An Bord Pleanala. With the exception of the proposed disposal of dredge spoil at the Burford Bank as part of both projects there is no spatial overlap between these projects and in combination / cumulative impacts between the proposed works on the foreshore for both projects are not considered likely.

AS previously noted, however, the disposal of dredged material at sea requires a Dumping at Sea Permit from the EPA. The proposed disposal of dredge spoil at this site as part of Alexandra Basin Redevelopment Project is the subject of an application for a Dumping at Sea permit to the EPA. (EPA Ref S0024-01) and the effect of this activity on designated Natura 2000 site will be considered by the EPA as part of the Dumping at Sea Permit determination process.

Conclusion

Based on the above it is concluded that, subject to the full implementation of the mitigation measures set out in the EIS, Nis and associated documents submitted by the applicant, the proposed works on the foreshore as part of the Alexandra Basin Redevelopment Project are not likely to have significant effects on the Conservation Objectives or integrity of the following Natura 2000 sites:

 North Dublin Bay SAC (Site Code 000206),  North Bull Island SPA (Site Code 004006),  South Dublin Bay and River Tolka SPA (Site Code 004024),  South Dublin Bay SAC (Site Code 000210)

 Rockabill to Dalkey Island SAC (Site Code 003000), or on any other Natura 2000 site in the area.

Prepared by Marine Institute, on behalf of the MLVC 14 March 2016