Natura Impact Statement
Newport Town Park,
Co. Tipperary
This page has been left intentionally blank
18150-6011-C Natura Impact Statement September 2018
ISSUE FORM Project number 18150 Document number 6011 Document revision C Document title Natura Impact Statement: Newport Town Park Document status Issued for client Document prepared by Gerard Hayes (Senior Ecologist, B.Sc. Ed., MCIEEM) August 2018 Document checked by Hazel Dalton (Senior Ecologist, B.Sc. Wildlife Biology) September 2018
i
18150-6011-C Natura Impact Statement September 2018
Table of contents
1 SUMMARY OF FINDINGS ...... 5 1.1 Natura Impact Statement ...... 5
2 INTRODUCTION ...... 6
3 METHODOLOGY ...... 6 3.1 Appropriate Assessment Guidance ...... 6 3.2 Desk Study ...... 6 3.3 Field Surveys ...... 7 3.4 Assessment of Potentially Significant Effects ...... 7
4 DESCRIPTION OF THE PROJECT ...... 8 4.1 Brief Project Description ...... 8 4.2 Purpose of the Project...... 10 4.3 Site Location and Context ...... 10 4.4 Characteristics of the Project ...... 12
4.4.1 Riparian Leave Strip Exclusion Zone ...... 13 4.4.2 Protection of Watercourses (General Measures) ...... 13 4.4.3 Fuel and Oil Management ...... 14 4.4.4 Storage ...... 14 4.5 Description of the Receiving Environment ...... 15
4.5.1 Habitats ...... 15 4.5.2 Surface Water ...... 19 4.5.3 Hydrogeology ...... 20 4.5.4 Otter ...... 20 4.5.5 Fish ...... 21 4.6 Identification of Other Projects, Plans and Activities ...... 22
4.6.1 Newport Town Wastewater Treatment Plant ...... 22 4.6.2 Licenced Sites ...... 23 4.6.3 Planning Applications ...... 23 4.6.4 Ongoing Activities ...... 23 5 NATURA 2000 SITE – LOWER RIVER SHANNON CSAC ...... 26 5.1 Description of the Lower River Shannon cSAC ...... 26
5.1.1 Identification of Potentially Significant Impacts to Qualifying Features ...... 27 5.2 Assessment of Potentially Significant Effects ...... 37
5.2.1 Water Quality ...... 37 5.2.2 Habitat loss...... 38 5.2.3 Habitat alteration ...... 38 5.2.4 Disturbance and/or displacement of species ...... 39 5.2.5 Habitat or species fragmentation ...... 39
ii
18150-6011-C Natura Impact Statement September 2018
5.3 Assessment of Effect on Lower River Shannon cSAC Consevation Objectives ...... 39
5.3.1 Introduction ...... 39 5.3.2 Floating River Vegetation ...... 40 5.3.3 Sea Lamprey ...... 42 5.3.4 River Lamprey ...... 43 5.3.5 Brook Lamprey ...... 45 5.3.6 Atlantic Salmon ...... 46 5.3.7 Otter ...... 47 5.4 Assessment of Potentially Significant Cumulative Effects ...... 48 5.5 Mitigation ...... 48
5.5.1 Method statements ...... 49 5.5.2 Project ecologist ...... 50 5.5.3 Invasive Species Control ...... 50 5.5.4 Landscaping ...... 50 5.5.5 Otters ...... 51 5.5.6 Temporary Construction Compound ...... 51 5.5.7 Soil Stripping and Excavation Works ...... 52 5.5.8 Storage and Stockpiles of Excavated Material ...... 52 5.5.9 Drainage Controls ...... 52 5.5.10 Hydrocarbon Control ...... 53 5.5.11 Concrete Control and Wheel Washing ...... 53 5.5.12 Storage ...... 54 5.5.13 Waste management ...... 54 5.6 Residual Impacts ...... 55 5.7 Conclusion ...... 55
6 FURTHER RECOMMENDATIONS ...... 55
7 REFERENCES ...... 57
iii
18150-6011-C Natura Impact Statement September 2018
Table of tables
Table 1: List of habitats identified at the proposed Newport Town Park site (and Newport River). ... 15 Table 2: Impacts and activities with high effect on the Lower River Shannon cSAC. (Adapted from the Natura Standard Form)...... 25 Table 3. Identification of potentially significant impacts to qualifying features of the Lower River Shannon cSAC ...... 29
Table of figures
Figure 1: Masterplan of the proposed Newport Town Park...... 9 Figure 2: Site location in Newport, Co. Tipperary...... 11 Figure 3: Habitat map for the proposed Newport Town Park development site...... 16 Figure 4: Water regions, water quality and activities potentially affecting water quality in the Newport River catchment...... 21 Figure 5: Extent of the Lower River Shannon cSAC and the habitats of conservation interest. Inset maps detail the woodland habitats closest to the proposed development...... 28 Figure 6: Otter habitat extents at and adjacent to the proposed development site...... 36
List of appendices
Appendix 1 Screening for Appropriate Assessment Report Appendix 2 Lower River Shannon cSAC Site Synopsis Appendix 3 Giant Hogweed Control Plan (incl. map) Appendix 4 Environmental Commitments Appendix 5 Outline Non-native Invasive Species Management Plan
iv
18150-6011-C Natura Impact Statement September 2018
1 SUMMARY OF FINDINGS
1.1 NATURA IMPACT STATEMENT Project Title Newport Town Park Project Proponent Tipperary County Council Project Location Newport, County Tipperary In cases where an Appropriate Assessment is required a Natura Impact Statement (NIS) is prepared and includes a report of a scientific Natura Impact examination of evidence and data, carried out by competent persons to Statement identify and classify any implications of a project, individually, or in combination with other plans or projects, for Natura 2000 sites in view of the conservation objectives of the site. Provided that the recommended mitigation measures are implemented in full, it is not expected that significant impacts will result to the Conclusion qualifying features identified for appraisal in this NIS and thus it is not expected that the proposal will have an adverse impact on the integrity of Natura 2000 sites.
5
18150-6011-C Natura Impact Statement September 2018
2 INTRODUCTION Appropriate Assessment is the consideration of the impact of the project, either alone or in combination with other plans or projects on the integrity of the Natura 2000 site, with respect to the site’s ecological structure and function, and conservation objectives. Additionally, mitigation of these impacts can be considered. A Screening for Appropriate Assessment was completed and determined the need for full Appropriate Assessment (see Appendix 1), where effects on the Lower River Shannon cSAC were assessed as potentially significant, or uncertain. The site synopsis for the Lower River Shannon cSAC1 is provided in Appendix 2.
In cases where an Appropriate Assessment is required a Natura Impact Statement (NIS) shall be prepared and shall include a report of a scientific examination of evidence and data, carried out by competent persons to identify and classify any implications for Natura 2000 sites in the view of the conservation objectives of the site. The aim of the assessment is to provide a sufficient level of information to the competent authority on which to base their appropriate assessment of the plan or project. The plan or project should be fully described particularly in relation to the aspects that could interact with the surrounding environment. The proposed Town Park at Newport, Co. Tipperary, has been fully described in Section 4 below.
The focus of the assessment is to determine whether the construction and operation of the project will have a significant negative impact on the features of interest of a Natura 2000 site(s) i.e. habitats and species. This assessment identifies the environmental aspects of the project, in this case the Town Park at Newport, Co. Tipperary, that will interact with the ecological requirements or sensitivities of the habitats and species.
The test of the assessment is whether the plan or project will have ‘an adverse effect on the integrity of the site’. Where potentially significant effects are identified proven mitigation measures will be recommended.
3 METHODOLOGY
3.1 APPROPRIATE ASSESSMENT GUIDANCE This Natura Impact Statement has been undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the ‘Habitats’ Directive 92/43/EEC (EC, 2001) and the European Commission Guidance ‘Managing Natura 2000 sites’ (EC, 2000) and guidance prepared by the NPWS (DoEHLG, 2009).
3.2 DESK STUDY In order to complete the Natura Impact Statement certain information on the existing environment is required. A desk study was carried out to collate available information on the site’s natural environment. This comprised a review of the following publications, data and datasets:
OSI Aerial photography and 1:50000 mapping, and other mapping sources (online)
1 https://www.npws.ie/sites/default/files/protected-sites/synopsis/SY002165.pdf
6
18150-6011-C Natura Impact Statement September 2018
National Parks and Wildlife Service (NPWS) (online) including: o Conservation Objectives o Site data o Article 17 reports for habitats and species MulkearLIFE+ Nature Project National Biodiversity Data Centre (NBDC) (online) Teagasc soil area maps (NBDC website) Geological Survey Ireland (GSI) area maps (online) Environmental Protection Agency (EPA)(online) including: o EPA maps o Licence reports Shannon River Basin District (ShRBD) datasets (Water Framework Directive) (online) IFI WFD Fish Survey Map Guidance for Competent Authorities when dealing with proposals affecting SAC freshwater sites (SNH, 2006) Other information sources and reports footnoted or referenced in the course of the report
3.3 FIELD SURVEYS An ecological field survey was conducted by staff ecologists with Malachy Walsh and Partners Environmental Consultants during July 2017. The aim of this survey was to characterise the site and environs and establish the ecological features and resources at the site, particularly in relation to the conservation interests of the Lower River Shannon cSAC.
Habitats were categorised according to the Heritage Council’s A Guide to Habitats in Ireland (Fossitt, 2000). The presence of invasive plant species was noted.
Searches for signs of Otter including tracks, spraints, slides, hauling-out sites and holts were carried out. The Otter survey was conducted according to methodology described in Animal Tracks and Signs (Bang and Dahlstrom, 2001), and The Mammal Detective (Strachan, 1995).
The physical characteristics of the Newport River were noted. The riverine habitats were evaluated in cognisance of the leaflet ‘The Evaluation of habitat for Salmon and Trout’ (DANI, 1995) and ‘Ecology of the Atlantic Salmon’ (Hendry and Cragg-Hine, 2003) to assess habitat suitability for Salmonids. An evaluation of lamprey nursery habitat was also carried out based on the habitat requirements of juvenile lampreys as outlined in Maitland (2003).
A summary of the results of the ecological surveys is provided below in Section 4.5, below.
3.4 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS Following the completion of the Screening for Appropriate Assessment (see Appendix 1) it was concluded that the project could have a significant effect on one Natura 2000 site, namely the Lower River Shannon cSAC. An evaluation was undertaken in the NIS to determine which of the qualifying interests of the SAC potentially lie within the zone of influence of the project and required further assessment (see Section 5 below). This was done through a scientific examination of ecological evidence and data listed above in Section 3.2 or referenced in the report as well as the results of the ecological field surveys (Section 4.5).
7
18150-6011-C Natura Impact Statement September 2018
The significance of the potential impacts that might arise from the project was identified through the use of key indicators (see Section 5.2 below):
Habitat loss Habitat alteration Habitat or species fragmentation Disturbance and/or displacement of species Water quality and resource.
The effects of the project on the qualifying interests, potentially within the zone of influence of the project, were then assessed against the measures and targets designed to achieve the conservation objectives (NPWS, 2012a), to determine whether the project would have an adverse effect on the integrity of the Lower River Shannon cSAC (see Section 5.3 below).
4 DESCRIPTION OF THE PROJECT
4.1 BRIEF PROJECT DESCRIPTION Tipperary County Council proposes to develop a Town Park, incorporating a playground, at Newport, Co. Tipperary. The proposed town park site is located to the south of the R503 and to the west of Custom Gap Road. The proposed Town Park will include the following:
Children’s play area Specifically designed play equipment for use by people with a disability Zip wire Outdoor gym equipment Pump Track Multi-Use Games Area (MUGA) Recreational walkways Seating Bi-lingual signage displaying reference to applicable by-laws, rules, hours of opening etc. Interpretative panels Landscaping Car parking for approximately 26 No. cars, but this will be determined by the planning and design processes.
The overall design of the proposed Newport Town Park will ensure that the relationship of the Site to the town centre is fully considered and that appropriate pedestrian linkage is provided between the proposed Town Park and Newport Town Centre. The proposed Newport Town Park is illustrated in Figure 1. The site location is shown in Figure 2.
8
18150-6011-B Natura Impact Statement August 2018
Figure 1: Masterplan of the proposed Newport Town Park.
9
18150-6011-B Natura Impact Statement August 2018
4.2 PURPOSE OF THE PROJECT It is recognised that recreation and leisure facilities contribute to the quality of life for all that it serves. The provision of amenities which can cater for the demands of an increasing population and which can be accessible for all sectors and age groups is a central element in the delivery of sustainable communities. Tipperary County Council recognises the important role that areas of amenity and green linkages play in creating quality and healthy environments for all and seek to promote a balance between the protection of environmental assets and the facilitation of recreational use.
4.3 SITE LOCATION AND CONTEXT The proposed town park site is located to the south of the R503 and to the west of Custom Gap Road at Tullow, Newport. Co. Tipperary (See Figure 2). Newport is a small North Tipperary town located in the west of the Co. of North Tipperary, near the Co. Limerick border. It is located on the main road (R503) between Limerick and Thurles. Newport is within easy commuter distance of the Limerick/Shannon Gateway, as defined in the National Spatial Strategy. In many respects, Newport is often regarded as a dormitory town for Limerick City. Newport has primarily a residential catchment with an estimated current population of 1,995 persons in the census of 2016.
The proposed development is located adjacent to an existing housing estate (Mulkear View) and the Newport (Tipperary) River. It is noted that the Newport River is often referred to as the Mulkear River. The Environmental Protection Agency (EPA) refers to this watercourse as the Newport River. Throughout this report, the watercourse that flows adjacent to the site will be referred to as the Newport River. The proposed development site lies partially within the confines of the Newport Town municipal boundary which has an area of 1.48km2. The land use in the general area bordering or in reasonably close proximity to the site includes residential development along with offices, commercial and educational facilities. Housing is the principal land use along Custom Gap Road to the south of the site.
The proposed development site has been partially developed as incomplete housing, with works stalled. This work is considered to be related to conditional planning permission that was granted at the site in April 2003 for 95 dwelling units, a creche, entrances, roads and all associated site works (Tipperary planning register 02510476). Some house foundations occur within the site. There is evidence of related drainage at the site also, so it is concluded that significant ground works had taken place prior to cessation of this development. The proposed development is therefore categorised as a brownfield site, with imported stone and unfinished buildings forming some of the ground to the north and east of the site.
The site currently has no commercial use and is largely overgrown at its western extent, colonised by wild plants and young shrubs/trees. The site is bound to the northeast by an occupied housing development. The southern boundary of the site comprises a hedgerow/treeline. The Newport River within the Lower River Shannon cSAC lies to the north and west of the site.
10
18150-6011-C Natura Impact Statement September 2018
Figure 2: Site location in Newport, Co. Tipperary.
MulkearLIFE2 was established in Ireland and ran for a five-year period between 2009 and 2014. The main project aim was to restore, through in-stream rehabilitation works, degraded habitats along stretches of the Mulkear River and its principal tributaries for Atlantic Salmon, Sea Lamprey and European Otter. Inland Fisheries Ireland (IFI) was the co-ordinating partner, together with the Office of Public Works and Limerick County Council. There were multiple objectives of this project including enhancement of populations of Atlantic Salmon and Sea Lamprey through best practice instream
2 www.mulkearlife.com
11
18150-6011-C Natura Impact Statement September 2018 rehabilitation work, removing obstacles to the annual adult Sea Lamprey river upstream migration, improve breeding, resting habitat and food supply for Otters, as well as stopping and reversing the damage caused by invasive exotics (Giant hogweed and Japanese knotweed) and restoring the natural riparian zone through a management programme to prevent re-colonisation. The Newport River is included within the MulkearLIFE project.
4.4 CHARACTERISTICS OF THE PROJECT It is proposed that those works situated in closest proximity to the river will be phased such that the path, parallel to the river, will be completed first. This will be followed by the remainder of paths, infill of the grassland area and planting on the west and north of the site. In addition, a number of measures drawn from normal industry standards and best available techniques such as CIRIA technical guidance on water pollution control (Murnane et al., 2006) will be incorporated into the project design in order to control the risk, and thereby avoid and reduce the likely significance of any water quality impacts ensuing from the proposal. The proposal is described below.
Size, scale, area, land-take The proposed development site has an area of ca. 2.8ha.
Set up of site compound within east side of site Demarcation of riparian exclusion zone using appropriate fencing Construction of path which runs parallel to the river. This will act as a further buffer between the SAC and the construction works. Construction of remainder of paths and infill of grassland area and Details of physical changes planting in the west and north of the site. that will take place during Construction of paths, core area and informal garden area within the the various stages of central section of the site. implementing the proposal Construction of mixed amenity area Construction of car park on east side of site with integrated Sustainable Drainage System (SuDS) for management of surface water runoff. Construction of Mixed Use Games Area (MUGA) and Playground on east side of site. Connection to existing site services, including electricity, water and drainage. An estimated average of eight to ten workers will be involved in the construction at any one time. Excavation (950m3), fill material (930m3), footpaths (2,270m2), tarmac 2 2 2 2 Description of resource (740m ), paving (1,890m ), geotextile (2,420m ), top-soiling (12,120m ), 3 requirements for the fencing (1,260m), concrete (125m ), ducts & drainage pipes, public construction/operation and lighting, equipment for play areas. decommissioning of the Dumper, mini-excavator, compressor, lorries to deliver fill material. proposal (water resources, An excavator will be used to prepare the central and western sections of construction material, the site. human presence etc) Delivery trucks will need to call to site regularly. Materials such as steel, concrete, blocks, fencing, etc, will be delivered to site by means of trucks and delivery vehicles. Concrete will be ready mixed when delivered to site. Concrete truck washing will not be permitted on site. Description of timescale for the various activities that The construction period will be 4-6 months starting in the June following will take place as a result of grant of planning permission. implementation (including likely start and finish date)
12
18150-6011-C Natura Impact Statement September 2018
General construction waste, including packaging. Description of wastes Demolition and construction waste will be separated on site, recycled arising and other residues where possible and removed to a licensed waste disposal facility (metal, and their disposal masonry, concrete). No excavation spoil wastes are expected as excavations are minimal, and spoil will be backfilled into the core area. Identification of wastes arising and other residues All demolition waste will be removed off-site to a licensed recycling or (including quantities) that landfill facility as appropriate (metal, masonry, concrete). may be of particular concern in the context of the Natura 2000 network
The proposed development will include: riparian leave strip exclusion zone protection of watercourses (general measures) fuel and oil management storage
4.4.1 Riparian Leave Strip Exclusion Zone Prior to works commencing a riparian leave strip will be established using appropriate fencing and signage and its significance explained to all workers particularly machinery operators. Leave strips are the areas of land and vegetation adjacent to watercourses that are to remain in an undisturbed state, throughout the development process. No aspect of the proposal or its associated works will encroach in this area.
4.4.2 Protection of Watercourses (General Measures) The main risk to the water quality of the SAC results from the potential for hydrocarbon spillages or sediment discharging to the Newport River. These risks arise during the excavation and construction activities.
The following measures have been incorporated into the design of the project so as to ensure no significant negative water quality impact on the Lower River Shannon cSAC (002165) or its features of conservation interest:
Raw or uncured waste concrete / cementitious material will be removed from the site; Excavated spoil will be back filled in the core area; Fuelling and lubrication of equipment will be carried out under controlled conditions in bunded areas and away from watercourses or drains; Any spillage of fuels, lubricants or hydraulic oils will be immediately contained and the contaminated soil removed from the site and properly disposed of; Sufficient oil booms and oil soakage pads will be kept on site to deal with any accidental spillage; Waste oils and hydraulic fluids will be collected in leak-proof containers and removed from the site for disposal or re-cycling; Prior to any work it will be ensured that all construction equipment is mechanically sound to avoid leaks of oil, fuel, hydraulic fluids and grease; and
13
18150-6011-C Natura Impact Statement September 2018
Overnight parking of plant machinery and site vehicles will only take place in the designated site compound area away from watercourses and aquatic zones.
4.4.3 Fuel and Oil Management Fuel and oils must not, under any circumstances, discharge into any surface water body. The measures outlined below are designed to prevent fuel and oil from entering any surface water body and will describe the emergency procedures designed to control any accidental spillages. All site plant and machinery e.g. excavators, dumpers, etc, will be refuelled in a bunded designated area situated in the farmyard area and away from any watercourses, drains or riparian zones. All site vehicles (rigid or articulated vehicles, jeeps, cars and vans) will be fuelled off site. No servicing or repair of plant, machinery or vehicles will be undertaken outside the site compound area. The management of fuel on site will have regard to the following elements:
Prior to any work commencing it will be ensured that all construction equipment is mechanically sound to avoid leaks of oil, fuel, hydraulic fluids and grease; Fuels, lubricants and hydraulic fluids for equipment used will be carefully handled to avoid spillage and properly secured against unauthorised access or vandalism. Spill containment measures will be in-situ according to current best practice3; Mobile bowsers, tanks and drums will be stored in a secure, impermeable storage area, at least 50m away from drains and open water; Fuel containers will be stored within a secondary containment system e.g. bund for static tanks or a drip tray for mobile stores; Ancillary equipment such as hoses, pipe and pumps must be contained within the bund; Fuelling and lubrication of equipment will be carried out in bunded areas; Taps, nozzles or valves should be fitted with a lock system; Fuel and oil stores, including tanks and drums, will be regularly inspected for leaks and signs of damage; Only designated trained operators will be authorised to refuel plant on site; Procedures and contingency plans will be set up to deal with emergency accidents or spills; and Oil booms and oil soakage pads will be kept on site to deal with any accidental spillage. In the event of a spill any fluids collected and any contaminated soil will be collected in leak proof containers and removed from the site for disposal by a licensed contractor.
4.4.4 Storage The storage of materials, containers, stockpiles and waste, however temporary, will follow best practice at all times, and will be stored at dedicated areas only. Storage areas will be located:
At least 50m from drains and the Newport River; On an impermeable base; Under cover to prevent damage from the elements; In secure areas;
3http://www.envirocentre.ie/includes/documents/OilStorageBPG.pdf
14
18150-6011-C Natura Impact Statement September 2018
Well away from moving plant, machinery and vehicles; and On land not required until later in the development.
All containers will be stored upright and clearly labelled. Sufficient waste storage will be provided near to all working areas.
4.5 DESCRIPTION OF THE RECEIVING ENVIRONMENT This section describes the existing environment within the proposed development site, as well as other wider environmental factors that occur within, or influence the aquatic components of the Lower River Shannon within the Newport River catchment.
4.5.1 Habitats The habitats identified within the proposed development site during July 2018, as well as the Newport River in the zone of influence of the project, are listed in Table 1. The extent of these habitats are illustrated in Figure 3. These habitats are described below with an outline of their spatial distribution within the site.
Table 1: List of habitats identified at the proposed Newport Town Park site (and Newport River). Habitat Habitat Spatial description within site code Treeline WL2 Treeline occurs along the Newport River consists primarily of Sycamore Acer pseudoplanatus, Willow Salix sp. and Alder Alnus glutinosa. Scrub WS1 Patches of this habitat occur randomly almost throughout the site in association with recolonising ground and treelines. This scrub exists in the form of Willow Salix sp. of differing ages. The most common species recorded was Goat Willow S. caprea. Eroding/Upland FW1 The Newport River flows along the northern boundary of the site. This River watercourse is the receptor for all water related emissions from the site. Buildings and BL3 Manholes associated with site drainage that occur near the western boundary Artificial of the site. Surfaces Refuse and ED5 A small quantity of construction debris occurs near the entrance to the site. Other Waste This comprises wood and concrete products - this is considered inert. Spoil and Bare ED2 A few pockets of rock and stone (hardcore) with little/no soil cover occur at Ground various locations. This habitat is free draining and is prone to drying out, preventing plant colonisation. Recolonising ED3 This is the most common habitat at the proposed development site and occurs Bare ground as a mosaic with other habitats present.
The predominant environment within the site is a mosaic of ‘Scrub (WS1)’ habitat and ‘Spoil and Bare Ground (ED2)’ habitat. Scrub habitat occurs randomly almost throughout the site in the form of Willow Salix sp. of differing age. The most common species recorded was Goat Willow S. caprea with some White Willow S. alba also recorded. This habitat is progressing towards ‘Immature Woodland (WS2)’ and in the absence of human intervention would eventually be expected to develop into ‘(Mixed) Broadleaved Woodland (WD1)’.
15
18150-6011-C Natura Impact Statement September 2018
Figure 3: Habitat map for the proposed Newport Town Park development site.
16
18150-6011-C Natura Impact Statement September 2018
Plate 1: The predominant environment within the site is a mosaic of ‘Spoil and Bare Ground (ED2)’ and ‘Scrub (WS1)’ habitats. ‘Treeline (WL2)’ occurs along the Newport River consisting primarily of Sycamore, Willow and Alder. A few areas of rock and stone were categorised as ‘Spoil and Bare Ground (ED2)’. Wood and concrete products correspond to the habitat ‘Refuse and Other Waste (ED5).
Plate 2: The Newport River flows from east to west along the northern boundary of the site. This watercourse reach is characterised by riffle-glide-pool sequences and is classified as an ‘Eroding/Upland River (FW1)’. The bed of the Newport River consists of a combination of rock, cobble, gravel and fine substrates. Scrub habitat occurs almost throughout the site mostly as Goat Willow S. caprea.
Giant Hogweed
Japanese Knotweed
Plate 3: The eastern bank of the Newport River adjacent to the proposed development has been colonised by non-native plants, mainly Japanese Knotweed. Single stands of Giant Hogweed occur. The outlet from the drainage installed as part of the incomplete housing within the proposed development can be seen here.
17
18150-6011-C Natura Impact Statement September 2018
Manholes associated with site drainage occur near the western boundary of the site, these features are categorised as ‘Buildings and Artificial Surfaces (BL3)’. A few pockets of rock and stone (hardcore) with little/no soil cover occur at various locations. This habitat is free draining and is prone to drying out, preventing plant colonisation. Areas exhibiting these characteristics were categorised as ‘Spoil and Bare Ground (ED2)’. Relative to the size of the site, a small quantity of wood and concrete products construction debris occurs near the entrance to the site. This material is considered inert and corresponds to the habitat ‘Refuse and Other Waste (ED5)’.
‘Treeline (WL2)’ occurs along the Newport River. This habitat consists primarily of Sycamore Acer pseudoplanatus, Willow Salix)’ sp. and Alder Alnus glutinosa. Its banks have significant growth of non-native species, which die back seasonally, to leave bare banks in the winter season, when riparian habitats are prone to erosion. Much of the understory associated with this habitat, particularly along the southern bank, has been colonised by non-native plants, mainly Japanese Knotweed Fallopia japonica (locally abundant), single stands of Giant Hogweed Heracleum mantegazzianum (occasional) and a single stand of Himalayan Knotweed Persicaria wallichii. It is noted that a Giant Hogweed Control Plan has been prepared by ‘Mulkear Forestry’ for the proposed development site. This plan has been prepared in consultation with Mulkear LIFE Project, Inland Fisheries Ireland, National Parks and Wildlife Service, St. Mary’s Secondary School Newport, Newport Town Park Committee and residents of Mulkear View. Tipperary County Council are adhering to best practice and are undertaking steps to address the problem. A contractor has been appointed for the treatment of the giant hogweed and this has commenced in accordance with the plan. The first treatment was undertaken in July 2018. Best practice will be adhered to and will continue in the future. A Giant Hogweed Survey map produced in 2015 as well as the Giant Hogweed Control Plan are attached as Appendix 3.
The Newport River is classified as an ‘Eroding/Upland River (FW1)’. This watercourse flows from east to west along the northern boundary of the site. This watercourse is the receptor for all water related emissions from the site. This reach of river is heavily shaded by deciduous trees. The bed of the Newport River consists of a combination of rock, cobble, gravel and fine substrates. This reach of river is characterised by riffle-glide-pool sequences.
The morphology of the Newport River was found to be degraded adjacent to the proposed development site. There are two pipelines crossing the Newport River adjacent to the western extent of the proposed development site. These pipes are considered part of the waste water drainage infrastructure of Newport. A concrete platform has been installed within the river to support this pipe. This plinth is perched relative to the bed of the river immediately downstream and is deemed a passage problem for upstream movements of lampreys. Gabion baskets have been installed at the southern bank to the north (upstream) of the pipe and are collapsing into the river. The outlet from the drainage installed as part of the incomplete housing within the proposed development site is to the Newport River via a pipe in concrete housing. There was no flow from this pipe at the time of the current survey. Bank stabilisation works have been carried out on a stretch of the right bank of the Newport River (looking downstream), namely the pouring of concrete along the bank river interface. The riparian habitat and physical character of the Newport River is impacted by a non-native plant community as described above.
18
18150-6011-C Natura Impact Statement September 2018
Gabion basket
Plate 4: Pipeline crossing of the Newport River adjacent to the proposed development site. The associated concrete base represents an obstacle for the upstream passage of lampreys, a conservation interest of the Lower River Shannon cSAC. The gabion basket which is collapsing into river is a hydro-morphological impact on the channel.
4.5.2 Surface Water The Newport River is described above under habitats (Section 4.5.1). This section provides additional detail on the surface waters in the study area. The Newport River rises in Silvermines Mountain Range at Curreeny, Co. Tipperary. It flows through areas of hillside that contain significant amounts of mountain blanket bog. This often gives the river a high natural peaty colour in heavy rainfall events.
The Mulkear River and the lower reaches of the Newport River are characterised as drained and channelised watercourses, being subject to a number of arterial drainage schemes carried out during the 19th Century. Additional works were carried out during the 1990s, including a drainage scheme on the Newport River. There is no obvious channel drainage of the Newport River adjacent to the proposed development site. Ongoing drainage maintenance works result in the removal of instream / channel diversity (substrate diversity, boulders, debris) which may accumulate over time and also contribute to the over-deepening of the channel and removal of bankside diversity which regenerates.
The Newport River (EPA code 25N02) is a 4th order fast flowing river that flows directly adjacent to the proposed development site. Approximately 7.5km downstream of Newport, the Newport River is fed by the 4th order Annagh (Clare) River (25A02). After this confluence, the watercourse is called the Killeengarriff River. A further 5km downstream, the Killeengarriff/Newport River meets the 6th order Mulkear River (25M04). The Mulkear River is a large tributary of the River Shannon (25S01), meeting the Shannon downstream of Annacotty. The Newport River is within the Mulkear Water Management Unit area within Hydrometric Area 25. This area is part of the Shannon River Basin District (ShRBD).
The OPW operate a hydrometric gauge at Barrington’s Bridge on the Newport River (station 25002), ca. 10k downstream of the proposed development site. The 95%ile flow of the Newport River (flow equalled or exceeded for 95% of time) at Barrington’s Bridge is 0.686m3/s4. The 50%ile and 5%ile flow of the Newport River at Barrington’s Bridge is given as 3.631m3/s and 17.995m3/s respectively,
4 http://waterlevel.ie/hydro-data/search.html?rbd=SHANNON%20RBD#
19
18150-6011-C Natura Impact Statement September 2018 this data derived for the period 1954 to 2013. Using the EPA Hydrotool which returns flow duration curves for most rivers in Ireland, the stretch of the Newport River at Newport (25_475) has a 95%ile flow and mean flow of 0.638m3/s and 2.705m3/s respectively (mean flow was taken as the 30%ile river flow, as in MacCarthaigh, 1997).
As part of the Water Framework Monitoring Programme, the EPA carry out biological water quality monitoring at several locations in the Newport (Tipperary) River catchment. The Newport River was in a highly satisfactory ecological condition when surveyed in late July 2015. Encouragingly the improvement to high ecological condition noted in 2012 has been maintained. The abundance and diversity of sensitive macroinvertebrate species indicated high ecological conditions at all five stations surveyed although there is still cattle access along some sections5. The 2010-2015 river water quality status of the Newport (Tipperary) River was ‘Good’. The most recent assessment was undertaken in 2015. At Rockvale Bridge (EPA station 0200) ca. 3km upstream of the proposed development, biological water quality was rated ‘Q4-5’, equivalent to Water Framework Directive (WFD) ‘High Status’. At the bridge south of Shower (EPA station 0330), ca. 2.5km downstream of the proposed development, biological water quality was rated ‘Q4-5’, equivalent to Water Framework Directive (WFD) ‘High Status’. Water regions and the biological water quality locations described above are indicated in Figure 4.
4.5.3 Hydrogeology The proposed development is underlain by ‘Pale & red sandstone, grit & claystone’. This solid geology is part of the Keeper Hill Formation6. The soils along the Newport River (at the western and north-western extent of the site) are mapped as alluvial. ‘Surface water gleys’ and ‘ground water gleys’ are indicated as constituting the remainder of the site. The soil profile of the proposed development has been significantly altered however due to past development works.
The proposed development overlies an area of ‘High’ vulnerability. The proposed development site and the Newport River overly the Slieve Phelim ground water body (GWB). The Summary of Initial Characterisation report for this GWB indicates that the water table is above or close to the base of the subsoils and that the streams crossing the aquifer are gaining. Due to the shallow groundwater flow in this aquifer the groundwater and surface waters are closely linked. There are several ecosystems in the GWB dependent on groundwater.
4.5.4 Otter Otters utilise the aquatic habitats of the Newport River adjacent to the site. No evidence of an Otter holt was recorded along the banks of the study area, which included the riparian areas adjacent to the site from 50m downstream to 50m upstream of the site boundary. The built-up nature and level of disturbance through human activity in the surrounding area would make the stretch of the Mulkear River in close proximity to the proposed development less favourable for this timid species however.
5 http://www.epa.ie/QValue/webusers/PDFS/HA25.pdf?Submit=Get+Results 6 https://dcenr.maps.arcgis.com/apps/webappviewer/index.html?id=3400f393afa844538e5b81679552205d
20
18150-6011-C Natura Impact Statement September 2018
Figure 4: Water regions, water quality and activities potentially affecting water quality in the Newport River catchment.
4.5.5 Fish One site on the Newport River was electric fished by IFI as part of the WFD river surveillance monitoring programme in 2013. The survey site was located upstream of Rossaguile Bridge, just outside the village of Newport. Three electric-fishing passes were conducted using three bank-based electric fishing units on the 8th of July 2013, along a 40m length of channel. Riffle and pool dominated the habitat, while gravel and sand were most abundant among a good mix of substrate types. Four fish species were recorded in the Newport River during the 2013 survey. Salmon Salmo salar was the most abundant species recorded, followed by Brown Trout S. trutta, Stone Loach Barbatula barbatula and lamprey7. Three-spined Stickleback Gasterosteus aculeatus, Minnow Phoxinus phoxinus and European Eel Anguilla anguilla are likely to occur in the Newport River. It is noted that European eel is listed as ‘Critically endangered’ and is now ‘Red Listed’ according to the recently published ‘Red List No. 5: Amphibians, Reptiles & Freshwater Fish’ (King et al., 2011).
7 http://wfdfish.ie/wp-content/uploads/2013/08/SHIRBD_rivers_report_2013.pdf
21
18150-6011-C Natura Impact Statement September 2018
4.5.5.1 Salmon The Newport River was evaluated as an important Salmonid spawning and nursery area. The stretch of river potentially affected by the works are considered most suitable for juvenile Salmonids, with spawning habitat, and ample refuge habitat in the form of riffles, rocks, overhanging banks and instream debris (manly deadwood). Salmon fry/parr were recorded amongst rock and riffled parts of the channel. This reach of the river is expected to hold significant numbers of adult Salmon towards the spawning season (October-January). During the 2013 IFI investigation at Rossaguile Bridge, the total minimum density of 0+ Salmon was 0.229/m2, while the total minimum density of 1+ Salmon was 0.061/m2.
4.5.5.2 Lamprey Lamprey spawning habitat (corresponding to areas used by trout) also occurs in the river. Habitat for juvenile lamprey does occur in the channel, but due to the generally medium gradient of the river, the accumulation of fine sediment a requirement for the burrowing larvae is limited however. Shallow deposits of sand/silt do occur in some slow flowing parts of the river opposite eroding bends. These accretions are deep enough to support young lampreys, and larvae were detected during the current survey. As evident from the current survey, small pockets of deposited sand/silt do provide habitat for lampreys. During the 2013 IFI investigation at Rossaguile Br., the total minimum density of lamprey was 0.003/m2.
Juvenile Juvenile lamprey Salmon
Plate 5: The Newport River is an important habitat for Salmonid and lamprey spawning and rearing. Juvenile Salmon and lamprey were recorded in the Newport River adjacent to the proposed development during the current survey.
4.6 IDENTIFICATION OF OTHER PROJECTS, PLANS AND ACTIVITIES
4.6.1 Newport Town Wastewater Treatment Plant The Newport Town Wastewater Treatment Plant (WWTP licence register No. D0325-01,)8 has its primary effluent discharge point to the Newport River at Portryan, ca. 1km downstream of the proposed development. The agglomeration is served by a wastewater treatment plant with a Plant Capacity PE of 1900. In 2016, the Newport agglomeration had a PE of 2,631. The agglomeration has an existing combined gravity sewerage system with 2 No. pumping stations, which drains to the WWTP at Portryan. Figure 4 shows activities potentially affecting water quality in the Newport River catchment.
8 http://www.epa.ie/licences/lic_eDMS/090151b2805fc9a6.pdf
22
18150-6011-C Natura Impact Statement September 2018
The treatment process includes the following:
Preliminary Treatment (Automated Screen) Secondary Treatment (Conventional Activated Sludge) Nutrient Removal (Spent alum dosing to remove phosphorus compounds)
The main expansion of Newport Agglomeration has occurred along the main routes to the town centre. There is no significant waste water contribution from agriculture or from tourism/leisure facilities as tourism is limited in the area. There are still areas of land available for development. Not all of this population is served by the Agglomeration’s public sewers.
An Annual Environmental Report (AER) has been prepared for D0325-01, in accordance with the requirements of the wastewater discharge licence for the agglomeration9. The 2017 AER states that the WWTP is currently operating above its design capacity. With reference to criteria of the Urban Waste Water Regulations, the final effluent exceeded the emission limit value for Orthophosphate in 2017. There are two storm water overflows (SWO) within the Newport agglomeration. They are located at the inlet works at Newport WWTP (TPEFF2800D0325SW005, X:171300, Y:161557) and the Mulkear View Housing Estate (TPEFF2800D0325SW003, X: 172343, Y:161983). It is noted that much of the pipeline infrastructure associated with the latter is within the proposed Newport Town Park site. In the 2017 AER assessment of operation criteria, it was not possible to determine the compliance of the various SWOs due to the absence of data. It is noted that the compliance of these SWOs are unknown and their significance in relation to the Lower River Shannon cSAC was unknown. Therefore, further assessment of the agglomeration SWOs is required.
4.6.2 Licenced Sites One Section 4 Discharge point (Source Pressures for the Article 5 Characterisation and Risk Assessment Report for the Water Framework Directive 2000/60/EC) was identified along the Newport River. This discharge is from a Nursing Home (LR reference no. WP/WO85/04) located at Milbrae Lodge Nursing Home, Shower, Newport Co. Tipperary approximately 2Km downstream of the proposed development site.
4.6.3 Planning Applications A review of planning applications in the vicinity was carried out10. Several planning applications have been granted in the Newport area in the last five years, mostly related to residential housing. For example, permission was granted for demolition of an old type cottage house and the construction of a new single storey house complete with a new effluent treatment system at Tullow within the town of Newport in 2017 (ref: 17601016). Planning applications are ongoing within the Newport River catchment. For example, the construction of a new dwelling, garage, septic tank, percolation area has been requested at Garraunbeg, Killoscully, Newport (ref: 18600697).
4.6.4 Ongoing Activities Agriculture is the main land use within the catchment with the banks of the mid and lower reaches dominated by improved agricultural grasslands, which are drained and heavily fertilised. Agriculture and forestry are activities in the Newport River catchment that could act in combination with the project to negatively affect water quality.
9 http://www.epa.ie/licences/lic_eDMS/090151b280673883.pdf 10 http://www.eplanning.ie/TipperaryCC/searchresults
23
18150-6011-C Natura Impact Statement September 2018
The discharge of polluting substances from point (e.g. industrial pollutants, wastewater effluents) and diffuse (e.g. agriculture, on-site WWTP (septic tank) sources creates an existing pollution pressure within the Mulkear WMU, in particular the Newport WWTP in the context of the current study area. According to the Mulkear WMU, 95% of total phosphorous input to the area is diffuse and mainly from agriculture (76%), with the remaining from unsewered properties (8%), forestry (8%) and WWTP (5%)11.
Significant pressures have been identified for waterbodies that are at risk of not meeting their water quality objectives under the Water Framework Directive. While there are a multitude of pressures in every waterbody, the significant pressures are those pressures which need to be addressed in order to improve water quality. A robust scientific assessment process has been carried out to determine which pressures are the significant pressures. This has incorporated over 140 datasets, a suite of modelling tools, and local knowledge from field and enforcement staff from the local authorities, IFI and EPA. Impacts from hydromorphology include sediment/siltation pollution and alteration to the physical environment. Significant hydromorphology pressures are subcategorised into channelization, embankment, dams, barriers, weirs, locks, culverts, land drainage, overgrazing and bank erosion12. The upper reaches of the Newport River along with the Doonane River, a tributary that feeds the Newport River upstream of Newport, are categorized as channels with river hydromorphological pressures.
Agri-food is Ireland’s largest land-based indigenous industry. To meet the global demand for food, the Irish agri-food industry is attempting to increase output through ‘sustainable intensification of Irish agriculture’ in what has been dubbed ‘Food Harvest 2020’. Sustainable agricultural intensification is defined as ‘producing more output from the same area of land while reducing the negative environmental impacts’13. The 2020 visons are set out in the Department of Agriculture, Fisheries and Food document ‘Food Harvest 2020’14, where it is stated that Ireland’s extensive, low- input grass-based production systems are the foundation of its green credentials. Teagasc, of the same department is the state agency providing research, advisory in agriculture, horticulture, food and rural development in Ireland. Teagasc provides advice on Nitrogen, Phosphorus and Potassium application rates and timing of N fertiliser applications for various agricultural strands. For example, rates and timing of Nitrogen fertiliser applications for swards grazed by cattle at various stocking rates are provided15, and reach 279kg/ha. Teagasc note the requirement for compliance with nitrates regulations for total N application and timing, that recommendations are based on average soil fertility levels, and to fertilise to the stock-carrying capacity of the soil. There is no reliable soil test currently available for N however and therefore, there is no soil Index system for N in grassland. In practice, nutrient management plans can be difficult to implement properly. - it is deemed difficult to achieve a balance of nutrient application that is appropriate for each land-holding and
11http://www.wfdireland.ie/docs/1_River%20Basin%20Management%20Plans%202009%20- %202015/ShIRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/Mulkear%20WMU. pdf 12 https://www.catchments.ie/maps/ 13http://energyinagriculture.ie/wp-content/uploads/2017/05/Sustainable-Intensification-of-Irish-Agriculture- Pat-Murphy.pdf 14https://www.agriculture.gov.ie/media/migration/foodindustrydevelopmenttrademarkets/agri- foodandtheeconomy/foodharvest2020/2020FoodHarvestEng240810.pdf 15 https://www.teagasc.ie/crops/soil--soil-fertility/grassland/
24
18150-6011-C Natura Impact Statement September 2018 almost impossible to achieve in reality without nutrient losses considering the variability of the Irish climate and increased stocking density brought about by withdrawal of milk quotas in 2015. Since 2015, there has been an apparent upsurge in reseeding, land drainage and land reclamation to increase yields. The general intensification and extensification of the agri-sector in Ireland is considered significant in contributing to the nutrient loading to inland waters, driven primarily in many regions of Ireland by grazed grass. ‘Grazed grass is, and will continue to be, the cheapest animal feed for milk production in Ireland’16 while ‘Food production needs to increase 70-100% by 2050’1. While these production facts persist and while these aims are imminent, the Water Framework Directive (WFD) objective that all water bodies be at ‘Good’ Status by 2027 represents a serious challenge.
The most important impacts and activities with high effect on the Lower River Shannon cSAC are given in the Natura Standard form for the site. These are limited to ‘Medium’ and ‘Low’ ranking threats and pressures, as listed in Table 2. The main threats to the site, ranked as medium include agriculture (fertilisation, grazing), urbanisation, residential and commercial development, and reclamation of land. Lesser threats include invasion by non-native species, sylviculture, forestry and removal of beach materials.
Table 2: Impacts and activities with high effect on the Lower River Shannon cSAC. (Adapted from the Natura Standard Form). Rank Threats and Description inside/outside/both pressures [code] [i|o|b] Medium A08 Fertilisation o E01 Urbanisation, residential and commercial o development H04 Air pollution, air-borne pollutants o E03 Discharges o K02.03 Eutrophication (natural) o A04 Grazing i J02.01.01 Polderisation i J02.01.02 Reclamation of land from sea, estuary or marsh o Low I01 Invasive non-native species i D01.01 Paths, tracks, cycling tracks i G01.01 Nautical sports i B Sylviculture, forestry i F01 Marine and Freshwater Aquaculture i F03.01 Bait digging / collection i C01.01.02 Removal of beach materials i
16 https://www.teagasc.ie/media/website/animals/dairy/ManagingGrass.pdf
25
18150-6011-C Natura Impact Statement September 2018
5 NATURA 2000 SITE – LOWER RIVER SHANNON CSAC It has been concluded that the proposed development at Newport is likely to have a significant effect, or significant effects cannot be ruled out at this stage, on the following Natura 2000 site:
Lower River Shannon cSAC (002165)
When Natura 2000 sites are selected for stage 2 assessments, then all the qualifying features of conservation interest must be included in that stage of the assessment. However, when assessing impact, qualifying features are only considered relevant where a credible or tangible source- pathway-receptor link exists between the proposed development and a protected species or habitat type. In order for an impact to occur there must be a risk initiated by having a 'source' (e.g. nearby watercourse), a 'receptor' (e.g. a protected species associated aquatic or riparian habitats), and an impact pathway between the source and the receptor (e.g. a watercourse which connects the proposed development site to the Natura 2000 site). Identifying a risk that could, in theory, cause an impact does not automatically mean that the risk event will occur, or that it will cause or create an adverse impact. However, identification of the risk does mean that there is a possibility of ecological or environmental damage occurring, with the level and significance of the impact depending upon the nature of the risk, the extent of the exposure to the risk and the characteristics of the receptor.
Bearing in mind the scope, scale, nature and size of the project, its location relative to the distribution of the species and habitats listed and the degree of connectedness that exists between the project and the potential receptors, it is considered that not all of them are within the zone of potential impact of the proposal. An evaluation based on these factors to determine which species and habitats are the plausible ecological receptors for potential impacts of the unmitigated proposal has been conducted in Section 5.1.1 below. This evaluation determined that certain habitats and species, which are listed as qualifying interests for the SAC, should be selected for further assessment as plausible ecological receptors.
5.1 DESCRIPTION OF THE LOWER RIVER SHANNON CSAC The Lower River Shannon cSAC is very large, long site approximately 14 km wide and 120 km long, encompassing: the drained river valley which forms the River Shannon estuary; the broader River Fergus estuary, plus a number of smaller estuaries e.g. Poulnasherry Bay; the freshwater lower reaches of the Shannon River, between Killaloe and Limerick, plus the freshwater stretches of much of the Feale and Mulkear catchments; a marine area at the mouth of the Shannon estuary with high rocky cliffs to the north and south; ericaceous heath on Kerry Head and Loop Head; and several lagoons. The underlying geology ranges from Carboniferous limestone (east of Foynes) to Namurian shales and flagstones (west of Foynes) to Old Red Sandstone (at Kerry Head). The salinity of the system varies daily with the ebb and flood of the tide and with annual rainfall fluctuations seasonally.
This cSAC is designated for a variety of Annex I habitats (freshwater, terrestrial and intertidal) which include: sandbanks, estuaries, mudflats and sand flats, large shallow inlets and bays, reefs, vegetation of stony banks, vegetated sea cliffs, mudflats, Atlantic salt meadows, Mediterranean salt meadows, floating river vegetation, and alluvial forests. The Lower River Shannon cSAC site is also designated due to its importance for a number of Annex II species such as the Freshwater Pearl
26
18150-6011-C Natura Impact Statement September 2018
Mussel Margaritifera margaritifera, Sea Lamprey Petromyzon marinus, Brook Lamprey Lampetra planeri; River Lamprey Lampetra fluviatilis; Bottlenose dolphin Tursiops truncates and Otter Lutra lutra. Figure 5 gives the extent of the Lower River Shannon cSAC. The freshwater reaches of the Lower River Shannon cSAC within the northern extent of the Mulkear catchment, as well as the habitats of conservation interest are also shown in Figure 5.
5.1.1 Identification of Potentially Significant Impacts to Qualifying Features The following table lists the qualifying features of the Lower River Shannon cSAC and evaluates through a scientific examination of evidence and data whether or not these features should or should not be selected for further assessment in the NIS. The qualifying features that are selected for further assessment are discussed further in the section followed by an assessment of potentially significant effects arising from the proposed development.
27
18150-6011-C Natura Impact Statement September 2018
Figure 5: Extent of the Lower River Shannon cSAC and the habitats of conservation interest. Inset maps detail the woodland habitats closest to the proposed development.
28
18150-6011-B Natura Impact Statement August 2018
Table 3. Identification of potentially significant impacts to qualifying features of the Lower River Shannon cSAC Potential for Qualifying Feature Rationale Significant Impacts The extent of Sandbanks which are slightly covered by seawater all the time in Lower River Shannon cSAC is given in NPWS (2012a). The only Sandbanks which are mapped habitat of this type is in a marine area off Beal Point on the west coast of north Co. Kerry. This habitat is in excess of 150km to the west slightly covered by sea No of the proposed development so would not be affected. The project will not have a significant effect on sandbanks. Thus, the project will not water all the time affect the conservation objectives for Sandbanks which are slightly covered by sea water all the time and the habitat is not considered further in the NIS The Shannon and Fergus Estuaries form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon Estuary (considered to be a line across the narrow strait between Kilcredaun Point and Kilconly Point). Within this main unit there are several tributaries with their own ‘sub-estuaries’ e.g. the Deel River, Mulkear River, and Maigue River. The nearest estuarine habitat downstream Estuaries No of the proposed development is associated with the main channel of the River Shannon which lies at over 40 river km downstream of the project site. Given the characteristics of the project, it is not considered that the zone of influence of the project will extend this far. The project will not have a significant effect on Estuaries. Thus, the project will not affect the conservation objectives for Estuaries and the habitat is not considered further in the NIS. Mudflats and sandflats not covered by seawater at low tide occur in the River Shannon at Limerick, a distance of about 50km downstream of the Mudflats and sandflats project. Given the characteristics of the project, it is not considered that the zone of influence of the project will extent this far. The project will not covered by seawater No not have a significant effect on Mudflats and Sandflats. Thus, the project will not affect the conservation objectives for Mudflats and Sandflats at low tide and the habitat is not considered further in the NIS. The closest lagoon is the Shannon Airport Lagoon of 24.2ha. This lagoon is located ca. 60km west of the proposed development. Due to Coastal lagoons No geographical separation, the project will not affect the conservation objectives for coastal lagoons and the habitat is not considered further in the NIS. The Annex I habitat shallow inlets and bays is a large physiographic feature that may wholly or partly incorporate other Annex I habitats including Large shallow inlets and reefs, sandbanks and mudflats and sandflats within its area. Large shallow inlets and bays is mapped ca. 120km west of the proposed No bays development. Due to geographical separation, the project will not affect habitat area or community distribution, therefore the conservation objectives for Large shallow inlets and bays will not be affected and the habitat is not considered further in the NIS. Reef habitat occurs in the Shannon Estuary in excess of 50km west (60rkm downstream) of the proposed development. The distribution of Reef Reefs No will not be destabilised or reduced by the propose development taking account of the geographical separation. Thus, the project will not affect the conservation objectives for Reefs and the habitat is not considered further in the NIS This habitat occurs along the coast where shingle (cobbles and pebbles) and gravel have accumulated to form elevated ridges or banks above the high tide mark. The current area and extent is unknown and unmapped. At its closest, this habitat occurs at Ballymacrinan Bay, a distance in Perennial vegetation of No excess of 100km west of the project. Given the characteristics of the project, it is not considered that the zone of influence of the project will stony banks extend this far. The project will not have a significant effect on Perennial vegetation of stony banks. Thus, the project will not affect the conservation objectives for Perennial vegetation of stony banks and the habitat is not considered further in the NIS. Vegetated sea cliffs of No Vegetated sea cliffs of the Atlantic and Baltic coasts occur at the western extent of the Shannon Estuary. At its closest, this habitat is located at
29
18150-6011-B Natura Impact Statement August 2018
Potential for Qualifying Feature Rationale Significant Impacts the Atlantic and Baltic Baurrane on the southern coast of Co. Clare, in excess of 100km west of the proposed development. The project will not have any effect on this coasts habitat. Thus, the project will not affect the conservation objectives for Vegetated sea cliffs of the Atlantic and Baltic coasts and the habitat is not considered further in the NIS Salicornia and other annuals colonising mud and sand is a pioneer saltmarsh community that may occur on muddy sediment seaward of Salicornia and other established saltmarsh, or form patches within other saltmarsh communities where the elevation is suitable and there is regular tidal inundation. annuals colonizing mud No The habitat extent is unmapped but it lies at least a distance of about 40km downstream of the project. Given the characteristics of the project, and sand it is not considered that the zone of influence of the project will extend this far. The project will not have a significant effect on this Salicornia habitat. Thus, the project will not affect the conservation objectives for Salicornia habitat and the habitat is not considered further in the NIS. Atlantic salt meadows generally occupy the widest part of the saltmarsh gradient. They also contain a distinctive topography with an intricate network of creeks and salt pans occurring on the medium to large sized saltmarshes. Atlantic salt meadows contain several distinctive zones that Atlantic salt meadows are related to elevation and submergence frequency. The most upstream extent of the habitat is mapped at the margins of the estuary to the (Glauco-Puccinellietalia No west of Limerick City, a distance in excess of 40km downstream of the project. Given the characteristics of the project, it is not considered that maritimae) the zone of influence of the project will extend this far. The project will not have a significant effect on Atlantic salt meadows. Thus, the project will not affect the conservation objectives for Atlantic salt meadows and the habitat is not considered further in the NIS. Mediterranean salt meadows occupy the upper zone of saltmarshes and usually occur adjacent to the boundary with terrestrial habitats. They are widespread on the Irish coastline, however they are not as extensive as Atlantic salt meadows. The most easterlyextent of the habitat is Mediterranean salt mapped in the Shannon River estuary, a distance of about 50km downstream of the project. Given the characteristics of the project, it is not meadows (Juncetalia No considered that the zone of influence of the project will extend this far. The project will not have a significant effect on Mediterranean salt maritimi) meadows. Thus, the project will not affect the conservation objectives for Mediterranean salt meadows and the habitat is not considered further in the NIS. The EU (2003) definition of this habitat is very broad, especially when the presence of aquatic mosses is taken into account. Using this broad Water courses of plain to definition the habitat will be found in most watercourses in Ireland. The full distribution of this habitat and its sub-types in this site are currently montane levels with the unknown. The dominant floating-leaved species appears to be the common and widespread stream water-crowfoot. The moss Fontinalis Ranunculion fluitantis Yes antipyretica is present throughout the major river systems within the Lower River Shannon cSAC and likely occurs on rocky substrates in the and Callitricho- Newport River. Therefore, ‘Floating river vegetation’ as the habitat is commonly known is considered to be within the zone of influence of the Batrachion vegetation project and thus, there is potential for significant effects to this habitat. This habitat has been recorded on the eastern bank of the Shannon, just north of Castleconnell, Co. Limerick (NPWS, 2012a). Full distribution of Molinia meadows on this habitat in this site is currently unknown and it almost certainly occurs elsewhere. The proposed development will not bring about a decline in calcareous, peaty or the habitat distribution or any other attribute of this feature within the Lower River Shannon cSAC. There is no such habitat within or adjacent to No clayey-silt-laden soils the site, or within the hydrological influence of the proposed development site. The list of attributes and targets given in NPWS (2012a) will not (Molinion caeruleae) be affected. Thus, the project will not affect the conservation objectives for Molinia meadows on calcareous, peaty or clayey-silt-laden soils and the habitat is not considered further in the NIS. Old sessile oak woods Old sessile oak woods habitat is defined in the interpretation manual of EU habitats as "acidophilous Quercus petraea woods, with low, low- No with Ilex and Blechnum branched, trees, with many ferns, mosses, lichens and evergreen bushes”. These woodlands occur on acid or base-poor soils that may be either
30
18150-6011-B Natura Impact Statement August 2018
Potential for Qualifying Feature Rationale Significant Impacts in British Isles dry or humid, but not waterlogged. There is only one such woodland mapped within the SAC, along the main river channel of the Cahernahallia River in excess of 17km SE of Newport. Given the terrestrial nature and extent of the habitat, it is not considered to be within the zone of influence of the project. The project will not have a significant effect on Old oak woodlands. Thus, the project will not affect the conservation objectives for Old oak woodlands and the habitat is not considered further in the NIS. Alluvial forests with The interpretation manual of EU habitats 2007 states that all habitat types occur on heavy soils which are periodically inundated by the annual Alnus glutinosa and rise of river levels, but which are otherwise well drained and aerated during low water. In addition there are gallery forests of tall willows Fraxinus excelsior (Alno- No (Salicion albae) alongside river channels and occasionally on river islands, where the tree roots are almost continuously submerged. The nearest Padion, Alnion incanae, mapped habitat of this type is at Clare Glens along the main channel of the Clare River. This habitat does not occur downstream of the site. Thus, Salicion albae) the project will not affect the conservation objectives for alluvial woodlands and the habitat is not considered further in the NIS. The freshwater pearl mussel occurs in the Cloon River in Co. Clare within the Lower River Shannon cSAC. The Cloon River enters the main Freshwater pearl mussel Shannon Estuary in excess of 40km west of Limerick City, a significant distance downstream of the proposed development. This population (Margaritifera No therefore would not be impacted by the proposed development. Therefore, FPM is not within the zone of influence of the project and thus, margaritifera) there is no potential for significant effects to FPM and the species is not considered further in the NIS. Sea Lamprey s often spawn in the lower reaches of rivers but also migrate 50 miles and more upstream; the Sea Lamprey is commonly seen in Sea Lamprey Yes the Mulkear River. Lamprey has been recorded along the main river channel and many of its tributaries downstream of the project and thus, (Petromyzon marinus) there is potential for significant effects to the species. Brook Lamprey live their entire life in freshwater. They have been recorded along the main channel of the Mulkear and Newport River. Brook Lamprey Yes Therefore, Brook Lamprey is considered to be within the zone of influence of the project and thus, there is potential for significant effects to the (Lampetra planeri) species. River lampreys often spawn in the lower reaches of rivers but also migrate 50 miles and more upstream (Kurz and Costello, 1999). Juvenile River lamprey (Lampetra Yes lamprey have been recorded along the main river channel of the Mulkear and many of its tributaries. Therefore, River Lamprey is considered to fluviatilis) be within the zone of influence of the project and thus, there is potential for significant effects to the species. Salmon use rivers to reproduce and as nursery areas during their juvenile phase. Juvenille Salmon typically spend two winters before going to sea Atlantic Salmon (Salmo in spring as smolts. Most of the Irish fish spend one winter at sea before returning to their natal rivers. Salmon use the main channel of the Yes salar) Newport River and its tributaries. Therefore, Salmon is considered to be within the zone of influence of the project and thus, there is potential for significant effects to the species. There is a resident population of Bottle-nosed Dolphin in the Shannon Estuary. This is the only known resident population of this E.U. Habitats Common Bottlenose Directive Annex II species in Ireland. The Shannon Estuary is more than 50km downstream of the proposed development. Dolphin’s access to Dolphin (Tursiops No suitable habitat, including to critical areas, would not be affected by the proposed project and there would be no disturbance impacts. Therefore, truncates) Bottlenose Dolphin is not within the zone of influence of the project and thus, there is no potential for significant effects and the species is not considered further in the NIS. Otter have two basic requirements: aquatic prey and safe refuges where they can rest. Otter occur upstream and downstream of Newport. Otter (Lutra lutra) Yes Therefore, Otter is considered to be within the zone of influence of the project and thus, there is potential for significant effects to the species.
31
18150-6011-A Natura Impact Statement August 2018
5.1.1.1 Floating River Vegetation The EU (2003) definition of this habitat is very broad, especially when the presence of aquatic mosses is taken into account. Using this broad definition the habitat will be found in most watercourses in Ireland. The full distribution of this habitat and its sub-types in this site are currently unknown. The dominant floating-leaved species appears to be the common and widespread stream water-crowfoot. The basis for the selection of the SAC for the habitat was the presence of plant species that are listed as characteristic of the habitat, such as Batrachian species of Ranunculus, Potamogeton spp. and Fontinalis antipyretica (NPWS, 2012b). The sub-types of this habitat are poorly understood and their typical species have not yet been defined. The typical species may include higher plants, bryophytes, macroalgae and microalgae. River connectivity with the floodplain is essential for the functioning of this habitat. Review of the available data identifies three high conservation elements (sub-types) in the site, namely:
1. Groenlandia densa (L.) Fourr., Opposite-leaved Pondweed; 2. Schoenoplectus triqueter (L.) Palla;and 3. Triangular Club-rush Bryophyte-rich streams and rivers.
The first two sub-types are associated with tidal reaches of rivers, while the latter sub-type is found in fast-flowing stretches of unmodified streams and rivers. In addition to these three sub-types, it is likely that other high conservation value sub-types exist within the site. Further investigation of all sub-types is required (NPWS, 2012b).
Based on the broad definition of this habitat and while the full distribution of the habitat is unknown, it is considered that there is potential for it to be present within the main channel of the Newport River downstream of the project site. The stretch of river adjacent to the proposed development site is heavily shaded and is therefore deemed suboptimal with regard to a range of aquatic plants such as Ranunculus sp. The moss Fontinalis antipyretica is present throughout the major river systems within the Lower River Shannon cSAC and likely occurs on rocky substrates in the Newport River.
Phosphorous is typically the limiting nutrient, however increased nitrogen negatively impacts upon some aquatic plant communities. Nutrient enrichment leads to increased levels of filamentous green algae changes in Floating river vegetation species composition and abundance. Water quality should reach a minimum of Good status.
The main pressures to this habitat include a reduction in water quality and the main cause of this is agriculture. There has been a decline in high quality river sites between 1987 and 2008 across the country. While the habitat can tolerate moderate levels of pollution this has implications for the most oligotrophic habitat sub-types. The main problems for river habitats are the pollution of waters from eutrophication and other sources. Nutrient and organic losses from agriculture and municipal and industrial discharges are the most significant pressures and threats. While significant measures are being implemented to address pollution from regulated discharges and domestic wastewater systems, action to reduce losses from agriculture, the largest source of phosphorus to water is considered inadequate and there are currently no measures to address the impacts of peatland drainage and general degradation.
32
18150-6011-C Natura Impact Statement September 2018
The conservation status of ‘Floating river vegetation’ is considered ‘Unfavourable-Inadequate’.
5.1.1.2 Sea Lamprey All three species of lamprey spawn in fresh waters, and juveniles of all three species, known as ammocoetes, are found within the same catchments, using similar microhabitats, but with varying geographical distribution. Lampreys show a preference for gravel-dominated substratum for spawning, and mainly silt and sand-dominated substratum for nursery habitat (Harvey & Cowx, 2003).
Sea Lamprey migrate to sea only returning to rivers to spawn (Kurz and Costello, 1999). Sea Lamprey build nests (redds) and spawn in large and small rivers, usually at the downstream end of pools where there is a swift current. The Sea Lamprey usually spawns in late May or June, when the water temperature reaches at least 15⁰C (Maitland, 2003). They like sediments made up of small cobbles and pebbles for spawning. Once they hatch, the larvae called ammocoetes swim out of the nest and are washed downstream, where they accumulate in areas with slower water current e.g. backwaters, current eddies or behind big stones on the river bed. There the ammocoetes bury themselves in stable sandy silt rich in organic matter, where they remain until they become adults. After 3 to 6 years the ammocoetes become adults usually between July and September. Sea Lamprey and River Lamprey are known to spawn in the Shannon and in several tributaries (Kurz & Costello, 1999). On the main channel of the Shannon, anadromous sea and River Lampreys are generally limited to below the Shannon scheme (although there are some movements of individuals at the fish lock at Ardnacrusha each year.
Sea Lamprey s often spawn in the lower reaches of rivers but also migrate 50 miles and more upstream. The Sea Lamprey is commonly seen in the River Mulkear below the weir in Annacotty. The weir at Annacotty has been identified as a barrier to migrating lampreys and may still impede upstream migrating Sea Lamprey despite MulkearLIFE17 attempts to improve passage. There has been no catchment-wide survey of lamprey in the Mulkear catchment. Sea Lamprey has been recorded by the author as far upstream as Barrington’s Bridge, where a juvenile Sea Lamprey was recorded in the main channel of the Killeengarriff River ca. 11km downstream of Newport. There are suitable spawning areas and silt beds in the main channel of the Newport River adjacent to and downstream of the proposed development. Adult densities in this watercourse are likely to be low during the spawning season, noting that the spawning migration usually takes place from April with spawning between May and June.
Pollution to surface water from diffuse and point sources is a constant threat to aquatic organisms. Both adult and ammocoete life stages for lamprey have been shown to be vulnerable to the effects of pollution. The single largest pressure acting on adult Sea Lamprey is the presence of artificial physical barriers to passage for upstream migrating fish. The overall Conservation Status of the species is considered Bad in view of barriers to migration in view of low population levels recorded.
5.1.1.3 River Lamprey River Lamprey Lampetra fluviatilis are anadromous species, spending part of their life cycle in the marine environment and returning to natal watercourses to spawn. River Lamprey build nests
17 http://mulkearlife.com/inland-fisheries-ireland-replaced-lamprey-tiles-annacotty-weir-mulkear-river/
33
18150-6011-C Natura Impact Statement September 2018
(redds) and spawn in large and small rivers, usually at the downstream end of pools where there is a swift current and like sandy or gravelly sediment for spawning (Kurz and Costello, 1999). Spawning of river lampreys starts when the water temperature reaches 10–11⁰C, usually in March and April (Morris & Maitland 1987).
Given the difficulty differentiating juvenile Brook and River Lamprey, most studies group these two species together as Lampetra sp. Taking into account the passage problems at Annacotty and the relatively poor swimming capability of River lamprey, they are likely to occur in low numbers upstream of Annacotty weir. A recent post highlighted the issue of River lamprey passage at Annacotty in late March 201718, where a large accumulation of river lampreys were seen attempting to ascend the weir. It was pointed out that ‘even early run River Lampreys cannot pass here as this weir is never flooded out and there are no side channels etc. where lampreys can pass. This is a total barrier for River Lamprey (and Brook Lamprey L. planeri) migration…. The lampreys eventually give up and drop downstream to spawn below the weir. However, this causes them excessive stress and subjects them to very high levels of predation, and puts them at risk of disease’.
The main threats to River Lamprey are and river engineering, exploitation as bait by anglers and invasive molluscs on spawning beds.
The status of river lamprey is evaluated as being of 'Favourable' conservation status nationally (NPWS, 2013).
5.1.1.4 Brook Lamprey The Brook Lamprey Lampetra planeri is the smallest of the three lamprey native to Ireland and it is the only one of the three species that is non-parasitic and spends all its life in freshwater (Maitland & Campbell, 1992). The spawning season of Brook Lampreys starts when the water temperatures reach 10–11⁰C (Maitland, 2003). This usually occurs in March/April. Ammocoetes of the three lamprey species are often found in the same locations while Brook Lamprey can inhabit smaller streams often occurring closer to headwaters. Brook Lamprey tends to spawn at the downstream end of pools, but often in smaller rivers and in slightly shallower and slower flowing water building a nest in sandy or gravelly sediment (Kurz and Costello, 1999).
The main threats to the Brook Lamprey population arise from dredging and removal or sediments (which lamprey inhabit) and pollution of surface waters. Pollution to surface water from diffuse and point sources is a constant threat to aquatic organisms. Both adult and ammocoete life stages for lamprey have been shown to be vulnerable to the effects of pollution.
The status of Brook Lamprey is evaluated as being of 'Favourable' conservation status nationally (NPWS, 2013).
5.1.1.5 Atlantic Salmon Salmon use rivers to reproduce and as nursery areas during their juvenile phase. Juvenile Salmon typically spend two winters before going to sea in spring as smolts. Most of the Irish fish spend one winter at sea before returning to their natal rivers.
18 https://lampreysurveys.com/2017/04/16/thousands-of-river-lampreys-trapped-below-limerick-weir/
34
18150-6011-C Natura Impact Statement September 2018
The Technical Expert Group on Salmon19 is tasked with providing an annual report on the status of Salmon stocks for the purpose of advising the North South Standing Scientific Committee on Inland Fish on the sustainable management of Irish Salmon stocks. The Mulkear River was listed as a watercourse with a forecasted Salmon deficit, or below the required Conservation Limit (CL) for 2018 (TEGOS, 2018). The Conservation Limit applied by the Standing Scientific Committee for Salmon (SSCS) to establish the status of individual stocks is the “maximum sustainable yield” (MSY), also known as the stock level that maximizes the long-term average surplus, as defined and used by the International Council for the Exploration of the Sea (ICES) and the North Atlantic Salmon Conservation Organisation (NASCO). An index of at least 17 Salmon fry per 5 minute standardised electrofishing is used by the SSC as the cut-off between rivers below this threshold where the stock is clearly below Conservation Limits and those rivers above the threshold where it is more likely that the stock is meeting Conservation Limits (SSCS, 2016). The Mulkear River has a CL of 4214 and has a deficit of 719, reaching only 0.83 of its CL. It is therefore listed as a closed fishery in the 2018 Salmon Angling Regulation.
The water quality of the Newport River is adequately high for the spawning and rearing purposes of Salmonids. The Newport River is considered optimal habitat for spawning (good gravel beds and pool-glide sequences) and nursery grounds (riffle habitat with rocky substrate). The channel is large enough and has sufficiently deep pools to hold adult Salmon.
Pressures to Salmon arises from water pollution while threats relate to factors causing mortality at sea such as predation by seals, disease, parasites, pollution and climate change. Salmon require a ‘Q4’ water quality status at all sites sampled by the EPA and is currently being achieved at the stations upstream and downstream of Newport. The Conservation Status of Salmon is considered to be Unfavourable-Inadequate as the population is still low in comparison to previous decades.
5.1.1.6 Otter In Ireland, Otter populations are found along clean rivers and lakes, where fish and other prey are abundant, and where the adjacent habitat offers plenty of cover. Otters maintain territories and will defend their stretches of river bank or lake shore from other Otters. In lowland rivers and fish-rich lakes, Otters only need to maintain small territories. In freshwater areas, a variety of fish from sticklebacks to Salmon and Eels will be taken, while Crayfish and Frogs can be important locally or seasonally.
The Otter is widespread throughout the country, in freshwater and coastal habitats, and Ireland has long been considered to hold one of the most important Otter populations in Western Europe (Whilde, 1993). Otters can, potentially, exploit all stretches of a river system where they are present.
19https://www.fisheriesireland.ie/extranet/fisheries-management-1/Salmon/1496-the-status-of-irish-Salmon- stocks-in-2017-with-catch-advice-for-2018/file.html
35
18150-6011-C Natura Impact Statement September 2018
Figure 6: Otter habitat extents at and adjacent to the proposed development site.
The ecological survey conducted for this project (see Section 4.5.4 above) considered that Otters may potentially utilise the habitats adjacent to the proposed development site. The built-up nature and the disturbance through human activity in the surrounding area would make the section of river in close proximity to the proposed development unfavourable for this timid species. There was no evidence of an Otter holt in the stretch of the Newport River from 50m upstream to 50m downstream of the proposed development site. The freshwater and terrestrial habitat extents of Otter have been included in NPWS (2012a). These habitats adjacent to the proposed development site are indicated in Figure 6. The extent of terrestrial habitat is based on areas mapped to include a 10m terrestrial buffer along river banks, identified as critical for Otters (NPWS, 2007). The extent of freshwater habitat is calculated on the basis that Otters will utilise freshwater habitats from estuary to headwaters (Chapman and Chapman, 1982).
36
18150-6011-C Natura Impact Statement September 2018
Impacts that reduce the availability or quality of, or cause disturbance to, their terrestrial or aquatic habitats are likely to affect Otters. The main threats to Otters in Ireland are thought to be: habitat destruction (including river drainage and the clearance of bankside vegetation); pollution, particularly organic pollution resulting in fish kills; and accidental deaths (road traffic and fishing gear).
The conservation status of Otter is considered ‘Good’ given the widespread nature of its distribution throughout Ireland and its presence in a wide variety of habitat types.
5.2 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS
5.2.1 Water Quality
5.2.1.1 Construction Phase The footprint of the proposal is adjacent to and hydrologically connected to the Newport River, part of the Lower River Shannon cSAC. The construction phase of the proposed development will require demolition of existing housing floors and foundations, excavation, construction and landscaping. It will have direct impacts on the habitats within the proposed development site including terrestrial components of the Lower River Shannon cSAC adjacent to the Newport River. There will be potential impacts on the Newport River in terms of habitats, flora, fauna, water quality and fish through surface run-off. Pollution of the Newport River could be transferred to other fluvial habitats including the main channel of the Mulkear River.
The most likely potential impact of the project on receiving watercourses and aquatic habitats during the construction phase is the release of pollutants via runoff. These indirect impacts could arise through the disturbance, storage and spreading of soil, through excavated spoil, via hydrocarbon discharges or loss of concrete. Contamination or water quality impacts on the Newport River could result in impacts on the aquatic ecosystem and therefore the species that are dependent on good water quality for survival. The current water quality status of the Newport River (High) increases its sensitivity to pollution.
Any engineering works which cause runoff of sediments can also increase the levels of nutrients in receiving waters. This can potentially result in the enrichment or eutrophication of the affected areas downstream, and a possible change in water quality.
Another indirect potential adverse effect on fluvial habitats of downstream areas, and particularly within the Newport River is siltation of Salmon and Lamprey spawning gravels. Any pollution events may potentially have significant indirect effects on the aquatic species Salmon, Lampreys and Otter and the habitat ‘Floating river vegetation’.
The potential significant impacts of the project on aquatic ecology (without mitigation) are summarised as follows:
Pollution of watercourses with suspended solids due to runoff of sediment from construction and landscaped areas. Contamination of water courses with suspended solids may have the potential to impact on aquatic flora and fauna within the Newport River;
37
18150-6011-C Natura Impact Statement September 2018
Pollution of watercourses with nutrients due to ground disturbance during construction. The main potential sources of nutrient inputs to freshwater due to ground disturbance are from nutrients adsorbed or chemically bound to eroded suspended solids; Pollution of watercourses during construction phase, with other substances such as fuels, lubricants, waste concrete, waste water from wash facilities, etc; and Pollution of watercourses with surface drainage water from paved areas and road surfaces.
Releasing non-attenuated suspended solids and heavily contaminated run-off waters into the stormwater drainage that runs through the site has the potential to have a negative impact on the water quality of the Newport River. This would potentially be a temporary but significant negative impact. The risk of occurrence however can be adequately prevented by the implementation of standard best management practices and controls.
The proposed development land is brownfield and therefore, there is a risk of the presence of contaminated soils. As the site is generally located within the area of high aquifer vulnerability there is potential for significant risk to groundwater quality during the construction. Impacts on groundwater could have harmful effects on the Lower River Shannon cSAC if ground waters affected by the proposed development reach the Newport River.
5.2.1.2 Operation Phase The primary sources of potential operational phase impacts are predicted to be the completed park’s drainage system. Runoff from hard and impermeable surfaces may result in contaminated water reaching the Newport River.
5.2.2 Habitat loss The proposed development will involve works within the Lower River Shannon cSAC adjacent to the Newport River. There will be loss of ‘Treeline’, ‘Scrub’, ‘Recolonising bare ground’ and ‘Spoil and bare ground’ habitats within the Lower River Shannon cSAC. It is noted that these habitats are largely artificial and/or comprised of non-native species.
5.2.3 Habitat alteration There is the potential that aquatic habitats within the Newport River may be altered as a result of the ingress of pollutants and/or sediment during the construction phase.
A reduction in water quality due to chemicals or other substances entering the Newport River as a result of the construction phase of the proposed development could potentially have an impact on the habitats required by aquatic species for the various stages of their life cycles. One of the main risks is the siltation of gravel beds suitable for spawning Salmon and Lamprey which would reduce the availability of the habitat and if present, reduce oxygen levels to fish eggs or juvenile mussels occupying the substrate interstices. Nutrients such as phosphorous which are often bound to sediments could result in eutrophication and an increase in filamentous algae, which in turn can grow on gravels reducing the availability of the habitat and if present, reduce oxygen levels to fish eggs or juvenile mussels occupying the substrate interstices. An increase in polluting substances such as oils, fuels and cementitious materials in the water could reduce the suitability of the habitat for populations of Salmon, Lamprey and Otter, as well as affecting the river’s capacity to support floating rive vegetation.
38
18150-6011-C Natura Impact Statement September 2018
The spread of non-native species within the proposed development site, including further colonisation of invasive species along riparian areas of the Newport River and potentially other areas due to earth and heavy machinery movements would lead to alteration of habitats. The eradication of Giant Hogweed as per the non-native species management plan will likely result in an improvement to the understory floral composition associated with the treeline along the Newport River.
5.2.4 Disturbance and/or displacement of species There is potential for indirect disturbance or displacement of species arising from potential pollutants entering the Newport River during the construction phase of the proposed works. Pollutants include silt, chemicals or hydrocarbons associated with construction activities. Spawning Salmon and lamprey and juveniles mussels need a clean well aerated riverbed substrate to survive. Siltation of the substrate and eutrophication leading to increased biomass of filamentous algae would reduce the available suitable habitat. A reduction in water quality in the water column can reduce the suitability of the river for adult Salmon, Lamprey and Otter, resulting in disturbance/displacement of these species.
5.2.5 Habitat or species fragmentation There is potential for pollutants to enter the Newport River during the construction phase. Habitat and species fragmentation can be caused by polluted stretches of water, where fish cannot survive and where fish can be prevented from moving to spawning areas. A reduction in the quality of the river bed arising from siltation could fragment the available suitable habitat for spawning Salmon and Lamprey. Impacts on fish could have negative consequences for Otter.
5.3 ASSESSMENT OF EFFECT ON LOWER RIVER SHANNON CSAC CONSEVATION OBJECTIVES
5.3.1 Introduction In Section 5.1.1 above, an evaluation was undertaken to determine which of the qualifying interests of the Lower River Shannon cSAC potentially lie within the zone of influence of the project and required further assessment in the NIS. This was done through a scientific examination of ecological evidence and data listed above in Section 3.2 or referenced, as well as the results of the ecological field surveys (Section 4.5). The effects of the project on the qualifying interests, potentially within the zone of influence of the project, have been assessed against the measures designed to achieve the conservation objectives. The outcome of the assessment has been presented in the following sections.
39
18150-6011-C Natura Impact Statement September 2018
5.3.2 Floating River Vegetation The definition of this habitat is very broad, thus the habitat will be found in most watercourses in Ireland. The main pressures to this habitat include a reduction in water quality. The following table assesses the effects of the project against the measures designed to achieve the conservation objectives for ‘Floating river vegetation’. Where a measure may be negatively affected by the project the need for mitigation is indicated.
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required The full extent of this habitat is unknown. It is assumed to be downstream in the main channel on the basis of its broad definition and the precautionary principle. The construction Habitat Area stable or phase of the project could potentially result in sediment area/ Yes increasing release from excavations and deposit silt in the main channel Kms possibly affecting the area of the habitat downstream. Therefore, there is potential for this conservation objective to be negatively affected. The full distribution of this habitat and its sub-types within the site are unknown and the definition of Floating river vegetation is broad. The construction phase of the project Habitat could potentially result in sediment release from excavations distribution/ No decline Yes and deposit silt in the main channel possibly affecting the Occurrence distribution of the habitat downstream. Therefore, there is potential for this conservation objective to be negatively affected. A natural flow regime is required for both plant communities Hydrological Maintain and channel geomorphology to be in favourable condition. The regime: river appropriate project will not affect the hydrological regime of the No flow/ hydrological downstream watercourses. No significant effects to m/s regimes conservation objective anticipated. Hydrological Tidal regime appears to be an important influence on the regime: tidal Maintain distribution of certain pondweed. The project will not affect influence/ natural tidal the hydrological regime of the downstream tidally influenced No Daily regime areas. No significant effects to conservation objective fluctuations anticipated. Hydrological Maintain Freshwater seepages are considered important for both the regime: appropriate Groenlandia densa and Scheonoplectus triqueter subtypes. freshwater freshwater These habitats are in excess of 30km from the proposed No seepages/ seepage development and freshwater seepage regimes will not be m/s regimes affected to this extent. Substratum The size and distribution of substratum particles is largely Substratum dominated by determined by the river flows. The construction phase of the composition: sizes project could potentially result in sediment release from particle size Yes appropriate to excavations and deposit silt in the main channel. Therefore, range/ habitat sub- there is potential for this conservation objective to be mm type negatively affected. Water Concentration Phosphorous (MRP) is typically the limiting nutrient, however Yes quality: of nutrients increased nitrogen negatively impacts upon some aquatic
40
18150-6011-C Natura Impact Statement September 2018
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required Nutrients/ sufficiently low plant communities. Nutrient enrichment typically leads to mg/l to prevent increased filamentous algae biomass and consequent changes changes in in algae, bryophyte and macrophyte species composition and species abundance. The construction phase of the project could composition or potentially result in nutrient release. Therefore, there is habitat potential for this conservation objective to be negatively condition affected. The sub-types of this habitat are poorly understood and their Vegetation Typical species typical species have yet to be defined. They may include higher composition; of the habitat plants, bryophytes and microalgae. The construction phase of typical sub-type the project could potentially result in nutrient release, which Yes species/ present & in could alter vegetation composition. Therefore, there is Occurrence good condition potential for this conservation objective to be negatively affected. River connectivity with the floodplain is essential for the Floodplain Maintain area functioning of this habitat and is particularly important in connectivity: of active terms of sediment sorting and nutrient deposition. The project No area/ floodplain will not affect floodplain connectivity within the catchment. No Ha habitat significant effects to conservation objective anticipated. The area of riparian woodland at and While some trees are potentially affected, riparian woodland Riparian upstream of of conservation value (alluvial) will not. The trees affected are habitat/ No the in an area that is not strongly connected to the hyporheic zone Area bryophyte‐rich of the river. sub‐type should be maintained
41
18150-6011-C Natura Impact Statement September 2018
5.3.3 Sea Lamprey There is potential for suitable spawning areas and silt beds to occur in the main channel. Adults are also likely to be present along the main channel during the spawning season (April-June), albeit in low densities. The following table assesses the effects of the project against the measures designed to achieve the conservation objectives for Sea Lamprey. Where a measure may be negatively affected by the project the need for mitigation is indicated.
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required > 75% of main stem Distribution/ river The project will not result in the physical impediment to the % of river lengths migration of fish. No significant effects to conservation objective No accessible accessible anticipated. from estuary Lamprey can be present as juveniles for several years after hatching Population from eggs, and as adults before migration to sea and following structure of At least 3 migration for several months before spawning. The construction juveniles/ age/size phase of the project could potentially result in sediment release Yes Number of groups from excavations and silt up clean gravels in the main channel and age/size present reduce oxygen levels to the eggs. Therefore, there is potential for groups this conservation objective to be negatively affected. Juvenile Juveniles live buried in silt beds. The construction phase of the density in Juvenile project could potentially result in release of pollutants in the main fine density at channel and affect the quality of the water associated with the silt Yes sediment/ least 1 per beds. Therefore, based on the precautionary principle, there is Juveniles m2 potential for this conservation objective to be negatively affected. per m2 Extent and No decline The construction phase of the project could potentially result in distribution in extent & sediment release from excavations and silt up clean gravels in the of spawning distribution main channel and reduce oxygen levels to the eggs. Therefore, Yes habitat/ of there is potential for this conservation objective to be negatively m2 and spawning affected. occurrence beds Availability of juvenile Juvenile habitat consists of silt beds in slower-flowing reaches of More than habitat/ the river. The project will not affect the stability of the substrate. 50% Number of The construction phase of the project could potentially result in sample Yes positive release of pollutants in the main channel and affect the quality of sites sites in 3rd the water associated with the silt beds. Therefore, there is potential positive order for this conservation objective to be negatively affected. channels
42
18150-6011-C Natura Impact Statement September 2018
5.3.4 River Lamprey Taking into account the passage problems at Annacotty and the relatively poor swimming capability of River lamprey they are unlikely to be encountered in significant numbers upstream of the weir at Annacotty, but may occur in the Newport River in low densities. The following table assesses the effects of the project against the measures designed to achieve the conservation objectives for River lamprey. Where a measure may be negatively affected by the project the need for mitigation is indicated.
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required Access to all Distribution/ watercourses The project will not result in the physical impediment to % of river down to first the migration of fish. No significant effects to conservation No accessible order objective anticipated. streams Lamprey can be present as juveniles for several years after hatching from eggs, and as adults before migration to sea and following migration for several months before spawning. Taking into account the passage problems at Annacotty (weir) and the relatively poor swimming Population capability of River lamprey they are likely to found in low At least 3 structure of numbers upstream of the weir. However, it is age/size juveniles/ acknowledged that there is potential for spawning sites to Yes groups Number of be present downstream of the project. The construction present age/size groups phase of the project could potentially result in sediment release from excavations and silt up clean gravels in the main channel and reduce oxygen levels to the eggs. Therefore, based on the precautionary principle, there is potential for this conservation objective to be negatively affected. Juveniles live buried in silt beds. The construction phase of Juvenile the project could potentially result in release of pollutants Juvenile density in density at in the main channel and affect the quality of the water fine sediment/ Yes least 2 per associated with the silt beds. Therefore, based on the Juveniles per m2 m2 precautionary principle, there is potential for this conservation objective to be negatively affected. Taking into account the passage problems at Annacotty (weir) and the relatively poor swimming capability of River lamprey they are likely to found in low numbers upstream No decline in of the weir. However, it is acknowledged that there is Extent and extent & potential for spawning sites to be present downstream of distribution of distribution the project. The construction phase of the project could Yes spawning habitat/ of spawning potentially result in sediment release from excavations and m2 and occurrence beds silt up clean gravels in the main channel and reduce oxygen levels to the eggs. Therefore, based on the precautionary principle, there is potential for this conservation objective to be negatively affected. Availability of More than Juvenile habitat consists of silt beds in slower-flowing Yes juvenile habitat/ 50% sample reaches of the river. The project will not affect the stability
43
18150-6011-C Natura Impact Statement September 2018
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required Number of sites positive of the substrate. The construction phase of the project positive sites in 2nd could potentially result in release of pollutants in the main order channels channel and affect the quality of the water associated with (and the silt beds. Therefore, based on the precautionary greater), principle, there is potential for this conservation objective downstream to be negatively affected. of spawning areas
44
18150-6011-C Natura Impact Statement September 2018
5.3.5 Brook Lamprey Brook Lamprey occur in the Newport River adjacent to the downstream of the proposed development. The following table assesses the effects of the project against the measures designed to achieve the conservation objectives for Brook Lamprey. Where a measure may be negatively affected by the project the need for mitigation is indicated.
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required Distribution/ The project will not result in the physical impediment to Access to all % of river the movement of fish. No significant effects to No watercourses accessible conservation objective anticipated. Lamprey can be present as juveniles for several years after hatching from eggs, and as adults before spawning. Brook Lamprey tends to spawn at the downstream end of Population pools, but often in smaller rivers and in slightly shallower structure of and slower flowing water building a nest in sandy or juveniles/ At least 3 age/size gravelly sediment. The construction phase of the project Yes Number of groups present could potentially result in sediment release from age/size excavations and silt up clean gravels downstream and groups reduce oxygen levels to the eggs. Therefore, there is potential for this conservation objective to be negatively affected. Juveniles live buried in silt beds. The construction phase Juvenile of the project could potentially result in release of density in fine Juvenile density pollutants in the main channel and affect the quality of sediment/ Yes at least 2 per m2 the water associated with the silt beds. Therefore, based Juveniles per on the precautionary principle, there is potential for this m2 conservation objective to be negatively affected. Extent and The construction phase of the project could potentially distribution of No decline in result in sediment release from excavations and silt up spawning extent & clean gravels in the main channel and reduce oxygen Yes habitat/ distribution of levels to the eggs. Therefore, there is potential for this m2 and spawning beds conservation objective to be negatively affected. occurrence Availability of juvenile Juvenile habitat consists of silt beds in slower-flowing habitat/ reaches of the river. The project will not affect the Number of stability of the substrate. The construction phase of the positive sites More than 50% project could potentially result in release of pollutants in in 2nd order sample sites Yes the main channel and affect the quality of the water channels (and positive associated with the silt beds. Therefore, based on the greater), precautionary principle, there is potential for this downstream conservation objective to be negatively affected. of spawning areas
45
18150-6011-C Natura Impact Statement September 2018
5.3.6 Atlantic Salmon The Newport River is considered an important habitat for Salmon spawning (good gravel beds and pool-glide sequences) and is also regarded as a suitable Salmon nursery area (riffle habitat with rocky substrate). The channel is large enough and has sufficiently deep pools to hold adult Salmon. Water quality is adequate for juvenile Salmonids and young Salmon were recorded in the Newport River adjacent to the proposed development site during the current survey. The following table assesses the effects of the project against the measures designed to achieve the conservation objectives for Atlantic Salmon. Where a measure may be negatively affected by the project the need for mitigation is indicated.
Attribute/ Target Assessment of Potentially Significant Effects Mitigation Measure 100% of river Distribution/ The project will not result in the physical impediment of the channels to 2nd % of river migration of fish. No significant effects to conservation No order accessible accessible objective anticipated. from estuary Conservation The Mulkear River (includes the Newport River) is below its Adult Limit (CL) or CL for Salmon in 2018. There is potential for construction spawning each system phase impacts to indirectly affect the CL, as the early life Yes fish/ consistently stages of this species could be adversely affected, thus this Number exceeded attribute could be significantly affected. Maintain or The Mulkear River is below its CL for Salmon in 2018. Salmon fry exceed 0+ fry Salmon need good water quality high in oxygen, low in abundance/ mean nutrients and suspended solids, neutral pH and with Number of catchment‐wide temperatures never exceeding 25° C. The construction Yes fry/5 abundance phase of the project could potentially result in sediment minutes at 17 Salmon and nutrient release from excavations. Therefore, there is electrofishing fry/5 min potential for this conservation objective to be negatively sampling affected. Young Salmon need good water quality high in oxygen, low Out- in nutrients and suspended solids, neutral pH and with migrating temperatures never exceeding 25° C. The construction No significant smolt phase of the project could potentially result in sediment Yes decline abundance/ and nutrient release from excavations. Therefore, there is Number potential for this conservation objective to be negatively affected. The construction phase of the project could potentially Number and result in sediment release from excavations and silt up No decline in distribution clean gravels in the main channel. Eggs and alevins incubate number & of redds/ in the gravel until May and are unable to tolerate gravels Yes distribution of Number and becoming clogged with silt or sand. Therefore, there is redds occurrence potential for this conservation objective to be negatively affected. The nearest EPA biological monitoring point on the Newport River downstream of the proposed development Water At least ‘Q4’ at is the station south of Shower, ca. 2.5km downstream of quality/ all EPA sampled Yes the project, rated Q4-5 in 2015. There is a possibility that EPA Q value sites water quality at this station could be negatively affected by runoff during the construction phase.
46
18150-6011-C Natura Impact Statement September 2018
5.3.7 Otter Otter is considered present in the Newport River. The following table assesses the effects of the project against the measures designed to achieve the conservation objectives for Otter. Where a measure may be negatively affected by the project the need for mitigation is indicated.
Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required While the project may indirectly temporarily impact water Distribution/ quality of the receiving watercourses during construction, it is Percentage No significant not expected that it will affect the distribution of Otter No positive decline associated with the Newport River. The project will not survey sites significantly affect this conservation measure. The area of mapped Otter habitat identified as critical for Otters includes a 10m terrestrial buffer along river banks Extent of (NPWS, 2007). The project site boundary overlaps this buffer terrestrial No significant and will directly affect terrestrial habitats mapped as critical for Yes habitat/ decline Otters. Encroachment of Otter habitat could reduce the area of Ha available terrestrial habitat, especially given that the park will be open to the public and disturbance could result. During the construction phase there is potential for indirect temporary impacts to water quality of receiving watercourses Extent of during construction. The extent of the project influence is not marine No significant considered to reach the nearest marine habitats suitable for No habitat/ decline Otter, in excess 40km downstream. The project will not reduce Ha the area of available marine habitat. The project will not significantly affect this conservation measure. Extent of While the project may indirectly temporarily impact water freshwater No significant quality of the receiving watercourses, it is not expected that it (river) decline. No will reduce the area of available freshwater habitat. The project habitat/ will not significantly affect this conservation measure. Ha Extent of While the project may indirectly impact water quality of the No significant freshwater receiving watercourses, it is not upstream of any lake habitat decline. Area (lake/lagoon) and will thus not result in loss of area of any associated habitat. No calculated as habitat/ The project will not significantly affect this conservation 125.6ha Ha measure. Couching sites or holts have not been identified within the site. Couching No significant The project will not reduce the number of couching sites or sites and No decline holts. The project will not significantly affect this conservation holts measure. Impacts that reduce the availability or quality of, or cause disturbance to, their terrestrial or aquatic habitats are likely to affect Otters. Ample food supply is normally associated with Fish biomass No significant high water quality. Prey such as Salmonids need good water availability/ Yes decline quality. The construction phase of the project could potentially Kg result in pollutants release and knock-on effects on fish biomass. Therefore, there is potential for this conservation objective to be negatively affected. Barriers to No significant The project is confined to the boundary of the site and will not No connectivity decline impede the movement of Otter. No significant effects to CO
47
18150-6011-C Natura Impact Statement September 2018
5.4 ASSESSMENT OF POTENTIALLY SIGNIFICANT CUMULATIVE EFFECTS NPWS have identified the main threats to the SAC from agriculture sources (fertilisation, grazing), urbanisation, residential and commercial development, and reclamation of land.
The current pressures on the Newport River catchment include discharges to waters from the WWTP, industrial licenced sites and ongoing activities. These are set out in a local context in Section 4.6 above. There is potential for significant cumulative effects from these pressures on water quality during the construction phase of the project.
Climate is an important environmental influence on ecosystems. Changing climate affects ecosystems in a variety of ways. For instance, warming may force species to migrate to higher latitudes or higher elevations where temperatures are more conducive to their survival. Similarly, as sea level rises, saltwater intrusion into a freshwater system may force some key species to relocate or die, thus removing predators or prey that are critical in the existing food chain.
Climate change not only affects ecosystems and species directly, it also interacts with other human stressors such as development. Although some stressors cause only minor impacts when acting alone, their cumulative impact may lead to dramatic ecological changes (Settele et al, 2014). For instance, climate change may exacerbate the stress that land development places on fragile coastal areas. Additionally, recently reclaimed land near watercourses within and upstream of the Lower River Shannon cSAC may become vulnerable to erosion if climate change leads to increases in heavy rain storms.
Because species differ in their ability to adjust, asynchronies can develop, increasing species and ecosystem vulnerability. These asynchronies can include mismatches in the timing of migration, breeding, pest avoidance, and food availability. Growth and survival are reduced when migrants arrive at a location before or after food sources are present (Horton et al. 2014).
Ecosystems can serve as natural buffers from extreme events such as wildfires, flooding, and drought. Climate change and human modification may restrict ecosystems’ ability to temper the impacts of extreme conditions, and thus may increase vulnerability to damage. An example is riparian areas that act as buffer zones protecting riverine ecosystems from runoff of silt/nutrient laden waters via overland/pluvial flow, by absorbing/attenuating surface floodwaters.
Climate change and shifts in ecological conditions could support the spread of pathogens, parasites, diseases and non-native biota, with potentially serious effects on agriculture and aquatic ecosystems.
5.5 MITIGATION The key to avoid impacts to water during the works is good site management practices, tight controls, regular inspections and ongoing vigilance with staff and employees on site.
In order to avoid or reduce the risks associated with the potential impacts, the mitigation measures described below will be followed to reduce impact significance and adhere with the conservation objectives for the Lower River Shannon cSAC. A concise list of the primary mitigation measures are outlined in Appendix 4 (Environmental Commitments). This is a summary of the full measures listed hereunder. The Environmental Commitments are to provide environmental awareness for a
48
18150-6011-C Natura Impact Statement September 2018 prospective contractor. Implementation of the full mitigation will be required by the appointed contractor however.
At a minimum, the project characteristics listed above in Section 4.4 will be implemented to reduce impacts. The following additional measures will also be undertaken. It is imperative that non-native invasive species be eradicated from the site and the riparian areas of the Newport River adjacent to the proposed development in advance of any other works. Without this, the spread of damaging plants is highly likely, with subsequent damage and serious negative impacts on riparian areas of the Lower River Shannon cSAC. Treatment required to eradicate these plants at a later stage, would probably be more difficult and present additional risk if excavations/earthworks could, for example distribute rhizomes of Japanese Knotweed throughout the town park site.
To this end, a non-native Invasive Species Management Plan (ISMP) is required. A detailed plan will be devised prior to any site works commencing and followed in full. An outline non-native invasive species management plan is provided in Appendix 5 which gives guidance on the preparation of such a plan.
5.5.1 Method statements Method statements are used to translate the project requirements into planned systems of work instructions to the site staff and operatives. They are prepared for activities identified in the specification and risk assessments and are issued to all personnel responsible for and involved with the activity concerned.
They define the proposed method of working for an element or section of work taking into account the particular requirements of the project including site conditions, safety hazards, the contract drawings, specification or code of practice. They define the proposed use of plant, labour and materials, any hold points or permits and may be supplemented by drawings, sketches and produce data as necessary.
The principle aim of a method statement is to ensure that:
resources are available prior to start; tasks are thought out in advance; and safe working methods are defined, and workers involved are aware of the risks associated with the task
Prior to the commencement of any activities deemed to involve a significant risk to the environment, as identified, the contractor will develop a written method statement incorporating the mitigations outlined below. The proposed development will be constructed in cognisance of the following guidelines to minimise the impact on the Lower River Shannon cSAC:
'Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters' (IFI, 2016); and 'Control of water pollution from construction sites - Guidance for consultants and contractors' (Masters-Williams et al. 2001)
49
18150-6011-C Natura Impact Statement September 2018
The contractor appointed to carry out the work(s) will furnish method statements on construction methodologies prior to carrying out the works. These method statements will be submitted to Tipperary County Council, project engineers and the project ecologist for amendment/agreement prior to construction. All works will take place according to the final approved detailed method statement, including the exact detail of each aspect and timing of works.
5.5.2 Project ecologist A project ecologist will be appointed to monitor the works on a weekly basis for the full duration of the project. The project ecologist shall induct all construction members via ‘tool box talks’ making them aware of the method statement and the sensitivities of the site before they are allowed to access the site. The project ecologist will check that relevant staff are familiar with emergency response procedures and trained in the use of spill kits. Tool box talks will be undertaken on a weekly basis and for any new worker prior to commencement of work on site. The topics will be determined by the nature of the work being undertaken at the time.
The project ecologist will have the authority to suspend works if works are not being carried out in line with the agreed method statement or daily monitoring indicates that the proposed measures are not functioning adequately to minimise the potential impact to local ecology.
5.5.3 Invasive Species Control Prior to being brought onto the proposed Newport Town Park site, all plant and equipment will need to be clean and free of soil/mud/debris or any attached plant or animal material. All plant/equipment with water retaining compartments, tanks, etc. will require water to be drained or dried out before transportation to the site. Prior to entering the site, all plant/equipment will be visually inspected to ensure all adherent material and debris has been removed.
It may be the case that river water will have been used in certain plant/equipment (e.g. bowsers) intended for use at the proposed development site. Such plant/equipment will require cleaning and rinsing with a 1% solution of Virkon Aquatic or another proprietary disinfection product (e.g. 5% solution - 100ml/20litre of chlorine bleach) followed by thorough rinsing with clean water.
All equipment and all footwear/waders that will be placed within the water should be steam-cleaned prior to arrival on site to prevent foreign flora/fauna entering the water and after use to prevent the spread to other catchments in accordance with NRA (2010) and IFI guidelines20.
5.5.4 Landscaping Any planting of trees, shrubs and other species should comprise native species found in the locality. Favourable species are Oak Quercus robur, Ash fraxinus excelsior, Hazel Corylus avellana Whitethorn Crataegus monogyna and Willow Salix sp. Construction works adjacent to rivers can impact on the existing riparian vegetation cover. Where practicable, such cover, using the native species, should be restored as soon as possible after construction so as to limit short-term and longer-term impacts on the use of watercourses by faunal species. Riparian habitats can often be improved by additional planting along the affected watercourses. The aim of landscaping should be to ensure, in so far as is possible, maintenance of a vegetated wildlife corridor along the Newport River. Refer to ‘A Guide to Landscape Treatments for National Road Schemes in Ireland’ (NRA, 2006).
20 https://www.fisheriesireland.ie/Biosecurity/biosecurity.html
50
18150-6011-C Natura Impact Statement September 2018
The roots of trees which are to be preserved along the western boundary of the site should be protected in line with ‘Guidelines for the protection and preservation of trees, hedgerows and scrub prior to, during and post construction of national road schemes (NRA, 2006).
Taking account that the proposed development is directly adjacent to the Newport River, where hydro-morphological impacts were noted, and where post development opportunities to improve riparian instream habitats may be limited, amelioration measures along and within the channel are recommended as follows:
Bank stabilisaton at locations where banks are at risk of collapsing e.g. removing failing gabion baskets and installing rock armouring; and Improving fish passage at pipeline crossings over the Newport River.
Any instream works will be carried out in consultation with IFI and with reference to ‘Channels and Challenges - the enhancement of Salmonid rivers (O’Grady, 2006). Additionally, it is likely that bank stabilisation works will be required following removal of non-native invasive species.
In relation to illumination, any lights and lighting should be installed with reference to BCI (2010) ‘Bats & Lighting - Guidance Notes for planners, engineers, architects and developers’.
5.5.5 Otters To offset any loss of terrestrial habitat along the Newport River potentially used by Otters, it is recommended that an artificial Otter holt is constructed. This should be located at the south western limit of the site (see Figure 5). This area is deemed most suitable as it is away from the core area, and adjacent to the quiet and zone, and close to the species rich/habitat creation area. Otters do not tolerate disturbance at or near holts that are in active use by them, so fencing is recommended at the park side of the artificial holt. Guidance on the construction of an Otter holt will be taken from ‘Guidelines for the Treatment of Otters prior to the Construction of National Road Schemes’ (NRA, 2008) and MulkearLIFE’s ‘Management Guidelines for European Otter (Lutra lutra) in SACs’ 21
5.5.6 Temporary Construction Compound The following measures will be undertaken to avoid or minimise negative effects to water quality as a result of the erection of the temporary compound:
Drainage within the temporary site compound will be directed to an oil interceptor to prevent pollution if any spillage occur; Temporary toilet facilities will be connected to the public sewer network during the construction phase, alternatively, discharges from the toilets will go to a holding tank where the effluent will be temporarily stored and removed at regular intervals by an appropriate permitted/licensed and approved contractor; A bunded containment area will be provided within the compound for the storage of fuels, lubricants, oils etc; and The site compound will be in place for the duration of the construction phase and will be removed once the project is complete.
21 http://mulkearlife.com/wp-content/uploads/2015/05/MulkearLIFE_BP_OTTERS-FINAL.pdf
51
18150-6011-C Natura Impact Statement September 2018
5.5.7 Soil Stripping and Excavation Works The following measures will be undertaken to avoid or minimise negative effects to water quality as a result of excavations and earth works:
Drainage and associated pollution control measures will be implemented on site before the main body of construction activity commences; The timing of the construction phase soil stripping and excavation works will take account of predicted weather, particularly rainfall; Excavations and soil stripping activities will be suspended during periods of prolonged rainfall events; The earthworks materials will be placed and compacted in layers to prevent water ingress and degradation of the material; The 24 hour advance meteorological forecasting service from Met Éireann will be used; and In the event that petroleum contaminated soils or subsoils containing other potentially contaminated material are discovered during excavation activities (identified through staining, discoloration, or odour), this soil will be segregated, stockpiled, sampled for characterisation purposes sufficient to meet the requirements of the applicable disposal facility, transported off-site by a licensed transporter, and disposed of in an approved treatment or disposal facility.
5.5.8 Storage and Stockpiles of Excavated Material The following measures will be undertaken to avoid or minimise negative effects to water quality as a result of the storage and stockpiling of excavated earth:
Temporary stockpiles of excavated earth will be constructed within the lands made available; Stockpiles of stripped topsoil will be strored in locations with minimum trafficking to prevent damage and dusting; Stockpiled sub-soils will be located at suitably sheltered areas to prevent erosion or weathering and shall be shaped to ensure rainfall does not degrade the stored material; Where unsuitable material is encountered this will be stockpiled separately and removed in accordance with a Site Waste Method Statement; Stockpiles will be located away from drainage systems and silt retaining measures (silt fence, / silt curtain or other suitable materials) shall be installed along the down-gradient edges of stockpiled earth materials to reduce risk of silt run-off; All excavated materials from the site or introduced materials for construction will be either used or removed from the site; and No permanent spoil or stockpiles will be left on site, other than those materials required for landscaping, berm construction and construction generally.
5.5.9 Drainage Controls The following measures will be undertaken to avoid or minimise negative effects to water quality:
A silt fence will be erected along the boundary of the site next to the Newport River to prevent overland emissions from the works site to the riparian/aquatic area of the Lower River Shannon cSAC;
52
18150-6011-C Natura Impact Statement September 2018
Prior to works commencing, a riparian leave strip will be established using appropriate fencing and signage and its significance explained to all workers particularly machinery operators. This work will be carried out following full implementation of the non-native ISMP; The course of the underground drainage that runs along the western side of the proposed development site will be identified and no excavation works will take place that could interfere with this drain – this is considered a stormwater conduit, part of the Newport town drainage associated with the WWTP; IFI (2016) 'Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters' will be consulted in relation to necessary mitigation; Should dewatering of flooded excavation holes or pits be required, there will be no pumping of soiled waters to the Newport River or to areas that would allow overland flow to the Newport River; and Release of suspended solids will be controlled by interception (silt trap) and management of site run-off. If there is a requirement to release water, it will be to grassed areas of low gradient to allow water to percolate to ground. The location and specification of the settlement areas will be agreed with the site ecologist.
5.5.10 Hydrocarbon Control All equipment will be in good condition to avoid spillage or discharge of oil, smoke and excessive noise; An appropriate waste container will be placed at a suitable location to collect waste before disposal by an authorised company; Hazardous material storage areas will be identified, labelled, and properly marked and fitted with spill containment systems; Refuelling will be carried out by competent and trained people away from any environmentally sensitive areas; Excavators and other equipment will be checked for any fuel/oil leaks on a regular basis by the crew; Any spills we be reported immediately to the site agent/authorities; Use absorbent materials from the spill kit to mop up the spill (sand or absorbent materials will be used rather than detergents); Place boom around any affected water as a precaution; Do not wash spillage. Washing will only make the situation worse and disperse the pollutant; Shovel contaminated sand/earth/absorbent granules into sacks or skips; and A specialist oil removal company or contaminated soil company will remove pooled oil and/or soils contaminated oil.
5.5.11 Concrete Control and Wheel Washing Wet concrete pollution is silty and very alkaline (high pH) and can have a serious effect on watercourses and aquatic life. Concrete should not enter site water. The following measures will be implemented regarding concrete:
53
18150-6011-C Natura Impact Statement September 2018
Concrete pours shall not be carried out during forecasted periods of heavy rainfall. Weather forecasts will be monitored during the construction phase. The 24 hour advance meteorological forecasting service from Met Éireann will be used; Designate a concrete washout area away from drains and the Newport River; To reduce the volume of cementitious water, only concrete chutes will be washed down onsite. The concrete trucks will wash down their chutes at a designated chute wash down area in the site compound. The wash down area will consist of a polythene lined bunded area of adequate capacity; Wash-water from the washing out of mixers and other equipment will be undertaken at a designated chute wash down area in the site compound; Washout of concrete trucks should occur off‐site; No disposal of concrete remnants will be permitted elsewhere on site; A wheel wash will be installed near the construction site entrance and exit to wash construction vehicle tyres; The wheel wash area will be cleaned regularly so as to avoid the build-up of residue; and Water residue from the wheel wash will be fed through an interceptor/filter prior to discharging from the site to a grassed area away from the Newport River.
5.5.12 Storage The storage of materials, containers, stockpiles and waste, however temporary, should follow best practice at all times and be stored at designated areas. Storage will be located as follows:
Away from drains and any watercourses or drains; Fuel oils etc. should be stored on a sheltered dry elevated site well removed from aquatic zones; On an impermeable base; Under cover to prevent damage from the elements; In secure areas; Well away from moving plant, machinery and vehicles; and On land not required until later in the development.
All containers will be stored upright and clearly labelled. Sufficient storage should be supplied near to all working areas.
5.5.13 Waste management To contain and manage construction phase waste, two types of skip will be provided at the site compound; one for recyclable waste and others for various construction wastes. These skips will be emptied when required by a licensed waste management company.
Any waste lubricants/oils will be collected and stored in drums in the site compound within a prefabricated bunded storage unit and will be removed and disposed of by a licensed waste management company without delay.
54
18150-6011-C Natura Impact Statement September 2018
There will be no discharge of effluent or waste water on site. Waste water tank and sewage will be emptied as required and removed from site to a licensed facility. These staff facilities will be removed at the end of the construction phase.
5.6 RESIDUAL IMPACTS Provided that the recommended mitigation measures set out in Section 5.5 above are implemented in full, it is not expected that significant impacts will result to the qualifying features identified for appraisal in this NIS and thus it is not expected that the proposal will have an adverse impact on the integrity of Natura 2000 sites.
5.7 CONCLUSION In conclusion, provided the recommended mitigation measures are implemented in full it is not expected that the construction and operation of the proposed Newport Town Park will result in an adverse residual impact on the integrity of Natura 2000 sites considered in this NIS, namely the:
Lower River Shannon cSAC (002165)
The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EC (2000) defines ‘integrity’ as the ‘coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and/or population of species for which the site is or will be classified’. It is considered that the scale of the works, in addition to the implementation of the prescribed mitigation measures, would not give rise to significant impacts affecting the integrity of the Lower River Shannon cSAC. It is concluded that the Newport Town Park, subject to the proposed mitigation measures and conditions above, will not result in direct, indirect or cumulative impacts which would have the potential to adversely affect the conservation objectives of the Lower River Shannon cSAC in relation to the relevant Annex II species and Annex I habitats; with regard to their range, population densities or conservation status within the cSAC. Potential impacts on water quality in the Lower River Shannon cSAC are limited due to the small scale of the proposed works; the carrying assimilation capacity of the Newport along with mitigation measures including the protection of water quality and eradication of non-native invasive plants. There would be no changes to the Lower River Shannon with regard to the qualifying interests of these sites or key indicators of conservation value (i.e. water quality) or changes to site integrity.
6 FURTHER RECOMMENDATIONS This assessment has concluded that the proposed works would not affect the conservation interests of the Natura 2000 network and that the conservation interests of any designated area would not be adversely affected. While this report has considered the relevant Natura 2000 site and the associated Annex I habitats and Annex II listed species therein, it has not assessed protected flora and fauna outside of the Natura 2000 network. It is noted that there is potential for negative impacts on other flora and fauna outside of the Natura 2000 network but this is outside the scope this report.
There are several mechanisms by which wildlife has been legally protected in Ireland and this legislation should been taken into account for the current project. It is an offence to intentionally kill or injure a protected species or to wilfully interfere with or destroy the breeding site or resting place 55
18150-6011-C Natura Impact Statement September 2018 of a protected wild animal as per the Wildlife Act, 1976 and the Wildlife (Amendment) Act, 2000. Terrestrial mammals including all bats as well as aquatic species such as trout are afforded protection under Irish and/or European law, irrespective of whether they are located within or outside of the Natura 2000 network.
To this end, it is recommended that appropriate surveys are carried out to establish baseline features at the proposed works location where protected species could potentially occur, in order to evaluate the importance of the site for protected flora and fauna not listed as conservation interests in the Lower River Shannon cSAC, and provide mitigation where necessary, particularly in relation to bats. Bat survey methodology should follow the NPWS Wildlife Manual No. 25 ‘Bat Mitigation Guidelines for Ireland’ by Kelliher and Marnell (2006).
56
18150-6011-C Natura Impact Statement September 2018
7 REFERENCES BCI (2010) Bats & Lighting. Guidance Notes for: Planners, engineers, architects and developers. Produced by Bat Conservation Ireland with the assistance of the Irish Environmental Network.
Chapman, P.J. and Chapman, L.L. (1982). Otter survey of Ireland Unpublished Report to Vincent Wildlife Trust.
Department of the Environment, Heritage and Local Government (DoEHLG) (2009). Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government.
EA (2013) Managing Japanese knotweed on development sites - the knotweed code of practice (Version 3, Published in September 2006 / updated July 2013.). Environment Agency, Horizon House, Deanery Road, Bristol BS1 5AH.
EC (2000). Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. Luxembourg: Office for Official Publications of the European Communities.
European Commission (2007) Interpretation manual of European Union habitats- EUR 27. DG Environment, Brussels.
EC (2001). 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/EEC. Luxembourg: Office for Official Publications of the European Communities.
IFI (2016) Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus Co. Dublin. IFI/2016/1- 4298.
Horton, R., G. Yohe, W. Easterling, R. Kates, M. Ruth, E. Sussman, A. Whelchel, D. Wolfe, and F. Lipschultz (2014) Climate Change Impacts in the United States: The Third National Climate Assessment, Eds., U.S. Global Change Research Program, 16-1-nn.
IFI (2016) Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus Co. Dublin. IFI/2016/1- 4298.
Kelleher, C. & Marnell, F. (2006) Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland.
57
18150-6011-C Natura Impact Statement September 2018
Kelly, F.L., Matson, R., Connor, L., Feeney, R., Morrissey, E., Coyne, J. and Rocks, K. (2014) Water Framework Directive Fish Stock Survey of Rivers in the South Western River Basin District. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24.
Kurz, I. and Costello, M.J. (1999). An Outline of the Biology, Distribution and Conservation of Lampreys in Ireland. Irish Wildlife Manuals, No. 5.
Maitland PS (2003) Ecology of the River, Brook and Sea Lamprey . Conserving Natura 2000 Rivers Ecology Series No. 5. English Nature, Peterborough.
Masters-Williams, H., Heap, A., Kitts, H., Greenshaw, L., Davis, S., Fisher, P., Hendrie, M., Owens, D. (2001) Control of water pollution from construction sites. Guidance for consultants and contractors. DETR/CIRIA. London.
McGinnity, P., Gargan, P., Roche W., Mills, P., and McGarrigle M. (2003) Quantification of the freshwater Salmon habitat asset in Ireland using data interpreted in a GIS platform. Issue 3 of Irish Freshwater Fisheries Ecology and Management Series, Central Fisheries Board, Dublin, 3. 131 pp.
NPWS (2007) Supporting documentation for the Habitats Directive Conservation Status Assessment ‐ backing documents, Article 17 forms and supporting maps. Unpublished Report to NPWS.
NPWS (2012a) Conservation Objectives: Lower River Shannon cSAC 002165. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS (2012b) Conservation objectives supporting document for the Lower River Shannon cSAC (site code 2165) - Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation (habitat code 3260). Unpublished report, Version 1.
NPWS (2013) The Status of EU Protected Habitats and Species in Ireland. Species Assessments Volume 3. Version 1.0. Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.
NRA (2010) ‘Guidelines on the Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads’ Revision 1. National Roads Authority, St Martin’s House, Waterloo Road, Dublin 4
NRA (2006) ‘Guidelines for the protection and preservation of trees, hedgerows and scrub prior to, during and post construction of national road schemes. National Roads Authority.
NRA (2008) Guidelines for the Treatment of Otters prior to the Construction of National Road Schemes. National Roads Authority.
NS 2. (2010). Freshwater Pearl Mussel Second Draft Allow Sub-Basin Management Plan. Produced by NS 2, funded by DEHLG.
NRA (2006) A Guide to Landscape Treatments for National Road Schemes in Ireland. National Roads Authority, Dublin.
58
18150-6011-C Natura Impact Statement September 2018
O’Grady, M. (2006). Channels and Challenges. The enhancement of Salmonid rivers. Central Fisheries Board, Dublin. 142pp.
Reynolds, J.D. (1998). Conservation management of the white-clawed crayfish, Austropotamobius pallipes Part 1. Irish Wildlife Manuals No. 1. Dúchas, the Heritage Service, Dublin.
Settele, J., R. Scholes, R. Betts, S. Bunn, P. Leadley, D. Nepstad, J.T. Overpeck, and M.A. Taboada (2014). Terrestrial and Inland Water Systems. In: Climate Change 2014: Impacts, Adaptation and Vulnerability. Part A: Global and Sectoral Aspects. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press.
SNH (2006) Guidance for Competent Authorities when dealing with proposals affecting SAC freshwater sites. Scottish Natural Heritage. http:// http://www.snh.org.uk/pdfs/publications/heritagemanagement/guidanceforcompetentauthorities.p df
TEGOS (2018) Report of the Technical Expert Group on Salmon to Inland Fisheries Ireland (IFI). The Status of Irish Salmon Stocks in 2017 with Catch Advice for 2018.
Whilde, A., (1993) Threatened Mammals, Birds, Amphibians and Fish in Ireland – Irish Red Data Book 2: Vertebrates. HMSO, Belfast.
59
18491-6005-A Natura Impact Statement March 2018
Appendix 1 Screening for Appropriate Assessment Report
Appendix
Screening for Appropriate Assessment
Newport Town Park,
Co. Tipperary
This page has been left intentionally blank
18150-6010-C Screening for Appropriate Assessment September 2018
ISSUE FORM Project number 18150 Document number 6010 Document revision C Document title Screening of Appropriate Assessment: Newport Town Park Document status Issued for Client Document prepared by Gerard Hayes (Senior Ecologist, B.Sc. Ed., MCIEEM) Document checked by Hazel Dalton (Senior Ecologist, B.Sc. Wildlife Biology)
i
18150-6010-C Screening for Appropriate Assessment September 2018
Table of contents
SUMMARY OF FINDINGS...... 4
1 INTRODUCTION ...... 5 1.1 Purpose of Assessment ...... 5 1.2 Legislative context ...... 5 1.3 Stages of Appropriate Assessment...... 5
2 ASSESSMENT METHODOLOGY ...... 5 2.1 Appropriate Assesment Guidance ...... 5 2.2 Desk Study ...... 5 2.3 Screening for Appropriate Assessment ...... 6
3 SCREENING FOR APPROPRIATE ASSESSMENT ...... 6 3.1 Management of Natura 2000 sites ...... 6 3.2 Description of Project ...... 6
3.2.1 Brief Project Description ...... 6 3.2.2 Purpose of the Project ...... 7 3.2.3 Site Location and Context ...... 7 3.2.4 Description of the Site ...... 8 3.2.5 Characteristics of the Project ...... 9 3.3 Identification of Other Projects, Plans and Activities ...... 11 3.4 Identification of Natura 2000 Sites ...... 11
3.4.1 Zone of Impact Influence ...... 11 3.4.2 Identification of Natura 2000 Sites ...... 11 3.4.3 Characteristics of Natura 2000 sites within 15km ...... 13 3.4.4 Conservation Objectives ...... 14 3.5 Identification of Potential Impacts ...... 15 3.6 Assessment of Significance of Potential Impacts ...... 16
3.6.1 Habitat Loss and Alteration ...... 17 3.6.2 Water Quality ...... 17 3.6.3 Disturbance and/or Displacement of Species ...... 17 3.6.4 Habitat or Species Fragmentation...... 17 3.6.5 Cumulative/In-combination Impacts ...... 18 3.7 Conclusion of Screening Stage ...... 18
4 REFERENCES ...... 20
ii
18150-6010-C Screening for Appropriate Assessment September 2018
Table of tables
Table 1: Designated conservation sites within 15km radius of proposed development site ...... 11 Table 2: Designated site with qualifying features / conservation interests listed ...... 13
Table of figures
Figure 1: Site location in Newport Town ...... 8 Figure 2: Designated Natura 2000 sites within 15km of the proposed development site ...... 12
List of appendices
Appendix 1 Stages of Appropriate Assessment
iii
18150-6010-C Screening for Appropriate Assessment September 2018
SUMMARY OF FINDINGS
Project Title Newport Town Park Project Proponent Tipperary County Council Project Location Newport, County Tipperary The Screening for Appropriate Assessment is undertaken to determine Screening for the potential for likely significant effects of a project, individually, or in Appropriate combination with other plans or projects, in view of the conservation Assessment objectives of the site on a Natura 2000 Site. Conclusion It has been concluded with regard to the proposal to develop a town park Town Park, incorporating a playground, at Newport, Co. Tipperary, that significant effects cannot be ruled out at this stage, on the following Natura 2000 site:
Lower River Shannon SAC (002165)
4
18150-6010-C Screening for Appropriate Assessment September 2018
1 INTRODUCTION
1.1 PURPOSE OF ASSESSMENT This Screening for Appropriate Assessment has been undertaken to determine the potential for significant impacts on a proposal to develop a Town Park, incorporating a playground, at Newport, Co. Tipperary, on nearby sites with European conservation designations (i.e. Natura 2000 Sites).
This Screening for Appropriate Assessment has been undertaken by Malachy Walsh and Partners ecologists.
1.2 LEGISLATIVE CONTEXT The Habitats Directive (92/43/EEC) seeks to conserve natural habitats and of wild fauna and flora by the designation of Special Areas of Conservation (SACs) and the Birds Directive (79/409/EEC) seeks to protect birds of special importance by the designation of Special Protected Areas (SPAs). It is the responsibility of each member state to designate SPAs and SACs, both of which will form part of Natura 2000, a network of protected sites throughout the European Community. The Habitats Directive has been transposed into Irish law and the relevant Regulations are the European Communities (Birds and Natural Habitats) Regulations 2011. The requirement for Appropriate Assessment of the implications of plans and projects on the Natura 2000 network of sites comes from the Habitats Directive (Article 6(3)). Under the Planning and Development Act 2000 (amended) (Section 177U) a Local Authority is required to carry out a Screening for Appropriate Assessment of a proposed development prior to issuing consent. This information presented in this Screening for Appropriate Assessment will be used by the competent authority (in this case Tipperary County Council) to complete their screening exercise.
1.3 STAGES OF APPROPRIATE ASSESSMENT The Appropriate Assessment process is a four-stage process with issues and tests at each stage. An important aspect of the process is that the outcome at each successive stage determines whether a further stage in the process is required. The stages are set out in Appendix 1.
2 ASSESSMENT METHODOLOGY
2.1 APPROPRIATE ASSESMENT GUIDANCE This Screening for Appropriate Assessment, or Stage 1, has been undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the ‘Habitats’ Directive 92/43/EEC (EC, 2001) and the European Commission Guidance ‘Managing Natura 2000 sites’ (EC, 2000) and guidance prepared by the NPWS (DoEHLG, 2009).
2.2 DESK STUDY In order to complete the Natura Impact Statement certain information on the existing environment is required. A desk study was carried out to collate available information on the site’s natural environment. This comprised a review of the following publications, data and datasets:
OSI Aerial photography and 1:50000 mapping, and other mapping sources (online) National Parks and Wildlife Service (NPWS) (online) National Biodiversity Data Centre (NBDC) (online)
5
18150-6010-C Screening for Appropriate Assessment September 2018
Geological Survey Ireland (GSI) area maps (online) Shannon River Basin District (ShRBD) datasets (Water Framework Directive) (online) Other information sources and reports footnoted in the course of the report
2.3 SCREENING FOR APPROPRIATE ASSESSMENT As set out in the NPWS guidance, the task of establishing whether a plan or project is likely to have an effect on a Natura 2000 site(s) is based on a preliminary impact assessment using available information and data, including that outlined above, and other available environmental information, supplemented as necessary by local site information and ecological surveys. This is followed by a determination of whether there is a risk that the effects identified could be significant. The precautionary principle approach is required.
Once the potential impacts that may arise from the proposal are identified the significance of these is assessed through the use of key indicators:
Habitat loss and alteration Water quality and resource Disturbance and/or displacement of species Habitat or species fragmentation
3 SCREENING FOR APPROPRIATE ASSESSMENT Screening for Appropriate Assessment (Stage 1) determines the need for a full Appropriate Assessment (Stage 2) and consists of a number of steps, each of which is addressed in the following sections of this report:
4.1 Establish whether the project is necessary for the management of a Natura 2000 site 4.2 Description of the project 4.3 Identification of Natura 2000 sites potentially affected 4.4 Identification and description of individual and cumulative impacts of the project 4.5 Assessment of the significance of the impacts on the integrity of Natura 2000 sites 4.6 Conclusion of screening stage
3.1 MANAGEMENT OF NATURA 2000 SITES The proposal is not connected with or necessary to the conservation management of a Natura 2000 site.
3.2 DESCRIPTION OF PROJECT
3.2.1 Brief Project Description Tipperary County Council proposes to develop a Town Park, incorporating a playground, at Newport, Co. Tipperary. The proposed town park site is located to the south of the R503 and to the west of Custom Gap Road. The proposed Town Park will include a children’s play area, specifically designed play equipment for use by people with a disability, zip wire, outdoor gym equipment, pump track, recreational walkways, seating, bi-lingual signage displaying reference to applicable by-laws, rules, hours of opening, etc., landscaping and car parking for approximately 26 cars. The Council will have regard to strategies and guidelines including the National Development Plan 2007-2013, the
6
18150-6010-C Screening for Appropriate Assessment September 2018
Sustainable Residential Development in Urban Areas Guidelines (DoEHLG, 2009) and the Urban Design Manual, A Best Practice Guide (DoEHLG 2008).
3.2.2 Purpose of the Project It is recognised that quality recreation and leisure facilities contribute to the quality of life for all that it serves. The provision of amenities which can cater for the demands of an increasing population and which can be accessible for all sectors and age groups is a central element in the delivery of sustainable communities. Tipperary County Council recognises the important role that areas of amenity and green linkages play in creating quality and healthy environments for all and will seek to promote a balance between the protection of environmental assets and the facilitation of recreational use.
3.2.3 Site Location and Context The proposed town park site is located to the south of the R503 and to the west of Custom Gap Road at Tullow, Newport. Co. Tipperary (See Figure 1). The proposed development is located adjacent to an existing housing estate (Mulkear view) and the Newport (Tipperary) River. The site lies partially within the confines of the Newport Town municipal boundary. The land use in the general area bordering or in reasonably close proximity to the site includes residential development along with offices, commercial and educational facilities. Housing is the principal land use along Custom Gap Road to the south of the site.
7
18150-6010-C Screening for Appropriate Assessment September 2018
Figure 1: Site location in Newport Town
3.2.4 Description of the Site The proposed development site has been partially developed as incomplete housing, with works stalled. This work is considered to be related to conditional planning permission that was granted at the site in April 2003 for 95 dwelling units, a creche, entrances, roads and all associated site works (Tipperary planning register 02510476). Some house foundations occur within the site. There is evidence of related drainage at the site also, so it is concluded that significant ground works had taken place prior to cessation of this development. The proposed development is therefore
8
18150-6010-C Screening for Appropriate Assessment September 2018 categorised as a brownfield site, with imported stone and unfinished buildings forming some of the ground to the north and east of the site.
Newport is within easy commuter distance of the Limerick/Shannon Gateway, as defined in the National Spatial Strategy. In many respects, Newport is often regarded as a dormitory town for Limerick City. Newport is a small North Tipperary town located in the West of the County of North Tipperary, near the Co. Limerick border. Newport is located on the main road (R503) between Limerick and Thurles.
The site currently has no commercial use and is largely overgrown at its western extent, colonised by wild plants and young shrubs/trees. The site is bound to the northeast by an occupied housing development. The southern boundary of the site comprises a hedgerow/treeline. The Newport River within the Lower River Shannon SAC lies to the west of the site.
The Newport River (EPA code 25N02) is a 4th order fast flowing river. The Newport River rises in Silvermines Mountain Range at Curreeny, Co. Tipperary. It is a large fast flowing mountain river which often flows through areas of hillside that contain significant amounts of mountain blanket bog. This often gives the river a high natural peaty colour in heavy rainfall events.
It is fed by the 4th order Annagh River (25A02) before meeting the 6th order River Mulkear (25M04), a large tributary of the River Shannon (25S01) at Annacotty. The Newport River is within the Mulkear Water Management Unit area within Hydrometric Area 25. This area is part of the Shannon River Basin District (ShRBD).
The 2010-2015 river water quality status of the Newport (Tipperary) River was ‘Good’. The EPA carry out biological water quality monitoring at several locations in the Newport River catchment. The most recent assessment was undertaken in 2015, At Rockvale Bridge (EPA station 0200) ca. 3km upstream of the proposed development, biological water quality was rated Q4-5, equivalent to Water Framework Directive (WFD) ‘High Status’. At Portryan Bridge (EPA station 0300) ca. 1km downstream of the proposed development, biological water quality was rated Q5, equivalent to Water Framework Directive (WFD) ‘High Status’.
Using the EPA Hydrotool which returns flow duration curves for most rivers in Ireland, the stretch of the Newport River at Newport (25_475) has a 95%ile flow and mean flow of 0.638m3/s and 2.705m3/s respectively (mean flow was taken as the 30%ile river flow, as in MacCarthaigh, 1997).
3.2.5 Characteristics of the Project
The proposed development will include: riparian leave strip exclusion zone protection of watercourses (general measures) fuel and oil management storage
The proposal is described below.
9
18150-6010-C Screening for Appropriate Assessment September 2018
Size, scale, area, land-take The proposed development site has an area of ca. 2.8ha.
Set up of site compound within east side of site Demarcation of riparian exclusion zone using appropriate fencing Construction of path which runs parallel to the river. This will act as a further buffer between the SAC and the construction works. Construct of remainder of paths and Infill of grassland area and planting Details of physical changes on the west and north of the site. that will take place during Construction of paths, core area and informal garden area within the the various stages of central section of the site. implementing the proposal Construction of mixed amenity area Construction of car park on east side of site with integrated Sustainable Drainage System (SuDS) for management of surface water runoff. Construction of Mixed Use Games Area (MUGA) and Playground on east side of site. Connection to existing site services, including electricity, water and drainage. An estimated average of eight to ten workers will be involved in the construction at any one time. Excavation (950m2), fill material (930m3), footpaths (2,270m2), tarmac 2 2 2 2 Description of resource (740m ), paving (1,890m ), geotextile (2,420m ), top-soiling (12,120m ), requirements for the fencing (1,260m), concrete (125m3), ducts & drainage pipes, public construction/operation and lighting, equipment for play areas. decommissioning of the Dumper, mini-excavator, compressor, lorries to deliver fill material. proposal (water resources, An excavator will be used to prepare the central and western sections of construction material, the site. human presence etc) Delivery trucks will need to call to site regularly. Materials such as steel, concrete, blocks, fencing, etc, will be delivered to site by means of trucks and delivery vehicles. Concrete will be ready mixed when delivered to site. Concrete truck washing will not be permitted on site. Description of timescale for the various activities that The construction period will be 4-6 months starting in the June following will take place as a result of grant of planning permission implementation (including likely start and finish date)
General construction waste, including packaging. Description of wastes Demolition and construction waste will be separated on site, recycled arising and other residues where possible and removed to licensed waste disposal facility (metal, and their disposal masonry, concrete). No excavation spoil wastes are expected as excavations are minimal and spoil will be backfilled into core area Identification of wastes arising and other residues (including quantities) that All demolition waste will be removed off-site to licensed recycling or may be of particular landfill facility as appropriate (metal, masonry, concrete). concern in the context of the Natura 2000 network
10
18150-6010-C Screening for Appropriate Assessment September 2018
3.3 IDENTIFICATION OF OTHER PROJECTS, PLANS AND ACTIVITIES Other projects and activities that could act in combination with the project include:
Newport Town WWTP Other Industrial Emission licenced sites Other planning applications Ongoing activities associated with Newport town Ongoing activities associated with the catchment e.g. agriculture
3.4 IDENTIFICATION OF NATURA 2000 SITES
3.4.1 Zone of Impact Influence The screening stage of AA involves compiling a ‘long list’ of European sites within a zone of potential impact influence for later analysis which may or may ultimately not be significantly impacted upon by the proposal. All Natura 2000 sites within 15km of the proposal location will be characterised in the context of the rationale for designation and qualifying features, in accordance with NPWS guidance. In line with the precautionary principle, during the preparation of this report Natura 2000 sites that lie outside 15km that may be significantly impacted as a result of the proposed works were also considered. Following this, the potential impacts associated with the proposal will be identified before an assessment is made of the likely significance of these impacts.
As described above, the test for the screening for Appropriate Assessment is to assess, in view of best scientific knowledge, if the development, individually or in combination with other plan/project is likely to have a significant effect on a Nature 2000 site. If there are any significant, potentially significant, or uncertain effects, it will be necessary to proceed to Appropriate Assessment and submit an NIS.
3.4.2 Identification of Natura 2000 Sites In identifying potentially affected European sites, it has been decided to include all SACs and SPAs, within a 15km radius of the proposal site (See Figure 2). Table 1 below lists designated SACs and SPA within 15km or the anticipated zone of influence of the proposal site including their proximity. Given the nature, scope, scale and location of the works, it is not considered that the proposal will significantly affect Natura 2000 sites outside of those considered here.
Table 1: Designated conservation sites within 15km radius of proposed development site No. Designated Site Site Code Proximity of proposed development site to nearest point of designated site 1 Lower River Shannon SAC 002165 Within and directly adjacent to this site 2 Clare Glens SAC 000930 1.5km north 3 Slievefelim to Silvermines Mountains SPA 004165 1.8km northwest 4 Glenstal Wood SAC 001432 4.5km northwest 5 Keeper Hill SAC 001197 8.8km south southwest 6 Silvermines Mountains West SAC 002258 9.8km southwest 7 Lough Derg (Shannon) SPA 004058 12.5km south 8 Glenomra Wood SAC 001013 12.5km south east 9 Slieve Bernagh Bog SAC 002312 13.5km south east 10 Silvermines Mountains SAC 000939 14km south west 11 Bolingbrook Hill SAC 002124 14.8km south west
11
18150-6010-C Screening for Appropriate Assessment September 2018
Figure 2: Designated Natura 2000 sites within 15km of the proposed development site
12
18150-6010-C Screening for Appropriate Assessment September 2018
3.4.3 Characteristics of Natura 2000 sites within 15km The following tables list the features of interest for the SAC and SPA sites identified in the previous table. Information pertaining to designated sites is from site synopses, conservation objectives and other information available on www.npws.ie.
Table 2: Designated site with qualifying features / conservation interests listed Designated Site Qualifying features / Conservation interests Lower River Shannon Habitats SAC Sandbanks which are slightly covered by sea water all the time [1110] Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Coastal lagoons [1150] Large shallow inlets and bays [1160] Reefs [1170] Perennial vegetation of stony banks [1220] Vegetated sea cliffs of the Atlantic and Baltic coasts [1230] Salicornia and other annuals colonising mud and sand [1310] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae) [6410] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Species Margaritifera margaritifera (Freshwater Pearl Mussel) [1029] Petromyzon marinus (Sea Lamprey) [1095] Lampetra planeri (Brook Lamprey) [1096] Lampetra fluviatilis (River Lamprey) [1099] Salmo salar (Salmon) [1106] Tursiops truncatus (Common Bottlenose Dolphin) [1349] Lutra lutra (Otter) [1355] Clare Glens SAC Habitats Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Species Killarney fern (Trichomanes speciosum) [1421] Slievefelim to Species Silvermines Hen Harrier (Circus cyaneus) [A082] Mountains SPA Glenstal Wood SAC Species Killarney fern Trichomanes speciosum) [1421] Silvermines Habitats Mountains West SAC Northern Atlantic wet heaths with Erica tetralix [4010] European dry heaths [4030] Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and submountain areas, in Continental Europe) [6230] Blanket bog (*active only) [7130] Keeper Hill SAC Habitats Northern Atlantic wet heaths with Erica tetralix [4010] Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and submountain areas, in Continental Europe) [6230] Blanket bog (*active only) [7130] Bolingbrook Hill SAC Habitats Northern Atlantic wet heaths with Erica tetralix [4010] European dry heaths [4030] Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and
13
18150-6010-C Screening for Appropriate Assessment September 2018
submountain areas, in Continental Europe) [6230] Glenomra Wood Old Oak Woodlands [91A0] SAC Slieve Bernagh Bog Wet Heath [4010] SAC Dry Heath [4030] Blanket Bogs [(Active)7130] Silvermines Habitats Mountains Northern Atlantic wet heaths with Erica tetralix [4010] Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and submountain areas, in Continental Europe) [6230] Lough Derg Species (Shannon) SPA Cormorant (Phalacrocorax carbo) [A017] Tufted Duck (Aythya fuligula) [A061] Goldeneye (Bucephala clangula) [A067] Common Tern (Sterna hirundo) [A193] Wetland and Waterbirds [A999]
3.4.4 Conservation Objectives According to the Habitat’s Directive, the conservation status of a natural habitat will be taken as ‘favourable’ within its biogeographic range when:
its natural range and areas it covers within that range are stable or increasing, and the specific structure and functions which are necessary for its long-term maintenance exist and are likely to continue to exist for the foreseeable future, and the conservation status of its typical species is favourable as defined below.
According to the Habitat’s Directive, the conservation status of a species means the sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its populations. The conservation status will be taken as ’favourable’ within its biogeographic range when:
population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats, and the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.
The specific conservation objectives for each site are available on www.npws.ie. These have been accessed for the sites listed in the tables above on the 16th July 2018. Generic conservation objectives were available for the following sites:
Kilcolman Bog SPA Blackwater Callows SP Slievefelim to Silvermines Mountains SPA Lough Derg (Shannon) SPA
Site specific and more detailed conservation objectives were available for the following sites:
Lower River Shannon SAC (NPWS, 2012)
14
18150-6010-C Screening for Appropriate Assessment September 2018
Glenstal Wood SAC (NPWS, 2018a) Clare Glens SAC (NPWS, 2018b) Keeper Hill SAC (NPWS, 2017a) Silvermines Mountains West SAC (NPWS, 2017b) Silvermines Mountains SAC (NPWS, 2018c) Bolingbrook Hill SAC (NPWS, 2018d)
Management plans were not available for any sites.
All conservation objectives together with other designated site information are available on http://www.npws.ie/protectedsites/.
3.5 IDENTIFICATION OF POTENTIAL IMPACTS Potential likely ecological impacts arising from the project are identified in this section. Potential ecological impacts are likely to be associated with the construction phase of the project as there will be disturbance of soil and excavations and use of associated machinery next to a watercourse. The potential likely ecological impacts arising from the construction elements of the project are outlined in the table below while the paragraphs that follow describe operational impacts of the project, which are not expected to change with the operation of the project.
Description of elements of the project 1. Works will be conducted adjacent to a river channel likely to give rise to impacts on Natura designated as an SAC for the protection of aquatic species. 2000 sites. 2. The risk of a fuel or oil spillage into the waterway draining to the SAC due to the use of plant in close proximity to it. 3. The risk of the movement of sediment or suspended solids from the proposal site area to the adjacent river. Describe any likely direct, indirect or Works conducted upstream of a riparian SAC secondary impacts of the project (either Works duration of six months alone or in combination with other plans Small scale excavation will be required or projects) on Natura 2000 sites by virtue Some infill material will be imported of: Resources required include: o plant machinery Size and scale; o transport vehicles Land-take; o fuels and oils Distance from Natura 2000 Site or o cement key features of the Site; o top soil Resource requirements; Potential emissions include: Emissions; o water borne sediment Excavation requirements; o fuel or oil spill Transportation requirements; Duration of construction, operation etc.; and Other.
15
18150-6010-C Screening for Appropriate Assessment September 2018
Describe any likely changes to the site arising as a result of:
No significant changes under the criteria listed opposite are Reduction of habitat area; expected to ensue from the proposal Disturbance of key species; Some limited potential to create adverse water quality Habitat or species fragmentation; impacts in the Lower River Shannon SAC by means of ingress Reduction in species density; of hydrocarbons or sediment to the Newport River resides in Changes in key indicators of the programme of works required to construct the proposed conservation value; and town park. Climate change.
Describe any likely impacts on the Natura 2000 site as a whole in terms of: Some limited potential to create adverse water quality impacts in the Lower River Shannon SAC by means of ingress Interference with the Key of hydrocarbons or sediment to the Newport River resides in relationships that define the structure the programme of works required to construct the town of the site; and park. However, it is not expected that the proposal has the Interference with key relationships potential to interfere with the relationships that define the that define the function of the site. structure and function of the SAC
Describe from the above those elements of the project, or combination of It is not expected that significant adverse water quality elements, where the above impacts are impacts will ensue from the proposal that would adversely likely to be significant or where the scale affect the key relationships that define the structure and of magnitude of impacts is not known. function of the nearby SAC site.
3.6 ASSESSMENT OF SIGNIFICANCE OF POTENTIAL IMPACTS This section considers the list of sites identified in Section 3.4 above together with the potential ecological impacts identified in the previous section and determines whether the project is likely to have significant effects on a Natura 2000 site.
The likelihood of significant effects to a Natura 2000 site from the project was determined based on a number of indicators including:
Habitat loss Habitat alteration Habitat or species fragmentation Disturbance and/or displacement of species Water quality and resource
The likelihood of significant cumulative/in-combination effects is assessed in Section 3.6.5.
Clare Glens is located 1.5km south of the proposed development and has been designated due to the presence of ’Killarney fern (Trichomanes speciosum)’ and ‘Old sessile oak woods with Ilex and Blechnum in British Isles’. This site is not assessed in any more detail as there is no connection between this site and the proposed works.
At its closest, the proposed development site is located 1.8km northwest of the Slievefelim to Silvermines Mountains SPA, an extensive upland site located in Counties Tipperary and Limerick. This is an SPA for Hen harrier, a species listed under Annex I of the EU Birds Directive. It is one of the strongholds for Hen Harrier in the country. The site provides excellent nesting and foraging habitat for breeding Hen Harrier and is among the top five sites in the country for the species. This site is not
16
18150-6010-C Screening for Appropriate Assessment September 2018 included for further assessment of impacts due to geographical separation, and taking account of the disturbed nature / high human activity in the vicinity of the proposed development site.
The proposed development is considered to be spatially removed from other Natura 2000 sites within 15km to a degree that would preclude any significant impacts. For example, the Silvermines Mountains West SAC and the Lough Derg (Shannon) SPA are 9.8km and 12.5km from the proposed development, respectively, so no plausible impacts on the habitats and/or species of interest in these sites are envisaged in light of the proposed Newport Town Park.
The conservation objectives of these sites have been considered and there is no potential for significant effects. These sites will not be discussed any further.
With regard to potentially significant negative effects, the only Natura 2000 site identified is the Lower River Shannon SAC, as the proposed development site lies within/adjacent to the Newport River within this SAC. The indicators of significant impacts potentially arising from the proposed development are discussed below in terms of the within the Lower River Shannon SAC.
3.6.1 Habitat Loss and Alteration The footprint of the proposed project is within the Lower River Shannon SAC. Therefore, land take within this Natura 2000 site boundary is required and direct terrestrial and/or riparian habitat loss or alteration is expected to result from the proposal.
The construction phase of the proposal requires construction work in an area adjoining the Newport River. As a consequence, indirect habitat loss or alteration impacts caused either by potential water pollution impacts (e.g. run off of suspended solids from earthworks and exposed soil) within the Lower River Shannon could occur as a result of the project. Therefore, it cannot be objectively concluded that significant indirect impacts on the habitats and species, for which this site is designated, will not ensue from the current unmitigated construction phase.
3.6.2 Water Quality The water quality in the Newport River is essential for supporting the biological elements associated with the river habitat. Negative impacts to water quality in the Newport River as a result of the construction activities required to develop the site could have indirect impacts on the aquatic Qualifying Interests of the Lower River Shannon SAC. For example, uncontrolled silt run-off could impact negatively on Atlantic Salmon populations. For example, a reduction in water quality arising from the construction phase could affect the distribution and density of salmonids, which could potentially affect the availability of prey for otter. Due to the risk of water pollution from the proposed construction phase entering the Newport River within the Lower River Shannon SAC, the potential for occurrence of significant impacts cannot be ruled out.
3.6.3 Disturbance and/or Displacement of Species The construction phase of the proposal requires excavations. There is potential for displacement of Qualifying Interests in the event water pollutants entered the Newport River during the construction phase.
3.6.4 Habitat or Species Fragmentation Habitat fragmentation has been defined as ‘reduction and isolation of patches of natural environment’ (Hall et al., 1997 cited in Franklin et al., 2002) usually due to an external disturbance
17
18150-6010-C Screening for Appropriate Assessment September 2018 such that an alteration of the spatial composition of a habitat occurs that alters the habitat and ‘create[s] isolated or tenuously connected patches of the original habitat’ (Wiens, 1989 cited in Franklin et al., 2002). This results in spatial separation of habitat units which had previously been in a state of greater continuity. Negative effects of habitat fragmentation on species or populations can include increased isolation of populations or species which can detrimentally impact on the resilience or robustness of the populations reducing overall species diversity and altering species abundance. As there will be no direct habitat loss it is not considered that significant habitat fragmentation will arise from the proposal. However, if habitats or species distribution (e.g. spawning habitats) are significantly altered as a result of habitat alteration impacts arising from the proposed construction phase, then fragmentation could potentially occur.
3.6.5 Cumulative/In-combination Impacts There is potential for cumulative ecological effects to occur to the Newport River during the construction phase of the project together with ongoing pressures to the water quality in the catchment. For example, the 2016 Annual Environmental Report for the Newport Waste Water Treatment Plant (WWTP licence register No. D0325-01,)1 indicates that the annual maximum hydraulic and annual mean organic loading is greater than the peak treatment plant capacity. This WWTP has a plant capacity population equivalent of 1900 and is not designed for Phosphorus removal. Its primary discharge point to the Newport River2 at Portryan ca. 1km downstream of the proposed development site.
3.7 CONCLUSION OF SCREENING STAGE In conclusion, to determine the potential impacts, if any, of the project on nearby Natura 2000 sites, a screening process for Appropriate Assessment was undertaken. The proposed development is within 15km of nine Natura 2000 sites.
It has been objectively concluded during the screening process that eight sites within 15km of the project are unlikely to be significantly impacted by the proposal to develop land for amenity purposes at Newport:
Clare Glens SAC (000930) Slievefelim to Silvermines Mountains SPA (004165) Glenstal Wood SAC (001432) Keeper Hill SAC (001197) Silvermines Mountains West SAC (002258) Lough Derg (Shannon) SPA (004058) Glenomra Wood SAC (001013) Slieve Bernagh Bog SAC (002312) Silvermines Mountains (000939) Bolingbrook Hill SAC (002124)
It has been concluded in regard to the proposed Newport Town Park that significant effects cannot be ruled out at this stage, on the following Natura 2000 site:
Lower River Shannon SAC (002165)
1 http://www.epa.ie/licences/lic_eDMS/090151b2805fc9a6.pdf 2 http://www.epa.ie/licences/lic_eDMS/090151b2802b03ab.pdf
18
18150-6010-C Screening for Appropriate Assessment September 2018
Further assessment is required to determine whether the project is likely to adversely affect the integrity of this Natura 2000 site. An Appropriate Assessment of the project is required and a Natura Impact Statement (NIS) will need to be prepared to inform the Appropriate Assessment.
19
18150-6010-C Screening for Appropriate Assessment September 2018
4 REFERENCES Department of the Environment, Heritage and Local Government (DoEHLG) (2009). Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government.
EC (2000). Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. Luxembourg: Office for Official Publications of the European Communities.
EC (2001). 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/EEC. Luxembourg: Office for Official Publications of the European Communities.
Franklin, Alan B., Noon, Barry R. & Luke George T. (2002), What is Habitat Fragmentation?, Studies in Avian Biology No. 25:20-29.
NPWS (2012) Conservation Objectives: Lower River Shannon SAC 002165. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS (2017a) Conservation Objectives: Keeper Hill SAC 001197. Version 1. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.
NPWS (2017b) Conservation Objectives: Silvermines Mountains West SAC 002258. Version 1. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.
NPWS (2018a) Conservation Objectives: Glenstal Wood SAC 001432. Version 1. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.
NPWS (2018b) Conservation Objectives: Clare Glen SAC 000930. Version 1. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.
NPWS (2018c) Conservation Objectives: Silvermine Mountains SAC 000939. Version 1. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.
NPWS (2018d) Conservation Objectives: Bolingbrook Hill SAC 002124. Version 1. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.
20
18150-6010-C Screening for Appropriate Assessment September 2018
Appendix 1 Stages of Appropriate Assessment
Appendix
18150-6010-C Screening for Appropriate Assessment September 2018
Stage 1 - Screening
This is the first stage of the Appropriate Assessment process and that undertaken to determine the likelihood of significant impacts as a result of a proposed project or plan. It determines need for a full Appropriate Assessment.
If it can be concluded that no significant impacts to Natura 2000 sites are likely then the assessment can stop here. If not, it must proceed to Stage 2 for further more detailed assessment.
Stage 2 - Natura Impact Statement (NIS)
The second stage of the Appropriate Assessment process assesses the impact of the proposal (either alone or in combination with other projects or plans) on the integrity of the Natura 2000 site with respect to the conservation objectives of the site and its ecological structure and function. This is a much more detailed assessment that Stage 1. A Natura Impact Statement containing a professional scientific examination of the proposal is required and includes any mitigation measure to avoid, reduce or offset negative impacts.
If the outcome of Stage 2 is negative i.e. adverse impacts to the sites cannot be scientifically ruled out, despite mitigation, the plan or project should proceed to Stage 3 or be abandoned.
Stage 3 - Assessment of alternative solutions A detailed assessment must be undertaken to determine whether alternative ways of achieving the objective of the project/plan exists.
Where no alternatives exist the project/plan must proceed to Stage 4.
Stage 4 - Assessment where no alternative solutions exist and where adverse impacts remain The final stage is the main derogation process examining whether there are imperative reasons of overriding public interest (IROPI) for allowing a plan or project to adversely affect a Natura 2000 site where no less damaging solution exists.
Appendix
18150-6011-C Natura Impact Statement September 2018
Appendix 2 Lower River Shannon cSAC Site Synopsis
Appendix
18150-6011-C Natura Impact Statement September 2018
SITE NAME: LOWER RIVER SHANNON cSAC SITE CODE: 002165
Qualifying interests:
Annex I habitats Sandbanks which are slightly covered by sea water all the time [1110] Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Coastal lagoons [1150] Large shallow inlets and bays [1160] Reefs [1170] Perennial vegetation of stony banks [1220] Vegetated sea cliffs of the Atlantic and Baltic coasts [1230] Salicornia and other annuals colonizing mud and sand [1310] Spartina swards (Spartinion maritimae) [1320] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation [3260] Molinia meadows on calcareous, peaty or clavey-silt-laden soils (Molinion caeruleae) [6410] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0]
Annex II species Freshwater pearl mussel (Margaritifera margaritifera) [1029] Sea Lamprey (Petromyzon marinus) [1095] Brook Lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Salmon (Salmo salar) [1106] Bottle-nosed dolphin (Tursiops truncatus) [1349] Otter (Lutra lutra) [1355]
This very large site stretches along the Shannon valley from Killaloe to Loop Head/ Kerry Head, a distance of some 120km. The site thus encompasses the Shannon, Feale, Mulkear and Fergus Estuaries, the freshwater lower reaches of the River Shannon (between Killaloe and Limerick), the freshwater stretches of much of the Feale and Mulkear catchments and the marine area between Loop Head and Kerry Head. The Shannon and Fergus flow through Carboniferous limestone as far as Foynes, but west of Foynes Namurian shales and flagstones redominate (except at Kerry Head, which is formed from Old Red Sandstone). The eastern sections of the Feale catchment flow through Namurian Rocks and the western stretches through Carboniferous Limestone. The Mulkear flows through Lower Palaeozoic Rocks in the upper reaches before passing through Namurian Rocks, followed by Lower Carboniferous Shales and Carboniferous Limestone. The Mulkear River itself, immediately north of Pallas Green, passes through an area of Rhyolites, Tuffs and Agglomerates.
Appendix
18150-6011-C Natura Impact Statement September 2018
Rivers within the subcatchment of the Feale include the Galey, Smearlagh, Oolagh, Allaughaun, Owveg, Clydagh, Caher, Breanagh and Glenacarney. Rivers within the sub-catchment of the Mulkear include the Killeenagarriff, Annagh, Newport, the Dead River, the Bilboa, Glashacloonaraveela, Gortnageragh and Cahernahallia.
The site is a candidate SAC selected for lagoons and alluvial wet woodlands, both habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for floating river vegetation, Molinia meadows, estuaries, tidal mudflats, Atlantic salt meadows, Mediterranean salt meadows, Salicornia mudflats, sand banks, perennial vegetation of stony banks, sea cliffs, reefs and large shallow inlets and bays all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive – Bottle-nosed Dolphin, Sea Lamprey , River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Atlantic Salmon and Otter.
The Shannon and Fergus Estuaries form the largest estuarine complex in Ireland. They form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon estuary (considered to be a line across the narrow strait between Kilcredaun Point and Kilconly Point). Within this main unit there are several tributaries with their own ‘sub-estuaries’ e.g. the Deel River, Mulkear River, and Maigue River. To the west of Foynes, a number of small estuaries form indentations in the predominantly hard coastline, namely Poulnasherry Bay, Ballylongford Bay, Clonderalaw Bay and the Feale or Cashen River Estuary.
Both the Fergus and inner Shannon estuaries feature vast expanses of intertidal mudflats, often fringed with saltmarsh vegetation. The smaller estuaries also feature mudflats, but have their own unique characteristics, e.g. Poulnasherry Bay is stony and unusually rich in species and biotopes. Plant species are typically scarce on the mudflats, although there are some Eel-grass beds (Zostera spp.) and patches of green algae (e.g. Ulva sp. and Enteromorpha sp.). The main macro-invertebrate community, which has been noted from the inner Shannon and Fergus estuaries, is a Macoma- Scrobicularia-Nereis community.
In the transition zone between mudflats and saltmarsh, specialised colonisers of mud predominate: swards of Common Cord-grass (Spartina anglica) frequently occur in the upper parts of the estuaries. Less common are swards of Glasswort (Salicornia europaea agg.). In the innermost parts of the estuaries, the tidal channels or creeks are fringed with species such as Common Reed (Phragmites australis) and Club-rushes (Scirpus maritimus, S. tabernaemontani and S. triquetrus). In addition to the nationally rare Triangular Club-rush (Scirpus triqueter), two scarce species are found in some of these creeks (e.g. Ballinacurra Creek): Lesser Bulrush (Typha angustifolia) and Summer Snowflake (Leucojum aestivum).
Saltmarsh vegetation frequently fringes the mudflats. Over twenty areas of estuarine saltmarsh have been identified within the site, the most important of which are around the Fergus Estuary and at Ringmoylan Quay. The dominant type of saltmarsh present is Atlantic salt meadow occurring over mud. Characteristic species occurring include Common Saltmarsh Grass (Puccinellia maritima), Sea Aster (Aster tripolium), Thrift (Armeria maritima), Sea-milkwort (Glaux maritima), Sea Plantain (Plantago maritima), Red Fescue (Festuca rubra), Creeping Bent (Agrostis stolonifera), Saltmarsh
Appendix
18150-6011-C Natura Impact Statement September 2018
Rush (Juncus gerardi), Long-bracted Sedge (Carex extensa), Lesser Seaspurrey (Spergularia marina) and Sea Arrowgrass (Triglochin maritima). Areas of Mediterranean salt meadows, characterised by clumps of Sea Rush (Juncus maritimus) occur occasionally. Two scarce species are found on saltmarshes in the vicinity of the Fergus Estuary: a type of robust Saltmarsh-grass (Puccinellia foucaudii), sometimes placed within the compass of Common Saltmarsh-grass (Puccinellia maritima) and Hard-grass (Parapholis strigosa).
Saltmarsh vegetation also occurs around a number of lagoons within the site. The two which have been surveyed as part of a National Inventory of Lagoons are Shannon Airport Lagoon and Cloonconeen Pool. Cloonconeen Pool (4-5 ha) is a natural sedimentary lagoon impounded by a low cobble barrier. Seawater enters by percolation through the barrier and by overwash. This lagoon represents a type which may be unique to Ireland since the substrate is composed almost entirely of peat. The adjacent shore features one of the best examples of a drowned forest in Ireland. Aquatic vegetation in the lagoon includes typical species such as Beaked Tasselweed (Ruppia maritima) and green algae (Cladophora sp.). The fauna is not diverse, but is typical of a high salinity lagoon and includes six lagoon specialists (Hydrobia ventrosa, Cerastoderma glaucum, Lekanesphaera hookeri, Palaemonetes varians, Sigara stagnalis and Enochrus bicolor). In contrast, Shannon Airport Lagoon (2 ha) is an artificial saline lake with an artificial barrier and sluiced outlet. However, it supports two Red Data Book species of Stonewort (Chara canescens and Chara cf. connivens).
Most of the site west of Kilcredaun Point/Kilconly Point is bounded by high rocky sea cliffs. The cliffs in the outer part of the site are sparsely vegetated with lichens, Red Fescue, Sea Beet (Beta vulgaris), Sea Campion (Silene maritima), Thrift and Plantains (Plantago spp.). A rare endemic Sea Lavender (Limonium recurvum subsp. pseudotranswallinum) occurs on cliffs near Loop Head. Cliff-top vegetation usually consists of either grassland or maritime heath. The boulder clay cliffs further up the estuary tend to be more densely vegetated, with swards of Red Fescue and species such as Kidney Vetch (Anthyllis vulneraria) and Bird’s-foot Trefoil (Lotus corniculatus).
The site supports an excellent example of a large shallow inlet and bay. Littoral sediment communities in the mouth of the Shannon Estuary occur in areas that are exposed to wave action and also in areas extremely sheltered from wave action. Characteristically, exposed sediment communities are composed of coarse sand and have a sparse fauna. Species richness increases as conditions become more sheltered. All shores in the site have a zone of sand hoppers at the top and below this each of the shores has different characteristic species giving a range of different shore types in the cSAC.
The intertidal reefs in the Shannon Estuary are exposed or moderately exposed to wave action and subject to moderate tidal streams. Known sites are steeply sloping and show a good zonation down the shore. Well developed lichen zones and littoral reef communities offering a high species richness in the sublittoral fringe and strong populations of Paracentrotus lividus are found. The communities found are tolerant to sand scour and tidal streams. The infralittoral reefs range from sloping platforms with some vertical steps to ridged bedrock with gullies of sand between the ridges to ridged bedrock with boulders or a mixture of cobbles, gravel and sand. Kelp is very common to about
Appendix
18150-6011-C Natura Impact Statement September 2018
18m. Below this it becomes rare and the community is characterised by coralline crusts and red foliose algae. Flowing into the estuaries are a number of tidal rivers.
Other coastal habitats that occur within the site include the following:
Stony beaches and bedrock shores - these shores support a typical zonation of seaweeds (Fucus spp., Ascophyllum nodosum and kelps). Shingle beaches - the more stable areas of shingle support characteristic species such as Sea Beet, Sea Mayweed (Matricaria maritima), Sea Campion and Curled Dock (Rumex crispus). Sandbanks which are slightly covered by sea water at all times – there is a known occurrence of sand/gravel beds in the area from Kerry Head to Beal Head. Sand dunes - a small area of sand dunes occurs at Beal Point. The dominant species is Marram Grass (Ammophila arenaria).
Freshwater rivers have been included in the site, most notably the Feale and Mulkear catchments, the Shannon from Killaloe to Limerick (along with some of its tributaries, including a short stretch of the Kilmastulla River), the Fergus up as far as Ennis, and the Cloon River. These systems are very different in character: the Shannon being broad, generally slow-flowing and naturally eutrophic; the Fergus being smaller and alkaline; while the narrow, fast-flowing Cloon is acid in nature. The Feale and Mulkear catchments exhibit all the aspects of a river from source to mouth. Semi-natural habitats, such as wet grassland, wet woodland and marsh occur by the rivers, however, improved grassland is most common. One grassland type of particular conservation significance, Molinia meadows, occurs in several parts of the site and the examples at Worldsend on the River Shannon are especially noteworthy. Here are found areas of wet meadow dominated by rushes and sedges and supporting a diverse and species-rich vegetation, including such uncommon species as Blue- eyed Grass (Sisyrinchium bermudiana) and Pale Sedge (Carex pallescens).
Floating river vegetation characterised by species of Water-crowfoot (Ranunculus spp.), Pondweeds (Potamogeton spp.) and the moss Fontinalis antipyretica are present throughout the major river systems within the site. The rivers contain an interesting bryoflora with Schistidium alpicola var. alpicola recorded from in-stream boulders on the Bilboa, new to county Limerick.
Alluvial woodland occurs on the banks of the Shannon and on islands in the vicinity of the University of Limerick. The woodland is up to 50m wide on the banks and somewhat wider on the largest island. The most prominent woodland type is gallery woodland where White Willow (Salix alba) dominates the tree layer with occasional Alder (Alnus glutinosa). The shrub layer consists of various willow species with sally (Salix cinerea ssp. oleifolia) and what appear to be hybrids of S. alba x S. viminalis. The herbaceous layer consists of tall perennial herbs. A fringe of Bulrush (Typha sp.) occurs on the riverside of the woodland. On slightly higher ground above the wet woodland and on the raised embankment remnants of mixed oak-ash-alder woodland occur. These are poorly developed and contain numerous exotic species but locally there are signs that it is invading open grassland. Alder is the principal tree species with occasional Oak (Quercus robur), Elm (Ulmus glabra, U. procera), Hazel (Corylus avellana), Hawthorn (Crataegus monogyna) and the shrubs Guelder-rose (Viburnum opulus) and willows. The ground flora is species-rich.
Appendix
18150-6011-C Natura Impact Statement September 2018
Woodland is infrequent within the site; however Cahiracon Wood contains a strip of old Oak woodland. Sessile Oak (Quercus petraea) forms the canopy, with an understorey of Hazel and Holly (Ilex aquifolium). Great Wood-rush (Luzula sylvatica) dominates the ground flora. Less common species present include Great Horsetail (Equisetum telmeteia) and Pendulous Sedge (Carex pendula).
In the low hills to the south of the Slievefelim Mountains, the Cahernahallia River cuts a valley through the Upper Silurian rocks. For approximately 2km south of Cappagh Bridge at Knockanavar, the valley sides are wooded. The woodland consists of Birch (Betula spp.), Hazel, Oak, Rowan (Sorbus aucuparia), some Ash (Fraxinus excelsior) and Willow (Salix spp.). Most of the valley is not grazed by stock, and as a result the trees are regenerating well. The ground flora feature prominent Greater wood-rush and Bilberry (Vaccinium myrtillus) with a typical range of woodland herbs. Where there is more light available, Bracken (Pteridium aquilinum) features.
The valley sides of the Bilboa and Gortnageragh Rivers, on higher ground north east of Cappamore, support patches of semi-natural broadleaf woodland dominated by Ash, Hazel, Oak and Birch. There is a good scrub layer with Hawthorn, Willow, Holly and Blackthorn (Prunus spinosa) common. The herb layer in these woodlands is often open with a typically rich mixture of woodland herbs and ferns. Moss species diversity is high. The woodlands are ungrazed. The hazel is actively coppiced in places.
There is a small area of actively regenerating cut away raised bog at Ballyrorheen. It is situated approx. 5km north west of Cappamore Co. Limerick. The bog contains some wet areas with good moss (Sphagnum) cover. Species of particular interest include the Cranberry (Vaccinium oxycoccos) and the White Sedge (Carex curta) along with two other regionally rare mosses including S. fimbriatum. The site is being invaded by Birch (Betula pubescens) scrub woodland. Both commercial forestry and the spread of rhododendron has greatly reduced the overall value of the site. A number of plant species that are Irish Red Data Book species occur within the site; several are protected under the Flora (Protection) Order, 1999:
Triangular Club-rush (Scirpus triquetrus) - in Ireland this protected species is only found in the Shannon Estuary, where it borders creeks in the inner estuary. Opposite-leaved Pondweed (Groenlandia densa) - this protected pondweed is found in the Shannon where it passes through Limerick City. The stronghold for this plant is the Park canal (NPWS, 2012). Meadow Barley (Hordeum secalinum) - this protected species is abundant in saltmarshes at Ringmoylan and Mantlehill. Hairy Violet (Viola hirta) - this protected violet occurs in the Askeaton/Foynes area. Golden Dock (Rumex maritimus) - noted as occurring in the River Fergus Estuary. Bearded Stonewort (Chara canescens) - a brackish water specialist found in Shannon Airport lagoon. Convergent Stonewort (Chara connivens) - presence in Shannon Airport Lagoon to be confirmed.
Appendix
18150-6011-C Natura Impact Statement September 2018
Overall, the Shannon and Fergus Estuaries support the largest numbers of wintering waterfowl in Ireland. The highest count in 1995-96 was 51,423 while in 1994-95 it was 62,701. Species listed on Annex I of the E.U. Birds Directive which contributed to these totals include: Great Northern Diver (3; 1994/95), Whooper Swan (201; 1995/96), Pale-bellied Brent Goose (246; 1995/96), Golden Plover (11,067; 1994/95) and Bar-tailed Godwit ( 476; 1995/96). In the past, three separate flocks of Greenland White-fronted Goose were regularly found but none were seen in 1993/94. Other wintering waders and wildfowl present include Greylag Goose (216; 1995/96), Shelduck (1,060; 1995/96), Wigeon (5,976; 1995/96); Teal (2,319; 1995-96); Mallard (528; 1995/96), Pintail (45; 1995/96), Shoveler (84; 1995/96), Tufted Duck (272; 1995/96), Scaup (121; 1995/96), Ringed Plover (240; 1995/96), Grey Plover (750; 1995/96), Lapwing (24,581; 1995/96), Knot (800; 1995/96), Dunlin (20,100; 1995/96), Snipe (719, 1995/96), Black-tailed Godwit (1062; 1995/96), Curlew (1504; 1995/96), Redshank (3228; 1995/96), Greenshank (36; 1995/96) and Turnstone (107; 1995/96). A number of wintering gulls are also present, including Black-headed Gull (2,216; 1995/96), Common Gull (366; 1995/96) and Lesser Black-backed Gull (100; 1994/95).
This is the most important coastal site in Ireland for a number of the waders including Lapwing, Dunlin, Snipe and Redshank. It also provides an important staging ground for species such as Black- tailed Godwit and Greenshank. A number of species listed on Annex I of the E.U. Birds Directive breed within the site. These include Peregine Falcon (2-3 pairs), Sandwich Tern (34 pairs on Rat Island, 1995), Common Tern (15 pairs: 2 on Sturamus Island and 13 on Rat Island, 1995), Chough (14- 41 pairs, 1992) and Kingfisher. Other breeding birds of note include Kittiwake (690 pairs at Loop Head, 1987) and Guillemot (4010 individuals at Loop Head, 1987)
There is a resident population of Bottle-nosed Dolphin in the Shannon Estuary consisting of at least 56-68 animals (1996). This is the only known resident population of this E.U. Habitats Directive Annex II species in Ireland. Otter, a species also listed on Annex II of this directive, is commonly found on the site.
Five species of fish listed on Annex II of the E.U. Habitats Directive are found within the site. These are Sea Lamprey (Petromyzon marinus), Brook Lamprey (Lampetra planeri), River Lamprey (Lampetra fluviatilis), Twaite Shad (Allosa fallax fallax) and Salmon (Salmo salar). The three lampreys and Salmon have all been observed spawning in the lower Shannon or its tributaries. The Fergus is important in its lower reaches for spring Salmon while the Mulkear catchment excels as a grilse fishery though spring fish are caught on the actual Mulkear River. The Feale is important for both types. Twaite Shad is not thought to spawn within the site. There are few other river systems in Ireland which contain all three species of Lamprey. Two additional fish of note, listed in the Irish Red Data Book also occur, namely Smelt (Osmerus eperlanus) and Pollan (Coregonus autumnalis pollan). Only the former has been observed spawning in the Shannon.
Freshwater Pearl-mussel (Margaritifera margaritifera), a species listed on Annex II of the E.U. Habitats Directive, occurs abundantly in parts of the Cloon River.
There is a wide range of land uses within the site. The most common use of the terrestrial parts is grazing by cattle and some areas have been damaged through overgrazing and poaching. Much of
Appendix
18150-6011-C Natura Impact Statement September 2018 the land adjacent to the rivers and estuaries has been improved or reclaimed and is protected by embankments (especially along the Fergus Estuary). Further, reclamation continues to pose a threat as do flood relief works (e.g. dredging of rivers). Gravel extraction poses a major threat on the Feale. In the past, Cord-grass (Spartina sp.) was planted to assist in land reclamation. This has spread widely, and may oust less vigorous colonisers of mud and may also reduce the area of mudflat available to feeding birds.
Domestic and industrial wastes are discharged into the Shannon, but water quality is generally satisfactory - except in the upper estuary, reflecting the sewage load from Limerick City. Analyses for trace metals suggest a relatively clean estuary with no influences by industrial discharges apparent. Further industrial development along the Shannon and water polluting operations are potential threats. Fishing is a main tourist attraction on the Shannon and there are a large number of Angler Associations, some with a number of beats. Fishing stands and styles have been erected in places. The River Feale is a designated Salmonid Water under the E.U. Freshwater Fish Directive. Other uses of the site include commercial angling, oyster farming, boating (including dolphin-watching trips) and shooting. Some of these may pose threats to the birds and dolphins through disturbance. Specific threats to the dolphins include underwater acoustic disturbance, entanglement in fishing gear and collisions with fast moving craft.
This site is of great ecological interest as it contains a high number of habitats and species listed on Annexes I and II of the E.U. Habitats Directive, including the priority habitat lagoon, the only known resident population of Bottle-nosed Dolphin in Ireland and all three Irish lamprey species. A good number of Red Data Book species are also present, perhaps most notably the thriving populations of Triangular Club-rush. A number of species listed on Annex I of the E.U. Birds Directive are also present, either wintering or breeding. Indeed, the Shannon and Fergus Estuaries form the largest estuarine complex in Ireland and support more wintering wildfowl and waders than any other site in the country. Most of the estuarine part of the site has been designated a Special Protection Area (SPA), under the E.U. Birds Directive, primarily to protect the large numbers of migratory birds present in winter.
Appendix
18150-6011-C Natura Impact Statement September 2018
Appendix 3 Giant Hogweed Control Plan (incl. map)
Appendix
Giant Hogweed Control Plan Draft 2: Screening
Project Details: Removal of Giant Hogweed at Newport Town Park
Site Location: Proposed Newport Town Park, Mulkear View, Tullow, Newport, Co Tipperary.
Works Location: Newport, Co Tipperary.
Client Tipperary County Council
Site Engineer John Cass Nenagh Municipal District Tipperary County Council Civic Offices Limerick Road Nenagh Co. Tipperary Tel: 0761065000 [email protected]
Mulkear Forestry, Contractor Foxhall, Newport, Co Tipperary Tel: +353861261794
Work Start Date: 15/04/18
Work Finish Date: 31/11/21
TABLE OF CONTENTS
1.0 Control Plan: 3 1.1 Plan Brief: 3 !1 1.2 Welfare: 3 1.3 Supervision on Site: 3 2.0 Standard Conditions of Operations 3 2.1 General Conservation Guidelines 3 2.2 Safety 4 2.3 The Environment 4 2.4. Consultation 6 2.5 Emergency Plan: 6 3. Site Safety 6 3.1 Site Safety Rules 6 3.2 Housekeeping: 6 4.0 Operation Specification 7 4.1 Summary of Operaton 7 4.2) Access 7 4.3) Survey 7 4.4 Site Preparation 7 5. Operation Methodology 8 5.1 Treatment Plan Year 1 8 5.2 Treatment Plan Year 2 8 5.3 Treatment Plan Year 3 8 5.4 Treatment Plan Year 4 8 6.0 Monitoring 8 7.0 Safety Controls applied to Eliminate or minimize the identified Hazards 9 8.0. Personal Protective Equipment Required 9 8.1 Supervisory 9 8.2 Spray Treatment 9 8.3 Seed Collection 9 9.0 Health and Safety Instructions for Persons involved with the Work 10 10.0 Names and Qualifications of Mulkear Forestry who will supervise the Work 10 11.0 Operations Contractors & Employee(s) involved in the Work 10 11.0 Identification of Plant & Equipment that will be used on site 10 12.0 Mulkear Forestry & Sub-Contractors: 11 Method Statement Approved By: ______11 13.0 Health and Safety Risk Assessment 12 14.0 Environmental Risk Assessment 15
!2 1.0 Control Plan: The objective of the operation is to carry out Giant Hogweed Heracleum mantegazzianum removal and control as per specification and locations highlighted in map Appendix 1.
1.1 Plan Brief: This will outline the work practices and methods that will be engaged in by Mulkear Forestry contractors. The controls outlined in the risk assessments will provide a safe system of work, both individually and collectively and with respect to all environmental risks concerned with the works.
1.2 Welfare: The Client will afford access to their on site welfare facilities at site, including washing facilities.
1.3 Supervision on Site: A designated site safety co-ordinator will be appointed to supervise work. The site safety co-ordinator will be experi- enced in this type of work and will be responsible for all persons under his control and the implementation of safe sys- tems of work. A list of roles and responsibilities will be made available on the Operation Site Plan prior to work com- mences. The Operations Site Plan is the operations plan and is available on site at all times during working Hours. The site safety co-ordinator at the property is listed below: - Mr Matthew Kelleher
2.0 Standard Conditions of Operations
2.1 General Conservation Guidelines The Mulkear River is part of the Lower Shannon Special Area of Conservation (SAC). The Mulkear River itself rises in the Slievefelim and Silvermines mountains in Co. Tipperary and joins the Shannon River below Annacotty in Co. Lim- erick. The main river channel is approximately 21.5 km long. Its principal tributaries are the Dead River, Bilboa and Newport rivers. The Site is situated on the Newport River tributary.
The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive
(* = priority; numbers in brackets are Natura 2000 codes): SITE SYNOPSIS
[1110] Sandbanks [1130] Estuaries [1140] Tidal Mudflats and Sandflats [1150] Coastal Lagoons* [1160] Large Shallow Inlets and Bays [1170] Reefs [1220] Perennial Vegetation of Stony Banks [1230] Vegetated Sea Cliffs [1310] Salicornia Mud [1330] Atlantic Salt Meadows !3 [1410] Mediterranean Salt Meadows [3260] Floating River Vegetation [6410] Molinia Meadows [91E0] Alluvial Forests* [1029] Freshwater Pearl Mussel (Margaritifera margaritifera) [1095] Sea Lamprey (Petromyzon marinus) [1096] Brook Lamprey (Lampetra planeri) [1099] River Lamprey (Lampetra fluviatilis) [1106] Atlantic Salmon (Salmo salar) [1349] Bottle-nosed Dolphin (Tursiops truncatus) [1355] Otter (Lutra lutra)
Crayfish Plague Works carried out on Newport river are highlighted as high risk for transfer of Crayfish Plague.The fungus- like Aphanomyces astaci that causes the lethal crayfish plague is related to potato blight and grape disease, which also crossed the Atlantic to Europe. Each American crayfish species carries a different strain of the plague. The ‘Pacifastacus’ strain appears completely lethal and eradicates all native crayfish. It is essential that the plan enforce hygiene, so that there is no possibility of plague spores entering Irish waters.
2.2 Safety
Giant hogweed can cause severe skin burns, the plant produces a sap that is hazardous to humans, particularly in the presence of direct sunlight. The large leaves of the plant create sufficient shade to suppress indigenous herbaceous un- der-storey plants along bank-sides.
a) All persons engaged in Operations shall comply with current safety legislation Safety, Health and Welfare at Work (General Applications) Regulations, 2007 & SAFETY, HEALTH AND WELFARE AT WORK (CONSTRUCTION) REGULATIONS 2013
b) Comply with guidelines including the safe use of chemicals
c) The contractor shall provide and erect sufficient warning signs on all approach roads to operations sites and maintain throughout operations.
d) Leave all sites in a safe condition at the end of each working day.
e) All persons to use correct PPE outlined
f) First Aid training and equipment to be kept onsite at all times
g) Contractor Safety Statement & Method Statement to be understood be all works persons
h) Site Safety co-ordinator to monitor for safety during the course of the operation
i) Mulkear Forestry to control and implement safe clearance zone throughout operations.
2.3 The Environment
!4 a) Comply with guidelines in relation to Fisheries, and Water Quality including the safe use of herbicides and working on an SAC watercourse;
Irish Legislation and European Union (EU) Directives relating to water are listed below:
Irish Legislation: European Communities (Water Policy) Regulations, 2003 (S.I. No. 722 of 2003) European Communities (Drinking Water) Regulations 2014 (S.I. 122 of 2014) European Communities Environmental Objectives (Surface Waters) Regulations, 2009 (S.I. No. 272 of 2009) European Communities Environmental Objectives (Groundwater) Regulations, 2010 (S.I. No. 9 of 2010) European Communities (Good Agricultural Practice for Protection of Waters) Regulations, 2010 (S.I. No. 610 of 2010) European Communities (Technical Specifications for the Chemical Analysis and Monitoring of Water Status) Regulations, 2011 (S.I. No. 489 of 2011)
EU Directives: Birds Directive (79/409/EEC) ; Drinking Water Directive (80/778/EEC) as amended by Directive (98/83/EC); Major Accidents (Seveso) Directive (96/82/EC); Environmental Impact Assessment Directive (85/337/EEC); Sewage Sludge Directive (86/278/EEC); Urban Waste-water Treatment Directive (91/271/EEC); Plant Protection Products Directive (91/414/EEC); Nitrates Directive (91/676/EEC); Habitats Directive (92/43/EEC); Integrated Pollution Prevention Control Directive (96/61/EC); Water Framework Directive (2000/60/EC); Bathing Water Directive (2006/7/EC) (repeals 76/160/EEC); Groundwater Directive (2006/118/EC); Floods Directive (2007/56/EC); Marine Strategy Framework Directive (2008/56/EC). b) Avoid damage to amenity and recreational areas. c) Keep site litter free, remove waste oil and containers from site and dispose of them in appropriate environmental waste facility. d) Comply with "Code of Practice Safe use of Chemicals" a. Use approved chemical RoundUp Biactive when working within SAC river catchment b. Use dried protective cowls on spray equipment to eliminate unnecessary drift of chemicals to plant and aquatic life e) Code of Best Practice to be implemented while working within a river catchments. f) Disturbance of built environment and structure to be kept to an absolute minimum and all contractors to cease work on discovery of evidence of archaeology or defect of any kind. g) Enforce a containment area for working with chemicals including wash area a. Marked exclusion area agreed with construction h) Enforce a containment area for incineration of hazardous seed heads collected a. This area will be quarantined for trained personelle only and recored of visit to and fro b. Incineration to be carried out with regulations on air quality and agreed times with Tipperary Local Authority, Dept of Environment and the Fire Service i) Apply control measure to eliminate the spread of Crayfish plague spores, where contact with freshwater occurs with equipment and personnel wet gear should be disinfected using a bleach solution. j) Carry spillage control kits at all times and have a rapid response plan for chemical spillages k) Enforce an agreed exclusion zone for working where tools, equipment, PPE and materials entering must be either fully washed or disposed of onsite prior to leaving the site and prevent the spread of invasive plant ma- terials !5 2.4. Consultation
Mulkear Forestry will seek information and consult with relevant agencies pertaining to the listed habitats and species prior to commencement of operations.
Mulkear LIFE Project Inland Fisheries Ireland National Parks and Wildlife Service St Marys Secondary School Newport Newport Town Park Committee Mulkear View Residents
2.5 Emergency Plan: This work will be covered by Mulkear Forestry Safety Statement Emergency Plan for the site; this emergency plan will incorporate Mulkear Forestry procedures into the emergency plan and will be communicated to all persons at the Site Induction. All operators on site will have received first aid and manual handling training. A first aid kit and emergency contact details will be available at all times and access for emergency vehicles to be maintained at all times.
3. Site Safety
3.1 Site Safety Rules Roadways and entrances must be maintained and kept open during working times to facilitate emergency vehicles or egress in the event of an accident. All site work vehicles to parked at lay byes and not to obstruct traffic on forest road which will be entering and exiting the site.
Up to date emergency plan with relevant Telephone numbers on site.
All site personnel, visitors and supervisors must wear high visibility clothing and helmet on work site and full chemical control PPE when entering area of infection.
The infection area should be clearly outlined using either fencing of safety barriers and prohibition notices
Ensure a system is in place to check at break times that all personnel on site are OK and that no one is left behind at night.
Effective working alone procedures implemented - Each operator to have a mobile phone and contact numbers of other site operators. - Inform a work colleague of your whereabouts before commencing activity. - Inform a family member of your activities and estimated time of return. - Provide the Site Safety Coordinator with contact details of who to contact in the event of an emergency. - Carry out Daily Job Plan and keep daily records of work and progress - Each site must have an adequate first aid kit and person competent in its use. - All accidents and dangerous occurrences reported to Mulkear Forestry immediately. - All accidents and dangerous occurrences reported to principal Tipperary County Council. - Site safety signage erected and maintained on worksite. - All operators must wear high visibility clothing and helmet. - All equipment must be maintained in a safe condition and operated safely - All chemicals to be stored in a safe and stable manner and away from water courses and operators must have spill kits and washing kits available at all times - All relevant Personal Protective Equipment to be worn as per guidelines for safe use of herbicides. SEE PPE section in this document for work relating to chemical use.
These generic site safety rules apply to all Maintenance Operations and should be read in conjunction with site specific controls/rules as outlined in the Risk Assessment for each particular site.
3.2 Housekeeping: 1. ‘Clean as you go’ policy will be implemented on site. Each employee is responsible for keeping his own work area tidy.
!6 2. All waste materials considered contaminated to be removed off site by contractor and logged as biologically haz- ardous waste and disposed of using registered waste disposal and disposal catalogued fo future records. 3. All access ways and work platforms will be kept tidy and clear of obstructions at all times. 4. All fuel/chemicals and machine service points to be a minimum of 50 meters away from water courses and washing of equipment in agreed exclusion zone.
4.0 Operation Specification
4.1 Summary of Operaton
A. Chemical Control (Glyphosate (Roundup Biactive), minimum 4 Yr Programme of Spot Treat- ment B. Native tree/shrub, ground flora reconstitution C. 3+ Year post control monitoring
Objective: The objective is to capture all current growths hazardous material in first years treatment, using a more environmentally sensitive form of glyphosate, RoundUp Biactive which breaks down in soils quickly is least harmful to plants and wa- tercourses.
The treatment plan is to chemical treat plants 3 times in the growing season, April, June, and September over 4 years.
The type of spraying in concentrated and targeted at the leaf and stem of young plants while larger stems are inoculated to penetrate the root. This method limits the amount of chemical applied and is targeted at the hazardous plants only. Spray equipment uses cowls to protect against drift.
During flowering season (July) any remaining the umbels will be collected using floor mats and bags to capture the seed. The seed can be brought to nearby containment area for onsite incineration. It is hoped the removal of umbels will take away further seed leaving the previous 3 years seed bank to be treated in follow up treatments.
In the final year a programme of reconstitution for infected soils will be carried out. This involved the planting of na- tive ground flora, shrubs and trees to give ground coverage where re-infestation may occur.
4.2) Access Access to the site is through the Mulkear View estate. A gate is found at the rear of the estate and a gravelled area is found at the bottom of the site suitable for parking. Access should be agreed upon consultation with Mulkear View resi- dents prior to commencement.
4.3) Survey 1.A vegetation survey will be completed to identify areas needing treatment and also flora and fauna at risk of damage with plant distribution mapped and catalogued. 2. Plant density per 10 m2 and monitored regularly through treatment regime to measure success and monitor for re- infestation. 3.Upstream areas have been treated by Mulkear Life and OPW and liaison with these agencies will be provided to en- sure against any further upstream outbreaks affecting our treatments plan.
4.4 Site Preparation 1. Materials and personnel to be delivered by van through main entrance 2. Erect safety signage on surrounding compound 3. Erect an exclusion barrier and signage surrounding the works area. 4. Install a clearly defined area for washing personelle, equipment and for any incineration works. i. biological waste material and any items be contaminated such as PPE or clothing should be incinerated and catalogued
!7 ii. Access in and out of exclusion area should be restricted to personnel and machinery involved with hog- weed removal and control iii. Access from freshwater contact should be recorded for protection against spread of crayfish plague iv. Materials, equipment and persjonele from freshwater should be washed and disinfected to eliminate spread of Crayfish plague. Records kept v. Access in and out should of site be catalogued using sign in/out sheets
5. Operation Methodology
5.1 Treatment Plan Year 1 1. Seedlings spot treated through contact with leaf and stem 2. Stems, Stalks and flowering plants treated using a punctured stalk technique 300mm from flower/stalk head and treatment solution inoculated into stalk -1
3. Commence treatment in April, using 5l ha glyphosate (biactive) 4. Treat again in May, July and September; 1. In June/July locate and destroy flowering plants, (remove umbels and burn onsite)
5.2 Treatment Plan Year 2 1. Seedlings spot treated through contact with leaf and stem 2. Stems, Stalks and flowering plants treated using a punctured stalk technique 300mm from flower/stalk head and treatment solution inoculated into stalk -1
3. Commence treatment in April, using 5l ha glyphosate (biactive) 4. Treat again in May, July and September; 5. In June/July locate and destroy flowering plants, (remove umbels and burn onsite)
5.3 Treatment Plan Year 3 1. Seedlings spot treated through contact with leaf and stem 2. Stems, Stalks and flowering plants treated using a punctured stalk technique 300mm from flower/stalk head and treatment solution inoculated into stalk -1
3. Commence treatment in April, using 5l ha glyphosate (biactive) 4. Treat again in May, July and September; 5. In June/July locate and destroy flowering plants, (remove umbels and burn onsite)
5.4 Treatment Plan Year 4 1. Seedlings spot treated through contact with leaf and stem 2. Stems, Stalks and flowering plants treated using a punctured stalk technique 300mm from flower/stalk head and treatment solution inoculated into stalk 3. Commence native plant, shrub and tree planting on contaminated soil 1. Shade tolerant species of aquatic plants, shrub and trees. (Use only EU certified plant stock) -1
4. Commence spray treatment in April, using 5l ha glyphosate (biactive) 5. Treat again in May, July and September; 6. In June/July locate and destroy flowering plants, (remove umbels and burn onsite)
6.0 Monitoring 1. The site should be monitored regularly throughout treatment regime and surveys catalogued 2. The site should be monitored for a further 3 years following the treatment regime. 3. A survey should include a record of stems per 10 m2 and record details of growth stages of plants 4. Any further flora, fauna and cultural features present should be included in site monitoring forms.
!8 7.0 Safety Controls applied to Eliminate or minimize the identified Hazards
1. All operators trained as per statutory requirements. 2. Equipment in good condition, competent operators. 3. Fire extinguishers, first aid kits and pollution control kits will be available on site at all times. 4. Where work cannot be conducted within the scope of the method statement site management are to be consult- ed and method statement amended. 5. A competent site safety coordinator (Matt Kelleher) will be available on site at all times. 6. Signage to be erected on site prior to work commencement and maintained for the duration of the work. 7. Site Specific Hazard Identification Risk Assessment carried out and all operators read and understand its con- tent, signed and dated by each contractor. Work and Welfare in accordance with Safety, Health and Welfare at Work (General Application) Regulations 2007 8. Take due care when working adjacent to public roads 9. PPE to be worn at all times
8.0. Personal Protective Equipment Required
8.1 Supervisory • High Visibility Jackets
• Hard Hat
• Steel Toe Capped Boots
• Safety Gloves
• Eye Protection
8.2 Spray Treatment • Head to toe Spray Suit
• Heavy Duty Nitrile Gloves
• Protective Face Masks with disposable face shield
• Breathing respirators
• Steel Toe Capped wellingtons
• Shield when Mixing
8.3 Seed Collection • Head to toe Spray Suit
• Heavy Duty Nitrile Gloves for collection
• Fire Protective Gloves for burning
• Breathing respirator
• Protective Face Masks with disposable face shield
!9 • Steel Toe Capped wellingtons
• Fire Extinguisher
NOTE: Enforce and buddy system for putting on/off PPE equipment and have adequate wash facility in place for hos- ing down PPE and disposing of contaminated PPE equipment
9.0 Health and Safety Instructions for Persons involved with the Work
1) Conduct work in compliance with this work method statement. 2) Comply with Tipperary County Council site safety rules as indicated during induction. 3) All operators to attend a site induction course during construction stage. 4) Permits to be obtained prior to commencement of work. 5) Contractor safety statement will be applied at all times during the project. 6) Welfare provided by Code of Best Practice Forestry Operations 2009
10.0 Names and Qualifications of Mulkear Forestry who will supervise the Work
Name: Matthew Kelleher – Managing Director & Site Manager Qualifications: 10+ Years Experience Academic: BSc Forest Management (Conservation) Operations: NPTC Chemical Usage Unit PA1-6, Unit 151 Surveying: Training in National Vegetation Classification (NVC Scotland)
Experience: Invasive's and aquatic woodland sites Removal of 5ha Cherry Laurel in Semi Natural Woodland, Curraghchase - Coillte 2018 Removal of Japanese Knotweed in various locations, North Tipperary, Tipperary County Council, 2015 Removal of 4ha Rhododendron, Glenstal Forest - Coillte 2011 Restoration works on aquatic woodlands - Coillte, LIFE Project 2009
11.0 Operations Contractors & Employee(s) involved in the Work
Principal Contractor: Mulkear Forestry
Names Training Received Tom Starr Safe Pass, first aid and manual handling, DAFM Pesticide Advisor Matthew Kelleher Safe Pass, first aid and manual handling, NPTC Chemical Usage PA1-6 Shane Denihan Safe Pass, first aid and manual handling, NPTC Chemical Usage PA1-6 Unit 151
11.0 Identification of Plant & Equipment that will be used on site
Cooper Pegler knapsack including extendable lance Mantra Ultra Low Volume (ULV) Handheld Sprayer Handheld inoculation wand 2.0 meter
Additional Comments / Procedures: ( NB only used if task changes while on site)
!10 ______
12.0 Mulkear Forestry & Sub-Contractors: We the undersigned have read and understand the method statement and will comply with all specified requirements and controls.
Name: Date On Site: ______
Method Statement Approved By: ______
Date: ______
Method Statement Communicated By: ______Mulkear Forestry Managing Director Date: ______
!11 13.0 Health and Safety Risk Assessment The following risk assessment procedure identifies the hazards and the consequences of hazards should they occur. It also sets out the controls and the person(s) responsible.
HAZARD CONSEQUE RISK CONTROLS PERSON RESUL NCE (S) TANT Sev Likeli No. RESPON RISK erit hood Peopl SIBLE y e Affec ted
Public - Major M M 1-2 - Erect warning - WM L Injury signage. - Contra - Operators to stop ctor work if anyone approaches risk zone. - Close roadway or paths if necessary. - Contractor to notify FWM if public at risk.
Terrain & - Major M M 1-2 - Use suitable footware - WM L Slope Injury - Do not work where - Contra ground conditions are ctor unsteady or uneven or risk of falling into river
Slips, Trips - Minor L H 1 - Designated safe - FWM L & Falls Injury access route to - Contra operation ctor - Take due care & attention. - Wear PPE whilst on site. - Carry a mobile phone. - Daily conditional review - Due care when entering & exiting machinery
Manual - Major L H 1 - All operators to have - Contra L Handling Injury completed manual ctor - Disability handling course. - Only work within safe working limits of operator, keeping sections short and manageable lengths to avoid risk to operators
!12 Lack of - Fatal H H +1 - Provide Training in - FWM L First Aid First Aid - Contra and - Provide refresher ctor Training training Kits - Provide First Aid Kit on site
Failure to - Fatal H H +1 • Steel toe capped - FWM L use PPE - Eye boots - Contra Injury • Hard hat ctor • Eye Protection
Driving on - Fatal H H +1 • Obey Speed Limit - FWM L Site - Crash • Use flashing - Contra - Crush beacons ctor - Collision • Use laybys to allow larger vehicles to pass • Allow larger vehicles and vehicle’s ascending steep gradients right of way • Keep to the center of the road and avoid steep verges • Don’t drive off road • Only drive vehicles that are deemed roadworthy and display a in date CRVT test disc • Daily checks for signs of wear or damage to vehicle • T r a i l e r s a n d t r a n s p o r t i n g materials is to be carried out with due care to oncoming t r a f f i c a n d personelle, safety c h e c k s a n d u s e signals to signal oncoming traffic • Take all caution when reversing and risk to personelle • Roll over protection system
Injury from - Injury to • Wear suitable PPE - FWM L Hand Tools limbs • Have trained First - Contra - Cuts & Aider on site ctor Lesions • First aid box with access to wound dressing • Good housekeeping
!13 Chemical - Minor L M 1 - Store all chemicals - Contra L Injury and fuels in suitable ctor - Pollution containers. - PA1-6 Training - Store at least 50m from watercourses. - Use gloves when handling - Spillage Kits onsite at all times - Refuelling kits to be used - Good hygiene when handling chemicals, wash before eating and use of bathroom
Contact • Con H M +1 • Wear Suitable - FWM L with tam PPE - Contra Rodents & inat • Test objects ctor Weils ion before handling Disiese • Sick • Wash and clean nes hands s thouroughly • Dea • Wear th Watherproof clothing & Wash afer use while wearing gloves
!14 14.0 Environmental Risk Assessment The following risk assessment procedure identifies the hazards and the consequences of for the environment. It also sets out the controls and the person(s) responsible.
Environmen CONSEQUE RISK CONTROLS PERSON RESUL tal Factor NCE (S) TANT Sev Likeli No. RESPON RISK erit hood Peopl SIBLE y e Affec ted
Biodiversity Chemical Use approved chemical Self Low contact and dosage rates with flora and fauna Use protective cowl for drift
Dont operate during periods of wet or windy weather
Wash footware regularily when travelling outside treatment area
Complete chemical usage form daily and catalogue
!15 Crayfish Equipment and personnel in contact with freshwater treated as hazardous and disinfected
Contact and treatment recorded
Pollution of Use approved chemical Self Low watercours and dosage rates e Use protective cowl for drift
Dont operate during periods of wet or windy weather
Wash footware regularily when travelling outside treatment area or near watercourse
Complete chemical usage form daily and catalogue
!16 Chemical Check equipment Self Low spillage regularly
Use dedicate filling/ washing area 50m from watercourse
Pour concerntracte solutions back into containers and only wash small residues
Dispose of containers in approved environmental waste facility
Complete chemical usage form daily and catalogue
Soils Spread of Enforce containment Self Low invasive area for infested area plants and incineration area
Log access to and fro and limit to trained personelle
Wash equipment prior to leaving area
Catalogue equipment used onsite and limit travelling
!17 People Persons Use appropriate signage Self Low contact and prohibition notices with chemicals Enforce exclusion zone
Use approved chemical and dosage rates
Use protective cowl for drift
Dont operate during periods of wet or windy weather
Wash footware regularily when travelling outside treatment area or near watercourse
Complete chemical usage form daily and catalogue
Appendix 1: Survey Map
!18 18150-6011-C Natura Impact Statement September 2018
Appendix 4 Environmental Commitments
Appendix
18150-6011-C Natura Impact Statement September 2018
Note: To be read in conjunction with the full suite of mitigation in section 5.5
1. Method statements will be prepared by the appointed contractor. These will be used to translate the project requirements into planned systems of work instructions to the site staff and operatives involved. They will define the proposed method of working for an element or section of work taking into account the particular requirements of the project including site conditions, safety hazards, the contract drawings, specification or code of practice. They define the proposed use of plant, labour and materials, any hold points or permits and may be supplemented by drawings, sketches and produce data as necessary.
2. The site boundary will be marked by secure posts and robust high visibility tape. The Riparian Leave Strip Exclusion Zone will be demarcated and avoided once this construction element has been completed. These areas will be agreed with the site ecologist to ensure sensitive areas will be avoided. Machinery will not be permitted breach these agreed boundaries during subsequent work.
3. Substances that can cause water quality problems will need to be controlled adequately at all times during the works. The main risks are associated with excavated/bare soils, uncured concrete and oils. Measures to prevent erosion of soils and releases of oil will be required. A silt fence will be needed between the works and the Newport River. There will be no discharge of effluent or waste water on site. Spill kits and personnel practised in their use will be required in case of an oil spillage.
4. All construction equipment/gear will be stored at a site compound. Wastes generated on- site (construction and waste water) will be managed properly and taken to a licensed waste management company.
5. The meteorological forecasting service from Met Éireann will be used to avoid large excavations or soil stripping in advance of heavy rainfall.
6. A project ecologist (environmental clerk of works) will be appointed to monitor the works on a weekly basis for the full duration of the project. The contractor will work with the ecologist to deliver environmental compliance on site, as set out in the mitigation in the NIS. The ecologist will audit the construction works from an environmental viewpoint
Appendix
18150-6011-C Natura Impact Statement September 2018
Appendix 5 Outline Non-native Invasive Species Management Plan
Appendix
18150-6011-C Natura Impact Statement September 2018
The proposed development site surveyed during July 2018. It is noted that a purpose of this survey was just to conform presence/absence of non-native species on the site. A significant proportion of the site along the bank of the Newport River was found to be infested with the non-native invasive plant Japanese knotweed Fallopia japonica. The National Biodiversity Data Centre (NBDC) classifies this plant as a ‘High Impact’ invasive. Himalayan knotweed Persicaria wallichii also occurs, and the NBDC classifies this plant as a ‘Medium Impact’ invasive. The presence of Giant Hogweed (‘High Impact’ invasive) has been acknowledged and plans are in place to treat this plant.
Early et al. (2009) note that Japanese knotweed was first introduced into Ireland as an ornamental plant and has since infested a wide range of habitats, including the banks of rivers. It can grow up to 3 metres in height and forms very dense monocultures along river corridors. The rhizomes (roots) are very extensive growing up to 3 metres in depth and up to 7 metres laterally from the parent plant. Japanese knotweed is spread entirely via the movement of soil material contaminated with the rhizome or via plant material, as only female plants occur in Ireland. Spread is rapid and results in the exclusion of native species that function to maintain bankside stability along rivers. In the winter when it dies back it results in the banks being left bare and vulnerable to erosion (Early et al, 2009).
Regulations 49 and 50 of the European Communities (Birds and Natural Habitats) Regulations 2011 make it an offence to interfere with or disperse this plant so a licence will be required to proceed with work on the site. The non-native invasive plants at the proposed Newport Town Park location will have to be eradicated before the site can be developed.
It is important that further spread of Japanese knotweed and other non-native invasive plants is prevented. It is not advised to strim, cut, flail or chip the plants as tiny fragments can regenerate new plants and make the problem even more difficult to manage. It is also advised not to dig, move or dump soil which may contain plant material as this may contribute to its spread. Japanese knotweed can be controlled successfully through the application of appropriate herbicides by a competent person. However, eradication of this plant requires planning, as follow up treatments are usually required, and consideration needs to be given to management and disposal of dead plant material, and to the treatment of contaminated soils.
Figure A4.1 illustrates a flowchart for treating Japanese knotweed which sets out the options of management for Japanese knotweed. Prior to works, a detailed survey aimed at identifying and mapping all non-native invasive species will be required. Then, a non-native Invasive Species Management Plan (ISMP) is required for the proposed development site so that existing non-natives be eradicated and the introduction of further species prevented. A key guidance document that should be consulted in fulfilling this aim is 'Managing Japanese knotweed on development sites - the knotweed code of practice' (EA, 2013). The non-native ISMP will also have regard to guidance such as ‘The management of noxious weeds and non-native invasive plant species on national roads’ by NRA (2010) and other information on these species22. The following is advised in order to accomplish eradication and prevent the spread of non-native invasive plants at the site:
22 http://www.biodiversityireland.ie/projects/invasive-species/invasive-species-week/be-plant-wise/
Appendix
18150-6011-C Natura Impact Statement September 2018
no works should be undertaken within the site to prevent the spread and/or importation/exportation of non-native plants; a detailed survey is required to identify the extent of Japanese knotweed and any other non- native plants established in the site; the appointed contractor will devise a detailed Invasive Species Management Plan (ISMP) for the site with reference to EA (2013), ideally, the existing Giant Hogweed management plan will be incorporated into the ISMP, otherwise it will be implemented independently; a clerk of works will oversee the plan to let all relevant contractors on the site know how important the plan is.
The ISMP is an important document and provides a valuable record of the treatment of the site for future owners. It may also provide evidence that the site has been appropriately managed if subsequent non-native invasive plant re-growth results in litigation against the contractor/developer. The precise ISMP will be drawn up by a non-native plant control specialist who will decide eradication methodology (herbicide, bund, burial or combined treatment). The ISMP will contain the following:
Introduction to the site (description of the site, management objectives, etc.); Overview of the ISMP (description, setting priorities, preventing further spread); Specific control plans (management objectives and options, actions planned, evaluation of actions, resource needs).
REFERENCES
EA (2013) Managing Japanese knotweed on development sites - the knotweed code of practice (Version 3, Published in September 2006 / updated July 2013.). Environment Agency, Horizon House, Deanery Road, Bristol BS1 5AH.
NRA (2010) The Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads. National Roads Authority.
Early J, McDowell S, Caffrey J, O’Callaghan D, Meenan K, Toomath C, Fitzsimons B & Kelly J (2009). Field Guide to Invasive Species in Ireland. 2nd Edition. Northern Ireland Environment Agency.
Appendix
18150-6011-C Natura Impact Statement September 2018
Figure A4.1: Flowchart for treating Japanese knotweed. Taken from ‘Managing Japanese knotweed on development sites’ (EA, 2013).
Appendix