Natura Impact Statement



Legend:

Site Boundary

1 Flight Line numbers 1-14 Figure 9.6 : Winter Survey 2010/2011 Januuary - Flight Lines 

Legend:

Site Boundary

1 Flight Line numbers 1-18 Figure 9.7 : Winter Survey 2010/2011 February - Flight Lines Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

APPENDIX D: AVIFAUNA

TABLE D.1: VANTAGE POINT SURVEY WATCH DATA ‐ SPRING 2010

TABLE D.2: MONEYPOINT MONITORING ‐ AUTUMN 2010 WATCH INFORMATION

TABLE D.3: MONEYPOINT WINTER 2010 / 2011 VANTAGE POINT WATCH INFORMATION

TABLE D.4: MONEYPOINT FLIGHT ACTIVITY AUTUMN 2010

TABLE D.5: MONEYPOINT FLIGHT ACTIVITY WINTER 2010 / 2011

TABLE D.6: MONEYPOINT I‐WEBS SURVEYS AUTUMN 2010 & NOVEMBER 2010 ‐ FEBRUARY 2011

TABLE D.7: TOTAL SPECIES RECORDED AT MONEYPOINT IN AUTUMN 2010

TABLE D.8: MONEYPOINT TOTAL SPECIES LIST FOR WINTER 2010/2011 SURVEY

Appendix D: Avifauna Page D.1/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.1: Waterfowl Numbers at Moneypoint – November / December 2001

Species 1% National < 500m Height (m) On Site Height (m) level Peak count over water over ground

Bar-tailed Godwit 175 1 40 0 -

Blackheaded Gull N/A 26 0-150 26 30-150

Cormorant 105 8-10 1-100 15 3-150

Common Gull NA 20 1-30 6-10 -

Curlew 1,000 150 1-50 40 <3

Dunlin 1,200 5 N/A 0 -

Great Black-backed Gull N/A 3 1-200 3 -

Great Crested Grebe 35 3 N/A 0 -

Greenshank 20 1 N/A 0 -

Grey Heron 105 2 1 2 0-3

Herring Gull N/A 1 3m 0 -

Grey Plover 50 2 150 0 -

Lapwing 2,000 200 N/A 0 3 above road

Lesser Black-backed Gull N/A 1 N/A 1 2

Mallard 500 2 N/A 0 -

Moorhen N/A 0 - 3 N/A

Oystercatcher 700 32 <1 2 -

Pochard 350 0 - 1 N/A

Red-breasted Merganser 25 1 Low 0 -

Red Throated Diver N/A 5 1 0 -

Ringed Plover 100 6 N/A 0 -

Ring-billed Gull N/A 1 N/A 0 -

Shag N/A 1 3 1 14

Shelduck 125 5 3 0 -

Snipe N/A N/A N/A 40 < 20

Redshank 250 5 <1 1 -

Teal 500 2 N/A 0 -

Turnstone 100 11 N/A 0 -

Wigeon 1,000 4 Low 0 -

N/A: These species not observed in flight.

Appendix D: Avifauna Page D.2/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.2: Results from the Spring 2010 breeding bird survey at Moneypoint. Birds recorded within 100 m of the observer are shown along with maximum counts, % frequency occurrence and conservation status.

Transec Transec Transec Transec Max. % Frequency Conservation Common Name Scientific Name t 1 t 2 t 3 t 4 Count Occurrence Status*

Blackbird Turdus merula 11 11 0 8 11 75 Green

Blackcap Sylvia atricapilla 2 1 0 2 2 75 Green

Blue Tit Parus caeruleus 2 0 0 1 2 50 Green

Bullfinch Pyrrhula pyrrhula 0 2 0 2 2 50 Green

Chaffinch Fringilla coelebs 4 3 0 1 4 75 Green

Chiffchaff Phylloscopus collybita 6 0 0 2 6 50 Green

Coal Tit Parus ater 0 0 0 2 2 25 Green

Dunnock Prunella modularis 0 2 0 2 2 50 Green

Hooded Crow Corvus cornix 0 4 2 0 4 50 Green

House Sparrow Passer domesticus 0 0 0 1 1 25 Amber

Jackdaw Corvus monedula 3 8 0 12 12 75 Green

Lesser Black-backed Gull Larus fuscus 0 0 1 0 1 25 Amber

Linnet Carduelis cannabina 0 1 3 0 3 50 Amber

Magpie Pica pica 1 1 0 5 5 75 Green

Meadow Pipit Anthus pratensis 0 1 2 0 2 50 Green

Pheasant Phasianus colchicus 0 1 0 0 1 25 N/A**

Raven Corvus corax 0 3 0 0 3 25 Green

Appendix D: Avifauna Page D.3/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Transec Transec Transec Transec Max. % Frequency Conservation Common Name Scientific Name t 1 t 2 t 3 t 4 Count Occurrence Status*

Robin Erithacus rubecula 3 5 3 8 8 100 Green

Rook Corvus frugilegus 1 37 0 0 37 50 Green

Skylark Alauda arvensis 0 0 1 1 1 50 Amber

Song Thrush Turdus philomelos 6 1 0 2 6 75 Green

Starling Sturnus vulgaris 14 11 1 9 14 100 Amber

Swallow Hirundo rustica 1 13 0 2 13 75 Amber

Whimbrel Numenius phaeopus 0 0 40 1 40 50 Green

Whitethroat Sylvia communis 0 3 0 0 3 25 Green

Willow Warbler Phylloscopus trochilus 2 2 1 1 2 100 Green

Woodpigeon Columba palumbus 1 0 0 3 3 50 Green

Wren Troglodytes troglodytes 5 8 0 7 8 75 Green

No. of Species 28 15 20 9 20

* BoCCI, Birds of Concern in Ireland: Species highlighted in amber are of Medium Conservation Concern (Amber-listed) and birds highlighted in red are of High Conservation Concern (Red-listed) according to the Birds of Conservation Concern in Ireland list (BOCCI, Lynas et al., 2007). All other species are not currently of special conservation concern in Ireland (Green- listed).

** N/A, non applicable as Pheasant is a stocked species

Appendix D: Avifauna Page D.4/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.3: Vantage Point Survey Watch Data - Spring 2010

Date VP Start - Finish Sighting Flight Species No. Time On/Off Height (m) Weather

12/05/2010 1 10.15-13.15 1 1 Jackdaw 2 10.26 on 20 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 2 2 Hooded Crow 1 10.34 on 10 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 3 3 Raven 1 10.36 off 20 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 4 4 Sparrowhawk 1 11.09 on 5 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 5 5 Rook 1 11.17 on 10 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 6 6 Kestrel 1 11.36 on 60 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 7 7 Cormorant 1 11.56 off 10 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 8 8 Cormorant 1 11.56 off 10 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 9 9 Kestrel 1 12.26 on 40 Bright/Dry/Wind0/Vis ex.

12/05/2010 1 10.15-13.15 10 10 Raven 1 12.45 on 20 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 1 11 Woodpigeon 1 14.57 on 10 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 2 12 Raven 1 15.01 on 30 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 3 13 Raven 1 15.12 on 10 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 4 14 Sparrowhawk 1 15.29 on 120 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 5 15 Lesser Black Backed Gull 1 15.41 on 40 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 6 16 Whimbrel 16 16.15 on 15 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 7 17 Raven 1 16.2 on 40 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 8 18 Whimbrel 1 16.39 on 20 Bright/Dry/Wind0/Vis ex.

12/05/2010 2 14.30-17.30 9 19 Whimbrel 5 17.05 on 20 Bright/Dry/Wind0/Vis ex.

Appendix D: Avifauna Page D.5/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Date VP Start - Finish Sighting Flight Species No. Time On/Off Height (m) Weather

13/05/2010 3 09.30-12.30 1 20 Lesser Black Backed Gull 3 9.55 on 30 Bright/Showers/Wind0/Vis.good

13/05/2010 3 09.30-12.30 2 21 Raven 1 10.27 on 30 Bright/Showers/Wind0/Vis.good

13/05/2010 3 09.30-12.30 3 22 Whimbrel 20 10.44 on 10 Bright/Showers/Wind0/Vis.good

13/05/2010 3 09.30-12.30 4 23 Whimbrel 11 11.45 on 15 Bright/Showers/Wind0/Vis.good

13/05/2010 1 13.00-16.00 1 24 Lesser Black Backed Gull 1 13.40 on 30 Bright/Showers/Wind0/Vis.good

13/05/2010 1 13.00-16.00 2 25 Grey Heron 1 14.12 on 5 Bright/Showers/Wind0/Vis.good

14/05/2010 2 09.00-12.00 1 26 Kestrel 1 9.36 ON 10 Bright/Dry/Cloud 60%/Vis. Ex.

14/05/2010 2 09.00-12.00 2 27 Whimbrel 4 10.29 ON 5 Bright/Dry/Cloud 60%/Vis. Ex.

14/05/2010 3 12.30-15.30 1 28 Lesser Black Backed Gull 1 12.39 on 10 Bright/Dry/Cloud 60%/Vis. Ex.

14/05/2010 3 12.30-15.30 2 29 Whimbrel 2 12.41 on 20 Bright/Dry/Cloud 60%/Vis. Ex.

All habiats are Improved Agricultural Grassand (IAG)

Appendix D: Avifauna Page D.6/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.4: Moneypoint Monitoring - Autumn 2010 Watch Information

Wind Grid VP Date Start-Finish Visibility Cloud Cover Speed/Directio Precipitation Temperature Reference n

3 01280 52802 31/08/2010 11.50 - 14.50 Excellent 50% E F1 None Warm

1 04542 52317 31/08/2010 15.10 - 18.10 Excellent 50% E F1 None Warm

3 01280 52802 01/09/2010 06.45 - 09.45 Good 70% E F1 None Warm

2 02507 53477 01/09/2010 10.10 - 13.10 Good 70% E F1 None Warm

1 04542 52317 01/09/2010 14.20 - 17.20 Good 70% E F1 None Warm

2 02507 53477 02/09/2010 07.30 - 10.30 Excellent 10% SE F1 None Warm

Appendix D: Avifauna Page D.7/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.5: Moneypoint Winter 2010 / 2011 Vantage Point Watch Information

Date Start-Finish Visibility Cloud Cover Wind Direction / Precipitation Temperature Speed

11/11/2010 07.30 – 09.30 Good 75% SW F3 + Gusts Showers Mild

11/11/2010 09.30 – 11.30 Good 75% SW F3 + Gusts Showers Mild

11/11/2010 11.45 – 13.45 Good 75% SW F3 + Gusts Showers Mild

15/12/2010 08.15 – 10.15 Good 80% Wind 0 Dry Cool

15/12/2010 10.20 – 12.20 Good 80% Wind 0 Dry Cool

15/12/2010 12.20 – 14.20 Good 80% Wind 0 Dry Cool

27/01/2011 08.30 – 10.30 Excellent 10% Wind 0 Dry Cool

27/01/2011 11.15 – 13.15 Excellent 10% Wind 0 Dry Cool

27/01/2011 13.20 – 15.20 Excellent 10% Wind 0 Dry Cool

22/02/2011 09.45 – 11.45 Excellent 80% S F1 Showers Mild

22/02/2011 11.51 – 13.51 Excellent 80% S F1 Showers Mild

22/02/2011 14.00 – 16.00 Excellent 80% S F1 Showers Mild

Appendix D: Avifauna Page D.8/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.6: Moneypoint Flight Activity Autumn 2010

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

AUGUST

1 31/08/2010 3 1 11.50-14.50 Curlew 11.50 30s 30

2 31/08/2010 3 2 11.50-14.50 Curlew 12.03 30s 30

3 31/08/2010 3 3 11.50-14.50 Black Headed Gull 12.12 10s 10

4 31/08/2010 3 4 11.50-14.50 Grey Heron 12.13 25s 25

5 31/08/2010 3 5 11.50-14.50 Herring Gull 12.19 30s 30

6 31/08/2010 3 6 11.50-14.50 Herring Gull 12.21 36s 36

7 31/08/2010 3 7 11.50-14.50 Common Gull 12.24 43s 43

8 31/08/2010 3 8 11.50-14.50 Common Gull 12.29 40s 40

9 31/08/2010 3 9 11.50-14.50 Common Gull 12.31 34s 34

10 31/08/2010 3 10 11.50-14.50 Curlew 12.36 25s 25

11 31/08/2010 3 11 11.50-14.50 Common Gull 12.51 32s 32 70 birds

12 31/08/2010 3 12 11.50-14.50 Curlew 12.51 10s 10

13 31/08/2010 3 13 11.50-14.50 Common Gull 13.01 17s 17

14 31/08/2010 3 14 11.50-14.50 Raven 13.02 81s 81

15 31/08/2010 3 15 11.50-14.50 Sparrowhawk 14.28 137s 137s

16 31/08/2010 3 16 11.50-14.50 Curlew 14.33 16s 16

17 31/08/2010 3 17 11.50-14.50 Curlew 14.33 18s 18

18 31/08/2010 1 18 15.10-18.10 Starling 15.41 107s 107 120 birds

Appendix D: Avifauna Page D.9/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

19 31/08/2010 1 19 15.10-18.10 Kestrel 16.02 40s 40

20 31/08/2010 1 20 15.10-18.10 Common Gull 16.5 114s 114

21 31/08/2010 1 21 15.10-18.10 Common Gull 17.51 33s 33

22 31/08/2010 1 22 15.10-18.10 Cormorant 17.58 120s 120 14 birds

SEPTEMBER

23 01/09/2010 3 23 06.45-09.45 Common Gull 6.56 162s 162 50 birds

24 01/09/2010 3 24 06.45-09.45 Common Gull 7.02 30s 30

25 01/09/2010 3 25 06.45-09.45 Black Headed Gull 7.06 64s 64

26 01/09/2010 3 26 06.45-09.45 Rook 7.06 30s 30

27 01/09/2010 3 27 06.45-09.45 Curlew 7.22 40s 40

28 01/09/2010 3 28 06.45-09.45 Curlew 7.25 25s 25

29 01/09/2010 3 29 06.45-09.45 Curlew 7.37 20s 20

30 01/09/2010 3 30 06.45-09.45 Black Headed Gull 7.39 49s 49 10 birds

31 01/09/2010 3 31 06.45-09.45 Black Headed Gull 7.41 92s 92 30 birds

32 01/09/2010 3 32 06.45-09.45 Cormorant 7.46 34s 34

33 01/09/2010 3 33 06.45-09.45 Common Gull 8.43 80s 80

34 01/09/2010 3 34 06.45-09.45 Common Gull 9.14 40s 40

35 01/09/2010 2 35 10.10-13.10 Sparrowhawk 10.19 40s 40

36 01/09/2010 2 36 10.10-13.10 Common Gull 10.44 142s 142

37 01/09/2010 2 37 10.10-13.10 Rook 10.55 20s 20

Appendix D: Avifauna Page D.10/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

38 01/09/2010 1 38 10.10-13.10 Black Headed Gull 11.01 120s 120

39 01/09/2010 1 39 10.10-13.10 Common Gull 11.59 108s 108

40 01/09/2010 1 40 14.20-17.20 Starling 14.2 120s 120 100 birds

41 01/09/2010 1 41 14.20-17.20 Black Headed Gull 14.37 20s 20

42 01/09/2010 1 42 14.20-17.20 Kestrel 14.51 42s 42

43 01/09/2010 1 43 14.20-17.20 Lesser Black Backed Gull 14.53 10s 10

44 01/09/2010 1 44 14.20-17.20 Glaucous Gull 15.03 97s 97

45 01/09/2010 1 45 14.20-17.20 Starling 15.16 45s 45

46 01/09/2010 1 46 14.20-17.20 Starling 15.29 25s 25 120 birds

47 01/09/2010 1 47 14.20-17.20 Kestrel 15.29 179s 179

48 01/09/2010 1 48 14.20-17.20 Grey Heron 15.35 42s 42

49 01/09/2010 1 49 14.20-17.20 Kestrel 15.4 12s 12

50 01/09/2010 1 50 14.20-17.20 Kestrel 15.5 98s 98

51 01/09/2010 1 51 14.20-17.20 Black Headed Gull 16.04 26s 26

52 02/09/2010 2 52 07.30-10.30 Curlew 7.41 31s 31

53 02/09/2010 2 53 07.30-10.30 Black Headed Gull 7.47 246s 246 17 Birds

54 02/09/2010 2 54 07.30-10.30 Common Gull 8.15 32s 32

55 02/09/2010 2 55 07.30-10.30 Raven 8.42 50s 50

56 02/09/2010 2 56 07.30-10.30 Curlew 8.49 50s 10 40

57 02/09/2010 2 57 07.30-10.30 Common Gull 9.16 29s 29 10 Birds

Appendix D: Avifauna Page D.11/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

58 02/09/2010 2 58 07.30-10.30 Lesser Black Backed Gull 9.31 17s 17

59 02/09/2010 2 59 07.30-10.30 Common Gull 9.36 120s 120

60 02/09/2010 2 60 07.30-10.30 Lesser Black Backed Gull 9.54 32s 32

61 02/09/2010 2 61 07.30-10.30 Lesser Black Backed Gull 10.25 16s 16

Appendix D: Avifauna Page D.12/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.7: Moneypoint Flight Activity Winter 2010 / 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

NOVEMBER

1 11/11/2010 1 1 07.30-09.30 Jackdaw 07.43 20s 20

2 11/11/2010 1 2 07.30-09.30 Hooded Crow 07.44 20s 20

3 11/11/2010 1 3 07.30-09.30 Hooded Crow 07.46 20s 20

4 11/11/2010 1 4 07.30-09.30 Rook 07.49 20s 20

5 11/11/2010 1 5 07.30-09.30 Rook 07.54 60s 20 10 birds

6 11/11/2010 1 6 07.30-09.30 Common Gull 08.23 30s 30

7 11/11/2010 1 7 07.30-09.30 Starling 08.24 10s 10

8 11/11/2010 1 8 07.30-09.30 Common Gull 08.26 60s 60

9 11/11/2010 1 9 07.30-09.30 Cormorant 08.38 20s 20

10 11/11/2010 1 10 07.30-09.30 Black Headed Gull 08.41 37s 37

11 11/11/2010 1 11 07.30-09.30 Cormorant 08.53 5s 10

12 11/11/2010 1 12 07.30-09.30 Rook 09.02 10s 10

13 11/11/2010 1 13 09.30-11.30 Cormorant 09.12 30s 30

14 11/11/2010 2 14 09.30-11.30 Lesser Black Backed Gull 09.44 40s 40

15 11/11/2010 2 15 09.30-11.30 Hooded Crow 09.48 15s 15

16 11/11/2010 2 16 09.30-11.30 Starling 09.59 10s 10 100

17 11/11/2010 2 17 09.30-11.30 Common Gull 10.06 60s 60 10

18 11/11/2010 2 18 09.30-11.30 Starling 10.12 10s 10 100

Appendix D: Avifauna Page D.13/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

19 11/11/2010 2 19 09.30-11.30 Common Gull 10.17 10s 10

20 11/11/2010 2 20 09.30-11.30 Lapwing 10.41 15s 15 40

21 11/11/2010 2 21 09.30-11.30 Lapwing 10.48 10s 10

22 11/11/2010 2 22 09.30-11.30 Starling 10.55 10s 10

23 11/11/2010 2 23 09.30-11.30 Black Headed Gull 10.57 30s 30

24 11/11/2010 3 24 11.45-13.45 Starling 11.47 30s 30

25 11/11/2010 3 25 11.45-13.45 Lapwing 11.49 15s 15

26 11/11/2010 3 26 11.45-13.45 Lapwing 12.15 15s 15 20

27 11/11/2010 3 27 11.45-13.45 Common Gull 12.28 20s 20 85

DECEMBER

28 15/12/2010 1 1 08.15-10.15 Cormorant 08.33 10s 10 6 birds

29 15/12/2010 1 2 08.15-10.15 Jackdaw 08.36 10s 10 Flock of 30

30 15/12/2010 1 3 08.15-10.15 Hooded Crow 08.44 15s 15

31 15/12/2010 1 4 08.15-10.15 Lesser Black Backed Gull 08.46 5s 5

32 15/12/2010 1 5 08.15-10.15 Rook 08.48 101s 101 2 birds

33 15/12/2010 1 6 08.15-10.15 Black Headed Gull 08.51 54s 54

34 15/12/2010 1 7 08.15-10.15 Jackdaw 08.58 47s 47

35 15/12/2010 1 8 08.15-10.15 Common Gull 09.08 10 10

36 15/12/2010 1 9 08.15-10.15 Lesser Black Backed Gull 09.10 11s 11

37 15/12/2010 1 10 08.15-10.15 Common Gull 09.17 86s 86

Appendix D: Avifauna Page D.14/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

38 15/12/2010 1 11 08.15-10.15 Lesser Black Backed Gull 09.43 80s 80

39 15/12/2010 1 12 08.15-10.15 Starling 09.47 10s 10

40 15/12/2010 1 13 08.15-10.15 Grey Heron 09.48 41s 41

41 15/12/2010 1 14 08.15-10.15 Black Headed Gull 09.49 45s 45

42 15/12/2010 2 15 10.20-12.20 Jackdaw 10.29 20s 20 14 birds

43 15/12/2010 2 16 10.20-12.20 Jackdaw 10.33 10s 10

44 15/12/2010 2 17 10.20-12.20 Lapwing 10.35 20s 20 10 birds

45 15/12/2010 2 18 10.20-12.20 Black Headed Gull 10.45 35s 35

46 15/12/2010 2 19 10.20-12.20 Hooded Crow 10.53 28s 28

47 15/12/2010 2 20 10.20-12.20 Raven 10.57 5s 5 2 birds

48 15/12/2010 2 21 10.20-12.20 Curlew 11.06 16s 16

49 15/12/2010 2 22 10.20-12.20 Curlew 11.09 31s 31 22 birds

50 15/12/2010 2 23 10.20-12.20 Lapwing 11.21 10s 10 15 birds

51 15/12/2010 2 24 10.20-12.20 Lapwing 11.25 20s 20 25 birds

52 15/12/2010 2 25 10.20-12.20 Lapwing 12.05 38s 38 7 birds

53 15/12/2010 3 26 12.20-14.20 Lapwing 12.33 14s 14

54 15/12/2010 3 27 12.20-14.20 Black Headed Gull 12.36 10s 10

55 15/12/2010 3 28 12.20-14.20 Curlew 12.41 31s 31 5 birds

56 15/12/2010 3 29 12.20-14.20 Curlew 13.14 27s 27

57 15/12/2010 3 30 12.20-14.20 Lapwing 13.22 27s 27 30 birds

Appendix D: Avifauna Page D.15/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

58 15/12/2010 3 31 12.20-14.20 Curlew 13.29 55s 55 30 birds

59 15/12/2010 3 32 12.20-14.20 Lapwing 13.29 55s 55 40 birds

60 15/12/2010 3 33 12.20-14.20 Black Headed Gull 14.04 78s 78

JANUARY

61 27/01/2011 1 1 08.30-10.30 Lesser Black Backed Gull 08.39 47s 47

62 27/01/2011 1 2 08.30-10.30 Hooded Crow 08.41 31s 31

63 27/01/2011 1 3 08.30-10.30 Raven 09.07 77s 77

64 27/01/2011 2 4 11.15-13.15 Lapwing 11.26 75s 75

65 27/01/2011 2 5 11.15-13.15 Curlew 11.31 20s 20 51 birds

66 27/01/2011 2 6 11.15-13.15 Merlin 11.43 30s 30

67 27/01/2011 2 7 11.15-13.15 Lapwing 11.48 30s 30 150 flock

68 27/01/2011 2 8 11.15-13.15 Sparrowhawk 12.30 30s 30

69 27/01/2011 2 9 11.15-13.15 Curlew 12.59 43s 43 80 birds

70 27/01/2011 2 10 11.15-13.15 Grey Heron 13.06 26s 26

71 27/01/2011 3 11 13.20-15.20 Curlew 13.24 34s 34 30 birds

72 27/01/2011 3 12 13.20-15.20 Cormorant 13.43 11s 11

73 27/01/2011 3 13 13.20-15.20 Sparrowhawk 14.03 15s 15

74 27/01/2011 3 14 13.20-15.20 Sparrowhawk 14.20 20s 20 Female

FEBRUARY

75 22/02/2011 1 1 09.45-11.45 Hooded Crow 10.15 33s 33

Appendix D: Avifauna Page D.16/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Bout Date VP Flightline Period Species Start Time <10 10-100 >100 Notes

76 22/02/2011 1 2 09.45-11.45 Black Headed Gull 10.27 72s 72

77 22/02/2011 1 3 09.45-11.45 Peregrine 10.31 10s 10

78 22/02/2011 1 4 09.45-11.45 Great Black Backed Gull 10.54 77s 77

79 22/02/2011 1 5 09.45-11.45 Raven 10.55 20s 20

80 22/02/2011 1 6 09.45-11.45 Herring Gull 11.20 20s 20

81 22/02/2011 1 7 09.45-11.45 Sparrowhawk 11.24 20s 20

82 22/02/2011 1 8 09.45-11.45 Raven 11.36 10s 10

83 22/02/2011 2 9 11.51-13.51 Hooded Crow 11.51 30s 30

84 22/02/2011 2 10 11.51-13.51 Redwing 12.12 24s 24 23 birds

85 22/02/2011 2 11 11.51-13.51 Snipe 12.23 30s 30 2 birds

86 22/02/2011 2 12 11.51-13.51 Sparrowhawk 12.55 10s 10

87 22/02/2011 3 13 14.00-16.00 Starling 14.25 20s 20 100 birds

88 22/02/2011 3 14 14.00-16.00 Rook 14.34 25s 25

89 22/02/2011 3 15 14.00-16.00 Curlew 14.40 20s 20

90 22/02/2011 3 16 14.00-16.00 Rook 15.10 10s 10 60-70 birds

91 22/02/2011 3 17 14.00-16.00 Great Black Backed Gull 15.20 24s 24

92 22/02/2011 3 18 14.00-16.00 Black Headed Gull 15.22 31s 31 3 birds

Appendix D: Avifauna Page D.17/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.8: Moneypoint I-WeBS Surveys Autumn 2010 & November 2010 - February 2011

Species Scientific Name Autumn 2010 Winter 2010 / 2011

Section Section Section A B C Totals November December January February

Black Guillemot Cepphus grylle - - - - 0 0 0 1

Black Headed Gull Larus ridibundus 48 0 1 49 49 0 20 8

Common Gull Larus canus 3 0 15 18 18 2 2 2

Common Sandpiper Actitis hypoleucos 0 0 1 1 1 0 0 0

Cormorant Phalacrocorax carbo 2 14 0 16 16 0 2 2

Curlew Numenius arquata 7 1 3 11 11 4 85 11

Dunlin Calidris alpina 0 0 10 10 10 0 2 0

Glaucous Gull Larus hyperboreus 0 0 1 1 1 0 0 0

Great Crested Grebe Podiceps cristatus - - - - 0 4 6 3

Great Northern Diver Gavia immer - - - - 0 0 1 1

Greenshank Tringa nebularia 2 0 0 2 2 0 2 0

Grey Heron Ardea cinerea 1 0 2 3 3 1 0 0

Lesser Black Backed Gull Larus fuscus 2 0 1 3 3 0 0 0

Lapwing Vanellus vanellus 0 0 2 2 2 48 31 0

Little Egret Egretta garzetta 3 1 0 4 4 0 0 0

Mallard Anas platyrhynchos - - - - 0 0 1 2

Mediterranean Gull Larus melanocephalus 2 0 0 2 2 0 0 0

Appendix D: Avifauna Page D.18/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Species Scientific Name Autumn 2010 Winter 2010 / 2011

Section Section Section A B C Totals November December January February

Mute Swan Cygnus olor 2 0 0 2 2 0 0 0

Oystercatcher Haematopus ostralegus 1 3 2 6 6 13 26 15

Razorbill Alca torda - - - - 0 0 0 1

Red Breasted Merganser Mergus serrator - - - - 0 1 0 0

Redshank Tringa totanus 9 0 0 9 9 2 2 9

Ringed Plover Charadrius hiaticula 0 0 31 31 31 0 14 0

Shelduck Tadorna tadorna - - - - 0 0 1 0

Teal Anas crecca 5 0 0 5 5 0 35 0

Turnstone Arenaria interpres 0 0 20 20 20 3 11 21

Wigeon Anas penelope - - - - 0 0 24 0

Appendix D: Avifauna Page D.19/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.9: Total Species Recorded at Moneypoint in Autumn 2010

Common Name (Scientific Name) Common Name (Scientific Name)

Black Headed Gull (Larus ridibundus) Lesser Black Backed Gull (Larus fuscus)

Blackbird (Turdus merula) Linnet (Carduelis cannabina)

Blue Tit (Parus caeruleus) Little Egret (Egretta garzetta)

Chiffchaff (Fringilla coelebs) Magpie (Pica pica)

Collared Dove (Streptopelia decaocto) Mediterranean Gull (Larus melanocephalus)

Common Gull (Larus canus) Mute Swan (Cygnus olor)

Common Sandpiper (Actitis hypoleucos) Oystercatcher (Haematopus ostralegus)

Cormorant (Phalacrocorax carbo) Pied Wagtail (Motacilla alba)

Curlew (Numenius arquata) Raven (Corvus corax)

Dunlin (Calidris alpina) Ringed Plover (Charadrius hiaticula)

Glaucous Gull (Larus hyperboreus) Robin (Erithacus rubecula)

Goldfinch (Carduelis carduelis) Rook (Corvus frugilegus0

Greenshank (Tringa nebularia) Sparrowhawk (Accipiter nisus)

Grey Heron (Ardea cinerea) Starling (Sturnus vulgaris)

Grey Wagtail (Motacilla cinerea) Swallow (Hirundo rustica)

Hooded Crow (Corvus cornix) Teal (Anas crecca)

House Martin (Delichon urbica) Turnstone (Arenaria interpres)

House Sparrow 9Passer domesticus) Willow Warbler (Phylloscopus trochilus)

Jackdaw (Corvus monedula) Woodpigeon (Columba palumbus)

Kestrel (Falco tinnunculus) Wren (Troglodytes troglodytes)

Lapwing (Vanellus vanellus)

Appendix D: Avifauna Page D.20/21 Moneypoint Wind Farm Environmental Impact Statement

Co. Clare November 2011

Table D.10: Moneypoint Total Species List for Winter 2010/2011 Survey

Common Name (Latin Name) Common Name (Latin Name)

Bullfinch (Pyrrhula pyrrhula) Magpie (Pica pica)

Blackbird (Turdus merula) Mallard (Anas platyrhynchos)

Black Guillemot (Cepphus grylle) Meadow Pipit (Anthus pratensis)

Black Headed Gull (Larus ridibundus) Mediterranean Gull (Larus melanocephalus)

Collared Dove (Streptopelia decaocto) Merlin (Falco columbarius)

Common Gull (Larus canus) Mute Swan (Cygnus olor)

Common Sandpiper (Actitis hypoleucos) Oystercatcher (Haematopus ostralegus)

Cormorant (Phalacrocorax carbo) Peregrine (Falco peregrinus)

Chaffinch (Fringilla coelebs) Pied Wagtail (Motacilla alba)

Glaucous Gull (Larus hyperboreus) Raven (Corvus corax)

Curlew (Numenius arquata) Razorbill (Alca torda)

Dunlin (Calidris alpina0 Ringed Plover (Charadrius hiaticula)

Dunnock (Prunella modularis) Reed Bunting (Emberiza schoeniclus)

Fieldfare (Turdus pilaris) Redshank(Tringa totanus)

Goldcrest (Regulus regulus) Red Breasted Merganser (Mergus serrator)

Goldfinch (Carduelis carduelis) Redwing (Turdus iliacus)

Great Northern Diver (Gavia immer) Robin (Erithacus rubecula)

Great Crested Grebe (Podiceps cristatus) Rook (Corvus frugilegus)

Great Tit (Parus Major) Shelduck (Tadorna tadorna)

Greenshank (Tringa nebularia) Snipe (Gallinago gallinago)

Grey Heron (Ardea cinerea) Starling (Sturnus vulgaris)

House Sparrow (Passer domesticus) Stonechat (Saxicola torquata)

Hooded Crow (Corvus cornix) Sparrowhawk (Accipiter nisus)

Jackdaw (Corvus monedula) Teal (Anas crecca)

Lapwing (Vanellus vanellus) Turnstone (Arenaria interpres)

Lesser Black Backed Gull (Larus fuscus) Wigeon (Anas penelope)

Little Egret (Egretta garzetta) Woodpigeon (Columba palumbus)

Long Tailed Tit (Aegithalos caudatus)

Appendix D: Avifauna Page D.21/21

Appendix VII

Biospheric Engineering Ltd., Report on Underwater Noise Attenuation Trials at Moneypoint, Co. Clare in Connection with Planning Application P12-74, October 2012 ESB INTERNATIONAL

REPORT ON UNDERWATER NOISE ATTENUATION TRIALS AT MONEYPOINT, CO. CLARE IN CONNECTION WITH PLANNING APPLICATION P12-74

REPORT ON UNDERWATER NOISE ATTENUATION

PROPOSED WIND FARM AT MONEYPOINT, CO. CLARE.

REPORT TO REPORT SUBMITTED BY

Mr. Gerry Kelly Eugene McKeown B.E., L.L.B., M.Sc., Chartered Engineer ESB International Biospheric Engineering Ltd

Stephen Court Bearna, Co. Galway St. Stephens Green Tel: +353 (0)91 591 336 Dublin 2 Email: [email protected] Tel: +353 (0)1 703 8000 www.biospheric.ie

Introduction ...... 5

Testing ...... 5

Noise Propagation & Mitigation ...... 5

Description of Underwater Noise Metrics ...... 6

Introduction ...... 6

Peak Sound Level ...... 6

RMS Sound Pressure Level ...... 6

Sound Exposure Level ...... 7

Cumulative Sound Exposure Level ...... 7

Signal duration for transient sounds ...... 8

Source Level ...... 8

Received Level ...... 8

Transmission Loss ...... 8

Criteria For Assessing Impacts ...... 9

Introduction ...... 9

NMFS (1995) guidelines...... 9

NOAA (2006) guidelines ...... 9

Southall et al, 2007...... 10

HESS (1997) behavioural disturbance criteria ...... 11

Comparison with hearing threshold ...... 11

NPWS Draft Guidance Document ...... 11

Test Methodology ...... 13

Received Levels...... 13

Signal Analysis ...... 16

Licensing ...... 17

Background Noise Levels at Moneypoint ...... 18

Difficulties encountered in carrying out the survey ...... 19

Pile Driving Source Levels ...... 21

Pile Driving Generally ...... 21

Pile Driving offshore ...... 22

...... 24

Pile Driving Near the Shore ...... 24

Noise Prediction ...... 25

Damage Criteria ...... 25

Disturbance Criteria ...... 26

Results ...... 26

Mitigation ...... 29

Conclusion ...... 31

References ...... 32

Appendix A – NPWS Licence ...... 38

Appendix B – MMO Reporting Sheets ...... 39

INTRODUCTION ESB Wind Development has applied for permission to construct a Wind Farm comprising 5 wind turbines at Moneypoint Power Station, Carrowdotia, Kilimer, Co. Clare. Clare County Council, as the planning authority, wrote to ESB Wind Development on 3rd April 2012 requesting further information, including inter alia:

(2)(iii) With regards the impact of the proposed development on dolphins and whales, it ·is noted that the Lower River Shannon c. SAC is the only protected site for bottlenose dolphins, which are listed as Annex II species under the E.U. Habitats Directive, in Ireland. There are concerns that sound pressure waves from potential piling and blasting may enter the marine environment, thus disturbing potential foraging sites for the dolphins. In this regard, please address this concern in the Natura Impact Statement, and also please submit attenuation trials to estimate the energy sound pressure waves entering the marine environment from piling and blasting. The passage of sound pressure from the terrestrial to the marine environment will depend on bedrock and other factors and thus must be site specific.

This report has been prepared to address the quantification of noise entering the marine environment from piling and blasting. It should be pointed out that there are no plans for blasting on site and the pile driving activity will take place onshore, rather than in the water column.

TESTING

Site specific noise attenuation tests were carried out at Moneypoint on Saturday 6th October 2012. The testing is described in this report and comprised making and recording third octave band underwater sounds at different distances from the source. The recordings were post processed to determine a transmission loss for the site.

NOISE PROPAGATION & MITIGATION Published noise emissions for pile driving were used to construct a noise model and estimate a zone of impact for the pile driving activity. While noise levels are such that no physical harm to any marine animal will arise, there is the potential for some disturbance, in particular for pinnipeds and cetacean species. The extent of this zone has been calculated to be 64m.

In order to protect marine species a monitoring zone of 200m has been determined and appropriate mitigation measures recommended for the pile driving phase of construction.

DESCRIPTION OF UNDERWATER NOISE METRICS

INTRODUCTION

Studies by Thomsen et al. (2006), Southall et al. (2007) for example, provide detailed reviews of the metrics used to measure and assess the impact of underwater noise in the marine environment. De Jong et al (2011) have provided further clarification on appropriate metrics, from which a brief overview is provided below. Sound may be defined as the periodic disturbance in pressure from some equilibrium value. The unit of pressure is given in Pascals (Pa) or Newton per square metre (N/m2).

By convention, however, sound levels are expressed in decibels (dB) relative to a fixed reference pressure commonly 1 µPa for measurements made underwater. This is because measurements typically cover a very wide range of pressure values

PEAK SOUND LEVEL For transient pressure pulses such as an explosion or a single discharge of an airgun, the peak sound level is the maximum absolute value of the instantaneous sound pressure recorded over a given time interval. Hence:

Peak Level (zero-to-peak) = 20 x log 10 (Ppeak /Pref)

When the pulse has approximately equal positive and negative parts to the waveform, the peak-to-peak level is often quoted and this is equal to twice the peak level or 6 dB higher.

RMS SOUND PRESSURE LEVEL The Root-Mean-Square (RMS) Sound Pressure Level is used to quantify noise of a continuous nature. Underwater sound sources of this type include shipping, sonar transmissions, drilling or cutting operations, or background sea noise. The RMS Sound Pressure level is the mean square pressure level measured over a given time interval (t), and hence represents a measure of the average sound pressure level over that time. It is expressed as:

RMS Sound Pressure Level = 20 x log 10 (PRMS/Pref)

Where RMS Sound Pressure Levels are used to quantify the noise from transients, the time period over which the measurements are averaged must be quoted as the RMS value will vary with the averaging time period. Where the noise is continuous, as

6 in the examples given above, the time period over which measurements are taken is not relevant as the measurement will give the same result regardless of the period over which the measurements are averaged.

SOUND EXPOSURE LEVEL The problems associated with the time period over which the Sound Pressure Levels are averaged, as highlighted above, can be overcome by describing a transient pressure wave in terms of the Sound Exposure Level (SEL). The Sound Exposure Level is the time integral of the square pressure over a time window long enough to include the entire pressure pulse. The Sound Exposure Level is therefore the sum of the acoustic energy over a measurement period, and effectively takes account of both the level of the sound, and the duration over which the sound is present in the acoustic environment. Sound Exposure (SE) is defined by the equation:

SE = p2(t)dt T 0 ∫ where p is the acoustic pressure in Pascals, T is the duration of the sound in seconds and t is time. The Sound Exposure is a measure of the acoustic energy and therefore has units of Pascal squared seconds (Pa2s).

To express the Sound Exposure as a logarithmic decibel, it is compared with a reference acoustic energy level of 1 µPa2s. The Sound Exposure Level (SEL) is then defined by:

2 2 SEL = 10 Log10 ( ) / 푇 ∫0 푝 푡 푑푡 푃 푟푒푓

Where a sound time period is less than a second the RMS Sound Pressure Level will be greater than the Sound Exposure Level. For signals of greater than 1 second, the Sound Exposure Level will be greater than the RMS Sound Pressure Level where:

SEL = SPL + 10 log10 T

CUMULATIVE SOUND EXPOSURE LEVEL Where multiple transient pressure wave events occur, for example during pile driving or seismic operations, the total or cumulative Sound Exposure Level from multiple events can be calculated by summing the Sound Exposure Level from a number of individual events.

SIGNAL DURATION FOR TRANSIENT SOUNDS The time during which a specified percentage x of unweighted sound exposure occurs

(e.g.,  90 is the time window during which 90 % of the energy arrives), expressed in milliseconds (ms).

SOURCE LEVEL The source level (SL) is the apparent strength of a sound source at a reference distance, usually 1 m, from the source. For example, a source may be quoted as having a source Sound Pressure Level of 100 dB re 1µPa @ 1 m. In practise the parameters of the source are rarely measured at such a close range, and the source level is inferred by back-propagating the noise from a number of far field measurements

RECEIVED LEVEL The Received level (RL) is the strength of the acoustic field at a given depth and range relative to the source. As the sound varies with range, it is important to state the range at which the measurement has been taken or the estimate has been made.

TRANSMISSION LOSS The transmission loss (TL) represents the loss in intensity or pressure of the acoustic field strength as the sound propagates from source to receptor. In general terms the transmission loss is given by:

TL = N log(r) + α r where r is the range from the source, N is a factor for attenuation due to geometric spreading, and α (in dB.km-1) is a factor for the absorption of sound in water. Hence, the received sound level at a range r from a source is given by:

RL = SL - TL which can be written in the form:

RL = SL – N log(r) - αr

CRITERIA FOR ASSESSING IMPACTS

INTRODUCTION

This section of the report describes briefly the assessment criteria proposed by investigators to assess the impact of underwater sound upon cetaceans. These criteria are then used to estimate impact zones about the sound source using the results from underwater sound propagation modelling.

It should be noted that currently these criteria have had little or no validation under open water conditions. Auditory injury data from controlled tests with a few captive animals have been used as the basis for developing the auditory injury, Permanent Threshold Shift (PTS) and Temporary Threshold Shift (TTS) guidance criteria. Observations of behavioural avoidance with concurrent acoustic measurements are sparse, and hence the behavioural avoidance criteria are speculative.

NMFS (1995) GUIDELINES.

US National Marine Fisheries Service (NMFS) and National Oceanographic and Atmospheric Administration (NOAA) agencies initially used RMS Sound Pressure Levels to determine underwater noise impact zones for marine mammals (NMFS, 1995). The US NMFS considered, as a guideline, that underwater Sound Pressure Levels (RMS) above 180 dB re 1 µPa, could cause TTS in cetaceans, and 190 dB re. 1 µPa in pinnipeds (NMFS, 1995). A lower (Level B) harassment criteria based on a received RMS Sound Pressure Level of 160 dB re.1µPa has also been used to establish behavioural avoidance zones. These metrics are conservative in terms of preventing auditory injury, but as they were developed for military sonar applications, are not directly applicable when considering impulsive sound, and do not consider either the peak level of noise, or its frequency dependence in relation to the receptor species (Madsen, 2005). Southall et al. (2007) discuss these guidance criteria and considered that although the NMFS stated these criteria to be precautionary, there was no empirical evidence as to whether exposure to higher levels of pulsed sound would or would not cause auditory or other injuries.

NOAA (2006) GUIDELINES

More recently, NOAA have also developed auditory injury exposure criteria based on the total energy exposure. A Sound Exposure Level of 195 dB re.1µPa2s is considered as the onset of TTS injury, with an exposure of 215 dB re.1µPa2s specified by NOAA (2006) as the onset of PTS auditory injury. These auditory injury criteria were based

9 on noise exposure tests with captive marine mammals exposed to short duration (1 second), narrow band tones similar to sonar transmissions (Schlundt et al, 2000) and extrapolation of data from terrestrial mammals. The mean SEL required to produce an onset of TTS in these tests was found to be 195 dB re.1µPa2s. This result was supported by the short-duration tone data of Finneran et al. (2000, 2003) and longer duration noise data from Nachtigall et al. (2003).

Together, these data were considered to demonstrate that TTS in cetaceans is correlated with the received SEL and that the onset of TTS exposures fits with an equal-energy of 195 dB re.1µPa2s. The criteria were therefore considered applicable to signals of varying duration.

Whilst this approach may not have been developed for assessing impulsive noise, the approach of calculating the cumulative SEL by summing the noise from successive transient pressure pulses has been used in a recent COWRIE study (SMRU 2007) for estimating auditory injury zones from pile driving operations.

SOUTHALL ET AL, 2007.

Southall et. al. produced a comprehensive review of the impacts of underwater noise on marine mammals and proposed criteria for preventing injury based on both peak sound levels and Sound Exposure Level (Southall et al. 2007). The Sound Exposure Level criteria can be applied either to a single transient pulse or the cumulative energy from multiple pulses.

To take account of the wide frequency dependence in the auditory response of marine species, M-Weighting frequency functions for low, mid and high frequency hearing cetaceans and for pinnipeds were proposed.

The Southall et al. (2007) study proposes a peak noise criterion of 230 dB re. 1 µPa for cetaceans (peak level), and 218 dB re. 1µPa for pinnipeds, to prevent auditory injury (PTS onset); and a Sound Exposure Level of 198 dB re.1µPa2s M-Weighted for cetaceans, and 186 dB re.1µPa2s M-Weighted for pinnipeds. The lower (more conservative) of the criteria applies for any given application.

TTS onset is defined at a peak noise criterion of 224 dB re. 1 µPa for cetaceans, and 212 dB re. 1 µPa for pinnipeds; and a corresponding Sound Exposure Level of 183 dB re.1µPa2s M-Weighted for cetaceans, and 171 dB re.1µPa2s M-Weighted for pinnipeds.

Again, the lower of the criteria applies.

HESS (1997) BEHAVIOURAL DISTURBANCE CRITERIA

Behavioural disturbance from underwater sound sources is far more difficult to define and is dependent upon many factors related to the circumstances of the exposure (Southall et al. (2007). The Southall et al. study uses a ‘behavioural response severity’ scale as a measure of response.

The report by the High Energy Seismic Survey (HESS) Team (1997) prepared for the California State Lands Commission and the US Minerals Management Service concluded that behavioural disturbance to marine mammals would most likely occur at received Sound Pressure Levels above 140 dB re.1µPa (RMS), and quotes the studies of Richardson et al. (1995) in support of this. However, in stating this, the study recognised that there are a wide variety of responses by marine mammal groups when exposed to seismic sounds.

COMPARISON WITH HEARING THRESHOLD

Behavioural response and auditory injury from underwater sound is often assessed by comparing the received sound level with the auditory threshold of marine mammals.

Richardson et al. (1995), Erbe and Farmer (2000), Madsen et al. (2006), Thomsen et al. (2006), David (2006) for example, all use critical bands, normally octave or third octave band received levels of noise in comparison with the corresponding marine mammal hearing threshold in order to estimate the range of audibility and zones of influence from underwater sound sources.

Unfortunately there is little or no scientific evidence to support this methodology. Given the caveats outlined in the introduction above, there is no consideration of this methodology in this report.

NPWS DRAFT GUIDANCE DOCUMENT

The National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht has published a Draft Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters, (NPWS 2012). This document is based on a re-examination of a previous Code of Practice relating to Acoustic Seafloor Surveys. The Draft Guidance follows the Southall et. al (2007) categorisation of sound sources and marine mammals. Appendices 3A and 3B of the Draft Guidance restate the Southall et. al. received level criteria with respect to Irish- occurring species. These are illustrated below.

For the purpose of this report the primary criteria are SEL and Peak Pressure.

TEST METHODOLOGY

RECEIVED LEVELS

As outlined in the section on metrics, underwater noise levels during the construction of the proposed development will depend on the source level and sound propagation in the area. In order to determine the propagation loss, site specific attenuation testing was carried out using a known source

The test area is immediately adjacent to the Moneypoint site. High water on the date of the test was at 08:45 hrs, just as testing commenced.

The test comprised of the playing of one third octave band white noise (a random continuous signal with a flat power spectrum). Third octave bands were chosen as these bandwidths represent a first approximation on masking bandwidths for bottlenose dolphins, even though there is evidence to indicate that critical bandwidths of some marine mammals become wider at low and very high frequencies, whereas at intermediate frequencies they are likely to be narrower (Richardson et. al. 1995).

Third octave white noise in short pulses was prepared on a WAV file for playback through the underwater sound source. A spectrogram of part of the file is reproduced below indicating the narrow frequency bands.

The sound source has been designed and custom built for Biospheric Engineering Ltd and uses two transducers, one for low frequency and one for high frequency. The low frequency element comprises a flat disc transducer and the high frequency transducer is a spherical element. The combination of transducers and cables is built into acoustically transparent netting that maintains the transducer spatial separation and takes the tensile load off the cables.

The transducers are deployed over the side of the source vessel at a depth of 5m. The source vessel is anchored for the duration of the test. The receiving vessel operates independently but for distances of less than 80m maintains a link to the source vessel by rope to ensure accurate inter-location of vessels. At larger distances the receiver vessel measures the distance to the source vessel by means of a range- finder device. At distances of 1 km, GPS coordinates are used.

Testing was carried out at a series of points further from the source over a 3 hour period.

At each point the WAV file with the one third octave bursts was played and recorded.

SIGNAL ANALYSIS Post analysis was carried out using Avisoft Bioacoustics Labview and Signal Lab’s SigView 32 software packages. Calibration was carried out using a Bruel & Kjaer type 4223 hydrophone calibrator and cross checked with a Bruel & Kjaer type 2250 sound level analyser.

LICENSING To carry out site specific acoustic testing, it is necessary to make noise underwater and take a series of measurements at increasing distances from the source as outlined in the previous section. This type of test requires a Derogation Licence under Regulation 54 of the European Communities (Birds and Natural Habitats) Regulations 2011.

Biospheric Engineering Ltd applied for such a licence in May 2012 and was granted a licence on 10th September 2012.

The main licensing requirements were:

1. To provide adequate watch for marine mammals prior to testing 2. To limit noise levels to 140 dB

In order to ensure adequate watch for marine mammals was kept, the two vessels used for the survey were launched from points upstream and downstream of the test area at Moneypoint. One vessel with MMO Eugene McKeown on board, launched at the Kilimer Ferries slipway to the east of the site and the second vessel with ecologist Howard Williams on board launched at Cappa Pier, to the west.

Both vessels motored to the test site at a speed of 5 knots, keeping watch for marine mammals on the way. When on site a further watch was kept for 45 minutes prior to commencing testing. Following a ‘soft-start’ testing was carried out over a 3 hour period, followed by a further watch for 30 minutes. No marine mammals were sighted during the day.

Noise levels were limited to 140 dB on the expectation that this would be loud enough to provide sufficient margin over background noise levels for a clear test result. Due to higher than expected underwater noise levels at Moneypoint, this was not possible. A short burst of louder noise (to 160 dB at 16 kHz) was used during the last test run to try and maximise the difference between test and background noise. This provided confirmation that the test methodology was accurate and could provide a full result in other circumstances.

Due to these limitations in keeping within licence conditions a conservative approach to the noise modeling, including the adoption of a conservative value for attenuation. The value chosen will have the effect of extending the ‘impact zone’ of the pile driving activity, beyond that which is likely to be affected.

Sea state and wind on the date of testing were ideal, as can be seen in the photograph above.

The reporting required under the licensing is attached at Appendix B.

BACKGROUND NOISE LEVELS AT MONEYPOINT Background Noise levels in inshore waters are generally higher than those prevailing in the open ocean. This is due to localised shipping and other anthropogenic noise combined with natural noise levels from biological and physical sources. In some locations biological noise can be considerable whereas on an exposed coastline, wind and wave activity can result in considerably elevated noise levels.

Background noise levels at Moneypoint were measured along with two other locations, upriver at Labasheeda and downriver at Kilbaha. The measured levels at Moneypoint were significantly higher than those found elsewhere in the estuary. The noise levels are generally broad band with no dominant tones. This type of noise is characteristic of turbulent flowing water.

The higher levels at Moneypoint can be attributed to turbulent flow at the headland and to some extent noise from the power station, most probably the intake and outflow of cooling water, which by its nature would be expected to be broad band. The volume of water is in the order of 115,000 m3/hr with all three turbo-alternator units on full load. A coal ship was being unloaded at the time but there were no obvious tones from mechanical plant (such as cooling water pumps or a generator on board the ship) present so the background noise levels are attributed to water flow in the area.

DIFFICULTIES ENCOUNTERED IN CARRYING OUT THE SURVEY Due to the elevated background noise levels at Moneypoint, combined with the licence requirement to limit noise emissions to less than 140 dB, it was not possible to get a clear picture of the attenuation properties of the underwater noise environment at Moneypoint. While levels of 130 dB were measured close to the source, background levels did not permit sufficient margin over background to draw conclusions on attenuation levels. There is clearly attenuation between the levels recorded 4m from the source and 800m from the source but the levels at 800m are

19 determined by elevated background levels rather than attenuated received levels from the source.

For this reason a conservative approach has been adopted and cylindrical spreading losses have been assumed in the attenuation calculations. This will lead to an over estimation of the ‘impact zone’ from pile driving.

In order to attempt to overcome the limitations due to high background noise, the limiter on the acoustic source was over-ridden for a short period in an attempt to get sufficient difference between the source level and the received level at 800m. This was only effective at frequencies above 4 kHz, as can be seen above. At higher frequencies the expected 20 dB+ differential is evident.

PILE DRIVING SOURCE LEVELS

PILE DRIVING GENERALLY Pile driving takes three forms, rotary drilling into place, high frequency vibration driving and impact pile driving. The noise levels associated with each type increases, with the worst case being impact pile driving. The choice of technology is site dependent. For the purpose of this assessment we have assumed ‘worst case’, i.e. impact pile driving.

The piles will be founded on natural ground. Bedrock is relatively shallow at this part of the site and it is anticipated that the piles will be founded on rock. The depth, diameter and number of piles will be determined following the site investigation.

While driven piles are possible at turbine T1, this construction technique would require mobilisation of a second piling rig. For that reason, it is likely that the piles for turbine T1 will also be drilled. In any case, this turbine is located in the ash storage area north of the N67 Kilrush – Killimer road and at its closest is at more than 300 m from the estuary, at which distance no impacts would be anticipated.

For the purpose of this assessment a worst case scenario of driving piles is assumed. In the more likely event of rotary piling, noise emissions will be significantly reduced, to the extent that noise would barely be detectable above background levels.

Pile driving noise is a function of the technology chosen, pile diameter, ground conditions and depth of piling required. In the case of impact pile driving, a pile is driven by impact blows at the top end until it ‘refuses’ further driving. The foundation design is based on the pile being sufficiently stable at that point to support the design load for the duration of the design life. Driving is done by striking the top end of the pile with ‘constant’ energy every 1 to 2 seconds over an extended period.

Driving generally starts with a series of low energy blows (typically 6 – 10) and the process is stopped to ensure the pile is correctly aligned, a further series of blows is then struck and the pile checked again. This pattern could be repeated every couple of minutes over a 30 minute period until the pile is correctly aligned and embedded in the ground. Blows during this phase are generally at partial energy, as low as 10% of ‘driving’ energy and effectively provide a ‘soft start’ to the pile driving process.

Once the pile is correctly aligned and embedded the production driving starts at full power and blows are struck every one to two seconds at maximum energy until the pile meets ‘refusal’ point. At that stage piling stops and preparation is made for the next pile.

Pile driving energy is generally measured in kilo Newton Metres (kNm) and the energy is generally proportional to the diameter of the pile. Noise levels are a function of the pile driving energy, the more energy used to drive the pile, the more noise is generated.

The process of physically driving a pile is generally completed in 4 to 8 hours whereas the whole process of setting up the rig, getting the pile into position and back filling the pile (if it is being done) takes several days.

PILE DRIVING OFFSHORE Offshore pile driving is generally carried out for major marine infrastructure works or more recently for offshore wind farm construction. The construction of offshore wind farms has led to considerable concern regarding underwater noise from pile driving. It must be remembered that for offshore wind farm construction, pile diameters are in the region of 3 to 4 metres in diameter. This is because the construction could be a monopole construction where the pile must take all the horizontal load components as well as the vertical load. On shore piles are generally designed to support vertical loads only. The lateral loads are generally taken by the surrounding ground and there are no waves, wind or current forces to counteract. Pile diameters on shore are generally less than 1m and with a 4 times reduction in radius, the energy required to drive piles is subject to an order of magnitude reduction. Typical offshore piling energies are in the order of 800 kNm whereas on shore energies are in the order of 100 kNm.

Offshore piles couple with the water column directly, i.e. the striking force on the top of the pile radiates noise outward as the energy of the strike travels down the pile. As the pile meets resistance ‘pile ringing’ can result in considerable noise emissions along the length of the pile, which in almost all cases is the full water depth. This can be mitigated in various ways but a second noise transmission path is through the bottom of the pile into the seabed and back up into the water column.

Considerable work has been done in modeling and measuring noise from pile driving, e.g. Reinhall & Dahl (2011), De Jong & Ainslie (2008) and Zampoli et. al. (2012). From Reinhall & Dahl it can be seen that the reflected wave in the sediment is subject to significant energy absorption as the pulse travels through the sediment. This has two significant impacts on the pulse; (a) it reduces the peak pressure value and (b) it

22 extends the pulse duration in time. This is precisely what happens an impulse sound as it attenuates over distance underwater. The noise is attenuated much more rapidly through the sediment and the transition at the sediment/water column boundary has another significant attenuation factor due to Snells Law.

The effect of the attenuation can be seen in the following trace taken from Betke (2012)

PILE DRIVING NEAR THE SHORE In the case of pile driving near the shore, the pile is confined in clay/rock/sediment on land. This confinement means that there is no direct coupling between the pile and the water column. The energy driving the pile is attenuated significantly prior to coupling with the water column and the peak pressure level in the water is significantly reduced. This has a knock on effect in the total energy introduced into the water column.

These Figures suggest that energy transferred through the pile couples into the ground and propagates in a form of a low frequency impulse, thereafter coupling into the water; thus the area adjacent to the pile is effectively ensonified. The low frequency pulses generated by pile installation are significantly attenuated prior to coupling with the water column.

As outlined earlier underwater noise levels arising from pile driving have been extensively studied, in particular for the installation of offshore wind turbines. Typical values for SEL for pile driving large steel piles are in the order of 190 dB re 1 µPa2s @ 1m.

For pile driving the criteria is generally quoted with reference to SEL. This is due to the impulsive nature of the sound and more accurately reflects the total energy transmitted to the water body in pile driving.

Published SEL figures are generally derived from piles being driven into marine sediments. In the case of the proposed Moneypoint development the piling will be driven (or more likely drilled) into the ground on shore.

Data has been reported for construction pile driving in and near a river bed in the US in Theiss & Reyff (2007). This data includes reporting on a project in Stockton California where identical piles were driven into the ground in a river bed and ‘dry’ piles driven into the river bank. Underwater noise measurements were taken for both types of piles. The results are as follows:

Pile diam. Location Distance Peak RMS SEL dB dB dB 0.508m In river 10m 208 187 176 0.508m 20m 201 184 173 0.508m River 10m 198 183 171 0.508m bank 20m 188 172 163

The estimated piling energy was 66 kNm (Delmag 2010). Note that for equivalent distances the Peak levels drop by over 10 dB and the SEL levels drop by 7.5 dB as a result of the decoupling.

In a similar project at Geyserville, California larger piles were driven into the riverbank and the resulting underwater noise level measurements were as follows:

Pile diam. Location Distance Peak RMS SEL dB dB dB 1.22m River bank 10m 198 185 175

The estimated piling energy in this case was a maximum of 360 kNm, but from the noise levels it is unlikely that the pile driver was operating at full power, the larger machine was required for the larger pile diameter.

In the case of Moneypoint it is unlikely that the piles will be any greater than 1.22m, the most likely scenario is 0.8 to 1.0m piles to provide a base for a large concrete pad foundation. The pile driving energy has been taken as similar to the Geyserville data above.

NOISE PREDICTION

DAMAGE CRITERIA

From the data outlined above a noise prediction for peak and SEL levels was carried out to determine at what distance the Southall criteria would be exceeded. Due to the significant attenuation effect from pile driving on land as opposed to pile driving in the water column, the Southall damage criteria are not exceeded at any distance.

This means that marine animals (the most likely species being bottlenose dolphin, but all marine species have been catered for) are not subject to risk of hearing or other physical damage due to the proposed pile driving activity.

DISTURBANCE CRITERIA The disturbance criteria in Southall are conservative and based on studies that include Arctic and other remote populations of animals. In Irish Inshore waters, as with inshore waters in any industrialised nation, underwater noise levels are higher than those prevailing in the open ocean and remote areas. Marine animal populations are more accustomed to shipping and other anthropogenic noise sources.

It is well documented that pinnipeds and lone bottlenose dolphins frequent busy ports. The resident population of bottlenose dolphins in the Shannon Estuary is regarded as relatively stable Berrow et. al. (2010) in spite of years of industrial development and increasing shipping traffic in the area.

The threshold values for disturbance have therefore been taken at the upper level of the band outlined in Southall (2007) in the following calculations. Due to near field effects at frequencies below 500 Hz, the attenuation has been assumed at cylindrical (worst case), so that impact zones are at a maximum extent.

RESULTS As can be seen on the ‘Damage’ thresholds, no marine species is at risk. This applies to both peak exposure and SEL exposure levels. For disturbance pinnipeds represent the worst case with disturbance our to 64m, mid-frequency cetaceans (bottlenose dolphins) are potentially disturbed out to 32m and fish out to 8m.

Underwater Noise - Pile Driving at Moneypoint Wind Farm Project: Moneypoint Wind Farm Engineers: ESB International Date: 12th November 2012 By: EMcKeown

Damage Criteria

PILE DRIVING NOISE Peak Frequency 16Hz 31Hz 62.5Hz 125Hz 250Hz 500 Hz 1000Hz 2000Hz 4000Hz 8000Hz 16000Hz

Pile Driving 1m Steel Pile dB re 1 uPa @ 1m 208 191 182 182 199 206 201 190 188 180 170 160 Reduction due to land base 10 198 181 172 172 189 196 191 180 178 170 160 150

Exposure at Range Limit 1m 2m 4m 8m 16m 32m 64m 128m 256m 512m 1km Southall Criteria MF Cetaceans 230.0 198.0 195.0 192.0 189.0 186.0 183.0 180.0 177.0 174.0 171.0 168.0 Southhall Criteria Pinnipeds 218.0 198.0 195.0 192.0 189.0 186.0 183.0 180.0 177.0 174.0 171.0 168.0 Popper et al Criteria Fish 195.0 198.0 195.0 192.0 189.0 186.0 183.0 180.0 177.0 174.0 171.0 168.0

PILE DRIVING NOISE SEL Frequency 16Hz 31Hz 62.5Hz 125Hz 250Hz 500 Hz 1000Hz 2000Hz 4000Hz 8000Hz 16000Hz

Pile Driving 1m Steel Pile dB re 1 uPa @ 1m 185 168 159 159 176 183 178 167 165 157 147 137 Reduction due to land base 8 178 161 152 152 169 176 171 160 158 150 140 130 Duration (milliseconds) 90.0 Blows per second 1.0 SEL dB re 1 uPa2.s @ 1m 167 Exposure at Range Limit 1m 2m 4m 8m 16m 32m 64m 128m 256m 512m 1km Southall Criteria MF Cetaceans 198.0 167.1 164.1 161.1 158.1 155.1 152.1 149.1 146.1 143.1 140.1 137.1 Southhall Criteria Pinnipeds 186.0 167.1 164.1 161.1 158.1 155.1 152.1 149.1 146.1 143.1 140.1 137.1 Popper et al Criteria Fish 187.0 167.1 164.1 161.1 158.1 155.1 152.1 149.1 146.1 143.1 140.1 137.1

27 Underwater Noise - Pile Driving at Moneypoint Wind Farm Project: Moneypoint Wind Farm Engineers: ESB International Date: 12th November 2012 By: EMcKeown

Disturbance Criteria

PILE DRIVING NOISE Peak Frequency 16Hz 31Hz 62.5Hz 125Hz 250Hz 500 Hz 1000Hz 2000Hz 4000Hz 8000Hz 16000Hz

Pile Driving 1m Steel Pile dB re 1 uPa @ 1m 208 191 182 182 199 206 201 190 188 180 170 160 Reduction due to land base 10 198 181 172 172 189 196 191 180 178 170 160 150

Exposure at Range Limit 1m 2m 4m 8m 16m 32m 64m 128m 256m 512m 1km Southall Criteria MF Cetaceans 180.0 198.0 195.0 192.0 189.0 186.0 183.0 180.0 177.0 174.0 171.0 168.0 Southhall Criteria Pinnipeds 180.0 198.0 195.0 192.0 189.0 186.0 183.0 180.0 177.0 174.0 171.0 168.0 Popper et al Criteria Fish 187.0 198.0 195.0 192.0 189.0 186.0 183.0 180.0 177.0 174.0 171.0 168.0

PILE DRIVING NOISE SEL Frequency 16Hz 31Hz 62.5Hz 125Hz 250Hz 500 Hz 1000Hz 2000Hz 4000Hz 8000Hz 16000Hz

Pile Driving 1m Steel Pile dB re 1 uPa @ 1m 185 168 159 159 176 183 178 167 165 157 147 137 Reduction due to land base 8 178 161 152 152 169 176 171 160 158 150 140 130 Duration (milliseconds) 90.0 Blows per second 1.0 SEL dB re 1 uPa2.s @ 1m 167 Exposure at Range Limit 1m 2m 4m 8m 16m 32m 64m 128m 256m 512m 1km Southall Criteria MF Cetaceans 180.0 167.1 164.1 161.1 158.1 155.1 152.1 149.1 146.1 143.1 140.1 137.1 Southhall Criteria Pinnipeds 180.0 167.1 164.1 161.1 158.1 155.1 152.1 149.1 146.1 143.1 140.1 137.1 Popper et al Criteria Fish 187.0 167.1 164.1 161.1 158.1 155.1 152.1 149.1 146.1 143.1 140.1 137.1

28 MITIGATION There is no risk of physical harm to marine species from underwater noise resulting from the proposed pile driving operation. There is some risk of disturbance to pinnipeds and mid frequency cetaceans at close range, the most likely disturbance being to bottlenose dolphins.

In order to minimise disturbance the following mitigation measures are proposed:

1. A qualified and experienced marine mammal observer (MMO), independent of the piling contractor, shall be appointed to monitor for marine mammals and to log all relevant events using standardised data forms. 2. Underwater noise levels shall be measured during the course of pile driving activity, including the ‘ramp-up’ procedure. Monitoring shall be carried out independently from the pile driving contractor and the results reported to the Department of Arts, Heritage and the Gaeltacht. 3. The MMO shall advise the Works Superintendent within a previously agreed timeframe prior to scheduled activity if environmental conditions (e.g., sea state, light, visibility) are insufficient for effective visual monitoring. In such conditions, the activity of concern shall be postponed until acceptable conditions prevail. 4. In the event of suitable environmental conditions, a clear on-site communication signal shall be agreed between the MMO and the Works Superintendent as to whether the relevant activity may or may not proceed, or resume following a break (see below). Pile driving shall only proceed on positive confirmation with the MMO, which must be recorded by the MMO. 5. The use of clear ‘ramp-up’ (i.e., ‘soft-start’) procedures shall be implemented depending on the pile specification, the driving mechanism and the receiving substrate. Depending on the assessment of the pile specification, the driving mechanism and the receiving substrate, the ramp-up sequence of pile strikes may also employ an inter-strike time delay in order to minimise the initial cumulative effect of individual strikes. 6. The MMO shall conduct pre-start-up constant effort monitoring at least 30 minutes before the sound-producing activity is due to commence, continuing monitoring during and for 30 minutes following the activity. Sound-producing activity shall not commence until at least 30 minutes have elapsed with no marine mammal detections by the on-site MMO. 7. Operations shall not commence if marine mammals are detected within a 200m radial distance of the intended sound source, i.e., within the Monitored

Zone. This restriction also applies to any ramp-up procedure where the maximum sound output has not yet been attained. 8. Once begun, the activity may continue if weather conditions deteriorate or if marine mammals enter the 200m-radius Monitored Zone following start-up. If there is a break in pile striking activity for a period greater than 30 minutes then all pre-piling monitoring measures and ramp-up (where this is possible) shall recommence as for start-up. 9. Full reporting on MMO operations and mitigation undertaken should be provided to the Department of Arts, Heritage and the Gaeltacht to facilitate reporting under Article 17 of the EC Habitats Directive and future improvements to guidance.

CONCLUSION Background noise level measurements in the Shannon Estuary indicate that the noise level in the vicinity of Moneypoint is higher than at other non-industrial locations. A license to carry out site specific acoustic attenuation testing was applied for and received. Testing was carried out at Moneypoint on 6th October 2012, but due to limitations imposed in the licence regulating the activity, the results were not conclusive.

A noise propagation model has been constructed based on conservative factors to calculate the radius of impact of the proposed piling. The model indicates that no physical harm to any marine animal will arise. There is potential disturbance to pinnipeds for a radius of 64m and cetaceans for 32m from the shore. However, this is based on the use of driven piles rather than drilled piles, which is the proposed method of construction and whose potential impact is unlikely to be detected above background noise levels.

Mitigation measures including establishing a 200m observation zone from the shore and underwater noise monitoring during construction are proposed. Implementation of the mitigation measures will ensure that there will be no significant or residual impact to either the cSAC or the SPA as a result of the proposed wind farm development.

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36 finite-element propagation model., J. Acoust. Soc. Am. Volume 131, Issue 4, pp. 3392- 3392

APPENDIX A – NPWS LICENCE

APPENDIX B – MMO REPORTING SHEETS

MARINE MAMMAL RECORDING FORM - LOCATION AND EFFORT DATA (ACOUSTIC SEAFLOOR SURVEYS)

Ship ..Biospheric 1 Ship type (seismic/guard etc.) Acoustic survey .Survey type: Site Attenuation survey Licence no. DER 2012-59

Please record the following information every day (as many lines per day as you wish), even if no marine mammals are seen.

Date Observer Time you Time you Duration of Length of Blocks transited while Wind force Sea state Swell Visibility started stopped watch for time source looking for marine and direction looking looking marine was active mammals (or start and (use Beaufort (WMO Sea Choose from: Choose from: for for mammals while you end position if blocks scale) State Code) marine marine (mins) were looking not known) 0 = no Swell 1 = < 1 km mammal mammal for marine s s mammals 1= <1 m 2 = 1-5 km (UTC) (UTC) (mins) 2 = 1-2 m 3 = > 5 km

3 = 2+ m

6th Oct 2012 E McKeown 07:20 11:00 220 mins 72 mins Moneypoint survey 1 Light air 0-1 Calm 0 3 H Williams 07:15 11:00 225 mins 72 mins area 38/13 glassy to calm rippled

Return to: Marine Conservation Unit, Department of Environment, Heritage and Local Government, Third Floor, The Plaza Offices, Headford Road, Galway, Ireland within one month of completion of observations.

MARINE MAMMAL RECORDING FORM - RECORD OF OPERATIONS (ACOUSTIC SEAFLOOR SURVEYS)

Ship: Biospheric 1 Client: ESB International Survey Operator: Biospheric Engineering Licence No: DER 2012-59

Complete this form every time the Acoustic Source is used, including overnight, whether for shooting a line or for testing or for any other purpose. (Times should be in GMT)

Airgun activity Pre-shooting search Action necessary Date Time when Time when Time when Who carried Time when Time when Was there any Were Were marine If yes, If marine mammals soft start airguns airguns out a search pre- search for reason why hydro- mammals give time were present, what began reached stopped for marine shooting marine marine phones present in when action was taken? full power mammals? search for mammals mammals may used? the 30 marine (e.g. delay shooting) (Job title) marine ended not have been minutes mammals mammals seen? before the were last began (e.g. dark, fog, airguns seen swell, etc.) began firing? 6th Oct 08:35 08:43 10:45 Eugene 07:20 at 2012 McKeown Ferry slip (MMO) 11:00 No Yes No n/a n/a Howard 07:15 at Williams Cappa slip (Ecologist)

Appendix VIII

INIS Environmental Consultants Ltd., Avifauna Winter 2013/14 Survey Maps

Appendix IX

INIS Environmental Consultants Ltd., Moneypoint Wind Farm, Natura Impact Statement 2013

NATURA IMPACT STATEMENT

(ARTICLE 6 APPROPRIATE ASSESSMENT)

(Revision 1)

Proposed Five Turbine Wind Farm Moneypoint Power Station, Co. Clare

February 2013

INIS Environmental Consultants Ltd Planning and Environmental Consultants

Produced by INIS Environmental Consultants Ltd., Edenvale, Ennis, County Clare, Ireland. T: +353 (0) 65 6842465, M: +353 (0) 87 2831725, E: [email protected], W: www.inisenv.ie INIS Environmental Consultants Ltd. Moneypoint Wind Farm AA, 2013

Document details

Publisher: INIS Environmental Consultants Ltd. Planning and Environmental Consultants, Edenvale, Ennis, County Clare, Ireland.

T: +353 (0) 65 6842465 M: +353 (0) 87 2831725

E: [email protected], W: www.inisenv.ie

Client: ESBI, 18 – 21 St Stephens Green Dublin 2, Ireland.

T: +353 (0)1 703 80000

E: [email protected] W: www.esbi.ie

Document Title: Proposed 5 Turbine Wind Farm at Carrowdotia North and South, Co. Clare. Article 6 Appropriate Assessment.

Project Location: Carrowdotia North and Carrowdotia South, Moneypoint, Co. Clare.

Document Issue:

Revision Status Issue Date Author Approved by

0 Issue 02/10/2012 SM HW

1 Issue 07/02/2013 SM HW

Latest Revision Summary

Revision to reflect latest boundary and Conservation Objectives for SPA

2 TABLE OF CONTENTS

1 INTRODUCTION...... 5 1.1 STATEMENT OF AUTHORITY...... 7 1.2 LEGISLATIVE CONTEXT...... 8

2 MATERIALS AND METHODS...... 11 2.1 DESKTOP REVIEW ...... 13 2.2 HABITAT ASSESSMENT ...... 16 2.3 FAUNA ASSESSMENT...... 16 2.4 WATER QUALITY ASSESSMENT...... 17 2.4.1 Marine Habitat Assessment ...... 17 2.5 CRITERIA FOR EVALUATING IMPACT...... 18 2.5.1 Significance Criteria...... 18

3 CLARE COUNTY COUNCIL DEVELOPMENT PLAN 20112017 ...... 20 3.1 CLARE COUNTY DEVELOPMENT PLAN 2011‐2017 CONSERVATION OBJECTIVES FOR THE SAC AND SPA...... 23

4 STAGE 1: SCREENING / TEST OF SIGNIFICANCE...... 24 4.1 DESCRIPTION OF THE PROJECT ...... 24 4.2 DESCRIPTION OF THE RECEIVING ENVIRONMENT ...... 25 4.3 DESIGNATED SITES...... 26 4.3.1 Lower River Shannon SAC (002343) ...... 30 4.3.2 River Shannon and River Fergus Estuaries SPA (004077)...... 32 4.4 DESCRIPTION OF THE PROPOSED PLAN WITHIN THE RECEIVING ENVIRONMENT...... 35 4.5 POTENTIAL IMPACT ON NATURA 2000 SITES ...... 38 4.5.1 Potential Impact on the Lower River Shannon SAC ...... 38 4.5.2 Potential Impact on the River Shannon and River Fergus Estuaries SPA...... 43

5 STAGE 2: APPROPRIATE ASSESSMENT ...... 52 5.1 MITIGATION MEASURES...... 52 5.1.1 Mitigation by Avoidance ...... 53 5.1.2 General Mitigation...... 53 5.1.3 Mitigation Measures for Bottlenose Dolphins...... 54 5.1.4 Mitigation Measures for Avifauna...... 57 5.2 RESIDUAL IMPACTS ...... 57

6 CONCLUSION...... 59

7 REFERENCES...... 60

INIS Environmental Consultants Ltd. Moneypoint Wind Farm AA, 2013

APPENDICES

Appendix I Maps: Figure 1 Local Context Figure 2 Habitat Map

Appendix II NPWS Site Synopsis and Conservation Objectives

Appendix III INIS Environmental Consultants Ltd., Flora and Fauna Ecological Assessment, September 2010

Appendix IV INIS Environmental Consultants Ltd., Avifauna Monitoring Report, Spring 2010.

Appendix V INIS Environmental Consultants Ltd., Avifauna Monitoring Report, Autumn 2010.

Appendix VI INIS Environmental Consultants Ltd., Avifauna Monitoring Data, Winter 2010/2011.

Appendix VII Biospheric Engineering Ltd., Report on Underwater Noise Attenuation Trials at Moneypoint, Co. Clare in Connection with Planning Application P12‐74, October 2012.

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1 INTRODUCTION

INIS Environmental Consultants Ltd was commissioned to complete an Article 6 Appropriate Assessment (AA) for a proposed wind farm at Moneypoint Power Station in Co. Clare. This document assesses the likely significant impacts of the proposed works upon the Natura 2000 Special Areas of Conservation and Special Protected Areas in the surrounding landscape. This report is conducted in line with the requirements of Article 6(3) of the EU Habitats Directive (92/43/EEC) and the Guidance on Appropriate Assessment for Planning Authorities (NPWS, 2009).

Article 6 assessments are required under the Habitats Directive (92/43/EEC), where a plan or project may give rise to significant effects upon a Natura 2000 site. Natura 2000 sites are those identified as sites of community importance designated under the Habitats Directive (Special Areas of Conservation, here after referred to as SACs) or the Birds Directive (Special Protection Areas, here after referred to as SPAs).

Planning permission (Ref. PL. 03.130164) was granted by An Bord Pleanála in October 2002 for a nine-turbine wind farm at Carrowdotia North and Carrowdotia South, Moneypoint, Co. Clare. This followed an appeal of Clare County Council’s earlier decision of May 2002 to grant permission (Planning Ref No. 01/1538). While permission for the approved development remains in place, for various reasons, its construction has not been undertaken to date. It is now proposed to make alterations to the approved wind farm at Moneypoint and this is proposed in the form of a new planning application (Planning Ref No. 12/74). The revised proposal is generally equivalent to the development for which permission was granted and differs in respect of turbine numbers (fewer - reduced from nine to five) and turbine dimensions (larger).

The revised proposal has taken account of a number of constraints, including the following:  Technical advances in wind turbine technology that has seen larger turbines becoming the industry standard.

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 Completion of a wind measurement campaign on the site which allows the design of an optimum turbine layout that will be least impacted by disturbed airflow in and around the buildings of Moneypoint Generation Station.  Developments at Moneypoint Power Station and particularly the station’s Environmental Retrofit Project, which includes on-site landfilling of the by-product produced by the FGD process.

The revised proposal seeks to substitute the permitted development with an alternative arrangement. It is not intended that the approved development and the current proposal both be developed.

This AA forms part of the planning application for this new five turbine wind farm.

There are 14 Natura 2000 sites within a 30km radius of the proposed development site at Moneypoint. The proposal is located within the zone of potential impact (Scott Wilson et al., 2006) of the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries SPA (as presented in Figure 2 of Appendix I). The site synopsis and conservations objectives for these Natura sites are included as Appendix II of this report.

The potential impact of development works upon habitats and species and their conservation objectives within the designated sites are considered in this Appropriate Assessment. Where potential impacts are identified, appropriate mitigation measures to reduce / eliminate these impacts are outlined. This Stage 2 Appropriate Assessment takes cognisance of the findings of the EIA, particularly in relation to direct, indirect and ‘in combination’ (cumulative) potential impacts on protected habitats and species of the following Natura 2000 sites:  Lower River Shannon SAC (site code 111025);  River Shannon and River Fergus Estuaries SPA (site code: 004077).

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1.1 Statement of Authority

Qualified ecologist Howard Williams (CEnv CBiol MBiol MIEEM) completed his B.Sc. in Biological Sciences, National University of Ireland Cork, in June 1997. Following his degree he worked as a biologist for three years (1997- 2000). Mr. Williams has acted as lead ecologist on thirty two wind farm developments in Ireland and the UK since 2000. Mr. Williams is a full member of the Institute of Ecology and Environmental Management (IEEM). He is a Chartered Environmentalist (CEnv) with the Society for the Environment (Soc Env) and a Chartered Biologist (CBiol) with the Society of Biology.

Since 2000 he has worked as a professional ornithologist and has completed avian impact assessments / surveys on over twenty wind farm projects throughout Ireland.

In addition, Mr. Williams has worked assessing bats at proposed development sites at numerous locations throughout Ireland and has previously held a license from the National Parks and Wildlife Service to monitor lesser horseshoe bats at bat houses on the Ennis Bypass project. He has completed all relevant Bat Conservation Trust training programmes in England relating to the surveying of buildings and more importantly the planning and preparation of bat surveys.

Mr. Williams is principal ecologist with INIS Environmental Consultants Ltd and currently project manager on all INIS projects in the Republic of Ireland and the UK.

Mr. Keith Neary, B.Sc. Env. Sc. (Hons), Dip, FETAC, AIEEM, of INIS Environmental Consultants Ltd completed his B.Sc. in Environmental Sciences, National University of Ireland Cork. He has worked with Roscommon County Council Environment Section dealing with issues such as ecological assessment of proposed development sites, waste water discharge licenses, waste management permits, groundwater protection and groundwater source contamination identification. Keith Neary has spent the last three years working on various environmental projects including

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numerous habitat assessments with INIS Environmental Consultants Ltd both in the Republic and in Northern Ireland.

Mr. Neary has worked assessing habitats, bats and mammals at proposed development sites at numerous locations throughout Ireland and has attended several Bat Conservation Ireland survey training courses. He was also involved in operations to monitor lesser horseshoe bats at bat houses on the Ennis Bypass project. Mr. Neary is also capable of operating the advanced bat identification device i.e. the Anabat bat identification module. Mr. Neary is a member of Bat Conservation Ireland.

Stephanie Murphy B.Sc. M.Sc. MIEEM is a qualified Ecologist with a degree in Biological Sciences, National University of Ireland, Cork, received in 2002 and a Masters in Biodiversity and Conservation received from Leeds University in 2004. Stephanie has been involved in ecological surveys in Ireland since 2007. In addition, she has had work published in Irish Birds, Irish Naturalists’ Journal and the IEEM In Practice magazine. Stephanie is senior ecologist with INIS Environmental Consultants Ltd.

Christopher Cullen AIEEM is a qualified ecologist (Dip. In Field Ecology) and a graduate of UCC. In recent years he has worked on numerous bird surveys, both voluntary and non-voluntary. He has also been employed by BirdWatch Ireland as an avian surveyor and completed the national red grouse survey. He has worked for UCC as an avian researcher on hen harriers and as an avian surveyor for the Environmental Research Institute. He has had work published in peer-reviewed journals such as Irish Birds and the Irish Naturalists Journal. He has also co-authored work in Irish Birds and Ringing and Migration. Mr. Cullen is the Project Manager for Bird Survey Ireland, a wholly owned subsidiary of INIS Environmental Consultants Ltd.

1.2 Legislative Context

Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora - ‘The Habitats Directive’, has been transposed into Irish law by The European Community (Natural Habitats) Regulations 1997 (S.I. No. 94/1997).

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The 1997 Regulations were updated in 1998 and again in 2005 by The European Communities (Natural Habitats) (Amendment) Regulations 2005 (S.I. No. 378/2005). This amendment served to consolidate the main nature conservation legislation enacted in Ireland, meaning The Wildlife Act 1976, The Wildlife (Amendment) Act 2000, The European Communities (Natural Habitats) Regulations 1997, The European Communities (Natural Habitats) (Amendment) Regulations 1998, and to draw direct reference upon Council Directive 79/409/EC on the conservation of wild birds – ‘The Birds Directive’.

The Birds Directive (2009/147/EC) was adopted in 2009 to clarify the suite of amendments which had been required to the original 1979 Directive. This seeks to protect birds of conservation importance by the designation of Special Protection Areas (SPAs); whereas the Habitats Directive does the same for habitats and other species groups within Special Areas of Conservation (SACs). 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 areas throughout the European Community.

Article 6, paragraphs 3 and 4 of the Habitats Directive state as follows:

6(3) Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.

6(4) If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public

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interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

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

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2 MATERIALS AND METHODS

This Appropriate Assessment has been carried out using the following legislation and guidance documents:  Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg (EC 2000);  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, Office for Official Publications of the European Communities, Luxembourg (EC 2001);  The Habitats Regulations: A guide for competent authorities, Environment and Heritage Service, Belfast (EHS, 2002);  Guidance for Competent Authorities when dealing with proposals affecting SAC freshwater sites, Scottish Natural Heritage, Perth (SNH, 2006); and  Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC – Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission. Office for Official Publications of the European Communities, Luxembourg (EC 2007).  Appropriate Assessment of Plans and Projects in Ireland, Guidance for Planning Authorities (NPWS 2009).

The Article 6 Assessment has been prepared taking cognisance of the following legislation and guidelines: 1. Circular Letter SEA 1/087 & NPWS 1/08 Appropriate Assessment of Land Use Plans. 2. Methodological Guidance on the Provision of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites.

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3. Council Directive 92/43/EEC Appropriate Assessment of Plans, Scott Wilson, Levett-Therivel, Sustainability Consultants, Treweek Environmental. 4. Department of the Environment Heritage and Local Government (DoEHLG) Circular letter SEA 1 / 08 & NPWS 1 / 08 dated 15 February, 2008. 5. Department of the Environment Heritage and Local Government (DoEHLG) Appropriate Assessment Guidance for Planning Authorities (December 2009) and amended in March 2010.

Based on these guidelines, the assessment is a four-staged approach described below and illustrated in Plate 1.

Stage One: Screening / Test of Significance - the process which identifies the likely impacts upon a Natura 2000 site of a project or plan, either alone or in combination with other projects or plans, and considers whether these impacts are likely to be significant;

Stage Two: Appropriate Assessment - the consideration of the impact of the project or plan on the integrity of the Natura 2000 site, either alone or in combination with other projects or plans, with respect to the site’s structure and function and its conservation objectives. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts;

Stage Three: Assessment of Alternative Solutions - the process which examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 site; and

Stage Four: Assessment Where Adverse Impacts Remain - an assessment of compensatory measures where, in the light of an assessment of Imperative Reasons of Overriding Public

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Interest (IROPI), it is deemed that the project or plan should proceed.

This report contains a Stage 1 Screening Report and a Stage 2 Appropriate Assessment. It identifies the likely impacts upon the Natura 2000 site and where there are adverse impacts, an assessment of the potential mitigation of those impacts is provided. The assessment included site visits by ecologists in June 2011 and September 2012.

2.1 Desktop Review

A desktop review was carried out to identify features of ecological importance within the proposed development site and its immediate environs. The desktop study concentrated on two main areas of information: firstly, the publically available ecological information for the site locality, the SPA and the SAC (including all qualifying interests), and secondly, reports of ecological survey’s undertaken at Moneypoint Power Station in recent years. The following ecological reports undertaken at Moneypoint were reviewed:  Flora and Fauna Report for a proposed wind farm at Moneypoint, prepared by Eleanor Mayes in March 2001.  Bird Movements in the Vicinity of the Moneypoint Power Station, prepared by John N. Murphy in December 2001.  INIS Flora and Fauna Ecological Assessment (2010) which forms part of the EIS for the proposed Moneypoint Wind Farm (PL. Ref 12/74).  Moneypoint Windfarm Chapter 9 Avifauna, 2012.  INIS Avifauna Monitoring Report, Spring 2010.  INIS Avifauna Monitoring Report, Autumn 2010.  INIS Avifauna Monitoring Report, Winter 2010/2011.

A boat-based acoustic survey has also been undertaken to investigate the potential effects of piling works on marine mammals (October 2012). The results of these surveys have been reviewed to inform the findings of this AA.

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Plate 1: Flowchart outlining the appropriate assessment process (Adapted from EC 2001).

Is the PP directly connected with or necessary to the site management for Yes nature conservation?

Is the PP likely to have significant effects on the site? No

Yes

Assess implications for site’s Will the PP adversely affect the conservation objectives integrity of the site? No

Yes

Redraft the PP Yes Are there alternative solutions?

No Authorisation may be granted

Does the site host a priority habitat or species?

No Yes

Are there imperative reasons of Are there human health or safety overriding public interest? consideration or important environmental benefits? Yes

No Yes No

Authorisation must not be Authorisation may be granted for Authorisation may be granted other reasons of overriding public granted. interest, following consultation with Compensation the Commission. Compensation measures are taken. measures have to be taken. The Commission is informed.

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A review of the extent of designated conservation sites was carried out by consulting the National Parks and Wildlife Service (NPWS). The extent of the River Shannon and River Fergus Estuaries SPA has been significantly increased since 2011. The location of this SPA in relation to the proposed wind farm site is illustrated in Figure 2. A review of the published literature was undertaken in order to collate data on the receiving environment, including species and habitats of conservation concern in the study area. The following bodies provided information for this report (via publicly available documents):  National Parks and Wildlife Service (NPWS);  National Biodiversity Data Centre (NBDC);  Clare County Council (CCC);  Environmental Protection Agency (EPA);  Archaeology Ireland;  Office of Public Works (OPW);  Bat Conservation Ireland (BCI).  Environmental Protection Agency (EPA);

The relevant Development Plan under the Planning and Development Act, 2000 is the Clare County Council Development Plan 2011-2017 including its Appropriate Assessment. These documents have been reviewed as part of this Appropriate Assessment.

The following maps were utilised for this Appropriate Assessment:  Ordnance Survey of Ireland, Discovery Series 1:50,000. Sheets 58  ESBI revised wind farm layout drawing (Figure 1, Appendix I)  INIS Habitat Map (Figure 2 (Revised June 2010), Appendix I)  INIS Bat Survey Maps (Sonograms from 2010)  INIS Avifauna Maps from Avifauna Monitoring Reports, Spring, Autumn and Winter 2010/2011 (Appendices IV - VI).

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2.2 Habitat Assessment

The proposed wind farm development site was visited in August and September 2010. The habitat within the site was defined in relation to the habitat classification scheme published by the Heritage Council in A Guide to Habitats in Ireland (Fossitt, 2000). Habitats were identified and target notes were made on all semi-natural habitats encountered during the survey including notes on dominant vegetation, possible presence of rare or scarce species, topography, disturbance and management. Illustrative plates of the site and surrounding areas are provided in Appendix III. Previous ecological assessment work carried out at Moneypoint in 2001 in connection with the approved wind farm development and in 2003 in connection with the Environmental Retrofit Project by Ecological Consultant Ms. Eleanor Mayes was also consulted.

2.3 Fauna Assessment

A mammal survey was carried out over three consecutive days during late August and early September 2010. The site and surrounding areas were walked. All mammals recorded during site visits were noted and listed. Signs and tracks of mammals are the best way of assessing a site without conducting night surveys. All signs and tracks were assessed as they were encountered in the field.

Avifauna at Moneypoint was assessed in February 2001 by ecological consultant Ms. Eleanor Mayes. A comprehensive survey of bird movements at the site was undertaken in November / December 2001 in relation to the approved wind farm development at Moneypoint. A breeding bird survey was carried out at Moneypoint over three days in May 2010 (see Appendix IV). The scope of the survey was to assess spring (early breeding season and migration) usage of the site by both wildfowl and terrestrial species. Survey methods included Breeding Bird Transects following Countryside Bird Survey Methodology and a Vantage Point Survey to observe wildfowl movements over the site. A wildfowl survey following recommended methodologies for IWeBS (Irish Wetland Bird Survey) and vantage point methodology was carried out over autumn (see Appendix V) and winter of 2010/2011 (see

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Appendix VI). This survey monitored wildfowl usage of the subject site on a monthly basis. All methodologies follow current best practice.

An amphibian survey was also conducted during late August and early September 2010 by searching any water bodies i.e. ditches and ponds on site (see Appendix III for full report).

A bat survey was conducted over two nights during late August and early September 2010 to assess usage of the site by bat species. All bats recorded during site visits were noted and listed. Signs and droppings of bats were checked for at all accessible potential roost sites during day surveys (see Appendix III for full report).

A full description of all field surveys conducted may be seen in the Flora and Fauna Chapter and Avifauna Chapter of the EIS.

2.4 Water Quality Assessment

Under the terms of its IPPC Licence No. 605-02, ESB Moneypoint has ten licensed aqueous emission points. As required by its IPPC Licence, ESB Moneypoint reports annually to the EPA on compliance with limit values in the Licence, as part of its Annual Environmental Report (AER). The wind farm development will not alter the nature, composition, volume or location of existing discharges from the site.

The development will involve no redirection of surface water runoff within the Moneypoint site and, in introducing no additional impermeable hard stand areas, will result in no additional surface water run-off.

2.4.1 Marine Habitat Assessment

The marine environment at Moneypoint has been the subject of multiple investigations over time that has established a wealth of knowledge concerning ecological aspects of the Lower River Shannon SAC in the vicinity of the site. These have included the following:  Intertidal and Oceanographic Survey; AquaFact International Services (1992);

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 An Assessment of the Intertidal Environment in the Vicinity of the ESB Generating Plant at Moneypoint Co. Clare; AquaFact International Services (1993);  Cetaceans Desktop Literature Review; INIS Environmental Consultants Ltd (2010);  A Report to the ESB on Plankton Studies in the Vicinity of the Outfall, Moneypoint, Co. Clare; Aqua-Fact International Services (1999);  EPA IPPC Discharge Licensing for Moneypoint Power Station (ongoing).

Equivalent surveys have been undertaken over the years at Tarbert Generating Station, Co. Kerry, which is located on the opposite shore of the Shannon Estuary to Moneypoint.

All of these have demonstrated the continuing healthy state of the environment in the marine vicinity of ESB Moneypoint Power Station.

2.5 Criteria for Evaluating Impact

The impact significance is a combined function of the value of the affected feature (its ecological importance), the type of impact and the magnitude of the impact. It is necessary to identify the value of ecological features within the study area in order to evaluate the significance and magnitude of possible impacts. The proposed wind farm site is evaluated and given an overall significance rating on the basis of the criteria outlined in the National Roads Authority Guidelines for the Ecological Assessment of Road Schemes (2004) report. This system is given in the INIS Flora and Fauna Ecological Assessment (September 2010, Revised June 2011) of the proposed wind farm site which forms part of the EIS.

2.5.1 Significance Criteria

An impact’s significance is measured bearing in mind the site’s evaluation for nature conservation. An impact of severe significance is one which is likely to cause a considerable drop in the biodiversity value of a site that is extremely important for nature conservation. An impact of major significance will also impinge on an important nature conservation site or species but the impact

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will be less marked. An impact of moderate significance will cause a significant loss in biodiversity on a site but is unlikely to impinge on statutory sites or species. A minor impact will have only a very limited impact on biodiversity whereas an impact that is termed negligible/not significant is one that is most unlikely to impact in any way on biodiversity. IEEM (2006) define an ecologically significant impact as an impact (negative or positive) on the integrity of a defined site or ecosystem and/or the conservation status of habitats or species within a given geographic area. The integrity of a site is the coherence of its ecological structure and function, across its whole area, which enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified (IEEM, 2006). Best scientific professional judgment has been used in some cases, to assess the significance of predicted effects.

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3 CLARE COUNTY COUNCIL DEVELOPMENT PLAN 2011- 2017

The Shannon Estuary is recognised as a major natural resource in the Mid- West Regional Planning Guidelines 2010-2022. These guidelines advocate a co-coordinated approach to the development of the estuary and also note the need to capitalize on the inherent possibilities of accommodating large-scale industrial development to harness the economic potential of the estuary; subject to underlying principles of sustainable development within the remit of a Strategic Integrated Framework Plan.

The Natura 2000 Site designation restricts the activities that can take place in the estuary waters. Any proposed developments coming forward within the site or within the catchments of the site, and likely to have an effect on the sites qualifying interests will be subject to Habitats Directive Assessment (HDA). In addition, all plans and projects associated with the site will have to consider the "in combination" effects from other plans and projects coming forward that have or will affect the site. This Stage 2 Appropriate Assessment fulfils this aspect of the County Development Plan HDA.

The Clare County Development Plan 2011-2017 Appropriate Assessment has taken into account the existing water quality in the estuary area and has indicated that the plans and programs are in place to address the protection of these waters (Shannon International River Basin Management Plan (2009- 2015)). It is considered unlikely that in-combination impacts will occur as a result of the proposal to construct a wind farm, as no additional surface water runoff will be created and in any case all discharges from the Moneypoint site must conform to the standards of the Moneypoint IPPC licence. This license is drafted to conform to the conservation objectives of the Lower River Shannon SAC. The ongoing monitoring of this area is critical to ensure the adequate protection and management of the site. (There will be no in-combinations effects with this proposed development (PL. 12/74) and the approved wind farm (PL. 03.130164), as the proposals are mutually exclusive, i.e. it is

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proposed to replace the approved wind farm with this five turbine proposed project.)

Consideration is given to a Strategic Integrated Framework Plan for the Shannon Estuary (see section 6.6.2 Clare County Development Plan 2011- 2017 - Appropriate Assessment and Chapters 14 (Shannon Estuary) and 15 (Marine and Coastal Zone Management) of the Clare County Development Plan). All necessary estuarine water quality monitoring for the proposed wind farm development will be covered under the remit of the ESB Moneypoint IPPC Licence monitoring regime. Any additional ecological monitoring required to cover other aspects (species or habitats) of the Lower River Shannon SAC and / or any other designations have been previously outlined in the INIS Flora and Fauna Ecological Assessment (September 2010, Revised June 2011, see Appendix III). Furthermore, any superseding ecological monitoring conditions outlined by the competent authority should planning be granted will also be implemented. Relevant extracts from the Clare County Development Pan 2011-2017 are as follows:

Table 1: Volume 1 – Written Statement.

Development Plan Objective: Moneypoint CDP 14.4 It is an objective of the Development Plan:

a) To facilitate the development of the energy infrastructure at the Moneypoint site and work with others to ensure that the potential to diversify is supported, if required – ensuring in particular that all such developments shall not adversely affect species and habitats designated by the Habitats Directive;

b) To facilitate the potential to develop additional complementary sea-related industrial activities at the Moneypoint site – ensuring in particular that all such developments shall not adversely affect species and habitats designated by the Habitats Directive. Development Plan Objective: Renewable Energy on the Shannon Estuary CDP 14.5 It is an objective of Clare County Council:

To encourage renewable energy developments along

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Shannon Estuary, including wave and tidal, that are appropriately sited, designed and balanced with other planning and environmental considerations – ensuring in particular that all such developments shall not adversely affect species and habitats designated by the Habitats. Development Plan Objective: Natura 200 Sites CDP 17.3 It is an objective of the Development Plan:

a) To afford the highest level of protection to all designated Natura 2000 sites in accordance with the relevant Directives and legislation on such matters; b) To require all planning applications development within, adjacent to, or with the potential to affect a Natura 2000 site to submit a Natura Impact Statement in accordance with the Habitats Directive (1992); c) To recognise and afford appropriate protection to any new or modified SPAs or SACs that are identified during the lifetime of this Plan.

Table 2: Volume 5 - Wind Energy Strategy

WES Nine: ‘Acceptable in Principle’

These areas are considered suitable for wind farm development because of:  Sufficient wind speeds,  Access to grid network, and  Established patterns of inquiries. Projects within these areas must:  Demonstrate conformity with existing and approved wind farms to avoid visual clutter.

 Designed and developed in line with the Planning Guidelines in terms of siting, layout and environmental studies.

 Provide a Habitats Directive Assessment under Article 6 of the Habitat Regulations if situated in proximity to a Special Area of Conservation or Special Protection Area will require.

Target wind energy generation from *Acceptable in Principle areas is 150 MW

*Moneypoint is within the area identified as “Acceptable in Principle”

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The proposed project is in line with objectives and policy statements of the Clare County Development Plan 2011-2017:  Volume 1 – Written Statement, Clare County Development Pan 2011- 2017 CDP 14.4 and CDP 14.5,  Volume 5 - Wind Energy Strategy WES Nine: ‘Acceptable in Principle’.

3.1 Clare County Development Plan 2011-2017 Conservation Objectives for the SAC and SPA

At the time of preparation of the County Development Plan, specific conservation management plans were unavailable for the majority of the sites occurring within the Habitat Directive Assessment area. For such sites a list of generic Conservation Management Objectives (CMOs) was generated in consultation with the NPWS and included in the Clare County Development Plan.

The Conservation Management Objectives for SACs include:  To maintain the Annex I habitats for which the SAC has been selected at favourable conservation status;  To maintain the Annex II species for which the SAC has been selected at favourable conservation status;  To maintain the extent, species richness and biodiversity of the entire site; and  To establish effective liaison and co-operation with landowners, legal users and relevant authorities.

The Conservation Management Objectives for SPAs include:  To maintain the bird species of special conservation interest, for which the SPA has been designated, at favourable conservation status.

For site-specific Conservation Objectives of each of these two sites please see Section 4.3.

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4 STAGE 1: SCREENING / TEST OF SIGNIFICANCE

Stage One examines whether or not likely effects upon a Natura 2000 site will be significant. The proposed wind farm is located in the townlands of Carrowdotia North and Carrowdotia South, Moneypoint, Co. Clare (see Figure 1, Appendix I).

The Screening process in this report follows the matrix outlined in the EC report (2001) and the NPWS Guidance for Planning Authorities (2009). The headings to be covered by this matrix are outlined below and are discussed further in the following text.  Brief description of the project or plan.  Brief description of the Natura 2000 site.

Following a description of the development and the plan, the Assessment Criteria will determine the magnitude of impact (if any) that the proposed plan or project (in this case project) will have on the Natura 2000 site.

4.1 Description of the Project

It is proposed to construct a five turbine wind farm at Carrowdotia North and Carrowdotia South, Moneypoint, Co. Clare in substitution for an approved nine turbine wind farm which received planning permission (PL. 03.130164) in 2002 but has not proceeded to development. The main components of the scheme are wind turbines, a minor modification to the existing 110 kV Electrical Transformer Station with the construction of an additional Control Building to house electrical equipment and an anemometer mast. Five wind turbines will be installed and they will have a maximum base to blade tip dimension of 152 m. The necessary access / construction roads already exist on site.

One turbine (T1) will be located in the ash storage area to the north of the N67 where three turbines were located in the approved (but not built) Moneypoint Wind Farm, which will be replaced by this proposed development. The remaining four turbines will be within the main station area, with three (T2-T4) to the west of the station main building and the other (T5) to the east

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station main building at the edge of the coal store. Six turbines were located south of the N67 in the approved development (but not built). Ground investigations may indicate piling as a preferred construction method at turbines T1 and T4. The potential for utilisation of piling works are considered where necessary later in this report.

Access to all of the above locations is available for construction purposes without modification to existing surface conditions, i.e. no additional access tracks are required. The existing Moneypoint Power Station site was developed by extensive cut and fill operations. Significant volumes of rockfill were deposited to reclaim an area of approximately 30 ha from the Shannon Estuary, principally at the south-western part of the site. As a result of the cut and fill operations, the upper soil stratum consists of made ground of rockfill, overlying natural sediments, soils and bedrock. The variable depth to bedrock is generally <2 m.

4.2 Description of the Receiving Environment

Approximate Subject Site central co-ordinates are 503520, 651803; OS Sheet: 64, 1:50000. The site is located within the Townlands of Carrowdotia South and Carrowdotia North. The local context of the Subject Site is illustrated in Figure 1, Appendix I. The site is located on the Shannon Estuary. Most of the site frontage onto the estuary is rock armoured reclaimed land, with a small area of low rocky cliff at the eastern end of the site. A jetty with ship mooring and coal un-loaders extends parallel to the shore. The shoreline to the west of the site at Ballymacrinan Bay is a narrow steeply shelving cobble/ gravel beach, sloping up to low/ very low soft cliffs. Rock was excavated from the coal storage area for use in the power station site reclamation, leaving steep banks of broken/ eroded rock surface running up to the site boundary in this area. Soil berms have now matured with vegetation, especially on the exterior of the eastern and north eastern site boundaries.

The site area includes a range of habitat types from almost entirely un- vegetated coal store and gravelled yard areas, to landscaped and regularly mown grassed areas, ash disposal areas much of which have been levelled and sown with grass, and new and established mixed woodland. The general

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surrounding area is gently rolling countryside in agricultural use. Land use is intensive in the immediate area, with almost all land under grass crop. Field boundaries are hedgerows, dominated by hawthorn, ash and bramble. The underlying rocks are upper Carboniferous shales, the soils are gleys, with acid brown earths, and peats occurring locally. A small number of drainage ditches are present at the Subject Site on grassland areas, many only existing as narrow, shallow short linear cuttings. There is no extensive drainage network and natural drainage at the locality is good. In addition, there are no flowing streams or rivers on-site or proximal to the site. Several old derelict buildings with bat roost potential also exist on site or proximal to the site. Illustrative Plates of the existing environment are presented in the INIS Flora and Fauna Ecological Assessment (September 2010, Revised June 2011) presented in Appendix III.

4.3 Designated Sites

There are a total of 14 Natura 2000 sites located within 30 km of the proposed Moneypoint five turbine wind farm. These are listed in Table 3 and illustrated in Figure 1. Of these, two sites have the potential to be affected by the proposed development: the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries SPA (see Figure 2).

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Table 3: Natura 2000 sites within 30 km of the proposed Moneypoint five turbine wind farm.

Name Site Designation Notes Distance and direction code from subject site

Lower River 002165 SAC This very large site stretches along the Shannon valley from Killaloe to Loop Adjacent southern and Shannon Head/Kerry Head, a distance of 120 km. The site is an SAC selected for western site boundaries. lagoons, alluvial wet woodlands, floating river vegetation, Molina meadows, estuaries, tidal mudflats, Atlantic salt meadows, Mediterranean salt meadows, sea cliffs, reefs and large inlets and bays, amongst others, all Annex I habitats of the EU Habitats Directives. The site is also selected for species listed on Annex II of the same directive such as bottlenose dolphin, sea lamprey, river lamprey, brook lamprey, freshwater pearl mussel, Atlantic salmon and otter.

River Shannon 004077 SPA The site is of great ornithological interest, being of international importance on Adjacent to southern and and River Fergus account of the numbers of wintering birds it supports. It also supports western site boundaries Estuaries internationally important numbers of three species, i.e. Dunlin, Black-tailed Godwit and Redshank. In addition, there are 16 species that have populations

of national importance.

Stack's to 004161 SPA Designated for the protection of Hen Harrier (Circus cyaneus) [A082]. ~12km SE Mullaghareirk, West Limerick Hills and Mount Eagle

Tullaher Lough & 002343 SAC Features in interest include active raised bogs, degraded raised bogs still ~15km NE Bog capable of natural regeneration, transition mires and quaking bogs, depressions on peat substrates of the Rhynchosporion

Carrowmore 002250 SAC Features of Interest include Vertigo angustior, reefs, embryonic shifting dunes, ~16km NNE Dunes shifting dunes along the shoreline with Ammorphila arenaria (white dunes), fixed coastal dunes with herbaceous vegetation (grey dunes).

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Name Site Designation Notes Distance and direction code from subject site

Mid Clare Coast 004182 SPA Features of Interest include: Cormorant (Phalacrocorax carbo) [A017], Ringed ~17 km north west Plover (Charadrius hiaticula) [A137], Sanderling (Calidris alba) [A144], Purple SAC Sandpiper (Calidris maritima) [A148], Dunlin (Calidris alpina) [A149], Turnstone (Arenaria interpres) [A169], Barnacle Goose (Branta leucopsis) [A396], Wetlands & Waterbirds [A999].

Carrowmore Point 000764 SAC Features of Interest include: Cormorant (Phalacrocorax carbo) [A017], Ringed ~17km north west to Spanish Point Plover (Charadrius hiaticula) [A137], Sanderling (Calidris alba) [A144], Purple and Islands Sandpiper (Calidris maritima) [A148], Dunlin (Calidris alpina) [A149], Turnstone (Arenaria interpres) [A169], Barnacle Goose (Branta leucopsis) [A396], Wetlands & Waterbirds [A999], various islands important to birds for roosting and dune systems.

Moanveanlagh 002351 SAC Features of interest include active raised bogs, degraded raised bogs still ~19km S Bog capable of natural regeneration and depressions on peat substrates of the Rhynchosporion.

Kilkee Reefs 002264 SAC Features of Interest include large shallow inlets and bays, reefs and ~20km E submerged or partly submerged sea caves.

Illaunonearaun 004114 SPA Designated for the protection of the Barnacle Goose (Branta leucopsis) [A396]. 21km W

Barrigone 000432 SAC Features of interest include marsh fritillary, Juniperus communis formations on ~22km E heaths or calcareous grasslands, semi-natural dry grasslands and scrubland facies on calcareous substrates, limestone pavements.

Askeaton Fen 002279 SAC Features of interest include calcareous fens with Cladium mariscus and ~30km E Complex species of the Caricion davallianae, alkaline fens.

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Figure 1: Natura 2000 sites within 30km of the proposed development (Courtesy of npws.ie)

Location of proposed wind farm

Figure 2: Natura 2000 sites with the potential to be affected by the proposed development (Courtesy of npws.ie)

Location of proposed wind farm

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The wind farm is located adjacent to the north shores of the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries SPA. The potential impact of the wind farm and its associated works upon habitats and species and on the conservation objectives of these two Natura 2000 sites are considered in this Article 6 Appropriate Assessment.

4.3.1 Lower River Shannon SAC (002343)

This Natura 2000 site lies adjacent to the proposed project area and is therefore screened for any potential for impact to the SAC. The qualifying interests of the SAC are presented in Table 4 along with an assessment of potential impact on each as a result of the proposed development.

The Conservation Objectives of the Lower River Shannon SAC [002165] were updated in 2012 and are presented in Appendix II along with the Site Synopsis of the SAC.

The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of habitats and species of community interest. These habitats and species are listed in the Habitats and Birds Directives and Special Areas of Conservation and Special Protection Areas are designated to afford protection to the most vulnerable of them. These two designations are collectively known as the Natura 2000 network.

European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations that will ensure the ecological integrity of these sites.

A site-specific conservation objective aims to define favourable conservation condition for a particular habitat or species at that site.

The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level.

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Favourable conservation status of a habitat is achieved when:  its natural range, and area it covers within that range, is 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.

The favourable conservation status of a species is achieved 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.

Only one qualifying interest of the SAC, Tursiops truncatus, may be affected by the proposed wind farm development at Moneypoint. The proposed wind farm is approximately 10 meters to the north of the Lower River Shannon SAC site. As the entire development is located outside the SAC boundary, there will be no direct impact on habitats or species for which the SAC is designated. However, as piling may be required for Turbines T1 and T4, this may have an indirect negative impact on bottlenose dolphins utilising the estuary.

Ground-borne vibration due to construction is very rapidly attenuated over distance. BS 5228-2: 2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites – Part 2: Vibration discusses vibration attenuation at distances up to some tens of metres from the source. Vibration from construction activities at hundreds of metres from the receptors is considered to be not significant. In that context, turbine T1 is located in the ash storage area at some considerable distance from the estuary and only the possible piling of turbine T4 is considered to be of relevance.

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Table 4: Qualifying Interests of the Lower River Shannon SAC and potential impact as a result of the proposed development.

Natura Item Description Potential Code Impact

1096 Brook lamprey (Lampetra planeri) X 1099 River lamprey (Lampetra fluviatillis) X 1095 Sea lamprey (Petromyzon marinus) X 1106 Salmon (Salmo salar) X 1029 Freshwater pearl mussel (Margaritifera margaritifera) X 1349 Bottlenose dolphin (Tursiops truncatus) Yes Species 1355 Otter (Lutra lutra) X 1130 Estuaries X 1140 Mudflats and sandflats not covered by seawater at low tide X 1310 Salicornia and other annuals colonizing mud and sand X 1110 Sandbanks which are slightly covered by sea water all the X time 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) X 1410 Mediterranean salt meadows (Juncetalia maritimi) X 3260 Water courses of plain to montane levels with the X Ranunculion fluitantis and Callitricho-Batrachion vegetation 1150 Coastal lagoons X 1160 Large shallow inlets and bays X 1170 Reefs X 1220 Perennial vegetation of stony banks X 6410 Molinia meadows on calcareous, peaty or clayey-silt-laden X soils (Molinion caeruleae) 91E0 Alluvial forests with Alnus glutinosa and Fraxinus excelsior X (Alno-Padion, Alnion incanae, Salicion albae) 1230 Vegetated sea cliffs of the Atlantic and Baltic coasts X Habitat Habitat 1320 Spartina swards (Spartinion maritimae) X

4.3.2 River Shannon and River Fergus Estuaries SPA (004077)

The River Shannon and River Fergus Estuaries SPA was extended in 2012 and now covers the entire Shannon Estuary from Limerick city and Clarecastle to Carrigaholt Bay near Doonaha, Co. Clare. It forms the largest estuarine complex in Ireland. This SPA overlaps with the Lower River Shannon SAC (002165) (See Figure 2).

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The site has vast expanses of intertidal flats. The main macro-invertebrate community present is a Macoma-Scrobicularia-Nereis community, which provides a rick food resource for the wintering birds.

The site is of great ornithological interest, being of international importance on account of the numbers of wintering birds it supports. It also supports internationally important numbers of three species, i.e. Dunlin, Black-tailed Godwit and Redshank. In addition, there are 16 species that have populations of national importance. For several of the bird species, it is the top site in the country. Also of note is that three of the species which occur regularly are listed on Annex I of the E.U. Birds Directive, i.e. Whooper Swan, Golden Plover and Bar-tailed Godwit. Also found is the nationally rare Triangular Club-rush (Scirpus triqueter).

The Conservation Objectives of the River Shannon and River Fergus Estuaries SPA [004077] were updated in September 2012 to deal specifically with each qualifying interest of the SPA. These qualifying interests are listed in Table 5. The Conservation Objectives of the SPA are included in Appendix II along with the updated Site Synopsis for the SPA, which was received from NPWS on 29th January 2013. At the time of writing (29/01/2013) the Site Synopsis had not been updated on the NPWS website to reflect the extension in area of the SPA.

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A site-specific conservation objective aims to define favourable conservation condition for a particular habitat or species at that site.

Favourable conservation status of a habitat is achieved when:  its natural range, and area it covers within that range, is 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.

The favourable conservation status of a species is achieved when:  population 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.

As the River Shannon and River Fergus SPA borders the south and west the proposed development at Moneypoint, the potential for direct and indirect impact to certain wildfowl and migratory birds, which frequent the area around the Moneypoint site, exists.

Based on scientific evidence through onsite surveys and the analysis of related documents (found on npws.ie), the conservation objectives of the SPA or the SAC will not be adversely affected by the proposed development.

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Table 5: Qualifying Interests of the River Shannon and River Fergus SPA and potential impact as a result of the proposed development.

Natura Item Description Potential Code Impact

A017 Cormorant (Phalacrocorax carbo) Yes A038 Whooper swan (Cygnus cygnus) X A046 Light-bellied Brent Goose (Branta bernicla hrota) X A048 Shelduck (Tadorna tadorna) Yes A050 Wigeon (Anas penelope) Yes A052 Teal (Anas crecca) Yes A054 Pintail (Anas acuta) X A056 Shoveler (Anas clypeata) X A062 Scaup (Aythya marila) X A137 Ringed Plover (Charadrius hiaticula) Yes A140 Golden Plover (Pluvialis apricaria) X A141 Grey Plover (Pluvialis squatarola) X A142 Lapwing (Vanellus vanellus) Yes A143 Knot (Calidris canutus) X A149 Dunlin (Calidris alpina) Yes A156 Black-tailed Godwit (Limosa limosa) X A157 Bar-tailed Godwit (Limosa lapponica) X A160 Curlew (Numerius arquata) Yes A162 Redshank (Tringa totanus) Yes A164 Greenshank (Tringa nebularia) Yes Species A179 Black-headed Gull (Chroicocephalus ridibundus) Yes A999 Wetlands X

4.4 Description of the Proposed Plan within the Receiving Environment

One turbine (T1) will be located in the ash storage area to the north of the N67 where three turbines were located in the approved Moneypoint Wind Farm. The remaining four turbines will be within the main power station area, there being three (T2-T4) to the west of the station main building and the other (T5) to the east station main building at the edge of the coal store.

The ash storage area was a naturally occurring valley into which significant quantities of ash have been placed since the initial development of the power

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station. T1 is located in an area classified as Improved Agricultural Grasslands (GA1) and Recolonising Bare Ground ED3 (Fossitt, 2000). Both these habitats are of low ecological value (see Figure 2, Appendix I). The turbine will be founded at the finished ground elevation in this area. It is expected that the turbine foundation will comprise a conventional spread footing at a depth of about 2 m below existing ground level. Construction will involve limited excavation of stored ash. Piling is the likely preferred construction method at turbine T1.

Turbines T2 and T3 are in the area where the pre-development conditions of the Moneypoint site remain. T2 is in an area classified as Buildings and Artificial Surfaces BL3 as per Fossitt (2000) (see Figure 2, Appendix I), an area of no ecological value. T3 is in an area classified as Recolonising Bare Ground ED3 (Fossitt, 2000), an area of low ecological value. The wind farm will entail excavation work to a depth of approximately 2.5 m to prepare the ground for construction of conventional spread footings.

Turbine T4 is in the area of made ground of rockfill placed during reclamation of this part of the power station site during its development. The foundation will likely be piled here. T4 is in an area of Amenity grasslands GA2 (Fossitt, 2000), an area of low ecological value and of no significant conservation value (see Figure 2, Appendix I).

Turbine T5 is at the lower part of the coal store. This area is identified as Buildings and Artificial Surfaces BL3 as per Fossitt (2000) and is of no ecological value, (see Figure 2, Appendix I). Ground conditions here represent the reduced formation level comprising a shallow depth of rockfill over solid rock arising from the significant excavations that took place here in development of the power station site. The turbine foundation will comprise a conventional spread footing at a depth of about 2 m below existing ground level.

Turbines T3 and T4 are the turbines that will be located closest to the Estuary. There will be no alteration to the shoreline at these locations and no direct impacts on the SAC or the SPA with regards to land take. An approved

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access road is located close to the shoreline here. Turbines T3 & T4 will be located on the landward side of the access road. This separation from the Estuary provides a suitable buffer zone to the SAC and SPA. Additional rock protection in this area is already approved to provide protection to vehicles on the access road from wind blown spray and water possibly breaking over the existing rock armouring during severe stormy weather conditions. This will provide further protection of proposed works from the Natura 2000 boundaries. The exact locations of the proposed turbines are outlined in Table 6. There is no wetland habitat within the boundary of the proposed development site at Moneypoint. No wetland habitat (a qualifying interest of the SPA) will be affected by the proposed development.

Table 6: OSI grid coordinates of proposed turbines at Moneypoint.

Turbine Reference Number OSI Coordinate (x,y) Final Base Elevation (mOD)

T1 102890, 152233 15.60

T2 103035, 151956 10.28

T3 102734, 151616 5.20

T4 103118. 151510 5.80

T5 104176, 151320 12.70

It should also be noted that surface waters arising during the construction phase of the project will be managed within the remit of ESB Moneypoint’s IPPC Licence No. 605-02. This licence is in line with all of the conservation objectives of the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries SPA. Under the terms of its IPPC Licence, ESB Moneypoint has ten licensed aqueous emission points.

The wind farm development will not alter the nature, composition, volume or location of existing discharges from the site. The development will involve no redirection of surface water runoff and result in no additional surface water run-off.

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4.5 Potential Impact on Natura 2000 Sites

In the absence of mitigation measures, the Stage 1 Screening Assessment indicates that there is the potential for indirect impact to bottlenose dolphins within the Lower River Shannon SAC and possible direct and/or indirect impact to avifauna that utilise the River Shannon and River Fergus Estuaries SPA, as a result of the proposed development. The significance of these impacts is now assessed.

4.5.1 Potential Impact on the Lower River Shannon SAC

There are sixteen publications relating to the Lower River Shannon SAC (Unpublished NPWS reports) on the NPWS website. These supporting documents cover various habitats and species of qualifying interest, with specific conservation objectives for each. Those that are relevant to this Appropriate Assessment have been reviewed (see list below) as part of the scientific assessment of potential impacts on this Natura 2000 site. All pertinent information relating to the Moneypoint site is presented.

Unpublished NPWS reports reviewed as part of the Appropriate Assessment process:  Lower River Shannon SAC (002165) Conservation objectives supporting document coastal habitats [Version 1]  Lower River Shannon SAC (002165) Conservation objectives supporting document lagoon habitats [Version 1]  Lower River Shannon SAC (002165) Conservation objectives supporting document water courses [Version 1]  Lower River Shannon SAC (002165) Conservation objectives supporting document woodland habitats [Version 1]  Lower River Shannon SAC (002170): Conservation Objectives supporting document – Marine habitats and species (Version 1). 2012. Unpublished report to NPWS.  Bottlenose Dolphin SAC Survey 2010. Berrow et al. Unpublished report to NPWS.

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4.5.1.1 Potential Impact on Coastal Habitats

The Lower River Shannon SAC (site code: 2165) is designated for a range of coastal habitats including vegetated shingle, saltmarsh and sea cliff. The following five coastal habitats are included in the list of qualifying interests for the site:  Perennial vegetation of stony banks (1220)  Salicornia and other annuals colonising mud and sand (1310)  Atlantic salt meadows (Glauco-Puccinellietalia maritimae) (1330)  Mediterranean salt meadows (Juncetaliea maritimi) (1410)  Vegetated sea cliffs of the Atlantic and Baltic Coasts (1230)

A further three habitats were also recorded within the Lower Shannon SAC by the Coastal Monitoring Project (CMP) (Ryle et al., 2009):  Embryonic shifting dunes (2110)  Shifting dunes along the shoreline with Ammophila arenaria (white dunes) (2120)  Fixed coastal dunes with herbaceous vegetation (grey dunes) (2130)

These habitats were recorded at Beal Point and Ballybunnion sub-sites (Ryle et al., 2009)

Perennial vegetation of stony banks (1220) is the only designated coastal habitat proximal to the Moneypoint site, situated at Ballymacrinan Bay (shingle site). Ballymacrinan Bay is located outside the proposed development site at Moneypoint; this coastal habitat will not be affected by any of the site construction or operation activities.

4.5.1.2 Potential Impact on Lagoon Habitats

No lagoons are present in the vicinity of the Moneypoint site and this habitat type will not be affected by the proposed development.

4.5.1.3 Potential Impact on Water Courses

There are no water courses of plain to montane levels with Ranunculion fluitantis and Callitricho-Batrachion vegetation present in the vicinity of the

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Moneypoint site and this habitat type will not be affected by the proposed development.

4.5.1.4 Potential Impact on Woodland Habitats

Woodland habitats of conservation concern do not exist on or proximal to the Moneypoint site and therefore are not discussed further in this report.

4.5.1.5 Potential Impact on Marine Habitats and Species

The marine habitat type ‘Intertidal Sand to Mixed Sediment with Polychaetes, Molluscs and Crustaceans Community Complex’ occurs at Clonderalaw Bay and Poulnasherry Bay. These bays are several kilometres from Moneypoint and will not be affected by the proposed development.

“Subtidal Sand to Mixed Sediment with Nucula nucleus Community Complex” occurs in the area from Foynes Island to Kilcredaun Point. It is found offshore from Moneypoint Power Station. No works will take place within this habitat type and it will not be affected by the proposed development.

“Subtidal Sand to Mixed Sediment with Nephtys Spp. Community Complex” occurs in Clonderalaw Bay and Ballymacrinan Bay. No works will take place within this habitat type and it will not be affected by the proposed development.

A small strip of “Fucoid-Dominated Intertidal Reef Community Complex” exists along the coast of Moneypoint. As all works will be restricted to dry ground, this habitat type will not be affected by the proposed development.

In summary, there will be no impact to habitats designated under the Lower River Shannon SAC as a result of the proposed development. Protected species bottlenose dolphins and otters are discussed below.

4.5.1.6 Potential Impact on Bottlenose Dolphins

The Lower River Shannon SAC is the only site designated for the protection of bottlenose dolphins in Ireland, making it the most important site for the conservation of cetaceans in the country. Bottlenose dolphins are listed as Annex II species under the E.U. Habitats Directive. The Shannon Estuary is

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home to the only known resident group of bottlenose dolphins, who breed there every year. The bottlenose dolphin population that occurs in the Shannon is one of only six known resident European populations (Rogan et al., 2000).

The size, community structure, distribution and habitat use of bottlenose dolphin inhabiting the Lower River Shannon SAC are quite well understood. Survey efforts primarily targeting the summer-autumn period and using a photo-ID based mark-recapture technique have delivered population estimates for the site in 2000, 2003, 2007, 2008 and 2010 which have been relatively consistent between years. The most recent (i.e. fifth) population estimation survey conducted in the summer of 2010 resulted in an estimate of 107 +/- 12 individuals and it concluded that the population trajectory has been stable since estimations efforts began. Group sizes tend to be comparatively small (most commonly 3-15 individuals, median = 6) but highly variable in composition. However, larger aggregations may occasionally be recorded, as is the case both in coastal waters and further offshore, particularly in the summer months.

There is the potential that sound pressure waves from construction works such as piling and blasting on site may enter the marine environment, disturbing potential foraging sites for dolphins. The passage of sound pressure from the terrestrial to the marine environment will depend on bedrock and other factors. Turbine T4 is in an area of made ground of rockfill placed during reclamation of this part of the power station site during its development. The need for piling of foundations may occur at this turbine location.

Bottlenose dolphins are known to range widely throughout the site and, due to the size of the site and consistent data available, research effort has predominantly targeted the broader downstream area lying to the west of Tarbert and extending as far as Kerry Head and Loop Head. However, the vast majority of records are contained within the Lower River Shannon site. Research effort has led to the identification of two core locations within which the majority of dolphin records occur. These ‘critical areas’ (presented in

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Figure 7 of the Lower River Shannon SAC (002170): Conservation Objectives supporting document – Marine habitats and species (Version 1). 2012. Unpublished report to NPWS) represent high value habitats used preferentially by the species within its overall range at the site and they broadly coincide with areas of steep benthic (i.e. seafloor) slope, greater depth and stronger currents. The smaller of these two areas is approximately off shore from the Moneypoint site.

The following technical clarification is provided in relation to specific conservation objectives and targets for Annex II species to facilitate the appropriate assessment process:

Objective: To maintain the favourable conservation condition of bottlenose dolphin in Lower River Shannon, which is defined by the following list of attributes and targets:  Target 1: Species range within the site should not be restricted by artificial barriers to site use.  Target 2: Critical areas, representing habitat used preferably by bottlenose dolphin, should be conserved in a natural condition. Operations or activities that cause displacement of individuals from a critical area (i.e. preferred habitat) or alteration of natural behaviour to an extent that may ultimately interfere with key ecological functions would be regarded as significant and should therefore be avoided.  Target 3: Human activities should occur at levels that do not adversely affect the bottlenose dolphin population at the site. Proposed activities or operations should not introduce man-made energy (e.g. aerial or underwater noise, light or thermal energy) at levels that could result in a significant negative impact on individuals and/or the population of bottlenose dolphin within the site.

The proposed works during the construction phase of the development may result in elevated underwater noise and has the potential to displace individuals off shore of the development site. Thus in the absence of mitigation, the proposed works could have potentially impacted Targets 2 and 3 of the SAC conservation objective for this species.

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As the Shannon Estuary is designated an SAC, it is of International ecological importance (A rated). The temporary impact of such construction works, which may affect a small but critical part of the estuary, is therefore considered a Major Negative impact on bottlenose dolphins within the SAC (NRA, 2004).

4.5.1.7 Potential Impact on Otters

The Conservation objectives of the SAC list seven attributes, which should be maintained to prevent impact to otters. These include distribution, extent of habitat (terrestrial, marine, river and lagoon), couching sites and holts, fish biomass and habitat connectivity. None of these attributes will by affected by the proposed development. No holts or other tracks/signs of otters have been identified within the site. Any resulting disturbance from the development will be contained within the existing industrial site of Moneypoint Power Station. Therefore, otters are not considered further in this report.

4.5.2 Potential Impact on the River Shannon and River Fergus Estuaries SPA

Eight related publications (Unpublished NPWS reports – see list below) are presented on the NPWS website / River Shannon and River Fergus Estuaries SPA webpage. These reports cover various habitats and species distributions within the SPA and SAC. INIS has reviewed all these unpublished reports as part of their scientific assessment. All pertinent information relating to the Moneypoint site has been presented on the following pages.

Unpublished NPWS supporting documents for the SPA reviewed as part of the Appropriate Assessment process:  River Shannon and River Fergus Estuaries SPA (04077) Conservation objectives supporting document – Appendix 8.1 [Version 1]  River Shannon and River Fergus Estuaries SPA (04077) Conservation objectives supporting document – Appendix 8.2 [Version 1]  River Shannon and River Fergus Estuaries SPA (04077) Conservation objectives supporting document – Appendix 9 [Version 1]  River Shannon and River Fergus Estuaries SPA (04077) Conservation objectives supporting document [Version 1]

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The above documents present water bird distribution records during low tide surveys (October 2010 – February 2011). The distribution and summary data of features of interest i.e. wintering (non-breeding) species (n=20) is supplied within 3 PDF documents (Appendices 8.1, 8.2 & 9; Maps have not been produced for Whooper Swan due to insufficient data). The maps within these documents show species distribution through dot density diagrams for intertidal and subtidal habitats within the SPA. From these we can assess what species/species densities are present at intertidal/subtidal habitats near Moneypoint.

The subsites that are closest to Moneypoint are: OH507 (Cappagh / Hog Island), OH 521-4 (Clonderalaw Bay), OI425 (Tarbert Island) and OK 509 (Reenturk / Knockbrack). These subsites vary in importance to waders / waterfowl populations as shown on the dot density diagrams. For example, OH507 which is the closest monitored subsite to Moneypoint exhibits a very low usage for waterfowl/waders either for foraging or roosting (almost zero usage), whereas a subsite in Clonderalaw Bay (OH 522), a few kilometres to the east of Moneypoint, shows hundreds of birds roosting at times and at OK 509 (Reenturk on the Kerry side of the estuary) thousands of birds were recorded roosting. Foraging activity at these sites will vary also throughout the tidal cycle with some sites being more important than others.

This SPA is designated for wetlands and 21 water bird species. There are no wetlands within the proposed development site at Moneypoint and there will be no impact to this habitat type as a result of the development. For this reason wetlands are not considered further in this report.

However, there is the potential for impact on avifauna utilising the SPA. The assessment of this impact is investigated below with cognisance to both the conservation objectives of the site (and its supporting documentation outlined above) and the site-specific scientific studies carried out Moneypoint in recent years (see below for summary of these findings).

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4.5.2.1 Potential Impact on Avifauna

The River Shannon and River Fergus Estuaries SPA is an internationally important site on account of the numbers of wintering birds it supports. It also supports internationally important numbers of three species, i.e. Dunlin, Black- tailed Godwit and Redshank. In addition, there are 16 species that have populations of national importance. As this SPA borders the south and west boundaries of the proposed development site at Moneypoint, there is the potential for direct and/or indirect effects on birds as they move within the SPA. The main potential impact on birds is likely to result from disturbance / displacement during the construction phase and collision risk during the operation phase.

A number of scientific reports (including site-specific avifaunal reports listed in Section 2.1 and presented in Appendices IV and V, and related publications listed on www.npws.ie) have been reviewed to assess the level of potential impact on individual species/habitats of qualifying interest within the SPA and SAC. What follows is a summary of the most relevant findings of the available scientific research.

2001 Survey:

Bird counts and observations were carried out on the Moneypoint site over eight days in November and early December 2001. Significant movements of waterfowl within the Shannon Estuary were found to occur well clear of the Moneypoint site, with birds predominantly flying east-west in the middle of the estuary. Waterfowl using Clonderalaw Bay were not observed to move further west than Killimer Bay / Lynch’s Point on survey days. Flightlines out of Poulnasherry Bay were mostly in a north-south direction. Small numbers of waterfowl were recorded in the immediate vicinity of Moneypoint, with bird use centred on Ballymacrinan Bay. No species occurred in nationally important numbers in the immediate vicinity of Moneypoint during the survey period, with numbers at most being at 10% of the 1% national level. Species recorded regularly as feeding within or flying through the site were Cormorant, Grey Heron, Snipe, Curlew and Gulls. Lapwing moved between Ballymacrinan Bay and wet fields to the north.

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2010/2011 Vantage Point Surveys:

Vantage point surveys were carried out in spring, autumn and winter of 2010/2011 with all methodologies following current best practice. Three vantage points were employed for the site during each survey with two watches of three hours duration carried out at each vantage point. A total of 11, 12 and 19 species were recorded during spring, autumn and winter respectively. One species of qualifying interest of the SPA was recorded in or near the Moneypoint site during the spring survey. A Cormorant was recorded twice off-site, flying low over the shores by Moneypoint Power Station. Cormorant is a water bird species and was recorded off-site on both occasions, offshore from the generating station.

During the autumn vantage point surveys only two species of qualifying interest were recorded, the black-headed gull and the cormorant. The black- headed gull was recorded on eight occasions with most sightings of single birds, except on three occasions with flocks of 10, 17 and 30 birds. The average flying time for this species was 78 seconds, the majority of which (87.5%) was between 10-100m flight height (the remainder being less than 10m). Of these eight sightings, two sightings of lone birds were recorded within the zone of influence of the proposed development site (one near Poulnadarree and one near Carrowdotia South). All other sightings, including all recordings of flocks of more than one bird, were recorded either at Ballymacrinan or Ballymacrinan Bay.

There were just two sightings of cormorants during vantage point watches in autumn, one at the southeastern point of the Moneypoint coastline (n=14 birds) and one off the coast in Ballymacrinan Bay (n=1 bird). It is clear that cormorants frequently fish off the southeast coast of Moneypoint, offshore from the proposed development site.

Most sightings of birds during vantage point surveys were concentrated between Ballymacrinan Bay and Clooneylissaun in the western section of the site.

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Of the 19 species that were recorded during the Winter 2010/2011 vantage point survey, four were listed as qualifying interests of the SPA. These included cormorant, lapwing, curlew and black-headed gull. Lapwing was the most frequently recorded (n=13), followed by curlew and black-headed gull (both n=9) and finally cormorant (n=5). Overall flight duration was highest for the black-headed gull. Most lapwing movements involved frequent but short localised flights. Both wildfowl and gulls were found to predominantly use height band 10-100m. Distribution of recorded flight lines was primarily in two distinct areas, the area south of Killimer village between VP1 and the coast and also the area north of Ballymacrinan Bay. The majority of wildfowl flight lines were either birds moving along the coast (such as Cormorant), visible from VP1, or birds moving between fields and/or Ballymacrinan Bay at the western part of the site. Many of these movements were brief, as species such as lapwing and curlew were often disturbed from foraging in fields due to agricultural activity.

2010/2011 I-WeBS Surveys:

An autumn and winter wetland bird survey following methodologies employed on I-WeBS surveys was carried out in August / September 2010 and November – February 2010/2011, with the exact methodology employed being a ‘look-see’ method (Bibby et al, 1992 in Crowe 2005). This involves recording the number of individuals of a number of waterbird species on visits to predefined wetland sites (Crowe 2005). In this instance the pre-defined sites were Lynch’s Point to Killimer (Section A), Killimer to Moneypoint (Section B) and Moneypoint to Ballymacrinan Bay (Section C) (see Figure 1 Appendix V).

A total of 19 species was recorded during autumn surveys, including 10 species of qualifying interest; mute swan, cormorant, black-headed gull, curlew, greenshank, redshank, dunlin, ringed plover, teal and lapwing. The lowest number of species (4) was recorded in Section B (Killimer to Moneypoint). Black headed gull was the most abundant species (n=49) with 48 birds recorded in Section A. Ringed plover was also in relative high abundance and only seen in Section C. Cormorant was the most abundant

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species in Section B. The flight line maps indicate that the western area around Ballymacrinan Bay and north to Clooneylissaun has the greatest bird activity within the site, followed by the central area from Killimer to Moneypoint. Flight heights of all species recorded were within 100 m. Results from the I-WeBS survey indicated that Lynch’s Point to Killimer (Section A) is an important site for black headed gulls (48). Moneypoint to Ballymacrinan Bay (Section C) also held good numbers of wading birds and gulls.

A total of 27 species was recorded during winter surveys, including 12 species of qualifying interest; mute swan, cormorant, black-headed gull, curlew, greenshank, redshank, dunlin, ringed plover, teal, lapwing, wigeon and shelduck. The primary areas of usage were Section A, from Lynch’s Point to Killimer and Section C, which included Ballymacrinan Bay. Total Wildfowl peaked in January with a maximum of 265 birds recorded on January 27. This total was comprised of birds from 17 different species. Lapwing and Curlew were a large component of the birds recorded in January (n=31, 85 respectively), in addition a casual count of 150 Lapwing and 80 Curlew was also recorded in January making these two species the most abundant overall during the mid winter period. Many of these birds were recorded foraging in fields proximal to the coast during vantage point effort.

Areas primarily used by wildfowl included Killimer Quay (east of the subject site), Ballymacrinan Bay and also the fields immediately north of Ballymacrinan Bay, which were used by foraging gulls and waders such as Curlew and Lapwing. Overall numbers were still relatively low within the context of the subject site and its proximity to the SPA. Waders were recorded in low numbers, with most only recorded on two out of four months (November and January). Two mute swans were recorded in the month of November only. No further sightings of this species were made.

4.5.2.2 Potential Impacts based on Results of Scientific Research

The main species of interest found to utilise the area around the site during winter months include cormorant, curlew, lapwing and black-headed gulls. Areas primarily used by wildfowl included Killimer Quay (east of the subject site), Ballymacrinan Bay and also the fields immediately north of

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Ballymacrinan Bay, which were used by foraging gulls and waders such as curlew and lapwing. Overall numbers were still relatively low within the context of the subject site and its proximity to the SPA.

The majority of wintering wildfowl and waders, which utilise the Ballymacrinan Bay area and coastal zone immediately south of the power station, are unlikely to be affected by the proposed development. Many of these species, such as cormorant, greenshank, redshank, dunlin, ringed plover, teal, wigeon and shelduck, are tied to specific tidal habitats where no turbines are proposed and therefore the impact on these species is considered insignificant. Mute swan were recorded in very low numbers in one month only. The low density of this species significantly reduces potential impact from the development.

Cormorants are present along the coast of Moneypoint. These piscivorous birds spend most of their time over water or perched on rocky outcrops along the coast. While they may be disturbed or displaced during the construction phase of the development, there is unlikely to be any residual impact to this species in the long term. Any displacement is not likely to be significant as there is ample available fishing habitat within the estuary.

Impacts are expected to arise principally from disturbance from the presence of the turbine structures, rather than from collision. This is due to factors such as flight height, flocking behaviour, diurnal/nocturnal activity of these species and dependence on specific feeding habitats e.g. tidal zones. Some alteration to flight lines and feeding areas may occur for cormorant, lapwing and curlew in the short and medium term as a result of the development. None of these species is expected to be permanently displaced from the immediate locality of Moneypoint and will continue to use the site as they become habituated to new structures, in the way that existing power station structures are accommodated in the existing patterns of use by birds in the area. The proposed development will have no impact on available foraging habitat or prey species for waterfowl or waders.

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One species particularly sensitive to wind farm proximity is curlew, when breeding in upland areas (Pearce-Higgins et al. 2009). Curlew can be affected by displacement particularly during the breeding season. However no breeding was recorded within the site boundary nor are there any historical records for breeding curlew proximal to the site. Curlews were recorded on site feeding in the ash storage area, upon which one turbine is planned. It is believed that any displacement from foraging areas for this species can be adequately compensated for within the surrounding hinterland e.g. the fields to the north of Ballymacrinan Bay. The local and migratory populations of the avifauna in the area will not be adversely affected by this development. None of the aforementioned species depends on this site exclusively.

From the data compiled at Moneypoint through autumn/winter surveying it is quite clear that there are no large aggregations of wintering wildfowl roosting at, or proximal to, the site. More importantly there are no large movements of birds at high tide using Moneypoint as a transit route to travel to roosting grounds elsewhere along the coast.

The River Shannon and River Fergus Estuaries is designated an SPA and it is of International ecological importance (A rated). As the main qualifying interests of the SPA which were found to frequent the proposed development site are not particularly sensitive to collision risk, the main potential impact on these species is disturbance/displacement. Birds become habituated to permanent structures over time, as is the case with the existing power plant and its stacks. As the numbers of birds found to utilise the area surrounding Moneypoint were found to be below nationally important numbers, the long- term impact on birds as a result of this wind farm, adjacent to a small area of the SPA, is considered a Moderate Negative impact on avifauna within the SPA (NRA, 2004) (the SPA site itself will remain unaffected as works are located outside the boundary of the SPA).

Potential Cumulative Impact

There are no other projects currently proposed or planned in the locality of the proposed Moneypoint wind farm which could give rise to any in-combination

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impacts. The nine turbine development permitted at Moneypoint in 2002 (PL. 03.130164) has not been built. This current application for a five turbine wind farm on the same site is proposed in substitution of the approved nine turbine wind farm. It is not intended that the approved development and the current proposal both be developed. Thus, in-combination impacts between this proposed development (Pl. Ref 12/74) and PL. 03.130164 will never occur.

It is not expected that there will be any in-combination effect from this development and the future projects of the Clare Council Planning Department Development Plan 2011-2017. The proposed development is in line with Objectives CDP 14.4, CDP 14.5 and 17.3 of the Clare County Development Plan (Section 3).

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5 STAGE 2: APPROPRIATE ASSESSMENT

Each individual qualifying interest of the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries SPA was investigated in terms of its presence, abundance and/or movements within the vicinity of the proposed development site at Moneypoint Power Station, and in terms of the construction works proposed. Following in depth assessment of the evidence- based scientific material (see Section 4) it has been found that will be no impact on protected habitats, plants or otters as a result of this project, alone or in combination with other projects.

Following a full review of all available evidence-based scientific research on species within these designated sites, it has been found that there is the potential for Major Negative impacts on bottlenose dolphin utilising the SAC and Moderate Negative impacts on avifauna within the SPA. In the absence of appropriate mitigation measures the impact on bottlenose dolphins would be significant. Where there are adverse impacts on a Natura 2000 site, an assessment of the potential mitigation of those impacts should be carried out. This Screening Assessment must therefore proceed to a Stage 2 Appropriate Assessment. Both general and species-specific mitigation measures are presented in this section. The significance of impacts to dolphins and avifauna are then reassessed in light of the mitigation measures proposed.

5.1 Mitigation Measures

Mitigation is required where significant negative impacts are likely to occur. The IEEM guidelines state that an impact is significant if it is ‘major negative’ or greater (IEEM, 2006). Mitigation measures have been devised and included herein in order minimise the scale of impacts affecting the qualifying interests of the Lower River Shannon SAC and River Shannon and River Fergus Estuaries SPA adjacent to Moneypoint Power Station. These measures will be adhered to during the construction, operation and decommissioning of the proposed five turbine wind farm at Moneypoint.

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5.1.1 Mitigation by Avoidance

A process of ‘mitigation by avoidance’ was undertaken by the EIA team during the design layout of Moneypoint Wind Farm. The existing approved road network has been utilised to the full extent with no requirement for additional tracks to be built. The turbine layout has been confined to accessible areas of low ecological value to reduce the overall impact through habitat loss or damage.

5.1.2 General Mitigation  A site-specific Construction Environmental Management Plan shall be prepared in advance of works. All construction personnel shall be informed of the sensitive nature of the SAC and SPA in the surrounding area.  Construction works will be conducted during daylight hours only to minimise disturbance to nocturnal mammals.  A site walkover will be undertaken over the footprint of the development prior to construction at an appropriate time of year by a suitable qualified ecologist. This will ensure any wildlife refuges may be located and managed according to the NRA guidelines prior to site clearance.  No disturbance to habitats or flora outside the required construction footprint will occur.  Traffic speed will be limited within the existing restrictions applying on site to avoid injuring mammals that may cross the roads.  All construction materials and equipment will be removed from site post works.  Office and toilet facilities for use during the construction period are already available at the Moneypoint site and no additional temporary facilities will be provided.  No fuel storage tanks will be stored within 50m of the SAC, and refuelling and machine repair/maintenance will not occur within 50m of the SAC.  The on-site ecologist will have a ‘stop works’ authority throughout the construction process.

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5.1.3 Mitigation Measures for Bottlenose Dolphins

Depending on the methodology employed, sound pressure waves from piling may travel and enter the SAC marine environment. This may result in a Major Negative impact on bottlenose dolphins within a small are of the estuary (NRS, 2004).

Piling involves three separate construction methods, namely rotary drilling bored piling place, high frequency vibration driving and impact pile driving. Separate noise levels are associated with each method, with the lowest noise levels being associated with rotary drilling and the worst case being impact pile driving. The choice of technology is site dependent.

Turbine T4 at Moneypoint is located on an area that was recovered from the estuary by placing rockfill material during the site development works phase of the power station construction. The piles will be drilled through the rockfill material, as it would not be possible to drive piles through this fill material. The piles will be founded on natural ground. Bedrock is relatively shallow at this part of the site and it is anticipated that the piles will be founded on rock. The depth, diameter and number of piles will be determined during the detailed structural design.

The proposed method of piling is the method with the least potential for generating sound pressure waves. Nonetheless, potential impacts were assessed on the basis of a worst-case scenario where impact pile driving is used.

From the data available a noise prediction for peak exposure and Sound Exposure Level (SEL) was carried out to determine at what distance recognised criteria would be exceeded (see Appendix VII for Report on Underwater Noise Attenuation Trials at Moneypoint).

Damage Criteria: Due to the significant attenuation effect from piling on land as opposed to piling in the water column, the damage criteria are not exceeded at any distance. This means that marine animals (the most likely species being bottlenose dolphin, but all marine species have been catered

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for) are not subject to risk of hearing or other physical damage due to the proposed piling activity.

Disturbance Criteria: The disturbance criteria adopted are conservative and based on studies that include remote populations of animals. In Irish inshore waters, as with inshore waters in any industrialised country, underwater noise levels are higher than those prevailing in the open ocean and in remote areas, and marine animal populations are more accustomed to shipping and other anthropogenic noise sources. It is well documented that pinnipeds and lone bottlenose dolphins frequent busy ports. The resident population of bottlenose dolphins in the Shannon Estuary is regarded as relatively stable (Berrow et al., 2010), in spite of years of industrial development and increasing shipping traffic in the area. The threshold values for disturbance, which were taken at the upper level of the band, were not exceeded and no marine species is at risk. This applies to both peak exposure and SEL exposure levels. For disturbance pinnipeds represent the worst case with disturbance out to 64 m, mid-frequency cetaceans (bottlenose dolphins) are potentially disturbed out to 32 m and fish out to 8m.

The noise predictions show that, on the basis of very conservative assumptions regarding the method of piling to be used and conservative thresholds, there is no risk of physical harm to marine species from underwater noise resulting from the proposed piling operation.

In order to minimise disturbance the following mitigation measures are proposed:  A qualified and experienced marine mammal observer (MMO), independent of the piling contractor, shall be appointed to monitor for marine mammals and to log all relevant events using standardised data forms.  Underwater noise levels shall be measured during the course of piling activity, including the ‘ramp-up’ procedure. Monitoring shall be carried out independently from the piling contractor and the results reported to the Department of Arts, Heritage and the Gaeltacht.

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 The MMO shall advise the Works Superintendent with a previously agreed timeframe prior to scheduled activity if environmental conditions, e.g. sea state, light, visibility, are insufficient for effective visual monitoring. In such conditions, the activity of concern shall be postponed until acceptable conditions prevail.  In the event of suitable environmental conditions, a clear on-site communication signal shall be agreed between the MMO and the Works Superintendent as to whether the relevant activity may or may not proceed, or resume following a break (see below). Piling shall only proceed on positive confirmation with the MMO, which must be recorded by the MMO.  The MMO shall conduct pre-start-up constant effort at least 30 minutes before the sound-producing activity is due to commence, continuing monitoring during and for 30 minutes following the activity. Sound- producing activity shall not commence until at least 30 minutes have elapsed with no marine mammal detections by the on-site MMO.  Operations shall not commence if marine mammals are detected within a 200m radial distance of the intended sound source, i.e. within the Monitored Zone. This restriction also applies to any ramp-up procedure where the maximum sound output has not yet been attained.  Once begun, the activity may continue if weather conditions deteriorate or if marine mammals enter the 200m-radius Monitored Zone following start-up. If there is a break in pile striking activity for a period greater than 30 minutes then all pre-piling monitoring measures and ramp-up (where this is possible) shall recommence as for start-up.  Full reporting on MMO operations and mitigation undertaken should be provided to the Department of Arts, Heritage and the Gaeltacht to facilitate reporting under Article 17 of the EU Habitats Directive and future improvements to guidance.

Following the application of all mitigation measures outlined above, critical areas will be conserved without any restriction of species range within the site. Noise levels will be restricted to reduce disturbance and continuous monitoring will ensure impact to dolphins is kept to a minimum.

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Given the mobile nature of these mammals, the short duration involved in the construction of turbine T4 and the existence of suitable habitat in the surrounding estuary, any disturbance/displacement of bottlenose dolphins as a result of the construction of the wind farm is considered minor negative following mitigation measures outlined above.

5.1.4 Mitigation Measures for Avifauna

To minimise the impact of the proposed development on the avifaunal population utilising the site, including those qualifying interests of the nearby SPA, the following measures are proposed.  There will be no removal of vegetation such as hedgerows and treelines.  Construction works for the turbines should take place outside the winter months (November to February inclusive) where possible.  The highest turbine within the site will be lit according to Irish Aviation Authority guidance.  Underground cables will be used to connect turbines to the substation.  Corpse searches should be carried out in the first five years of operation during winter months to assess the collision risk impact to wintering wildfowl. A protocol for these corpse searches should be agreed prior to survey works with NPWS.

The numbers of waterfowl potentially affected at Moneypoint are small relative to the extent of the SPA. No works will take place within the SPA itself. Very small numbers of some species do utilise the Moneypoint site for foraging during the winter. Given the mitigation measures outlined above, the highly mobile nature of these species, and the availability of suitable foraging habitat in the surrounding area, the overall predicted impact on avifauna is assessed as minor negative.

5.2 Residual Impacts

The residual impact may be defined as the potential impact remaining after mitigation measures have been adopted into a project. Generally, a proposed development adequately considers the ecological issues in its design, so that

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its impacts on the existing environment are minimised to an acceptable level of slight residual impacts. Occasionally, where significant impacts cannot be avoided or reduced, the consequences of significant residual impacts in light of planning policies and legislation should be considered (IEEM, 2006). Significant residual environmental effects may be offset by appropriate compensatory measures nearby/elsewhere (IEEM, 2006). Table 7 presents the overall predicted impact post-mitigation as well as any long-term residual impact.

Table 7: Significance of Residual Impacts

Environmental Potential Impact Potential Potential Significance Impact Impact of Residual Element Significance Significance Impact Pre- Post- Mitigation Mitigation

Major Minor Bottlenose Dolphins None Negative Negative Lower Shannon

Estuary SAC

Cumulative Impacts None None None

Moderate Minor Avifauna None River Shannon & Negative Negative River Fergus Estuaries SPA Cumulative Impact None None None

No Significant Overall Significance of Residual Impacts on SAC and SPA Residual Impact * The IEEM guidelines state that an impact is significant if it is ‘major negative’ or greater (IEEM, 2006).

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6 CONCLUSION

A Stage 1 and Stage 2 Appropriate Assessment have been carried out for a proposed five turbine wind farm at Moneypoint Power Station to replace the nine turbine wind farm previously granted but not built. The Stage 1 Screening Assessment found that potential adverse impacts on qualifying interests of Natura 2000 sites – Lower River Shannon SAC and River Shannon and River Fergus Estuaries SPA were likely. In response to this a Stage 2 Appropriate Assessment was carried out, which considered the impact of the project on the integrity of the two Natura 2000 sites, either alone or in combination with other projects or plans, with respect to the site’s structure and function and its conservation objectives. This Stage 2 Appropriate Assessment was completed with a full review of all scientific evidence available (both published and unpublished) and taking full cognizance of the conservation objectives of the SPA and SAC. Potential impacts of the proposed project were highlighted and mitigation measures were proposed, where relevant.

Following appropriate mitigation measures regarding bottlenose dolphins and wintering wildfowl, it has been assessed that there will be no significant or residual impact to either the SAC or the SPA as a result of the proposed five turbine development.

There are no other projects currently proposed or planned in the locality of the proposed Moneypoint wind farm which could give rise to any in-combination impacts. The nine turbine development permitted at Moneypoint in 2002 (PL. 03.130164) has not been built and this application for a five turbine wind farm on the same site is proposed to substitute the approved nine turbine wind farm. Thus, there will be no in-combination impacts.

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Fossitt, J.A. (2000). A Guide to The Habitats of Ireland. The Heritage Council, Kilkenny.

Hayden, T. and Harrington, R. (2002). Exploring Irish Mammals. Town House, Dublin.

IEEM (2002). Guidelines for Ecological Evaluation and Assessment. Draft Report. Institute of Ecological and Environmental Management.

JNCC (1993). Handbook for Phase 1 Habitat Survey. Joint Nature Conservation Committee, Peterborough.

Montes M.R. and Jaque Barrios (1995) [ Effects of wind turbine power plants on the avifauna in the Campo de Gibraltor Region]. Spanish Ornithological Society.

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Percival, S.M. (2005) Birds and windfarms: what are the real issues? British Birds 98 April 2005 pp194-204

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Pierce-Higgins, J.W., Leigh, S., Langston, R.H.W., Bainbridge, I.P., Bullman, R. (2009). The distribution of breeding birds around upland wind farms. Journal of Applied Ecology. 46, 1323-1331.

Richardson, W.J., Greene Jr., C.R., and Malme, C.I. (1995). Marine Mammals and Noise. Acedemic Press, San Diego.

Rogan, E., Ingram, S., Holmes, B., and O’Flanagan, C. (2000). A Survey of Bottlenose Dolphins in the Shannon Estuary. Coastal Resources Centre, Dept. of Zoology and Animal Ecology, University College Cork.

Scannell, M.J.P., and D. M. Synnott (1987). Census catalogue of the flora of Ireland. Stationery Office, Dublin.

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Strickland M.D.; Wallace, P.E.; Kronner K. and Orloff S. 1999. Effects of Bird Deterrent Methods Applied to Wind Turbines at the CARES Wind Power Site in Washington State. Western EcoSystems Tech. Inc. pp1.