Dixon Brosnan

environmental consultants

IC 7 .

Projm Ecology minaReport (NISI resm to an expnrlon ofthe Mctiale Engineering LM. mianukturlng fpdltty at kllinrok, .

Client 0' Waghan Momn

I- I I

DmBmsnan The Cedars, Brldewmd, Ovens, CO Cork TelO86 851 14371 m4@dhonbrosnanm I mmrv.dmonbman.com

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

EPA Export 03-03-2014:23:31:34 1. Background

According to the EU Birds Directive (79/409/EEC) and Habitats Directive (92/43/EEC), member states are required to designate areas in order to protect priority habitats and species. These sites are known as Special Protection Areas (SPA) and Special Areas of Conservation (SAC) respectively. Collectively, these sites are known as Natura 2000 sites. An "appropriate assessment" (AA) means an assessment, based on best scientific knowledge, of the potential impacts of a plan or project on the consewation objectives of any Natura 2000 site and the development where necessary of measures to preclude negative effects. The impact assessment must include the indirect and cumulative impacts of approving the plan considered, with any current or proposed activities, development or policies impacting on the site. All plans and projects should aim to identify any possible impacts early in the plan-making process and then either alter the plan to avoid them or introduce mitigation measures to the point where no adverse impacts remain.

An appropriate assessment is an assessment carried out under Article 6(3) and 6(4) of the Habitats Directive.

Article 6(3) of the Habitats Directive states: Any plan or project not directly connected with or neczssary io the manugement of the site but likely to have a sign@cunt effect thereon, either individually or in combination with other pions or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's For inspection purposes only. Consent of copyright owner required for any other use. conservation objectiwes. In the light of the conclusions of the assessment of the implicutims for the site and subjec&to the provisions of parograph 4, the competent nationd authorities $ha//agree tu the plan or project only after hoving ascertained that it will not adversely affect the integray of the site concerned and, if appropriate, after having obtained the opinion of the generul public.

Article 6(4) states: ,fi in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, Q p15n or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of social or economic nature, the Member Srute shall take all compensatory measures necessary to ensure that the owrall coherence of Nutura 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 sofefy, to beneficial consequences of primary

EPA Export 03-03-2014:23:31:34 impwtance for the environment w, further to an opinion from the Commission, to other Imperatk reasons of overriding public interest.

2. Methodology for appropriate asssssment This assessment follows the methodology guidelines outlined in the publication Hksessment of plans and projects significantly affecting Natura 2000 sltes, methodological guidance on the provisions of Articles 6(3) and 6(4) of the Habitats Directive 92/43/EEC" (2001). This ecological assessment was carried out by Carl Dixon MSc. Applied Ecology, Vincent Murphy Mk Ecosystem Consewation & Landscape Management and tan McDermott MSc Ecological Assessment.

These assessments are uswlly dealt with in a step by step process. Steps one and tHK)are described

Stage 1. Screening Screening is the technique applied to determine whether a particular plan would be likely to have significant effects on a Natura 2000 site and would thus warrant an Appropriate Assessment. The key indicator that will determine if an Appropriate Assessment is required is the determination of whether the development is likely to have signflcant enwirunmentd on a Natura 2000 site or not.

Stage 2. Appropriate Assessment For inspection purposes only. Consent of copyright owner required for any other use. This step is required if the screening report indicates that the development is likely to have a significant impam on a Natura Zoo0 site. The AA considers the potential impact of the plan or 0 project on the integrity on Natura 2000 sites, either alone or in combination with other projects, with respect to the site's structure, function and conservation objectives. Where there are adverse impacts, an assessment of the potential mitigation of these impacts in also required.

3. Screening of propwed development 3.1 Proposed development The existing facility was purpose built in 1997 and is located approximately lkm northwest of Ballinrobe on the N84. The site covers an area of approximately 13.Sha, with one large building (10,mm2) housing offices, fabrication areas, assembly lines, paint spray area and bunded paint stores. There are a number of smaller buildings that are used for Research & Development (R&D)

EPA Export 03-03-2014:23:31:34 and paint storage, and an extensive paved open storage yard. Mctlale has operated the ufacturing plant for more than 15 years and currently employs 190 workers at the facility.

It is proposed to increase production at the plant and this will involve the construction of a 18,000m' extension, to the south of the existing main building, to house the manufacturing lines and the introduction of a new painting process. This will require planning permission from Mayo County Council and an Industrial Emissions Directive (IED) License from the Environmental Protection Agency (EPA).

using organic solvent based paints and assembly. The paints are applied in spray booths using electrostatic guns. The manufacturing process will remain generally the same, however it is proposed to introduce a new water based paint process to replace the solvent based paints. Electrophoresis (Eaating) using water based paints is proposed as it is considered a viable alternative to the application of organic solvent based paints.

An air assessment based on the EPA's ambient air quality databases and detailed emission dispersion modelling was conducted by Odour Monitoring (OMI) Ltd. The air modelling shows that the maximum predicted ground level concentration (GLC) of emissions are well within their air quality limit values. The modelling indicates that the operation of the facility will have an imperceptible impact on air qu For inspection purposes only. Consent of copyright owner required for any other use.

The principles of Sustainable Drainage Systems {SUDS) were applied in the design of the extension. Rainwater run-off from the roof of the extension will be collected and diverted to a rainwater harvesting system for use as 'grey water' in the welfare facilities and the E-Coating plant. Surplus water will be discharged to ground via new soakaways and there will be no direct discharge to surface waters. A new surface water drainage system, will be instalted to collect rainwater run-off from the new paved areas. The run-off will pass through art attenuation tanwsilt trap and 2 No Class 1011 Interceptors before discharging to a percolation area.

The design of the percolation are took into consideration the requirements of the Guidance on the Authorisation of Dixharges to Groundwater, issued by the €PA. It is predicted that the impact on ground and groundwater will be imperceptible

EPA Export 03-03-2014:23:31:34 Sewage will be discharged to the local authority sewer.

3.2OesignatedConsurvationAreao The proposed development will not directly impact on any designated Natura 2000 sites i.e. Special Area of Conservation (SAC/cSAC) or Special Protected Area (SPA/pSPA) or on any Natural Heritage Area (NHA), Statutory Nature Reserve or National Park. Natura 2000 within lOkm of the proposed development are listed below in Table 1 and are shown on Fig. 1. Given the limited nature of the proposed works the relevant Natura 2000 sites, for the purposes of this report, are the Lough Cam/ Mask Complex SAC 001774, SPA 004062 and Lough Cam SPA 004051 (lmted 1.9km, 2.6km and 2.4km respectively from the proposed development site). No theoretical impact on the remaining Natura 2000 sites have been identified. No impact on the closest pNHA (Lough Carra/ Mask Complex 001774, lomted 1.9km away) has been identified. Site synopses for retevant Natura 2000 sites are included in Appendix 1.

fable 1. Pmtected &as within iSkm ofp.oposad sias.

I --=

Lough Cam/ Mask complex 001774 1.9km W Kllglassan / Caherawostia turlough complex O005011 8.4km E Skealoghan turlough I000541 6.5km SE Ardkill turlough I 000461 9.6km SE For inspection purposes only. Clyard kettle holes Consent of copyright000480 owner required for any other use. 6.6km SE

Kildun souterrain 002320 8.8km 5 .. Moor hall (Lough Cam) I 000527 9.0km N Carrowkeel Turlough I ow75 Ukm NE Lough Corrlb I 4wz llkm s Mocorha Lough 1536 11.5km SE Shrule furlough l3km SE SPAand pSPA I LoughMask 2.6km W I oo4062 I I Lough Carra ow051 2.4km N 4042 llkm s pNHA I Lou& Cam/ Mask wmplex I 001774 I 1.91tm w I I Moor hall (Lough Carra) I 000527 I9.0kmN I I LoughManan I 001533 I9.0krnN I

EPA Export 03-03-2014:23:31:34 Kilgfassan / Caheravoostia turlough complex 0oO504 8.4km E Skealoghan turlough 000541 6.5km SE Ardkill turlough OOO461 9.6km SE ward kettle holes 000480 6.6km SSE

Figure 1. Development site in relation to protected am.

3.3 Natura 2000 sites - Features of Meres& and c#servatIon objectheS. The overall aim of the Habitats Dlreaive For is inspectionto maintain purposes or only. restore the favourable conservation status Consent of copyright owner required for any other use.

of habitats and species of community interest. These habitats and species are listed in the Habitats and Birds Directives and Special Areas of Consenratfon and Special Protection Areas are designated to afford protection to the most vulnerable of them. I 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. The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable consenration status of those habitats and species at a national level.

Favourable conservation status of a habitat is achievd when:

EPA Export 03-03-2014:23:31:34 its natural range, and the area it covers within that range, are stable or increasing; 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; 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 la ns on a long-term basis.

0 3.3.1 Lwgh Cam/Mask Complex SAC 001774 Features of Interest: lesser horseshoe bat (Rhinolophus hipposideros) [1M3] Otter (f utro Iutru) [1355] Shining sickle moss (Drepanocludusuernicosus) [1393] Oligotrophic waters containing very few minerals of sandy plains (Littorelletah uniforroe) [3110] Hard oligo-mesotrophic waters with benthic vegetation of Chum spp. [3140] European dry heaths [a301 For inspection purposes only. Consent of copyright owner required for any other use. Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco Brometdio)(*importantorchid sites) [6210] 0 Calcareous fens with Cladium mariscus and species of the Caricion davollianae 172101 Alkaline fens [7230] Limestone pavements [824OJ Alluvial forests with Ahus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91EO]

Conservation obiectiw: To maintain or restore the favourable conservation condition of the Annex 1 habitat(s) and/or the Annex II species for which the SAC has been selected: [1303 J Rhindophus hipposideros [1355] Lutra lutru

EPA Export 03-03-2014:23:31:34 .,,--,I.- - , . ~ . ,. ,. .- ... . .,. ' , , - ..'-. . ,. .- ,...... I , ,. .. - .\ ,. ..

. ^. (13931 Drepumc~adus(Hamatmulis) vernlcosus a [3110] Oligotrophk waters containing very few minerals of sandy plains (Ltttorelletdiu uniforue) I31401 Hard oligo-mesotrophic waters with benthic vegetation of thoro spp. I40301 European dry heaths [6210] Semi-natural dry grasslands and scrubland fades on calcareous substrates (Festuco Brometdio)(* important orchid sites) [7210] Calcareous fens with Cladium rnuriscus and species of the Curicion dmdliunae

[7230] Alkaline fens r': ' ,, -- (82401 Limestone pavements [91EO]* Alluvial forests with Alnus glutinma and Fraxfnus excelsior (Alno-Pudion, Alnlan incanm, Sakion alboe)

3.3.2 Lough Mask SPA OOW62 Features of lnterest Tufted Duck (Aythyofuligulo) IAO61l Black-headed Gull (Chroicocephulus ridibundus) (A1791

a Common Gull (Lorus conus) [A1821 Lesser Black-backed Gull (La~sfuscus)(A1831 Common Tern (Stemuhirundo) (A1931

Greenland White-fronted Goose For(Anser inspection ulbifronrfiauirostris) purposes only. IA3951 Consent of copyright owner required for any other use.

Wetlands & Waterbirds [ASSS] gonsewation objective: To maintain or restore the favourable conservation condition of the bird species listed as Special Consewation Interests for this SPA: Aflhya fu/igu/a[wintering] Chroicocephalus ridibundus (breeding] Lurus tunus [breeding) Lurusfuscus (breeding]

>. Stemu hirundo [breeding] <:

0 Anser crlbifrons flawirostris [wintering]

0 Wetlands

EPA Export 03-03-2014:23:31:34 3.3.3 Lough Cam SPA 004051 Features of Interest

0 Common Gull (Lorus canus) (A1821

gonserwrtion objectiwe: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA: larus canus [breeding]

4. Site descrlption 0 A field survey was carried out in July 2013 to Identify, map and evaluate habitats. The surveys covered the entirety of the site and its surrounding environs. Habitats were classified according to the classification scheme outlined in the Heritage Council publication A guide to hubituts in Iretund (Fossitt, 2000). The habitats recorded during site suweys are shown below on Fig. 2. The habitats to be affected by site works are generally common and unlikely to support rare or protected species. There are no surface water habitats in immediate proximity to the site. The Robe river is located approximately 350 meters to the south of the land ownership boundary and Lough Mask is located approximately 2.6km west at its closest point.

BUBuilt land and arttfidal surfaces

For inspection purposes only. WS1 Scrub Consent of copyright owner required for any other use.

GAl lmprwed qgrlcuttural grassland

e GAl Improved agricultural grassland/WSl Scrub GA2 Amenlty grassland 1 EDZSpdlandhareground

a' BaFlower beds and Mers WUHedgerow/ WUTreeline

EPA Export 03-03-2014:23:31:34 A

UIC4 prowcr bed$ and borders

d ,02 Spoil and bare ground A

Figure 2. Habitat map.

5. Potentlal Impam

For inspection purposes only. The potential for significant adverseConsent impacts of copyright ownerdesignated required for Naturaany other use. 2000 sites is vety low. Due to the on distance to the closest designated Natura 2000 site no impacts from noise or disturbance will occur. There will be no direct impact on designated habitatI and no species listed as species listed a qualifying interests for designated sites will utilise the habitats directly affected.

Theoretically, atthough unlikely, impacts could arise due to severe contamination of grounawater due to inadvertent leaks of hydrocattans or other chemicals during construction or operation of the facility. If of sufficient severity, groundwater pollution could impact on designated aquatic species and habitats listed as qualifying interests for the Lough Cam/Mask Complex SAC 001774 (i.e. Shining sickle moss (Dreponocladus uernlcosus) [1393], Oligotrophic waters containing very few minerals of sandy plains (Llttorelletdiu uniflorue) I31101 and Hard oligo-mesotrophic waters with oenthic vegetation of Cham spp. [3140]). In theory, although highly unlikely, severe impacts on water quality could impact on fish populations which provide prey for otter (qualifying interest for

EPA Export 03-03-2014:23:31:34 the Lough Carra/Mask Complex SAC) and piscivorous birds such as common tern (qualifying interest for the Lough Mask SPA -2).

Poor construction practices could allow the invastve species Japanese Knotweed to spread and in theory this could result In adverse impacts on designated sites.

6. Potentlal cumulatiw impacts It is considered probable that this project will have a significant impact on Natura 2000 sites and thus no significant cumulative impacts are considered likely.

The Ballinrobe Local Area Plan 201G2016 notes that Ballinrobe town Is currently the largest urban area in South Mayo and is an important sewice town for the wide agricultural hinterland of South 0 Mayo. Industries include a large meat plant geared towards exports (Jennings), a significant road construction company (Maddens), a number of small construction companies and a large bakery (western section of Irish Pride). The Mayo County Development Plan has identified the town as one of the counl#s Key Towns. The Development Plan has indicated that 40% of the countfs population growth is assumed to take place in the Counvs Key Towns, including Ballinrobe, and this will be at an annual average growth rate of 3.7%. Certain areas have been zoned for industrial development.

The Regional Planning Guidelines for the West 2004-2016 aim to deliver balanced regional development within the Western Region. Objectives identified include those which aim to stimulate For inspection purposes only. Consent of copyright owner required for any other use. social, economic and cultural development within the West. Ballinrobe is identifled as a key town in "zone E - South Mayo/North Galway". Objectives that relate specifidly to the future development of Ballinrobe include: a) those that aim to deliver the Ballinrobe By-Pass, connecting Ballinrobe with the Galway Gateway and Castlebar-Westport Hub; b) those objectives that aim to further develop the range of enterprise and employment opportunities available; and c) those that seek to exploit the area as a prime tourist location.

The Natlonal Spatial Strategy (NSS 2002-2020) identifies the national approach to spatial planning. The werarching aim of this plan is to facilitate balanced regionat development throughout the country. Ballinrobe has been identified as one of the Countty's 'Urban Centre/Key Towns' (i.e. has a

EPA Export 03-03-2014:23:31:34 population of between 1500-5000 people.) The NSS stresses the importance of promoting these areas as attractive tourist locations, harnessing their physical and cultural attributes.

Whilst the abve emphasise the importance of the town in the context of South Mayo and identify that future population growth is likely, no signilkant potential cumulative impacts have been identified.

6. SignWnce of effects screening matrix Bdef description of the project or plan It is proposed to expand the McHale Engineering Ltd (McHale) manufacturing facility at the Castlebar Road, Balllnrobe, County Mayo. The site covers an area of approximately 13.Sha, wlth one large building (10,0Wm2) housing offices, fabrication areas, assembly Ilnes, paint spray area and bunded paint stores. It is proposed to increase production at the plant and this will involve the construction of a 18,0Mlm2 extension to the south of the existing maln building to house the manufacturing lines and the introduction of a new painting prmss. The manufacturing process involves sheet metal cutting and forming; weldtng; deaning, painting using organic solvent based paints and assembly. The paints are applid in spray booths using electrostatic guns. The manufacturing process will remain generally the same, however it is proposed to introduce a new water based paint process to replace the solvent based paints.

sthe project plan dlmtb connected with NO or For inspectionor purposes only. wcesary to the management of theConsent Ate of copyright(prwMe owner required for any other use. ietatk)? hre there ather pmjKtS or plans that Wgethef wlth No other signinant projects or plans have been :he profea OT plan belng assessed could affect the identified. The McHale proposal will haw a negllglble ilte (prwlde detalk)? Impact on surface water, ground water and air and no signlflcant in-combinatlon impacts have been identified. Bdef description of the Natura ZUHl Ate LOUGH CARRA/MASK COMPLM SITE CODE 001774

Thls site is of conslderable conservation importance as it has good examples of six habttatr listed on Annex 1 of the EU Habitats Directive: lowland oligotrophic lakes, marl lakes, limestone pavement, dry heath, Uudium fen and alkaline fen. Some of these habitats are amongst the best examples of their kind in the country. It also has two Annex II mammal species and an Annex II invertebrate. The site is of ornlthologid importance for both wintering and breedlng blrds, with three Annex I Bird Directlve species occurring regularly. A relatively large number of other natlonally rare or localised plant and animal species occur, including the glacial relict Arctic Char.

EPA Export 03-03-2014:23:31:34 WENAME LOUGH MASK SPA WIT COW -2

Lough Mask is one of the most important inland gull breeding sites in the country, wRh nationally important populatlons of three gull species. It also has a natfonalty important colony of Common Tern, a species that is listed on Annex I of the E.U. Birds Oireaive. The site supports a good diversity of wintering waterfowl, inciudlng a nationally important populatlon of Tufted Duck. The Occurrence of Whooper Swan and Greenland White-fronted Goose, albeii in small numbers, is of note as these species are also listed on Annex I of the E.U. Birds Directive.

SITE NAME LOUGH CAMSPA. SITE =DE o04051

This site is of considerable ornlthologld importance for wintering birds, with nationally importance populations of two duck species. it is also of natlonal impoflane for two specles of nestlng gulls, and in 1999 held over 6% of the national total for Common Gull.

Assessment crftenra Theoretically Impacts on Natura Moo sites could Describe the individual elements of the project (either arise due to severe deteriorations in water due to alone or in combination with other plans or projects} operatlon of the facility or due to accidental likely to give rise to Impacts on the Natura 2000 site. spillages or discharges. Glwn the dlstance of the development from designated sites no direct disturbance of species listed as qualifying Interestsfor Natura 2000 sites is envfsaged. The slte Itself to does not support qualwing species or habitats. In the absence of significant impacts on water quatity or air quality no significant

For inspection purposes only. Oescribt any llltely dlrect, Indirect otConsent Mary of copyrightlmb owner Erequired for projectany other use. (efther alone In combination with of the or othew pfans OT projects) an the Natura 2WO slte by vlr Jtof: size and -/e and land-rake The she covers an area of approximately 13.5ha, with one large building (10,000m2) housing om-, fabricatlon areas, assembly tines, paint spray area and bunded paint stores. It is proposed to increase production at the plant and thls wlll involve the construction of a 18,000m’ extension to the south of the existlng main building to house the manufacturing lines and the introduction of a new painting process. distance from the Notum 2msite or key Lough Carra/ Mask Complex SAC 001774, Lough Mask features of the sire; SPA 004062 and Lough Cam SPA OO4051 are lomted 1.9km, 2.6km and 2.4km respectively from the proposed development site. Resourn requirements (water obstruction No additional reSource requirements have been etd: identified. emissions (dispd to knd, water or air); An alr assessment based on the EPA’s ambient alr qualidatabases and detalled emlsslon dispersion modelling was conducted by Odour Monitoring Ireland (OM) Ltd. The air modelling shows that the maximum predictedground I& concentration (GLC) of emlsslons are well within

EPA Export 03-03-2014:23:31:34 their air quality limit values. The madelting shows that the operation of the facility will have an imperceptible Impact on air quality in the vldniw of the site.

The principles of Sustainable Drainage Systems (SUDS) were applied in the deslgn of the extension. Rainwater runoff from the roof of the extension wlll be collected and diverted to a rainwater harvesting system for use as ‘grey watef in the welfare facilities and the E-Coating plant. Surplus water will be dixhargd to ground vla new soakaways and there will be no direct discharge to surface waters. A new surface water drainage system, wlll be installed to collect rainwater run-off from the new pawd areas. The runoff will pass through art attenuatlon tankjsilt trap and 2 No Class 1 Oil Interceptors before discharging to a percolation area.

All chemicals will be securely bundeed and waste water will be directed to local authority sewer. There are no surface wat to the site.

A shut off valve will be from the attenuation tank/silt trap and this will be actbtd in the event of an incident at the site that gives rise to the rlsk of surface water contamlnation to prevent the discharge of contaminated water to the percolation area.

McHale has site specific procedures to deal with spills and any emergencies that may arise to For inspection purposes only. Consent of copyright owner requiredensure for any that other use.the appropriate response actions are taken by tralned staff to minlmlse any associated environmentaltmpacts. Appropriate spill containment and clean-up equlpment Is pdded at the facility.

In the event of an Incident or accident at the facility, lncludfng a fire that could gkrise to the risk of surface water pollution, the shut offvalve on the outlet from the attenuation tank will be dosed to contain the contaminated surface water within the fadlws dratnage system and the firewater retention area. Following any such lnddent, the water that accumulates in the drainage system wlll be tested to Identb the a pproprlate management option.

There are no excavation requirements within the 6AC. There will be a sllght increase In traffic during construction.

EPA Export 03-03-2014:23:31:34 a duration of construction, opemtlon, 6-9 months for construction and commissioning decommissionina. etc: other nla Ocoalbe any kelychanges to the slte arldng as a res( t& reduction of hobitat area: There will be no reduction in habitat area of designated sites as a result of the proposed deve Io D m e n t . Although there my be localised short-term disturbance during the mnstructlon phase at the site no slgnlficant impact on birds and mammals is expeaed to occur. habitat or spdesjmgmentution; None is predicted as there will be no significant impacts on habitats or water quality or sIgniflmt direct disturbance of fauna.

reducfionin species density; None is predicted as there will be no significant impacts on habitats oc water quality or signfflwnt dlrect dlsturbanee of fauna.

changes in key indicators of conservation No impact on water quality, alr quallty or other value (water quality etc); indicators of conservation value is envisaged during wnstruction or operatlon of the facility. Standard mitigation measures will be implemented with respect to lapanese Knotweed.

climate change. .The project is expected to have no significant impact on cllmate change.

Dedbe any llkely impacts on the Natura roo0 sIte No direct Impacts on the Natura Moo site as a result as a whole in tenno of: of the proposed dwebpment are envisaged. It is not considered Itkely that there wlll be any tong term hterference wrth the key relationships fhuf significant Impacts on the key relationships that define the structure of the site; define the structure or function of the site. For inspection purposes only. Consent of copyright owner requiredPmutlons for any other will use. be taken in relation to all e intqkremce with key rehtionships that define the function of the site. construction actlvitles to ensure water quality Is maintained and thus no impact on qualifying aquatic habitats and species is envisaged.

The development will take place in an industrial area which Is already subject to high lewls of disturbance. Any slight increase in not= and disturbance will not be sienificant.

The works will not result in a loss of species density, fragmentation or have any significant effect In key indicators of consenration value within the Riir Sulr 6AC. oascribe fram #Is ahthwa elmof the The risk to qualmng interests from Impacts on key profeet ar plan, or eomblnath of ekmmtb, where spedes and habltats or slgntfiwnt negatiw impacts the above Impam are ltkdy to be d#ntfhnt or on water or air quality during mnstruction and whthe scale oc -Rude of Impacts t not operation Is considered negliglble. known.

7. Comluslons

EPA Export 03-03-2014:23:31:34 There are no drains or watercourses in proximity to the proposed site works which could potentially be affected by site works. Durfng operation of the facility there will be no discharges to surface or ground water with the exception of clean surface water run-off. Specific precautionary measures will be implemented to prevent significant impacts occurring due to chemical spills or fire.The Water Quality chapter of this EIS concluded the following:

The proposed rainwater harvesting will reduce the volume of groundwater recharge that occurs within the site, however given the size of the groundwuter Water Body, the impact to the reduction on the aqurfers quantitative status will be Indiscernible. The risk of impact on sutftrce water quality during the construction stage is low, while the risk to groundwater is negligible. me risk of impact on surface wuter quulity during the operational stage is low, while the risk to groundwater is dso low. There ore no emissions to surface water from the existing site ond, as the proposed development will not result in mynew emissions, it will not have any direct impact on off-sitewater courses.

In the absence of any discernible impact on water quality or air quality, no impact on Natura 2000 sites is predicted.

Overall there is no evidence to indicate that works will cause significant deterioration of the habitats of the qualifying species and species of special conservation interest or significant disturbance to these species thus ensuring the integrity of the site is maintained. No significant cumulative impacts are expected to occur. No significant indirect impacts are envisaged. For inspection purposes only. Consent of copyright owner required for any other use.

As no significant impact is envisaged, a stage 2 appropriate assessment is not considered necessary.

Appendix 1.

EPA Export 03-03-2014:23:31:34 SITE NAME: LOUGH CARWMASK COMPLEX

UTE CODE: 001774

This site is dominated by two large lakes, Lough Mask and Lough Carra, and includes the smaller Cloon Lough. On the western side, the site is overlooked by the Mountains, while to the east the landscape is largely low-lying agricukural land. The nearest large town is Ballinrobe which is about 4 km east of Lough Mask. The general geological character of the area is Carboniferous limestones, with some shales and sandstones on the western side of Lough Mask.

The underlying geology results in a great diversity of habitats, which support many Scarce and rare plants and animals. Six habitats which are on Annex I of the EU Habitats Directive are listed for this site, including two which are priority habitats - limestone pavement and Cladiurn fen.

Lough Mask, at over 8,000 ha, is the sixth largest lake in the country and with a maximum depth of 58 m it is one of the deepest. It is an excellent example of a lowland oligotrophic lake. Aquatic and wetland plant species present which are characteristic of this habitat include several Pondweed (Potumogeton)species, Water Lobelia (Lobelia dwtmanna) and Shoreweed (Littorello unrforu). The eastern part of the lake is shallow and is edged by a towlying shoreline which is subject to winter flooding. An intricate mixture of plant communlties has developed on the limestone, with bare pavement, scrubdominated pavement, dv grassland and heath. A variety of wetland habitats are also present, along with significant amounts of deciduous woodland along the eastern and southern shores. The western shoreline is less diverse and lacks the limestone communities. However, the fast-flowing Owenbrin River has created at its mouth an interesting delta of coarse sandy sediment.

Lough Carra, which is hydrologially linked to Mask, is one of the best examples in Ireland of a hard water marl lake. It is a shallow (mostly less than 2 m) predominantty spring fed lake with only a few streams flowing into it. Its well known pellucid green colour is due to calcareous encrustations. It has For inspection purposes only. well developed stonewort communitiesConsent of incopyright the submergedowner required for zones,any other use.with Chum cum, C. desmacuntha,

C. rudis and C. conrruriu recorded. Lough Carra, like the eastern and southern shores of Mask, is 0 fringed by a diverse complex of limestone and wetland habitats. The limestone pavement within this site represents the northern limit of the limestones of Clare and Galway. The limestone is variable In character, from open bare pavement to areas covered with dense scrub. Associated with the pavement are areas of dry calcareous grassland and dry heath. Characteristic species present include Bloody Crane’s-bill (Geranium sanguineurn), Yellow-wort (Blukrtonia perfdiiata), Carline Thistle (Cudinu vulgaris), Blue Fleabane (Erigeron ow), Wild Madder (Rubia peregrino), Rustyback (teteruch oflciinumm) und Quaking-grass (Brim media). Several plant species, notably Spring Gentian (Gentium wemu) and Dense-flowered Orchid (Iveotineo rnacuhta), occur at the northern limit of their distribution. The area is also noted for its diversity of orchid species. Scrub vegetation is variable in character, with extenshe areas dominated by Huzel [Cotyius owe//una)and Hawthorn (Crataegus monogym), with Buckthorn (Rhumnus cuthurticus), Alder Buckthorn (Fmngula ahus), Spindle (Euonymus europueus) and Ash (Fminus exceisior). The dry heath is well developed in places and is characterised by Gorse (Ukx europaeus), Bell Heather (Erica cinereu), Heather (Collunu uulguris) and St. Dabeoc’s Heath (Dubeocia cuntdwico). The diminutive orchid Lesser Twayblade (Listera cordota) occurs within the heath communities.

EPA Export 03-03-2014:23:31:34 A wide range of wetland habitats occur around Lough Carra and along patts of the eastern and southern shores of tough Mask, including Clodium fen and alkaline fen, both listed as Annex I habitats on the EU Habitats Directive. The C/udlum occurs as pure stands in places but also intermixed with Black Bog-rush (Schwnus nigricons), Common Clubrush (Scirpus /acustris),Common Reed (Phragmites uustruk) and a number of sedge species (Corn spp.). The alkaline fens are more extensive than the Cladlum fens and here Black Bog-rush is a dominant species. A rich diversity of flowering plant occurs in the fen communities. In addition to the fen habitats, there are spare but widespread reed swamps, wet grassland and some freshwater marshe communities around the lake shores.

Broad-leaved deciduous woodland occurs fairly frequently around much of the shores of the lakes and on some of the islands. This is often scrub-type woodland, which may be either dry and dominated by Hazel, Hawthorn and hh, or wet and dominated by Birch (Setuh spp.), Willow (Sulix spp.) and Alder (Ainus ghtinwu). In places the woodland is more developed and includes Sessile Oak (Quercus petraea), Holly (//ex oquifoiium) and Rowan (Sorbus oucupuriu).

A high concentration of rare plants are found at this site. Five species protected under the Flora Protection Order (1987) occur: Irish St. John's-wort (Hypericum canadenre), Chives (Allium schwnoprasum), Pillwort (Piluloriu g/obulifera), Irish lady's-t resses (Spirunrhes romanzofiana), and Small Cudweed (LMominimu). Two other Red Data Book plants, Alder Buckthorn (Frangulu ahus) and Bird's-nest Orchid (#eott/u nidus-uwis), also occur, along with two Red Data Book Stonewort species - Cham curfa and Cham rudis.

A large loft in the stable block of Curramore House provides a summer breeding site of the Lesser Horseshoe Bat (Rhinoluphus hipposideros), a species listed on Annex II of the €U Habitats Directive. The bats gain access to the loft through windows that extend from the ground floor to the loft area. The building is surrounded by mixed woods and is close to the shores of Lough Mask; both of these habitats provide ideal foraging habitat for the bats. In 1993 more than 100 bats were counted at this For inspection purposes only. site, which makes it of internationalConsent importance. of copyright owner A requiredsecond for anyinternationally other use. important summer roost of Lesser Horseshoe Bats occurs within the site at Ballykyne, near Clonbur. Over 150 bats have been counted at this site in recent years.

The site provide excellent habitat for Otter (Lutru /utm),also an Annex H species on the Habitats Directive, and the area has Pine Marten (Martes marks), a species listed in the Irish Red Data bok.

The site has important bird interests, both in winter and summer. It provides feeding areas for part of the Erriff/Derrycraff population of Greenland White-fronted Geese. This flock has declined somewhat in recent years but is still of national importance, with an average spring peak from 1989- 94 of 124 birds. The following count figures are the averages from suweys in January 1995 and January 1996: Wigeon 167; Mallard 397; Shoveler 57; Pochard 91; Tufted Duck 757; Goldeneye 158; Lapwlng 233; Curlew 118. Also, 68 Whooper Swan and 25 Gadwall were recorded in January 1996. The Shoveler, Tufted Duck and Goldeneye populations are of national importance. Bothlakes are traditional sites for breeding gulls and terns. In 1995, 44 pairs of Common Tern nested at Lough Mask, while in 1992 a census of gulls at both lakes resulted in the following: Black-headed Gull 1,451 pairs, Common Gull 407 pairs and Lesser Black-backed Gull 361 pairs. The Common Gull colony represents 11.3% of the national total, and the Lesser Black-backed Cull colony is 6.996 of the total.

EPA Export 03-03-2014:23:31:34 The deep waters of Lough Mask are home to a population of the glacial relict Arctic Char (5uMinus u/pinus), and a rare shrimp (Niphargus spp.) is also found In these waters. Lough Mask is a very important Brown Trout fishery. White-clawed Crayfish (Austropotumobiuspo//ipes), a species listed on Annex II of the Habitats Directive, has been recorded from Lough Carra.

This site is of considerable conselvation importance as It has good examples of six habitats listed on Annen I of the EU Habitats Directive: lowland oligotrophic lakes, marl lakes, limestone pavement, dry heath, Clodium fen and alkaline fen. Some of these habitats are amongst the best examples of their kind in the country. It ahhas two Annex II mammal species and an Annex II invertebrate. The site is of ornithological importance for both wintering and breeding birds, with three Annex I Bird Directive species occurring regularly. A relatively large number of other nationally rare or kcalsed plant and animal species occur, including the glacial relict Arctic Char.

SITE NAME: LOUGH MASK SPA

SITE CODE: OtMO62

0 Lough Mask, at over 8,OOO ha, is the sixth largest lake in the country. tt extends for over 14 krn along its long axis and is on average about 5 km in width. The underlying geology is of Carboniferous limestones, with some shales and sandstones. The main inflowing rivers are the Cfoon and Robe, and the stream from Lough Carra to the north-east. The main outflow is to Lough Corrib to the south. The lake is shallow off the eastern shore but considerably deeper off the western where there is a long narrow trench with a maximum depth of58 m. The water of the lake is moderately hard. During the 199Os, the trophic status of Lough Mask has changed from oligotrophic to mesotrophic due to a steady increase in phytoplankton growth. Aquatic and wetland plant species present are characteristic of oligotrophic systems - Water Lobelia (Lobelia dwtmunna), Shoreweed (Littordu unifom) and various Pondweed (Potomqeton)species. The eastern part of the lake is edged by a low-lying shoreline which is subject to winter flooding. An intricate mixture of plant communities has developed on the limestone, with bare For pavement, inspection purposes scrubdominated only. pavement, dry grassland and Consent of copyright owner required for any other use. heath. The western shoreline is less diverse and lacks the limestone communities. Islands are a feature of the lake, especially in the southeast sector.

0 lough Mask is one of the most important sites in the country for nesting Black-headed Cull (329 pairs in 19991, Common Gull (124 pairs in 1999) and Lesser Black-backed Gull (286 pairs in 1999). Whilst higher numbers of nesting gulls have been recorded in the recent past, the 1999 populations of the three species still accounted for 8.4%, 1.7% and 10%of the respective national totals. The lake is also a traditional breeding site for Common Tern, with 44 pairs in 1995 and 39 pairs in 1999.

In winter the site has a range of waterfowl, especially diving duck, with the Tufted Duck population (453) being of national importance - all figures are average peaks for 4 of the 5 winters in the period 1995/96-1999/00. It also supports Whooper Swan (54) and is visited at times by part of the Erriff/Derrycraff population of Greenland Whhe-fronted Goose (16).Other species using the site include Wigeon (a),Teal (99), Mallard (lOl), Pochard (65), Goldeneye (89), Coot (112), Red- breasted Merganser (IZ), Little Grebe (17), Mute Swan (49) and Cormorant (36).

EPA Export 03-03-2014:23:31:34 The lake ha5 a population of Arctic Char, a Red Data book species, and Is an important site for Otter, a species that is listed on Annex II of the E.U. Habitats Directive. Lough Mask is an important salmonid fishery.

The lake continues to be vulnerable to enrichment from surrounding agricultural and other comrnercial/domestic activities. The reasons for the decline in the breeding gull colonies in recent years are unknown, but it is considered that predation by feral American Mink is a problem.

Lough Mask is one of the most important inland gull breeding sites in the country, with nationally important populations of three gull species. It also has a nationally important colony of Common Tern, a species that is listed on Annex I of the E.U. Birds Directive. The site supports a good diversity of wintering waterfowl, including a nationally important population of Tufted Duck. The occurrence of Whooper Swan and Greenland White-fronted Goose, albeit in small numbers, is of note as these species are also listed on Annex I of the E.U. Birds Directive.

SITE NAME: LOUGH CARRA SPA

SITE CODE OO4051

lough Carra, which extends for over 9 km along its long axis, lies to the north-east of Lough Mask, in the (=orrib catchment. It is one of the best examples in Ireland of a hard water marl lake. It is a shallow (mean depth 1.5 m, max depth 18 m), predominantly spring-fed lake with only a few streams flowing into it. It is connected to Lough Mask via the Keel River. The water has an alkaline pH and negligible amounts of iron and manganese. Sodium and chloride are present in relatively high concentrations. lough Carra is classified as a mesotrophic system. Its well-known pellucid green colour is due to calcareous encrustations. lough Carra has welldeveloped stonewort communities in the submerged zones, and includes such species as Cham curta, C. desmacanthu, C. rudis and C. For inspection purposes only. contruriu. The lake has a highly indentedConsent of copyrightshoreline owner (over required 69 for anykm other in use.length) and is fringed by a dlverse complex of limestone and wetland habitats. The wetland habitats include both Great Fen-sedge (Clodium mariscm) fen and alkaline fen. The Cladium occurs as pure stands in places but is also intermixed with Black Bog-rush (Schwnus nlgrlccms), Common Club-rush (Scirpus lucustris),Common Reed (Phrogmitesoustrrr/~s) and a number of sedge species (Curex spp.). The alkaline fens are more extensive than the CIodium fens and in these Black Bog-rush is a dominant species. A rich diversity of flowering plant occurs in the fen communities. In addition to the fen habitats, there are widespread reed swamps, wet grassland and some freshwater marsh communities around the lakeshores. There is a good scattering of small islands within the lake.

The site is a significant ornithological site, both in winter and summer. It supports nationally important wintering populations of Shoveler (40) and Gadwall (26), along with a range of other species in relatively low numbers, including Wigeon (67), Teal (63),Mallard (152), Tufted Duck (la), Goldeneye (67), Pochard (36), Lapwing (245), little Grebe (14) and Great Crested Grebe (14) - all figures are average peaks for 4 of the 5 winters in the period 1995/96-1999/00. In the past, Lough Carra supported a population of Mallard of national importance.

The islands in Lough Carra have traditionally supported nesting gulls. In 1977, a suwey recorded Common Gull (436 individuals) and Black-headed Gull (3,341 individuals). In a repeat survey in 1993,

EPA Export 03-03-2014:23:31:35 the numbers of Common Gull and Blackheaded Gull had fallen to 72 and 252 individuals respectively. By 1999 the site supported 65 pairs of Common Gull, a signifiant increase, and c. 100 pain of Blackheaded Gull. Mink are considered to be a causative factor for the decline.

The site provide excellent habitat for Otter, a species that is listed on Annex II of theE.U. Habitats Directive. White-clawed Crayfish (Austropotumobius pu//ipes), a species that is also listed on Annex II of this directive, has been recorded from lough Cam.

Eutrophication of this hard water and naturally mesotrophic system is a serious threat. Increased planktonic algal growth was recorded during sampling in 1999. Clearance of lakeshore vegetation for agricultural intensification has occurred and is a continued threat.

This site is of considerable ornithological importance for wintering birds, with nationally importance populations of two duck species. It is also of national importance for two species of nesting gulls, and in 1999 held over 6% of the national total for Common Gull.

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

EPA Export 03-03-2014:23:31:35 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 03-03-2014:23:31:35