Sligo County Council Comhairle Chontae Shligigh

TUBBERCURRY, GRANGE AND STRANDHILL

DBO BUNDLE

DESIGN REVIEW REPORT

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

January 2013

EPA Export 20-02-2013:23:45:08

SLIGO COUNTY COUNCIL

TUBBERCURRY, GRANGE AND STRANDHILL DBO BUNDLE

DESIGN REVIEW REPORT

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

Nicholas O’Dwyer Ltd., Consulting Engineers, Nutgrove Office Park, Nutgrove Avenue, Dublin 14. January 2013

PROJECT NO. 20391

Revision Reason for Revision Prepared by Reviewed by Approved by Issue Date

- First Issue F. Lane N. Delaney N. Delaney 03/09/2012

A Updated following SCC / DECLG comments F. Lane N. Delaney N. Delaney 30/11/2012

B Updated following SCC comments F. Lane N. Delaney N. Delaney 28/01/2013

C

D

EPA Export 20-02-2013:23:45:08 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

CONTENTS

1 INTRODUCTION 1

2 POPULATION PROJECTIONS 2 2.1 Introduction 2 2.2 Census Data 2 2.3 Development Plans 2 2.4 Geodirectory Data 3 2.5 Population Growth Rates 4

3 REQUIRED EFFLUENT STANDARDS 7 3.1 Regulatory Requirements in the Receiving Waters 7 3.1.1 Urban Wastewater Treatment Regulations 7 3.1.2 Water Quality Requirements 7 3.1.3 Quality of Shellfish Waters 8 3.1.4 Bathing Water Quality 9 3.2 Waste Assimilative Capacity Calculations 9 3.2.1 Tubbercurry WWTW Effluent Discharge Standards 9 3.2.2 Grange WWTW Effluent Discharge Standards 10 3.2.3 Strandhill WWTW Effluent Discharge Standards 11 3.2.4 Summary of Proposed Effluent Discharge Standards 12

4 STRANDHILL TREATMENT OPTIONS 14 4.1 Existing Situation For inspection purposes only. 14 Consent of copyright owner required for any other use. 4.2 Primary Treatment 14 4.3 Secondary Treatment 14 4.4 Comparison of Treatment Options 15

5 TUBBERCURRY WWTP DISCHARGE LOCATION OPTIONS 17 5.1 Discharge Options 17 5.2 Ecological Impacts 17 5.3 Comparison of Outfall Costs 18 5.4 Recommended Outfall Location 20

6 TREATMENT PLANT LAYOUTS 21 6.1 Tubbercurry Wastewater Treatment Plant Layout 21 6.2 Grange Wastewater Treatment Plant Layout 21 6.3 Strandhill Wastewater Treatment Plant Layout 21

7 CONTRACT PROGRAMME 22

Nicholas O’Dwyer Ltd. i January 2013

EPA Export 20-02-2013:23:45:08 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

8 UPDATED COSTS ESTIMATES 24 8.1 Capital Costs Estimates 24 8.2 Operation and Maintenance Cost Estimates 25

9 CONCLUSIONS AND RECOMMENDATIONS 28

Appendix A: Breakdown of Non-Domestic PE Appendix B: Waste Assimilative Capacity Calculations Appendix C: Tubbercurry Ecological Assessments Appendix D: Strandhill Cost Comparison Appendix E: Tubbercurry Outfall Cost Comparison

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

Nicholas O’Dwyer Ltd. ii January 2013

EPA Export 20-02-2013:23:45:08 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

1 INTRODUCTION

A proposal to prepare a Design Review Report for the Tubbercurry, Grange and Strandhill DBO Bundle was submitted by Nicholas O’Dwyer in March 2012. Further to discussions with Sligo County Council, a modified proposal was submitted to Sligo County Council on 13th July 2012. Sligo County Council accepted the proposal to carry out the Design Review by email on 13th July 2012. The scope of this Design Review Report is as follows:-

- Review of population projection figures for Tubbercurry, Grange and Strandhill; - Determination of the implication for population change and Surface Water Regulations on the effluent standards for Tubbercurry, Grange and Strandhill; - Review effluent discharge location for Tubbercurry; - Prepare ecological assessment report for Tubbercurry discharge location options to River Moy; - Review potential for primary treatment being sufficient for Strandhill based on recent EPA licencing decisions; - Review options and determine the final effluent rising main route and discharge location (i.e. preliminary design) for Tubbercurry; - Review of Plant layouts for Tubbercurry, Grange and Strandhill for new WwTW capacity and effluent standards; - Revise the Contract Programme to reflect the procurement decision to be made by Sligo County Council; - Preparation of updated capital cost estimate for Tubbercurry, Grange and Strandhill; - Review O&M rates for the new proposal against the tendered rates; - Compare the revised Proposal to the tendered Proposal as submitted in 2008;

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

Nicholas O’Dwyer Ltd. 1 January 2013

EPA Export 20-02-2013:23:45:08 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

2 POPULATION PROJECTIONS

2.1 Introduction The population estimates for the Tubbercurry, Grange and Strandhill DBO Bundle were originally prepared in 2006 and reviewed in 2010 based on the Geodirectory information at the time, 2006 Census Data and flow and load surveys carried out at the plants.

The population estimates have been updated based on 2011 Census results, and current Geodirectory information. The population projections have been based on the Sligo County Development Plan and CSO population projection data in conjunction with Regional Planning Guidelines.

2.2 Census Data The census data for 2006 and 2011 was examined to establish the current domestic populations in each of the three towns and the growth rate from 2006 to 2011. This data is summarised in Table 2.1 below.

Table 2.1 – Census Population Change 2006 to 2011 Town Population % Increase in Population

2006 2011 Total % % per annum Grange 383 578 50.9 8.6 Strandhill 1413 1596 13.0 2.5 Tubbercurry 1421 1747 22.9 4.2

The Central Statistics Office (CSO) Regional Population Projections, 2011 – 2026 predicts an average population growth of 1.2% per annum for Border regions. This is an average growth rate. It is expected that the majority of this growth will be in urban areas with rural areas having a static or falling population.

For inspection purposes only. 2.3 Development Plans Consent of copyright owner required for any other use.

The Sligo County Development Plan 2011-2017 (CDP) includes population targets for towns in Sligo and Mini-Plans are being developed for towns not the subject of individual local area plans. Strandhill and Grange are designated as Principal Gateway Satellites in the Sligo CDP with growth in the area to be promoted in these towns rather than the general rural area. Tubbercurry is identified as a Key Support Town serving rural areas in the Sligo CDP.

The current Strandhill Local Area Plan, 2003-2012 is now substantially out of date in terms of population and population growth. Sligo County Council intends to review the Strandhill Local Area Plan 2003-2012 and prepare a Mini-Plan for Strandhill, which will be incorporated in the County Development Plan 2011-2017 (CDP). The Sligo CDP has set recommended population target of 1,700 for Strandhill by 2017. A Pre-draft Consultation Paper has been prepared by Sligo County Council to facilitate input from interested parties on the proposed Mini- Plan. The Pre-draft Consultation Paper identifies 14 hectares as the maximum amount of greenfield land that can be zoned for residential uses in Strandhill. At an average of 56 PE per hectare (i.e. 25 houses per hectare at 2.25 PE per house), this would amount to an additional 787 PE. A maximum of 50% of zoned

Nicholas O’Dwyer Ltd. 2 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

land would be expected to be developed over the life of the plan, i.e. an increase of 394 PE. This is equivalent to an annual growth rate of approximately 3.7% per annum.

Sligo County Council intends to prepare a Local Area Plan for Tubbercurry. This plan is currently at pre-consultation stage. The Sligo CDP has set recommended population target of 1,800 for Tubbercurry by 2017. The CDP sets out 22 hectares as the maximum amount of land that can be zoned for residential uses in the Tubbercurry LAP. At an average of 50 PE per hectare (i.e. 25 houses per hectare at 2.0 PE per house), this would amount to an additional 1,100 PE. A maximum of 50% of zoned land would be expected to be developed over the life of the plan, i.e. an increase of 550 PE. This is equivalent to an annual growth rate of approximately 4.5% per annum.

A Mini-Plan for Grange has been incorporated in the County Development Plan 2011-2017. Grange provides a wide range of services for the population of the village and the surrounding rural area, and is classified as a Principal Gateway Satellite in the Sligo County Development Plan. The Sligo CDP has set recommended population target of 600 for Grange by 2017. The Mini-Plan for Grange indicates that no additional land is required for the duration of the plan due to the current level of vacancy and approved planning applications, amounting to a total of 70 units. At an average of 2.7 PE per household (i.e. the current population per household), this would amount to an additional 189 PE. This is equivalent to an annual growth rate of approximately 5% per annum. However, further development may occur within the existing areas designated for “Mixed Use” in the old village core potentially increasing the growth rates.

The housing density assumed above is relatively high. However, the development plans propose to include infill and mixed development areas within the towns. These type of developments typically include a mix of houses and For inspection purposes only. apartments and a higherConsent housing of copyright density owner required than for any for other greenfilluse. sites. The population levels set in the Sligo CDP were set before the results of the 2011 Census were available. The level of population growth from 2006-2011 in Tubbercurry, Grange and Strandhill was higher than previously predicted. It is likely that the predicted 2017 populations will be exceeded prior to 2017 for all three towns.

2.4 Geodirectory Data Sligo County Council provided tables from the current Geodirectory for each of the catchment areas. The current residential and commercial / business premises are summarised in Table 2.2. The data in the Geodirectory has been used to establish the current domestic PE and non-domestic PE within the existing collection network. The boundary of the collection network is not exactly the same as the census boundary so the domestic populations vary slightly from Table 2.1 above. The domestic population is estimated based on the census increased by the estimated growth rate to 2012. The PE per residential unit when the census is compared to the geodirectory is low in Strandhill and Tubbercurry. This is likely to be due to a number of apartment developments which typically have a lower population density. The non-domestic PE has been

Nicholas O’Dwyer Ltd. 3 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

estimated based on an assessment of the particular units. Further details are included in Appendix A.

Table 2.2 – Summary of Geodirectory Data and Associated PE Town Residential Commercial / Total PE Business1 Total Units Total Total Units Total Non- Domestic PE Domestic PE Grange 210 567 49 183 750 Strandhill 714 1,607 59 5992 2,206 Tubbercurry 874 1,792 182 8953 2,687 Notes: 1. The Commercial / Business units include schools. 2. The Strandhill non-domestic PE includes the discharge from a new apart-hotel development commencing in 2013 and additional tourist load at beach area 3. Tubbercurry non-domestic PE includes an additional discharge pumped from the St Attracta’s secondary school and updated school PE.

2.5 Population Growth Rates The population growth rate in Tubbercurry, Grange and Strandhill has been high in the last number of years. The populations and growth rates from 2002 to 2011 are summarised in Table 2.3.

Table 2.3 – Population Data and Growth Rates Town 2002 2006 2011 Annual Annual Growth Growth 2002-2006 2006-2011 Grange 225 383 578 14.2% 8.6% Strandhill 1,002 1,413 1,596 9.0% 2.5% Tubbercurry 1,171 1,421 1,747 5.0% 4.2%

For inspection purposes only. Consent of copyright owner required for any other use. A high population growth rate was seen in all three towns from 2002 to 2006. This growth rate reduced from 2006 to 2011. This is partially due to the slowdown in the economy. In addition, the percentage annual growth rate, in an expanding urban area, typically decreases as the size of a town increases.

The population growth rate identified in the Sligo County Council in the Sligo CDP from 2006 to 2017 was based on sustainable growth rates. These populations and growth rates are summarised in Table 2.4.

Table 2.4 – Population Data from Sligo CDP and Calculated Growth Rates Town % Growth per 2006 2017 Annum Grange 383 600 4.17% Strandhill 1,413 1,700 1.70% Tubbercurry 1,421 1,800 2.17%

These growth rates have been used to predict an appropriate “medium” growth rate prediction for the next 25 years. It is expected that the medium growth rate will be less than the rates predicted in the Sligo CDP. The population growth

Nicholas O’Dwyer Ltd. 4 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

rates based on development of 50% of zoned land as detailed in the development plans for each of the towns is substantially higher than the medium growth rate detailed above. However, as current development is limited it is unlikely that these growth rates will be achieved. The medium growth rate has been taken as 1.2% for Grangeand Tubbercurry in line with the regional growth rate of 1.2% predicted by the CSO. A slightly higher growth rate of 1.3% per annum has been taken for Strandhill. Sligo County Council planning department have advised that recent growth in Strandhill was not due to any tax incentive schemes and that demand for housing in Strandhill has been sustained in recent years and the town is expected to continue to grow.

A low growth rate is estimated as 75% of the medium growth rate. The high growth rate is expected to be less than or equal to the 2006-2011 growth rates. It is assumed that the non-domestic loads will grow at a similar rate to the domestic loads. The total predicted growth rates for low, medium and high population projections are detailed in Table 2.5.

Table 2.5 – 25 Year Growth Rate Predictions Town Population Growth Rate (% per annum) Low Medium High Grange 0.9% 1.2% 6.0% Strandhill 0.9% 1.3% 2.5% Tubbercurry 0.9% 1.2% 3.6%

It is assumed that the non-domestic PE being discharged to the wastewater treatment plants will grow at the same rate as the domestic PE. The growth rates as detailed in Table 2.5 above have been applied to the total current PE estimated in Table 2.2. The total predicted low, medium and high population equivalents are detailed in Table 2.6.

For inspection purposes only. Table 2.6 – 25 Year PE ConsentPredictions of copyright (toowner 2037 required) for any other use.

Town Existing PE Population Equivalent at Predicted Growth Rates

Low Medium High Grange 750 938 1,011 3,365 Strandhill 2,206 2,811 3,046 4,055 Tubbercurry 2,687 3,361 3,620 6,500

The recommended design PE for each of the wastewater treatment plants is summarised in Table 2.7. The design PE recommended for Strandhill and Tubbercurry do not allow for a full 25 year design horizon as it is anticipated that the construction will be complete within 3 years allowing a 20 year operation and maintenance period. It is recommended that each of the sites is developed to allow for future expansion to allow for doubling the capacity of the wastewater treatment plant. This allows for potential future growth in the domestic or non- domestic sector within each of the towns without incurring any additional cost.

Nicholas O’Dwyer Ltd. 5 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

Table 2.7 – Design PE for Wastewater Treatment Plants Town Design Population Equivalent Phase I Phase II (future) Grange 1,100 3,300 Strandhill 3,000 6,000 Tubbercurry 3,500 7,000

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

Nicholas O’Dwyer Ltd. 6 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

3 REQUIRED EFFLUENT STANDARDS

3.1 Regulatory Requirements in the Receiving Waters

3.1.1 Urban Wastewater Treatment Regulations

The treated effluent discharged from the upgraded WWTW’s must be compliant with the Urban Waste Water Treatment Regulations (UWWTR) (S.I. No 254 of 2001). The Urban Waste Water Treatment Regulations require that wastewater entering a collecting system is subject to secondary treatment in respect of discharges to freshwaters and estuaries, from agglomerations with a population equivalent of greater than 2,000. This is applicable to the discharge from the Tubbercurry and Grange WWTW’s. The effluent concentrations presented in Table 3.1 therefore apply as a minimum.

Table 3.1 - UWWTR Effluent Concentrations

Parameter Maximum concentration (mg/l) Biological Oxygen Demand (BOD) 25 Total Suspended Solids (TSS) 35 Chemical Oxygen Demand (COD) 125

The Urban Waste Water Treatment Regulations require that wastewater entering a collecting system is subject to appropriate treatment in respect of discharges to coastal waters from agglomerations with a population equivalent of less than 10,000. This is applicable to the discharge from the Strandhill WWTW.

3.1.2 Water Quality Requirements

The Water Framework Directive (WFD) which established a new framework for

Community action in the field For inspection of water purposes policy only. (2000/60/EC) came into effect in Consent of copyright owner required for any other use. December 2000. The primary objective of the Water Framework Directive is to maintain the “high status” of waters where it exists, prevent deterioration in existing status of waters and to achieve at least “good status” in relation to all waters by 2015. The objective status of each of the waterbodies of concern in this study is presented in Table 3.2.

Table 3.2 - WFD Objective Status for Water Bodies

WWTW Waterbody Objective Tubbercurry WWTW Tubbercurry River Good status Tubbercurry WWTW River Moy Good status Strandhill WWTW Sligo Bay High status Grange WWTW Grange River Good status

The European Communities Environmental Objectives (Surface Waters) Regulations 2009 (SI No. 272 of 2009) have implemented new standards for surface waters for the further implementation of the Water Framework Directive. The Surface Water Regulations came into effect on the 30th July 2009. The

Nicholas O’Dwyer Ltd. 7 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

effluent standards for the Tubbercurry, Grange and Strandhill Wastewater Treatment Plants were set prior to the implementation of these regulations.

These regulations set new standards to be achieved for surface waters depending on the current status of the water body and are outlined in Table 3.2. The wastewater treatment plants in Tubbercurry and Grange discharge to rivers. The Strandhill wastewater treatment plant discharges to a coastal water body. The standards set in the Surface Water Regulations as summarised in Table 3.3 must be used to calculate the allowable effluent standards.

Table 3.3 - Surface Water Regulations Environmental Quality Standards (EQS)

Condition River Coastal water body High status < 1.3 (mean) or < 2.2 (95%ile) Biological Oxygen

Demand Good status < 1.5 (mean) or < (BOD) (mg O /l) 2 2.6 (95%ile)

High status < 0.040 (mean) or < 0.090 (95%ile) Total Ammonia Good status < 0.065 (mean) or < 0.140 (95%ile) High status < 0.025 (mean) or

< 0.045 (95%ile Molybdate Reactive

Phosphorus Good status < 0.035 (mean) or (MRP) (mg P/l) < 0.075 (95%ile)

Good status (34.5psu)/95%ile < 0.17 mg/N/l Dissolved Inorganic Good status (34.5psu)/95%ile Nitrogen < 0.17 mg/N/l (mg/N/l) High status (34.5psu)/95%ile < 0.17 mg/N/l For inspection purposes only. Consent of copyright owner required for any other use.

3.1.3 Quality of Shellfish Waters

The aim of the EC Shellfish Waters Directive (79/923/EEC) is to protect or improve shellfish waters in order to support shellfish life and growth, therefore contributing to the high quality of shellfish products directly edible to humans. The Quality of Shellfish Waters Regulations 2006 (S.I. No. 268 of 2006) as amended in 2009 (S.I. No. 55 of 2009) sets physical, chemical and microbiological water quality requirements that designated shellfish waters must either comply with (‘mandatory’ standards) or endeavour to meet (‘guideline’ standards). There are a number of designated Shellfish Waters surrounding Ireland including waters in Sligo Bay, which are less than 1km from the existing Strandhill WWTW outfall. The WWTW must therefore comply with the requirements for discharges to affecting shellfish waters as outlined in the regulations.

Nicholas O’Dwyer Ltd. 8 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

Table 3.4 Regulations Relevant to Shellfish Flesh Quality Regulation/Standard Classification/Category Faecal E. Coliform Coliforms per 100g per 100g of flesh of flesh EU Shellfish Directive Direct Human <300 <230 (91/492/EEC) Consumption Consumption after <6,000(*) <4,600(*) purification Consumption after <60,000 - intense purification (*) 90% of samples; All other requirements are for 100% of samples

It is difficult to correlate coliform levels in the water with coliform levels in shellfish. However, it is essential to minimise the levels of coliforms in designated shellfish waters. It is recommended that number of faecal coliform should be less than 300 per 100ml in the shellfish water.

In order to establish the required level of treatment and the recommended outfall length, an outfall dispersion model would be required.

3.1.4 Bathing Water Quality

The closest designated bathing waters to Strandhill are Rosses Point, approximately 4km to the north and Dunmoran beach, approximately 8km to the southwest. The beach at Rosses Point is designated as a Blue Flag Beach. The beach at Strandhill not designated as a bathing water. Due to the distance to the Rosses Point beach, it is unlikely that the discharge from Strandhill will have a significant impact. It is considered that if the treatment and dilution are sufficient to not negatively impact the designated shellfish wasters, the impact on the

bathing waters at Rosses Point For inspectionwill be purposes negligible only. . Consent of copyright owner required for any other use.

3.2 Waste Assimilative Capacity Calculations The Waste Assimilative capacity was calculated in accordance with the guidance published by the Water Services Training Group. Full details of the methodology for calculating the waste assimilative capacity and effluent standards, and the results for each of the wastewater treatment plants are included in Appendix B.

3.2.1 Tubbercurry WWTW Effluent Discharge Standards

The existing wastewater treatment plant in Tubbercurry discharges to the Tubbercurry River. This stream has a very low 95 percentile flowrate and thus a very low waste assimilative capacity. Two alternative discharge locations have been identified in the River Moy. A waste assimilative capacity calculation has been calculated for each of these three discharge locations. Up to date background water quality was provided by Sligo County Council from January 2011 to January 2012.

Nicholas O’Dwyer Ltd. 9 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

The results of the Waste Assimilative Capacity calculation based on the Surface Water Regulation parameters and revised population projections are outlined below in Table 3.5. A comparison is also made between the effluent standards as set out in the contract documents and the new effluent standards based on the Surface Water Regulations and a 95%ile flow. Detailed Waste Assimilative Capacity Calculations are presented in Appendix B.

Table 3.5 – Tubbercurry WWTW Effluent Standards

Effluent Standards (mg/l) Option 1 River Moy Option 2 Option 3 Contract 1.5km d/s River Moy at Tubbercurry Documents1 Annagh Br. Annagh Br. Stream3 Parameter (5,000 PE) (3,500 PE) (3,500 PE) (3,500 PE) BOD2 5 25 25 8.3 Ammonia 2.8 3.37 3.22 0.44 Ortho-phosphate 0.66 1.43 1.36 0.23 Notes: 1. The Contract Documents effluent standards were for the Tubbercurry River prior to the implementation of the Surface Water Regulations. 2. The minimum level of treatment is secondary treatment to a BOD of 25 mg/l in accordance with the Urban Wastewater Treatment Regulations. The calculated effluent BOD based on the waste assimilative capacity for discharge to the River Moy is >25mg/l. 3. Background concentrations for Tubbercurry River taken as "notional clean water" as used by the EPA in waste waster discharge licence application assessments

Ammonia levels of less than 1mg/l and ortho-phosphate levels of less than 0.5mg/l are difficult to achieve using standard treatment methods. The EPA Water Quality in Ireland Report 2007-2009 notes that serious pollution continued on the Tubbercurry Stream and Tubbercurry River due primarily to poorly treated municipal wastewater.

The options for effluent discharge are further evaluated in Section 5 in terms of ecological impacts, capital costs and other factors identified effecting selection of For inspection purposes only. outfall location. Consent of copyright owner required for any other use.

3.2.2 Grange WWTW Effluent Discharge Standards

The existing wastewater treatment plant in Grange discharges to the Grange River. The Grange River is currently designated as “high status” upstream of Grange and “good status” downstream of Grange.

Up to date background water quality data for the Waste Assimilative Capacity studies were obtained from Sligo County Council. Flow data at Rinroe Ford on the Grange River was obtained from the Environmental Protection Agency (EPA). The results of the Waste Assimilative Capacity calculation based on the Surface Water Regulation parameters and revised population projections are outlined below in Table 3.6. A comparison is also made between the effluent standards as set out in the contract documents and the new effluent standards based on the Surface Water Regulations and a 95%ile flow. Detailed Waste Assimilative Capacity Calculations are presented in Appendix B.

Nicholas O’Dwyer Ltd. 10 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

Table 3.6 – Grange WWTW Effluent Standards

Effluent Standards (mg/l) Contract Documents Phase 1 Ultimate Parameter (2,500 PE)1 (1,100 PE) (3,300 PE) BOD2 20 25 12.5 Ammonia 7 1.68 0.65 Ortho-phosphate 0.66 0.84 0.33 Notes: 1. The Contract Documents effluent standards were for the Tubbercurry River prior to the implementation of the Surface Water Regulations. 2. The minimum level of treatment recommended is secondary treatment to a BOD of 25 mg/l. The calculated effluent BOD based on the waste assimilative capacity at Phase 1 is >25mg/l.

There is a significant decrease in the effluent ammonia standard, from the Contract Document stage, required to meet the Surface Water Regulations. It will be necessary to provide a higher sludge age and consequently a high volume aeration tank in order to achieve the level nitrification of the wastewater required to meet this limit. Tertiary filters are likely to be required to achieve the ammonia and orthophosphate limits at the ultimate stage.

3.2.3 Strandhill WWTW Effluent Discharge Standards

The existing Strandhill WWTW discharges to an outfall just below the low water mark at the northern end of Strandhill beach. When considering a coastal water body, the Surface Water Regulations 2009 set Environmental Quality Standard values for Dissolved Oxygen (DO) and Dissolved Inorganic Nitrogen (DIN) only. The waters off Strandhill are designated as ‘high status’ and will therefore require a DIN (mg/l) of (34.5psu)/ < 0.17 mg/N/l. The median salinity measured in Sligo Bay is 34.1 PSU. The standard for DO is (35psu)/95%ile > 80% saturation as the lower limit and (35psu)/95%ile < 120% saturation as the upper limit. Waters to the north of the WWTW outfall For inspectionat Strandhill purposes only. in Sligo Bay have been designated as Consent of copyright owner required for any other use. shellfish waters, therefore the requirements of the Shellfish Regulations 2006 as amended (2009) as detailed in Section 3.1.3 will also have to be taken into consideration when setting effluent standards for Strandhill WWTW. The current effluent standards as set out in the Strandhill WWTW upgrade contract documents are presented in Table 3.7.

Table 3.7 - Strandhill Effluent Standards (Contract Documents) Maximum Parameter concentration (mg/l) Biological Oxygen Demand (BOD) 25 Total Suspended Solids (TSS) 35 Chemical Oxygen Demand (COD) 125 Total Ammonia 20

The effluent discharge from Strandhill is identified in the Sligo Bay Shellfish Area Characterisation Report Number 17 as potentially impacting the shellfish waters in Sligo Bay.

Nicholas O’Dwyer Ltd. 11 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

The original Preliminary Report and Tender Documents for the Strandhill WWTP proposed secondary treatment. The provision of secondary treatment provides mainly for reduction of BOD and suspended solids. The number faecal coliforms in the effluent from a secondary treatment plant are relatively high. Under the Urban Wastewater Treatment Regulations, appropriate treatment is required for discharge to coastal waters for population equivalents up to 10,000 PE. In some cases, it is more appropriate to provide primary treatment with a longer outfall pipeline than secondary treatment with a shorter outfall pipeline. The level of dilution provided by a longer outfall pipeline may be sufficient to dilute the effluent coliforms to an acceptable level at the shellfish waters.

At the time of preparation of the Preliminary Report for the Strandhill WWTP, Sligo Bay was not designated as a shellfish water. Based on the current status, it is possible that the effluent with secondary treatment only may require ultraviolet disinfection to reduce the impact on the shellfish water. Typical effluent faecal coliform levels for different levels of treatment are summarised in Table 3.8. Preliminary analysis suggests that primary treatment with a minimum outfall length of 1,500m would provide adequate dilution. The overall capital cost of this has been compared to Secondary treatment with an outfall length of 600m and secondary treatment with UV disinfection utilising the existing outfall. Futher details are included in Section 4.

Table 3.8 – Typical Effluent Faecal Coliform Levels MPN1 per Parameter 100ml Untreated 1 x 109 Primary treatment 1 x 107 Secondary treatment 1 x 106 Secondary treatment with UV disinfection 1 x 103 Note: 1. MPN = most probably number For inspection purposes only. Consent of copyright owner required for any other use.

In order to fully determine the impact on the receiving waters, an effluent dispersion model would be required. This would assess the impact of water depth, currents and tides on the dispersion of effluent in a coastal water. This would have the advantage of optimising the capital works and operation and maintenance requirements for the long-term development of Strandhill. The estimated cost for preparing an outfall dispersion model would be: €35,000 including all required surveys. It is likely that an extension of the outfall to give a minimum dilution of 50 (as recommended by the WRc) will be required to comply with the Surface Water Regulations. A Total Dissolved Inorganic Nitrogen of (0.17 x 50) = 8.5mg/L would be required to comply with the Surface Water Regulations after initial dilution.

3.2.4 Summary of Proposed Effluent Discharge Standards

A summary of the proposed effluent standards for Tubbercurry, Grange and Strandhill is included in Table 3.9. The effluent standards include the minimum effluent standards required by the Urban Wastewater Discharge Regulations of

Nicholas O’Dwyer Ltd. 12 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

25mg/l BOD, 35mg/l suspended solids and 125mg/l COD in addition to any higher level of treatment required to comply with the Surface Water Regulations as calculated above.

The effluent standards for Tubbercurry are for discharge to the River Moy at Annagh Bridge. The proposed effluent standards for Strandhill are based on secondary treatment. The standards for Strandhill and Tubbercurry are based on the recommendations in Section 4 and 5 respectively.

Table 3.9 – Summary of Effluent Standards

Effluent Standards (mg/l) Tubbercurry Grange Strandhill Parameter (3,500 PE) (1,100 PE) (3,000 PE) BOD (mg/l) 25 25 25 Suspended solids (mg/l) 35 35 35 COD (mg/l) 125 125 125 Ammonia (mg.N/l) 3.22 1.68 - Dissolved Inorganic nitrogen (mg.N/l) - - 8.5 Ortho-phosphate (mg.P/l) 1.36 0.84 - Faecal coliforms (no. per 100ml) - - 1 x 103

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

Nicholas O’Dwyer Ltd. 13 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

4 STRANDHILL TREATMENT OPTIONS

4.1 Existing Situation There is an existing wastewater treatment plant in Strandhill which is overloaded and not providing for full secondary treatment of the influent wastewater. The wastewater discharges to an outfall at the northern end of Strandhill beach just below the low water mark.

4.2 Primary Treatment The Urban Wastewater Treatment Regulations specify appropriate treatment for coastal discharges from agglomerations of less than 10,000 PE. The licences issued by the EPA for coastal discharges have reflected this where an appropriately sized outfall pipeline is in place.

In order for primary treatment to be suitable, sufficient dilution must be provided to comply with the Surface Water Regulations requirements for Dissolved Inorganic Nitrogen. In addition, the impact of any discharge on the shellfish waters designated in Sligo Bay must be examined.

A water depth of approximately 10m is reached approximately 1,500m from the low water mark in Strandhill. It may be necessary to extend an outfall pipeline to a depth of 15m, which is reached approximately 2,500m from the low water mark in Strandhill. There is a substantial difference in the capital cost between these two requirements and as such an outfall dispersion model examining the impacts is recommended.

Primary treatment produces a less stable sludge than secondary treatment and has a higher potential for creating nuisance odours. It is recommended that any primary settlement tanks and associated primary sludge areas are covered with odour extraction to prevent an odour nuisance. Primary treatment has the For inspection purposes only. advantage of providing Consenta lower of copyright operating owner required cost for anyand other a use. lower carbon footprint due to

the lower energy use. There is also a lower risk of pollution as the treatment is not dependent on a biological process.

4.3 Secondary Treatment The original contract documents proposed secondary treatment with no extension of the existing outfall pipeline. Further to the implementation of the Surface Water Regulations and the designation of Sligo Bay as a shellfish water, this may not be sufficient to provide compliance with the required water quality standards. In order to continue to use the existing outfall it is expected that the wastewater treatment plant would need to provide a higher level of nitrogen removal including an anoxic zone for denitrification. In addition, disinfection may be required in order to reduce the potential impact on the shellfish waters.

Alternatively secondary treatment with an extension of the existing outfall could potentially provide the required level of dilution to minimise the impact on the shellfish waters and provide for compliance with the Surface Water Regulations.

Nicholas O’Dwyer Ltd. 14 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

4.4 Comparison of Treatment Options The original contract documents proposed secondary treatment with no extension to the outfall pipeline. An assessment of the cost of primary, secondary and tertiary treatment options has been carried out. The comparative costs have been updated based on recent tender costs. The commencement year for operation and maintenance has been taken as 2015. A summary of the comparative costs is included in Table 4.1.

Table 4.1 – Cost Comparison of Strandhill Treatment Options1 Option 1 - Option 3 - Option 1 - Secondary Primary Secondary Item Treatment Treatment Treatment (existing (1500m (600m outfall) outfall) outfall) Capital Cost

Pumping Station M&E Works €90,000 €90,000 €90,000 Preliminary M&E Works €140,000 €140,000 €140,000 Primary M&E Works €40,000 Secondary M&E Works €220,000 €220,000 Sludge M&E Works €120,000 €120,000 €80,000 Odour removal M&E €90,000 €90,000 €110,000 Disinfection €110,000 Additional nitrogen removal €90,000 PS Civil Works €30,000 €30,000 €30,000 Preliminary Civil Works €90,000 €90,000 €90,000 Primary Civil Works €30,000 Secondary Civil Works €280,000 €280,000 Sludge Civil Works €90,000 €90,000 €72,000 For inspection purposes only. Site Civil Works Consent of copyright owner€115,000 required for any other use. €115,000 €80,000

Civil Works - nitrogen removal €90,000 Civil Works - disinfection €60,000 Civil Works - outfall upgrade €100,000 €1,200,000 €3,000,000 Total Capital Cost (excl. VAT) €1,715,000 €2,465,000 €3,762,000

Operating Cost 20 Year O&M NPV Cost (excl. VAT) €1,590,744 €1,514,994 €859,148 20 Year Total Whole Life Cost €3,305,744 €3,979,994 €4,621,148 (excl. VAT) 20 Year Total Whole Life Cost €3,752,019 €4,517,293 €5,245,003 (including VAT @ 13.5%)

Operating Cost 30 Year O&M NPV Cost (see page 2) €1,998,563 €1,903,394 €1,080,546 30 Year Total Whole Life Cost €3,713,563 €4,368,394 €4,842,546 (excl. VAT) 30 Year Total Whole Life Cost €4,214,895 €4,958,127 €5,496,290 (including VAT @ 13.5%)

Nicholas O’Dwyer Ltd. 15 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

The designation of Sligo Bay as high status under the Water Framework Directive and as a shellfish water under SI 55 of 2009 has set statutory water quality standards that must be achieved in Sligo Bay. There is potential for breach of Dissolved Inorganic Nitrogen standard in Sligo Bay without additional nitrogen removal, i.e. nitrification and denitrification. There is also a potential for coliform levels in the effluent to impact on the designated shellfish waters.

The financial analysis above has indicated that the lowest cost option for Strandhill is Option 1. In this option secondary treatment with disinfection and reuse of the existing outfall pipeline would be provided. Outfall dispersion modelling of the effluent would fully establish the level of treatment required and can potentially lead to cost savings if it is demonstrated that disinfection or additional nitrogen removal is unnecessary.

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

Nicholas O’Dwyer Ltd. 16 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

5 TUBBERCURRY WWTP DISCHARGE LOCATION OPTIONS

5.1 Discharge Options The existing Tubbercurry wastewater treatment plant discharges to the Tubbercurry River. Due to the level of dilution available, a high level of treatment is required in order to provide compliance with the Surface Water Regulations.

Two potential discharge locations in the River Moy have been identified. The first discharge location is at is approximately 1.5km downstream of Annagh Bridge on the River Moy. This route to this discharge location is initially along the R294 and then along a local road to south-west towards Tullanaglug. The final part of this outfall route would go across private land for approximately 40m, across private land, to a location downstream of the conflagration with the Tubbercurry River.

The second identified discharge location is at Annagh Bridge on the River Moy. The route to this point is along the R294 regional road with a length of approximately 4,800m from the wastewater treatment plant.

The location of the outfall options to the River Moy is shown on Drawing No. 20391-DR-01. The existing outfall location to the Tubbercurry River is adjacent to the wastewater treatment plant site shown on Drawing No. 20391-DR-02.

5.2 Ecological Impacts The River Moy is classified as a Special Area of Conservation (SAC) under the Habitats Directive. In order to fully assess the options for discharge to the River Moy an ecological assessment of the two discharge options identified above was undertaken. Following consultations with the National Parks and Wildlife Service, it was identified that the River Moy was a potential habitat for the pearl mussel (Margaritifera margaritifera). The pearl mussel is listed in Annex II and Annex V of the Habitats Directive and is highly sensitive to water quality. There is For inspection purposes only. therefore a potential forConsent significant of copyright ownerimpact required from for any otherwastewater use. discharges. In order

to identify potential habitats and impacts, a pearl mussel survey by a licenced pearl mussel specialist was carried out.

This survey identified one live pearl mussel in the stretch of the River Moy from Annagh Bridge to Banada Bridge. The survey concluded that there only a very small number of pearl mussels in the stretch of river surveyed and that the habitat is generally unsuitable for pearl mussel. The highest quality habitat for pearl mussel was identified between 1,300m and 2,400m downstream of Annagh Bridge. A copy of this survey is included in Appendix C as part of the Ecological Assessment Report.

Following the pearl mussel survey, an ecological assessment was carried out. A report based on this survey is included in Appendix C. Based on the ecological assessment and the pearl mussel survey there is no significant ecological factors which would make one option more suitable than the other. The option of discharging to Annagh Bridge would have the advantage of the pipeline being constructed mainly on roads with a minimal impact on riverbank life. The option of discharging 1.5km downstream of Annagh Bridge has the advantage of the

Nicholas O’Dwyer Ltd. 17 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

additional flows from the Tubbercurry River. However, some additional impacts on ecology have been identified in the Ecological Assessment Report due to disturbance of wet grassland/marsh and scrub of locally important value.

The ecological impacts on the Tubbercurry River would be an improvement to the ecology of the river. The current status of the river must be improved to good status under the Water Framework Directive. The required effluent standards needed to achieve good status in the river will be difficult to achieve on a consistent basis and any non-compliance would have a significant negative impact due to the low level of dilution available.

5.3 Comparison of Outfall Costs An assessment of the capital and operation and maintenance cost for the three outfall options considered was carried out. The costs are summarised in Table 5.1 below. The comparative costs have been updated based on recent tender costs. Further details are included in Appendix F to this report.

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

Nicholas O’Dwyer Ltd. 18 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

Table 5.1 – Tubbercurry Comparative Cost for Outfall Options

Option 1 River Option 2 River Option 3 Moy 2km d/s Moy at Tubbercurry Item Annagh Br. Annagh Br. Stream Capital Cost Storm / interception M&E Works €95,000 €95,000 €95,000 Preliminary M&E Works €140,000 €140,000 €140,000 Secondary M&E Works €360,000 €360,000 €360,000 Sludge M&E Works €145,000 €145,000 €155,000 Odour removal M&E €90,000 €90,000 €90,000 Tertiary filters M&E (BOD & P €280,000 removal) Additional aertion/nitrogen €20,000 removal Outfall PS M&E €15,000 €15,000 Storm Civil Works €90,000 €90,000 €90,000 Preliminary Civil Works €90,000 €90,000 €90,000 Secondary Civil Works €280,000 €280,000 €280,000 Sludge Civil Works €90,000 €90,000 €90,000 Site Civil Works €115,000 €115,000 €130,000 Addition Civil Works - nitrogen €90,000 €70,000 removal Civil Works - tertiary filters €120,000 Outfall PS Civil €35,000 €35,000 Outfall pipeline, 200mm diameter €750,0001 €768,0002 €10,000 @ €160 per metre Wayleave cost €10,000 - - Total Capital Cost (excluding €2,395,000 €2,313,000 €2,020,000 VAT) For inspection purposes only. Consent of copyright owner required for any other use.

Operation & Maintenance Cost3 20 Year O&M NPV Cost (excluding €1,786,280 €1,786,280 €2,062,113 VAT) 20 Year Total Whole Life Cost €4,181,280 €4,099,280 €4,082,113 (excluding VAT) 20 Year Total Whole Life Cost €4,745,753 €4,652,683 €4,633,199 (including VAT @ 13.5%)

30 Year O&M NPV Cost (excluding €2,241,011.39 €2,241,011.39 €2,585,017.65 VAT) 30 Year Total Whole Life Cost €4,636,011.39 €4,554,011.39 €4,605,017.65 (excluding VAT) 30 Year Total Whole Life Cost €5,261,872.93 €5,168,802.93 €5,226,695.04 (including VAT @ 13.5%) Notes: 1. 4,800m length. 2. 4,500m length. Additional cost of €30,000 included due to additional traffic management due to road width and additional river crossing 3. Details of calculation of outfall O&M cost comparison in Appendix E. O&M commencement year taken as 2015

Nicholas O’Dwyer Ltd. 19 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

5.4 Recommended Outfall Location The assessment of costs in Section 5.3 indicates that the lowest cost option over a 20 year whole life cost is to continue to discharge to the Tubbercurry River. However, the technology required to achieve the required effluent discharge standards, as calculated in Section 3 is new technology and not proven to continuously achieve the standards required. The risk of non-compliance and potential environmental liabilities associated with this are not considered to warrant the cost saving associated with this option. An assessment over a 30 year whole life cost indicates that the lowest cost option is to discharge to the River Moy.

There are potential cost savings on the outfall pipeline in a competitive tender process. It is recommended that a comprehensive site investigation is carried out along this line in order to establish the ground conditions. This will reduce the risk cost associated with the construction of this pipeline.

The cost for Option 1 and Option 2 are similar but due to the potentially higher ecological impact of Option 1 and the greater accessibility of the proposed discharge location for Option 2, Option 2 to discharge at Annagh Bridge is recommended.

It will be required to carry out a Stage 1 Appropriate Assessment Screening for the revised Tubbercurry WWTW and outfall pipeline as part of the planning application for the scheme. This screening report will identify whether a Stage 2 Appropriate Assessment is required. If a Stage 2 Appropriate Assessment is required, a revised planning application will need to be made to An Bord Pleanala.

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

Nicholas O’Dwyer Ltd. 20 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

6 TREATMENT PLANT LAYOUTS

6.1 Tubbercurry Wastewater Treatment Plant Layout The indicative Tubbercurry Wastewater Treatment plant layout has been updated, on Drawing No. 20391-DR-02 to reflect the proposed population equivalent of 3,500 PE. A minimum sludge age of 10 days within the aeration tank is recommended in order to achieve the required effluent ammonia levels. The proposed outfall rising main to the River Moy is shown on Drawing No. 20391-DR-01. A detailed site investigation along the outfall route is recommended in order to establish the ground conditions along the route and ensure a competitive tender. The tertiary filters proposed previously are not now required. However, tertiary filters may be required for future expansion to achieve the effluent nutrient requirements. The required overall aeration volume has decreased by approximately 40% since tender stage as a similar level of nitrogen removal is required for the Tubbercurry WWTP due to the proposal to extend the outfall to the River Moy.

6.2 Grange Wastewater Treatment Plant Layout The indicative Grange Wastewater Treatment plant layout has been updated, on Drawing No. 20391-DR-03 to reflect the proposed population equivalent of 1,100 PE. A minimum sludge age of 10 days within the aeration tank is recommended to provide nitrification in the secondary treatment process. A tertiary filter with nitrification and phosphorus removal is also likely to be required in order to achieve the required effluent ammonia and orthophosphate levels.

The capacity of the proposed wastewater treatment plant in Grange has reduced significantly from tender stage, from 2,500 PE to 1,100 PE. The overall aeration volume will not decrease by the same proportion due to the increased level of nitrification required. A decrease of aeration volume by approximately 25% is anticipated. For inspection purposes only. Consent of copyright owner required for any other use.

6.3 Strandhill Wastewater Treatment Plant Layout The indicative Strandhill Wastewater Treatment plant layout has been updated, on Drawing No. 20391-DR-04 to reflect the proposed population equivalent of 3,000 PE. A minimum sludge age of 10 days within the aeration tank is recommended with an anoxic zone to provide nitrification and denitrification in the secondary treatment process. An indicative layout of the option of primary treatment only is shown on Drawing No. 20391-DR-05.

The capacity of the proposed wastewater treatment plant in Strandhill has reduced from tender stage, from 4,500 PE to 3,000 PE. The overall aeration volume will not decrease substantially due to the increased level of nitrogen removal required to comply with the Dissolved Inorganic Nitrogen standards set in the Surface Water Regulations. An effluent ammonia level of 20mg/l was required previously. It is anticipated that a dissolved inorganic nitrogen standard will be imposed requiring both nitrification and denitrification. The proposed aeration tanks will incorporate anoxic zones to allow denitrification.

Nicholas O’Dwyer Ltd. 21 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

7 CONTRACT PROGRAMME

A contract programme for the upgrade of the scheme is shown overleaf. This includes for carrying out a new Part 8 planning for Tubbercurry. If a full appropriate assessment is required for any of the wastewater treatment plants, a Part XAB planning application will need to be submitted to An Bord Pleanála. The estimated timescale for this has been included on the programme overleaf in order to show the latest expected completion date.

It is recommended that an outfall dispersion model is prepared for Strandhill. Any required extension to the outfall pipeline will require a Foreshore Licence application to be prepared. The timescale for this has not been included on the programme overleaf as it is not known at this stage whether this is will be required.

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

Nicholas O’Dwyer Ltd. 22 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill DBO Bundle Design Review Report

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

Nicholas O’Dwyer Ltd. 23 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

8 UPDATED COSTS ESTIMATES

8.1 Capital Costs Estimates The cost estimate has been prepared based on the 2008 tender cost. The 2008 tender cost in Table 8.1 is the recommended tender cost. The costs have been updated based on an assessment of recent tenders, received up to November 2012, for similar size schemes and a review of the 2008 tender costs from the lowest three tenders. The cost for general items, including design, project management etc. is estimated to be 65% of the 2008 tender cost. The cost for civil works is estimated to be 70% of the 2008 tender cost. The cost for mechanical and electrical works is estimated to be 80% of the 2008 tender cost. The mechanical and electrical costs include a higher proportion of materials which have increased in cost since 2008. Therefore the overall drop in cost is less than for civil works which has a higher proportion of labour. Similarly the general items are largely labour and have a consequently high drop in cost.

The capital costs have been adjusted to take into account for the level of treatment required due to the Surface Water Regulations and the proposed new outfall for Tubbercurry as follows:-

 Cost reduction of 15% for Tubbercurry due to lower PE  Cost reduction of 20% for Grange due to lower PE  Cost reduction of 20% for Strandhill due to lower PE  Cost reduction in Tubbercurry due to removal of tertiary filters  Outfall pumping station, outfall rising main and cost increase for additional for stormwater storage included for Tubbercurry  Additional cost for nitrogen removal and disinfection for Strandhill and outfall upgrade

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

Nicholas O’Dwyer Ltd. 24 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Table 8.1 – Capital Cost Estimates Item Average 2008 Cost Estimate Tender Cost (for revised scope) Section 1. General Items 1,710,500 1,260,000

Section 2. Mechanical & Electrical Works 2.1 Tubbercurry Mechanical & Electrical Works 1,077,130 990,000 2.1A Tubbercurry reduction due to removal of -160,000 tertiary filters 2.1B Tubbercurry - outfall M&E PS 15,000 2.2 Grange Mechanical & Electrical Works 755,830 445,000 2.2A Grange additional nitrogen removal 25,000 2.3 Strandhill Mechanical & Electrical Works 718,780 660,000 2.3A Strandhill disinfection 110,000 2.3B Strandhill additional nitrogen removal 60,000 2.4 Existing Wastewater Treatment Plants - 107,500 62,000 Mechanical & Electrical Works (Gurteen & Carney) 2.5 Ballinfad Mechanical & Electrical Works 285,830 225,000

Section 3. Civil Works 3.1 Civil Works - Tubbercurry WWTW 1,240,525 680,000 3.1A Civil Works - Tubbercurry - removal of tertiary -40,000 filters 3.1B Civil Works - Tubbercurry -outfall PS cost 35,000 3.1C Civil Works - Tubbercurry -outfall cost 768,000 3.2 Civil Works - Strandhill WWTW 1,039,950 530,000 3.2A Civil Works - Strandhill - nitrogen removal 90,000 3.2B Civil Works - Strandhill - disinfection 60,000 3.2C Civil Works - Strandhill - outfall upgrade 100,000 3.3 Civil Works - Grange WWTW 795,240 375,000 For inspection purposes only. 3.3A Civil Works - Grange - additionalConsent ofnitrogen copyright owner required for any other use. 60,000 removal 3.4 Civil Works - Ballinafad WWTW 384,785 160,000

Total (excluding VAT) 8,116,070.00 6,510,000.00 V.A.T. @ 13.5% 1,095,669.45 878,850.00 Total (including VAT) 9,211,739.45 7,388,850

The tendered cost for the recommended tenderer in 2008 was €8,116,070 excluding VAT, i.e. the cost estimate has reduced by €1,606,070 (excluding VAT) since the scheme was tendered in 2008.

8.2 Operation and Maintenance Cost Estimates The operation and maintenance costs have been estimated based on the tendered costs, taking into account the changes to the required treatment levels and plant sizes. There is expected that there could be a small rise in treatment costs due to increases in electricity costs and the more stringent effluent standards proposed at Grange and Strandhill. However, recent tenders have shown a significant drop in cost, which is due to lower labour costs and more competitive

Nicholas O’Dwyer Ltd. 25 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

bids being received. Overall tender costs for operation and maintenance are currently approximately 85% the cost in 2008. The year of commencement for operation and maintenance has been taken as 2015. The populations and cost estimates have been updated to commence the 20 year operation and maintenance period from this date.

Details of the annual operation and maintenance costs for each of the wastewater treatment plants is included in Appendix G and summarised in Table 8.2 below. The 20 year NPV tender cost is the cost for the recommended tenderer based on the population projections included in the tender and may not provide a like for like comparison.

Table 8.2 – 20 Year Operation and Maintenance Cost Summary Wastewater 20 Year NPV 20 year NPV O&M Treatment Plant Tender Cost Total 20 year cost Cost Tubbercurry €1,999,419 €2,890,400 €1,786,280 Grange €1,133,496 €1,404,064 €870,101 Strandhill €1,915,331 €2,575,587 €1,590,744 Gurteen €1,169,218 €1,780,000 €1,081,902 Carney €1,081,281 €1,460,000 €876,221 Ballinafad €541,176 €515,000 €314,407 Total Cost €7,839,922 €10,625,699 €6,520,272 (Excluding VAT) VAT (@ 13.5 %) €1,058,389 €1,434,469 €880,237 Total Cost €8,898,311 €12,060,168 €7,400,508 (Including VAT)

The tendered cost for the recommended tenderer as a 20 year NPV of operation and maintenance costs in 2008 was €7,839,922 excluding VAT, i.e. the operation and maintenance cost estimate has reduced by €1,497,803 (including For inspection purposes only. VAT) since the scheme Consentwas tenderedof copyright owner in required 2008. for any other use.

8.3 Summary of Changes in Cost The overall change to the DBO Contract cost and the associated additional planning, preliminary contracts and tender requirements are summarised in Table 8.3 below to allow a comparison between the 2008 tender cost and the current cost estimate. Costs relating to construction management and construction supervision are not included.

Nicholas O’Dwyer Ltd. 26 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Table 8.3 – Comparison of Current and 2008 Costs 2008 Tender Item Cost Estimate, € Cost, € DBO Contract Total Capital Cost 8,116,070.00 6,510,000.00 Operation and maintenance 20 year NPV 7,839,921.52 6,520,271.54 Total Contract Cost (excluding VAT) 15,955,991.52 13,030,271.54 V.A.T. @ 13.5% 2,154,058.86 1,759,086.66 Total DBO Contract Estimate (including VAT) 18,110,050.38 14,789,358.20

Planning / Tender Stage Costs Design review report 14,800.00 Screening reports (4 No. sites) 9,000.00 Outfall dispersion modelling fees (Strandhill 2,500.00 outfall) Outfall dispersion modelling contract 35,000.00 Archaelogical assessment (Tubbercurry outfall) 1,500.00 Site investigation fees (Tubbercurry outfall) 2,500.00 Site investigation contract 25,000.00 Part 8 Planning (4 No. sites) 10,800.00 Stage 2 Appropriate Assessments (if required) (4 60,000.00 No. sites @ €15,000 per site) Additional cost for Part AXB Planning (4 No. sites) 6,000.00 (if required) Update WSPP, PSB etc. 5,000.00 Tender and prequalification fees 40,000.00

Health and safety costs For inspection purposes only. 7,000.00 Consent of copyright owner required for any other use. Expenses and printing 12,500.00 Total Fees and Planning (excluding VAT) 0.00 221,600.00 V.A.T. @ 21% 0.00 46,536.00 Planning / Tender Stage Costs (including 0.00 268,136.00 VAT)

Total (including VAT) 18,274,281.48 15,069,594.20

Change in Cost from 2008 3,040,456.18

The estimated total reduction in cost from 2008 to the current costs is €3,040,456.18 including VAT.

Nicholas O’Dwyer Ltd. 27 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

9 CONCLUSIONS AND RECOMMENDATIONS

A design review of the proposed wastewater treatment plants in Tubbercurry, Grange and Strandhill has been carried out. The following conclusions and recommendations have been made following the design review:-

1. Effluent standards for discharges have become more stringent due to the implementation of the Surface Water Regulations and the designation of Sligo Bay as a shellfish water. The proposed effluent standards are summarised as follows: Effluent Standards (mg/l) Tubbercurry Grange Strandhill Parameter (3,500 PE) (1,100 PE) (3,000 PE) BOD (mg/l) 25 25 25 Suspended solids (mg/l) 35 35 35 COD (mg/l) 125 125 125 Ammonia (mg.N/l) 3.22 1.68 - Dissolved Inorganic nitrogen (mg.N/l) - - 8.5 Ortho-phosphate (mg.P/l) 1.36 0.84 - Faecal coliforms (no. per 100ml) - - 1 x 103

2. It is proposed to relocate the outfall from Tubbercurry to the River Moy due to the greater dilution available.

3. A detailed site investigation along the proposed route for the Tubbercurry outfall pipeline is recommended.

4. An ecological assessment including a pearl mussel survey was undertaken

for the proposed discharge For inspection locations purposes only. in the River Moy. This assessment indicated that theConsent proposed of copyright owner discharge required for any location other use. at Annagh Bridge has the

lowest potential for ecological impact.

5. Further to the Planning and Development (Amendment) Act 2010, a Stage 1 Appropriate Assessment screening report is required for all developments. A screening report will be required for Tubbercurry, Grange, Strandhill and Ballinafad to assess potential impacts on any Natura 2000 sites.

6. Where the Stage 1 assessment identifies that a Stage 2 Appropriate Assessment is required, a planning application must be submitted to An Bord Pleanála under the Planning and Development (Amendment) Act.

7. An analysis of Strandhill WWTW has shown secondary treatment to be the most economic treatment based on a 20 year NPV analysis.

8. An effluent dispersion model is recommended for Strandhill in order to ensure the impact on the Sligo Bay shellfish water is minimised. The estimated cost for preparing an outfall dispersion model would be: €35,000 including all required surveys.

Nicholas O’Dwyer Ltd. 28 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

9. The total capital cost estimate for the scheme is estimated as €6,510,000 excluding VAT, a reduction of approximately €1.6 million (excluding VAT) since the scheme was tendered in 2008.

10. The 20 year NPV of the Operation and Maintenance Costs is estimated as: €6,520,272 excluding VAT a reduction of approximately €1.32 million (excluding VAT) since the scheme was tendered in 2008.

11. The estimated reduction in capital cost from 2008 to the current costs is: €3,320,692.18. The overall reduction in cost taking into account the additional planning and fees is: €3,040,456.18 including VAT.

12. It is anticipated that the wastewater treatment plants for Tubbercurry, Grange and Strandhill will be complete by mid-2016. The completion date may be expedited to the end of 2015 if Part XAB Planning is not required.

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

Nicholas O’Dwyer Ltd. 29 January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Appendix A

Breakdown of Non-Domestic PE

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date Title By Project Name: Tubbercurry, Grange and Strandhill SS 1.1 25-Jan-13 Non-Domestic PE Calculations F. Lane Sheet: 1 of 1

Tubbercurry

Schools No. Students & Teachers Creche x 3 57 assume 15 children each; 4 staff each School 1100 Schools; secondary 600 pupils,60 staff; primary: 175 pupils; 20 staff; VEC - 150 pupils, 20 staff Total Population from Schools 1157 PE per student/teacher 0.33 Total PE from Schools 382

Commercial Units No. PE per unit PE Public Houses 8 4.0 32 Bar Drinker (10 l/h/d) + Bar Meal (10 l/h/d) = 20 l/h/d (EPA). Assume 45 customers/d. Shops, Offices, Small Business 150 2.0 300 Assume office without canteen (30 l/h/d) as per EPA guidelines. Assume 15 people/d. Fire Station 1 2.0 2 Assume office without canteen (30 l/h/d) as per EPA guidelines. Assume 15 people/d. Take Away 3 0.7 2 Assume Amenity Site (Restaurant) (15 l/h/d) as per EPA guidelines. Assume 10 people per takeaway. Restaurant 8 3.3 27 Assume Amenity Site (Restaurant) (15 l/h/d) as per EPA guidelines. Assume 50 people per restaurant. B&B 3 8.0 24 Assume same as hotel. Guest 250l/h/d (EPA) and assume 7 guests per day. Nursing Home 1 31.1 32 Assume hostipal with nursing home (350l/h/d) as per EPA guidelines. Assume 20 guests / d. Vetinary Clinic 2 2.0 4 Assume office without canteen (30 l/h/d) as per EPA guidelines. Assume 15 people/d. Gym / Fitness Centre Clubs 5 2.7 14 Assume Amenity Site Football Club (30l/h/d) as per EPA guidelines. Assume 20 h/d. Hotel 2 37.8 76 Assume hotel with guests (250l/h/d) as per EPA guidelines. Assume average 34 guests / d. Total Commercial PE 183 513

Total Non-Domestic PE 895

Grange

Schools No. Students & Teachers Creches x 2 38 assume 15 children each; 4 staff each Primary School 55 Vocational School 115 Total Population from Schools 208 PE per student/teacher 0.33 1pe = 225 l/h/d and EPA recommend 40 l/h/d (use 0.33pe/student or staff to be conservative) Total PE from Schools 68.64

Commercial Units No. PE per unit PE Public Houses 3 4.0 12 Bar Drinker (10 l/h/d) + Bar Meal (10 l/h/d) = 20 l/h/d (EPA). Assume 45 customers/d. Shops, Offices, Small Business 28 2.0 56 Assume office with canteen (60 l/h/d) as per EPA guidelines. Assume 15 people per office/shop Factory 3 4.0 12 Assume office with canteen (60 l/h/d) as per EPA guidelines. Assume 15 people per factory Gym /Sports Clubs / Hall 3 2.7 8 Assume Amenity Site Football Club (30l/h/d) as per EPA guidelines. Assume 20 h/d. B&B 2 8.0 16 Assume same as hotel. Guest 250l/h/d (EPA) and assume 7 guests per day. Restaurant 3 3.3 10 Assume Amenity Site (Restaurant) (15 l/h/d) as per EPA guidelines. Assume 50 people per restaurant. Total Commercial PE 42 114

Total Non-Domestic PE 183 For inspection purposes only. Consent of copyright owner required for any other use.

Strandhill

Schools No. Students & Teachers National School 207 192 pupils and 15 teachers as per Preliminary Report Creche 30 Assume 30 in total Total Population from Schools 237 PE per student/teacher 0.33 1pe = 225 l/h/d and EPA recommend 40 l/h/d (use 0.33pe/student or staff to be conservative) Total PE from Schools 78.21

Commercial Units No. PE per unit PE Airport 1 4.0 4 Assume same as pub. Bar Drinker + Bar Meal (10 l/h/d) = 20 l/h/d (EPA). Assume 45 customers/d. B&B 5 8.0 40 Assume same as hotel. Guest 250l/h/d (EPA) and assume 7 guests per day. Service Station 1 2.7 3 Assume office with canteen (60 l/h/d) as per EPA guidelines; 10 staff and customers Caravan Park 1 10.7 11 Assume office with canteen (60 l/h/d) as per EPA guidelines. Assume 40 caravans. Church 1 6.7 7 Assume office without canteen (30 l/h/d) as per EPA guidelines. Assume 50 people/d. Clinic 1 11.1 12 Assume hospital with residential elderly people (250l/h/d) as per EPA guidelines. Assume 10 h/d. Factory 1 4.0 4 Assume office with canteen (60 l/h/d) as per EPA guidelines. Assume 15 people per factory Football Club / Rugby Club 2 2.7 6 Assume Amenity Site Football Club (30l/h/d) as per EPA guidelines. Assume 20 h/d. Golf Club 1 4.4 5 Assume Amenity Site Golf Club (20l/h/d) as per EPA guidelines. Assume 50 h/d. Hotel 4 36.7 147 Assume hotel with guests (250l/h/d) as per EPA guidelines. Assume average 33 guests / d. Apart-Hotel Complex 61 2.2 136 Assume hotel with guests (250l/h/d). Assume average 2 guests/d per appartment x 61 appartments Nursing Home 1 31.1 32 Assume hostipal with nursing home (350l/h/d) as per EPA guidelines. Assume 20 guests / d. Public House 4 4.0 16 Bar Drinker (10 l/h/d) + Bar Meal (10 l/h/d) = 20 l/h/d (EPA). Assume 45 customers/d. Restaurant 6 3.3 20 Assume Amenity Site (Restaurant) (15 l/h/d) as per EPA guidelines. Assume 50 people per restaurant. Seaweed Baths 1 1.8 2 Assume Amenity Site Swimming (10l/h/d) as per EPA guidelines. Assume 40 customers per day. Shop / Office / Hairdresser etc. 31 2.0 62 Assume office without canteen (30 l/h/d) as per EPA guidelines. Assume 15 people/d. Tourist day trips 300 0.04 14 Assume toilet blocks (10 l/h/d) as per EPA guidelines. Assume 300 people/d. Total Commercial PE 422 521

Total Non-Domestic PE 599

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:09 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Appendix B Waste Assimilative Capacity Calculations

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Waste Assimilative Capacity

The waste assimilative capacity of a river is calculated as a mass balance taking into account the difference between the background and allowable concentrations in the receiving waters. The allowable concentrations are set in the Surface Water Regulations.

The waste assimilative capacity is calculated using the following equation:-

WAC = [(Cmax x (Friver + Feff)) - (Cback x Friver)] x 86.4 kg/day in Effluent (Equation 1)

Where WAC = waste assimilative capacity 86.5 = conversion factor to kg/day

Cmax = maximum permissible concentration in river

Cback = background (upstream) pollutant concentration

Ceff = maximum permissible effluent concentration

Friver = river flowrate (taken as 95 percentile river flowrate) 3 Feff = effluent flow m /s

The maximum permissible effluent concentration is calculated as follows:

Ceff = [(WAC / Feff) / 86.4] = effluent concentration (mg/l) (Equation 2)

Rearranging Equation 1, the maximum permissible effluent concentration is calculated as follows:

Ceff = {[(Cmax x (Friver + Feff)) - (Cback x Friver)] / Feff)} = effluent conc. (mg/l) (Equation 3)

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry WwTW 1.2 24-Jan-13 F. Lane Sheet: 1 of 3

Waste Assimilative Capacity (WAC) Calculation

Name of River Tubbercurry Stream

m³/s Data Source m³/d Dry Weather Flow 0.010 Tubbercurry Stream 864 95% Flow 0.025 Tubbercurry Stream 2,160 Mean Annual Flow 0.193 Tubbercurry Stream 16,675

Average Measured Background Conc Allowable Downstream Conc (mean) mg/l Data Source 95%ile mg/l Carbonaceous BOD 0.500 Sligo co co 2008-2012 2.60 Surface Water Regs - Good Status Ammonia Nitrogen (NH) 0.030 Sligo co co 2008-2012 0.14 Surface Water Regs - Good Status Ortho Phosphate (OP) 0.020 Sligo co co 2008-2012 0.075 Surface Water Regs - Good Status Ortho P to Total P Ratio

Dry Weather Flow Flow in River Allowable effluent conc WAC Comments 95 Percentile BOD BOD m³/s m³/s mg/l (95%ile Flow) kg/d 0.0062 0.025 11.05 5.9324 p.e. Current 0.0091 0.025 8.36 6.5835 p.e. Phase I 0.0182 0.025 5.48 8.6310 p.e. Ultimate flow

95 Percentile NH NH m³/s m³/d mg/l kg/d 0.0062 0.025 0.58 0.3128 p.e. Current 0.0091 0.025 0.44 0.3479 p.e. Phase I 0.0182 0.025 0.29 0.4581 p.e. Ultimate flow

95 Percentile OP OP m³/s m³/d mg/l kg/d 0.0062 0.025 0.30 0.1587 p.e. Current 0.0091 0.025 0.23 0.1775 p.e. Phase I 0.0182 0.025 0.15 0.2365 p.e. Ultimate flow

Additional Comments Notional clean water used to calculate assimilative capacity

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry WwTW 1.2 24-Jan-13 F. Lane Sheet: 2 of 3

Waste Assimilative Capacity (WAC) Calculation

Name of River River Moy

m³/s Data Source m³/d Dry Weather Flow 0.180 Flow at Annagh Bridge 15,552 95% Flow 0.500 Flow at Annagh Bridge 43,200 Mean Annual Flow 4.995 Flow at Annagh Bridge 431,568

Average Measured Background Conc Allowable Downstream Conc (mean) mg/l Data Source 95%ile mg/l Carbonaceous BOD 0.986 Sligo co co 2011-2012 2.20 Surface Water Regs - High Status Ammonia Nitrogen (NH) 0.033 Sligo co co 2011-2012 0.09 Surface Water Regs - High Status Ortho Phosphate (OP) 0.021 Sligo co co 2011-2012 0.045 Surface Water Regs - High Status Ortho P to Total P Ratio

Dry Weather Flow Flow in River Allowable effluent conc WAC Comments 95 Percentile BOD BOD m³/s m³/s mg/l (95%ile Flow) kg/d 0.0062 0.500 99.85 53.626 p.e. Current 0.0091 0.500 68.80 54.177 p.e. Phase I 0.0182 0.500 35.50 55.910 p.e. Ultimate flow

95 Percentile NH NH m³/s m³/d mg/l kg/d 0.0062 0.500 4.67 2.511 p.e. Current 0.0091 0.500 3.22 2.533 p.e. Phase I 0.0182 0.500 1.65 2.604 p.e. Ultimate flow

95 Percentile OP OP m³/s m³/d mg/l kg/d 0.0062 0.500 1.98 1.061 p.e. Current 0.0091 0.500 1.36 1.072 p.e. Phase I 0.0182 0.500 0.70 1.108 p.e. Ultimate flow

Additional Comments Revised using chemical analyses data from Sligo Co Co2011-2012 from Station no. 0300 on Moy River at Annagh Bridge Flow data is estimated at Annagh Bridge from 2007 review For inspection purposes only. Consent of copyright owner required for any other use. River Moy has been assigned high ecological status by EPA therefore high status under the Surface Water Regulations is considered appropriate

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry WwTW 1.2 24-Jan-13 F. Lane Sheet: 3 of 3

Waste Assimilative Capacity (WAC) Calculation

Name of River River Moy

m³/s Data Source m³/d Dry Weather Flow 0.190 1.5km d/s at Annagh Bridge 16,416 95% Flow 0.525 1.5km d/s at Annagh Bridge 45,360 Mean Annual Flow 5.188 1.5km d/s at Annagh Bridge 448,243

Average Measured Background Conc Allowable Downstream Conc (mean) mg/l Data Source 95%ile mg/l Carbonaceous BOD 0.986 Sligo co co 2011-2012 2.20 Surface Water Regs - High Status Ammonia Nitrogen (NH) 0.033 Sligo co co 2011-2012 0.09 Surface Water Regs - High Status Ortho Phosphate (OP) 0.021 Sligo co co 2011-2012 0.045 Surface Water Regs - High Status Ortho P to Total P Ratio

Dry Weather Flow Flow in River Allowable effluent conc WAC Comments 95 Percentile BOD BOD m³/s m³/s mg/l (95%ile Flow) kg/d 0.0062 0.525 104.73 56.2486 p.e. Current 0.0091 0.525 72.13 56.7995 p.e. Phase I 0.0182 0.525 37.16 58.5320 p.e. Ultimate flow

95 Percentile NH NH m³/s m³/d mg/l kg/d 0.0062 0.525 4.90 2.6339 p.e. Current 0.0091 0.525 3.37 2.6564 p.e. Phase I 0.0182 0.525 1.73 2.7273 p.e. Ultimate flow

95 Percentile OP OP m³/s m³/d mg/l kg/d 0.0062 0.525 2.07 1.1128 p.e. Current 0.0091 0.525 1.43 1.1241 p.e. Phase I 0.0182 0.525 0.74 1.1595 p.e. Ultimate flow

Additional Comments Revised using chemical analyses data from Sligo Co Co2011-2012 from Station no. 0300 on Moy River at Annagh Bridge Flow data is estimated at Annagh Bridge from 2007 review plus Tubbercurry For inspection Stream purposes flows only. River Moy has been assigned high ecological status by EPAConsent therefore of highcopyright status owner under required the Surface for any Water other Regulations use. is considered appropriate

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Grange WwTW 1.0 14-Aug-12 F. Lane Sheet: 1 of 1

Waste Assimilative Capacity (WAC) Calculation

Name of River Grange River

m³/s Data Source m³/d Dry Weather Flow 0.020 EPA Flow data 1,728 95% Flow 0.040 EPA Flow Data 3,456 Mean Annual Flow 0.345 EPA Flow Data 29,808

Average Measured Background Conc Allowable Downstream Conc (mean) mg/l Data Source 95%ile mg/l Carbonaceous BOD 0.500 Sligo co co 2008-2012 2.60 Surface Water Regs - Good Status Ammonia Nitrogen (NH) 0.030 Sligo co co 2008-2012 0.14 Surface Water Regs - Good Status Ortho Phosphate (OP) 0.020 Sligo co co 2008-2012 0.075 Surface Water Regs - Good Status Ortho P to Total P Ratio

Dry Weather Flow Flow in River Allowable effluent conc WAC Comments 95 Percentile BOD BOD m³/s m³/s mg/l (95%ile Flow) kg/d 0.0016 0.040 53.80 7.6262 p.e. Current 0.0029 0.040 31.92 7.9011 p.e. Phase I 0.0086 0.040 12.37 9.1881 p.e. Ultimate flow

95 Percentile NH NH m³/s m³/d mg/l kg/d 0.0016 0.040 2.82 0.4000 p.e. Current 0.0029 0.040 1.68 0.4148 p.e. Phase I 0.0086 0.040 0.65 0.4841 p.e. Ultimate flow

95 Percentile OP OP m³/s m³/d mg/l kg/d 0.0016 0.040 1.41 0.2001 p.e. Current 0.0029 0.040 0.84 0.2080 p.e. Phase I 0.0086 0.040 0.33 0.2451 p.e. Ultimate flow

Additional Comments Revised using chemical analyses data from Sligo Co Co2008-2012 from Bridge SE of Grogagh Used formula 1 for WAC and mass balance calculation from the Water Services Training Group Guidance Notes. Flow data is as per EPA flow data at Rinroe Ford updated in 2009 For inspection purposes only. WAC includes effluent flows Consent of copyright owner required for any other use.

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Appendix C Ecological Assessments

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:10 Sligo County Council Comhairle Chontae Shligigh

TUBBERCURRY WWTW UPGRADE

Ecological Impact Assessment

Of Proposed Outfall Options

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

January 2013

EPA Export 20-02-2013:23:45:10

SLIGO COUNTY COUNCIL

TUBBERCURRY WwTW UPGRADE

ECOLOGICAL IMPACT ASSESSMENT OF PROPOSED OUTFALL OPTIONS

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

Nicholas O’ Dwyer Ltd., Consulting Engineers, Nutgrove Office Park, Nutgrove Avenue, Dublin 14. January 2013

PROJECT NO. 20391

Revision Reason for Revision Prepared by Reviewed by Approved by Issue Date

- First Issue Serena Keane Fiona Lane Neil Delaney 28/08/2012

A Incorporation of Client Comments Serena Keane Fiona Lane Neil Delaney 28/11/2012

B Population equivalent revised Serena Keane Fiona Lane Neil Delaney 28/01/2013

C

D

EPA Export 20-02-2013:23:45:10

Tubbercurry WwTW Upgrade Ecological Impact Assessment

CONTENTS

1. INTRODUCTION 1 1.1 Existing Works 2 1.2 Proposed Works 4

2. METHODOLOGY 6 2.1 Desk Study 6 2.2 Field Survey 6 2.3 Evaluation and Impact Assessment Criteria 7 2.3.1 Criteria for Assessing Significance of Impact on Terrestrial Sites 8 2.3.2 Criteria for Assessing Significance of Impact on Aquatic Habitats 9 2.4 Limitations to the Ecological Assessment 10 2.5 Pearl Mussel Survey 10

3. RESULTS 12 3.1 Designated Sites 12 3.1.1 Natura 2000 Sites 12 3.1.2 Margaritifera Sensitive Areas 14 3.2 Pearl Mussel Survey 14 3.3 Ecological Assessment of Option 1 15 3.4 Ecological Assessment of Option 2 16 3.5 Habitat Maps (Fossitt, J.A. 2000) 18

4. SITE EVALUATION AND IMPACT SIGNIFICANCE 26 For inspection purposes only. Consent of copyright owner required for any other use. 5. MITIGATION MEASURES 29 5.1 Construction 29 5.2 Operation 30

6. CONCLUSION 31

7. OBLIGATIONS OF LOCAL AUTHORITY RELEVANT TO HABITATS/SPECIES UNDER NATIONAL AND EU LEGISLATION 33 7.1 Consultation 34

Appendix A: Pearl Mussel Survey Appendix B: Consultation

Nicholas O’ Dwyer Ltd. I January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

1. INTRODUCTION

On behalf of Sligo County Council, Nicholas O’ Dwyer Ltd. have prepared an Ecological Impact Assessment as part of the Design Review for the Tubbercurry Wastewater Treatment Works (WwTW) to assess the impacts of the proposed effluent rising main and outfall options on the ecological environment.

The objectives of this report were as follows:  To provide baseline data on habitats, flora and fauna by way of field survey and desk review.  To assess potential impacts of the proposed development on habitats, flora and fauna.  To recommend mitigation measures as considered necessary.  To highlight the principle legal obligations of the County Council in relation to habitats, flora and fauna.

This report is formulated in the context and spirit of the Wildlife Act, 1976 (S.I. No. 39 of 1976), The Wildlife (Amendment) Act, 2000 (S.I. No. 71 of 2001), the EC Council Directive on the Conservation of Natural Habitats of Wild Fauna and Flora 92/43/EEC (better known as the ‘Habitats Directive’), the subsequent transposition of this directive into Irish law – The European Communities (Natural Habitats) Regulations, (S.I. No. 94 of 1997), The European Communities (Natural Habitats) (Amendment) Regulations, 1998 (S.I. No. 233/1998), The Wildlife For inspection purposes only. (Amendment) Bill, 1999Consent (S.I. of copyright No. owner 38 required of for 1999), any other use. The European Communities

(Natural Habitats) (Amendment) Regulations 2005 (S.I. No. 378 of 2005), as well as Council Directive 79/409/EC on the conservation of wild birds – ‘Birds Directive’ (implemented under the Wildlife Acts). This study also considers the Irish Red Data Books and Lists.

This study was carried out with reference as applicable to the Environmental Protection Agency’s (EPA) ‘Guidelines on the Information to be contained in Environmental Impact Statements (March 2002) and Advice Notes on Current Practice (EPA, 2003).

Nicholas O’ Dwyer Ltd. 1 January 20132

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

1.1 Existing Works

The WwTW serving Tubbercurry Town was constructed in the 1970s and is owned and operated by Sligo County Council. The existing WwTW is located to the west of Tubbercurry Town as shown in Figure 1.1 overleaf. The treated effluent discharges via a single outfall to the Tubbercurry River which flows along the northern boundary of the WwTW and discharges into the River Moy Special Area of Conservation (SAC) approximately 5km downstream.

Tubbercurry WwTW was originally designed to treat a load of approximately 1,400 p.e. (population equivalent). However, it is currently overloaded, treating 2,387 p.e resulting in the discharged treated effluent failing to comply with the discharge standards specified in the Urban Waste Water Treatment Regulations, 2001 (S.I. of 254 of 2001). The effluent is also not being treated to a high enough standard to allow the Tubbercurry River to achieve “good status” as defined in the Surface Water Regulations 2009 (S.I. of 272 of 2009). During their 2006 Urban Wastewater Audit of Sligo County Council the Environmental Protection Agency (EPA) reported the Tubbercurry River as being seriously polluted on most occasions since 1990, when surveyed by their biologists. Combined sewer overflows (situated in the centre of town and downstream of the WwTW) and the Tubbercurry WwTW have been identified as the primary cause of this pollution. The unlined grassed plot, which was used for tertiary treatment of effluent prior to discharge to the Tubbercurry River, was identified as having the potential to contaminate groundwater. Under Section 63 of the EPA Act 1992 and For inspection purposes only. Consent of copyright owner required for any other use. 2003 a direction was issued to Sligo County Council on 3 January 2007 requiring them to undertake works at the WwTW and on the sewer network to prevent untreated and/or poorly treated wastewater entering the Tubbercurry River. Screens have now been installed on the combined sewer overflows preventing the discharge of large solids to the watercourse; use of the grass plot at the WwTW to polish the final effluent has ceased; and storm water tanks have been provided, to limit the amount of untreated effluent being discharged during a storm event. The Council is targeting trade effluent discharges to the sewer network to prevent heavy grease loadings on the plant.

Nicholas O’ Dwyer Ltd. 2 January 20132

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

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

Figure 1.1 Location of existing Tubbercurry WwTW

Nicholas O’ Dwyer Ltd. 3 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

1.2 Proposed Works

The upgrade of the existing treatment plant is to be procured via a DBO Contract. These works will all take place within the existing site. The upgrade works will enable the WwTW to provide modern, effective effluent treatment with a proposed design capacity of 3,500 p.e. It is proposed that treated effluent and storm flows in excess of 3DWF (Dry Weather Flow), after 2 hours retention would be discharged to the outfall. Currently two options for the relocation of the outfall to the River Moy are being considered which are described below and presented in Figure 1.2 overleaf.

Option 1: Construction of a new rising main which follows the R294 road for approximately 3km west of the Tubbercurry WwTW, then a local road South West for 2km before discharging to the River Moy in the townland of Tullanaglug south of the confluence with the Tubbercurry River.

Option 2: Construction of a new rising main along the R294 Road to Ballina discharging to the River Moy at Annagh Bridge, approximately 5km to the west of the existing WwTW.

In order to ensure no adverse effects on the integrity of the ecological environment arise, the contractor appointed to construct the outfall will not be permitted to transgress from the design limits or mitigation measures detailed in For inspection purposes only. this report unless it canConsent be ofestablished copyright owner required that for there any other would use. be no adverse effect on

the integrity of the ecological environment in general, in particular the Moy Special Area of Conservation. The contract documents would incorporate the design limits and mitigation measures specified later on in this report, each submitted tender would be robustly examined to ensure strict adherence with these design limits and mitigation measures.

Nicholas O’ Dwyer Ltd. 4 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

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

Rising Main Option 1 Rising Main Option 2

Figure 1.2 Location of proposed works

Nicholas O’ Dwyer Ltd. 5 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

2. METHODOLOGY

2.1 Desk Study

A desk study of the proposed works location was carried out to collate all available information on the ecological environment relevant to the study area. Aerial photography was initially used to classify habitats and to highlight specific areas of ecological interest. Sites of International Importance in proximity to the proposed works were examined. Designated conservation sites of ecological concern include Special Areas of Conservation (SAC) and Special Protection Areas (SPA). Sites of National Importance including Natural Heritage Areas (NHA) and proposed Natural Heritage Areas (pNHA) were also assessed within the wider study area. Furthermore, a review of published literature, including the Sligo County Development Plan 2011-2017 was undertaken in order to collate data on species and habitats of conservation concern on and in the immediate study area. The National Parks and Wildlife Service (NPWS) map viewer and online datasets available on the NPWS website (www.npws.ie) were used for the identification of the boundaries of designated areas and accessing records of protected species from the study areas. The Irish Red Data Book for vascular plants (Curtis and McGough, Wildlife Service Ireland, 1988) and S.I. No. 94/1999, the Flora Protection Order S.I. No. 94/1999 were checked for listed plants in the impact area. The Irish Red Data Book for Vertebrates including threatened mammals, birds, amphibians and fish in Ireland (McGough, Curtis and Whilde, Wildlife Service Ireland, 1993) were also consulted. For inspection purposes only. Consent of copyright owner required for any other use.

2.2 Field Survey

A walk over survey was undertaken of the proposed pipeline routes and outfall location to ascertain the presence of or the potential for protected species and habitats. During the field based survey deviations were made from the route to investigate adjoining areas as considered necessary. Copies of various large scale maps, available data sets and aerial photographs showing the proposed development were used during the field work. Habitats were classified using ‘A Guide to Habitats in Ireland’ (Fossitt, 2000). Particular attention was given to the possible presence of habitats and/or species which are legally protected under Irish or European legislation (especially the Flora Protection Order 1999; Wildlife Act 1976; Wildlife (Amendment) Act 2000; EU Habitats Directive; EU Birds Directive). A habitat map of the two outfall sites was created using GIS analysis. Particular ecological features of interest were marked as Target Notes on the map and accompanied with a photograph.

Nicholas O’ Dwyer Ltd. 6 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

2.3 Evaluation and Impact Assessment Criteria

Designated sites and habitats were evaluated and their significance assessed using the system developed by conservation services and published in ‘Guidelines for Assessment of Ecological Impacts of National Road Schemes (NRA 2004)’. Sites and habitats were evaluated using Table 2.1 below and given an overall significance rating on the basis of the criteria outlined in Table 2.2 for terrestrial habitats and Table 2.3 for aquatic habitats. The value of a site depends on its local, national or international importance and the impact is assessed based on the amount of habitat affected.

Table 2.1 Site Evaluation Scheme Rating Qualifying Criteria

Internationally important  Sites designated (or qualifying for designation) as SAC* or SPA* under the EU Habitats or Birds Directives. A  Undesignated sites containing good examples of Annex I priority habitats under the EU Habitats Directive.  Major salmon river fisheries.  Major salmonid (salmon, trout or char) lake fisheries. Nationally important  Sites or waters designated or proposed as an NHA* or statutory Nature Reserves.  Undesignated sites containing good examples of Annex I habitats (under EU Habitats Directive).  Undesignated sites containing significant numbers of resident or B regularly occurring populations of Annex II species under the EU Habitats Directive or Annex I species under the EU Birds Directive or species protected under the Wildlife (Amendment) Act 2000. For inspection purposes only.  MajorConsent trout of river copyright fisheries. owner required for any other use.

 Water bodies with major amenity fishery value.  Commercially important coarse fisheries. High value, locally important  Sites containing semi-natural habitat types with high biodiversity in a local context and a high degree of naturalness, or significant populations of locally rare species.

 Small water bodies with known salmonid populations or with good

potential salmonid habitat.

C  Sites containing any resident or regularly occurring populations of Annex II species under the EU Habitats Directive or Annex I species under the EU Birds Directive.  Large water bodies with some coarse fisheries value. Moderate value, locally important  Sites containing some semi-natural habitat or locally important for wildlife. D  Small water bodies with some coarse fisheries value or some potential salmonid habitat.  Any water body with unpolluted water (Q-value rating 4-5).

Nicholas O’ Dwyer Ltd. 7 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

Table 2.1 Site Evaluation Scheme cont’d Rating Qualifying Criteria Low value, locally important  Artificial or highly modified habitats with low species diversity E and low wildlife value.  Water bodies with no current fisheries value and no significant potential fisheries value.

* SAC = Special Area of Conservation, SPA= Special Protection Area, NHA= Natural Heritage Area

2.3.1 Criteria for Assessing Significance of Impact on Terrestrial Sites

The guidelines used for assessing the significance of impacts on terrestrial flora and fauna are outlined in Table 2.2 below.

Table 2.2 Criteria for Assessing Impact Significance (Terrestrial Sites) Site A sites B sites C sites D sites E sites category* ► Internationally Nationally High Moderate Low important important value, value, value, locally locally locally Impact level important important important ▼ Severe Any permanent Permanent negative impacts impacts on a large part of a site Major Temporary Permanent Permanent negative impacts on a impacts on impacts on large part of a a small part a large site of a site part of a For inspection purposes only.site Consent of copyright owner required for any other use. Moderate Temporary Temporary Permanent Permanent negative impacts on a impacts on impacts on impacts on a small part of a a large part a small large part of site of a site part of a a site site Minor Temporary Temporary Permanent Permanent negative impacts on impacts on impacts on a impacts on a small part a large small part of a large part of a site part of a a site of a site site Neutral No impacts No impacts No impacts No impacts Permanent impacts on a small part of a site Minor Permanent Permanent positive beneficial beneficial impacts on a impacts on small part of a large part a site of a site

Nicholas O’ Dwyer Ltd. 8 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

Table 2.2 cont’d Criteria for Assessing Impact Significance (Terrestrial Sites) Site A sites B sites C sites D sites E sites category* ► International Nationally High Moderate Low ly important important value, value, value, locally locally locally Impact level important important important ▼ Moderate Permanent Permanent positive beneficial beneficial impacts on impacts on a a small large part of part of a a site site Major Permanent Permanent positive beneficial beneficial impacts on impacts on a small part a large of a site part of a site

* Site categories A to E are defined in Table 2.1.

2.3.2 Criteria for Assessing Significance of Impact on Aquatic Habitats

Aquatic impacts are defined on the basis of severity of impact on salmonid fish or any rare, protected, or commercially significant species and/or habitats. Assessment of the importance of a potential impact takes into account not only the ecological considerations in the immediate vicinity of the potential impact, but also geographical and wider catchment considerations. If spawning and nursery habitat are limiting factors in short supply in a particular river system, then impacts on them will have an importance out of proportion with their apparent For inspection purposes only. face value. Because of Consenttheir of amenity, copyright owner commercial required for any other and use. legal status, salmonid fish

(trout and salmon) are given special consideration. If an aspect of a proposed development is judged likely to have a measurable negative effect on salmonid fish populations, it would be classified as a significant potential impact. The guidelines used for assessing the significance of impacts on flora, fauna and fisheries are outlined overleaf in Table 2.3.

In line with the EPA guide lines (EPA 2002) the following terms are defined when quantifying duration;

 Temporary: Up to 1 year  Short term: From 1 to 7 years  Medium term: 7 to 15 years  Long term: 15-16 years  Permanent: over 60 years

Nicholas O’ Dwyer Ltd. 9 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

For the purposes of this report ‘localised’ impacts on rivers are loosely defined as impacts measurable no more than 250 meters from the impact source. Any impact on salmonid spawning habitat or nursery habitat where it is in short supply would be regarded as an extensive impact as it is likely to have an impact on the salmonid population beyond the immediate vicinity of the impact source.

Table 2.3 Criteria for Assessing Impact Significance (Aquatic Sites)

Site Extent of Duration Medium- Category Impact Temporary Short-term Long-term term Extensive Major Severe Severe Severe A site Localised Major Major Severe Severe Extensive Major Major Severe Severe B site Localised Moderate Moderate Major Major Extensive Moderate Moderate Major Major C sites Localised Minor Moderate Moderate Moderate Extensive Minor Minor Moderate Moderate D sites Localised Not significant Minor Minor Minor Extensive Not significant Not significant Minor Minor

E sites Localised Not significant Not significant Not significant Not significant * Site categories A to E are defined in Table 2.1.

2.4 Limitations to the Ecological Assessment

The field survey was undertaken in August 2012 when a variety of plants are in flower and easily identifiable and animal activity is relatively high. This report presents a broad ecological assessment based on habitat classification rather than For inspection purposes only. a detailed list of species.Consent This of copyrightlevel ownerof detail required foris anysuff othericient use. to assess the value of the

habitats. Overall no significant difficulties were encountered in compiling information on the flora and fauna of the study area. As the Moy is designated as a Margaritigifera sensitive area a specific pearl mussel survey for a 4.1km stretch between Annagh Bridge and Banada was deemed necessary. The methodology is described below in Section 2.5 in detail, and the full report is included in Appendix A of this document.

2.5 Pearl Mussel Survey

Very little information is available on the current distribution of Margaritifera in the upper River Moy. Margaritifera was known to occur further upstream of Annagh Bridge in the Owenaher River (NPWS Database) and shells have also been recorded further downstream at Cooleen Bridge (O’Connor 2004). In order to assist with assessment of the potential impacts of these proposed effluent discharge points, an investigation of the distribution of Margaritifera margaritifera

Nicholas O’ Dwyer Ltd. 10 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

(L.) was undertaken by Dr Eugene Ross in the River Moy between Annagh Bridge and Banada Bridge. The full report is included in Appendix A.

A preliminary site visit took place on August 10th, and the survey was conducted on August 12th and 13th, 2012 using modified Stage 1 Margaritifera Survey methodology. A total of 4.1km of the River Moy was investigated, starting immediately upstream of Annagh Bridge and finishing at Banada Bridge. A Bic Tobago SOT kayak was used to travel downstream from Annagh Bridge to Banada Bridge, and to facilitate observation of the river substrate while travelling between the 42 pre-defined search locations located at intervals of 100m along the 4.1km stretch investigated. At each of these locations, two 2m long transects were searched for Margaritifera. The grid references of transects searched were recorded using a Garmin GPS60 hand held global positioning device. The transects were searched for Margaritifera by wading while observing the river substrate with a bathyscope. Where necessary, deeper transects were searched by snorkelling. A diving torch was used to illuminate the substrate in any heavily shaded areas and mussel abundance was to be estimated according to the ACFOR scale as follows:

a. Abundant / at capacity in places (> 1,500 / 100m length river, if at capacity > 250 / m² in appropriate habitat) b. Common to good numbers, not at capacity (301 – 1,500 / 100m length river) For inspection purposes only. c. Frequent (41 – 300Consent / of100m copyright lengthowner required river) for any other use.

d. Occasional / Rare (1 to 40 / 100m length river) e. Absent

At each location where transects were searched, additional data on river depth, substrate composition, in-stream vegetation, water state, and silt plume kick test were recorded. Site descriptive photographs were taken at each location investigated.

Nicholas O’ Dwyer Ltd. 11 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

3. RESULTS

The results of the Ecological Impact Assessment and specialist Pearl Mussel Survey are presented below. Habitat maps with associated Target Notes of both proposed outfall location are presented in Section 3.4 below. Habitats have been classified according to “A Guide to Habitats in Ireland” (Fossitt, J.A. 2000). Target Notes highlight distinguishing features, flora and fauna.

3.1 Designated Sites

3.1.1 Natura 2000 Sites

Special Areas of Conservation (SACs) are sites of international importance designated for the presence of listed habitats or species that are of European importance. Special Protection Areas (SPAs) are sites of international importance designated because of the presence of bird populations that are of European importance. Sites of national importance in the Republic of Ireland are termed Natural Heritage Areas (NHA’s) or proposed Natural Heritage Areas (pNHA).

Both proposed outfall locations discharge directly to the River Moy. The River Moy forms part of the River Moy SAC (Site Code: 002298), a map of which is presented in Figure 3.1 below. The proposed pipeline routes are along roadways for most of their length. Both rising main options traverse tributaries and the main channel of the Tubbercurry River four times. Although not designated as part of the Moy SAC, these tributaries and the Tubbercurry River all discharge to

the River Moy which forms part For inspection of the purposes Moy only. SAC. Consent of copyright owner required for any other use.

The Moy SAC comprises almost the entire freshwater element of the Moy and its tributaries including both Loughs Conn and Cullin. The site is a candidate SAC selected for alluvial wet woodlands and raised bog, both priority habitats on Annex I of the E.U. Habitats Directive. The site is also a candidate SAC selected for old oak woodlands, alkaline fens, degraded raised bog and Rhynchosporion, all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive – Atlantic Salmon, Otter, Sea and Brook Lamprey and White-clawed Crayfish.

The works do not have the potential to impact on any Special Protection Areas or National Heritage Areas.

Nicholas O’ Dwyer Ltd. 12 January 2013

EPA Export 20-02-2013:23:45:10 Tubbercurry WwTW Upgrade Ecological Impact Assessment

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

Rising Main Option 1 Rising Main Option 2

Fig 3.1 Location of Moy Special Area of Conservation and locations where the rising main options traverse the Tubbercurry River

Nicholas O’ Dwyer Ltd. 13 January 2013

EPA Export 20-02-2013:23:45:10

Tubbercurry WwTW Upgrade Ecological Impact Assessment

3.1.2 Margaritifera Sensitive Areas

The Sligo part of the River Moy is designated as a Margaritifera Sensitive Area. A map of all Margaritifera Sensitive Categories are included in Appendix B provided through consultation with the National Parks and Wildlife Service.

The sensitive area category for which this section of the River Moy is designated is “Catchments of other extant populations”. These mussel populations may lie (in part) within SAC, other nature conservation sites or in the wider countryside. Those populations within SAC were not considered of sufficient quality to warrant designation for the species and detailed restoration objectives, targets, plans or measures are unlikely to be developed. However, the potential effects of any plans, developments or activities on the populations, including the potential to cause ‘environmental damage’ as per the Environmental Liability Directive and Regulations, must be determined through SEA, EIA or other ecological assessment. Very little information is available on the current distribution of Margaritifera in the upper River Moy. Margaritifera was known to occur further upstream of Annagh Bridge in the Owenaher River (NPWS Database) and shells have also been recorded further downstream at Cooleen Bridge (O’Connor 2004). In order to assist with assessment of the potential impacts of these proposed effluent discharge points, an investigation of the distribution of Margaritifera margaritifera (L.) was undertaken in the River Moy For inspection purposes only. between Annagh BridgeConsent and of Banada copyright owner Bridge. required for any other use.

3.2 Pearl Mussel Survey

The findings of the pearl mussel survey were as follows  The river habitat in the 4.1km stretch of the upper River Moy investigated was generally homogeneous, consisting mainly of slow glide habitat with unstable, mobile, heavily silted sand, gravel and cobble substrates, which are generally not suitable for Margaritifera margaritifera.  A single live specimen of Margaritifera was found, but no concentrations of mussels were observed in the 4.1km long stretch investigated and no high quality habitat capable of supporting juvenile Margaritifera was observed. It was concluded that only a very small number of mussels are present in the stretch of the upper River Moy investigated.  Although no habitat that could be described as ideal for Margaritifera was observed, the highest quality habitat observed was located between 1300m

Nicholas O’ Dwyer Ltd. 14 January 2013

EPA Export 20-02-2013:23:45:10

Tubbercurry WwTW Upgrade Ecological Impact Assessment

and 2400m downstream of Annagh Bridge. This stretch included the site where the live mussel was recorded, the Tubbercurry River confluence and the location of the downstream potential effluent discharge point (Option 1) at Tullanaglug/Creghassaun.

3.3 Ecological Assessment of Option 1

This option involves the construction of a new rising main which follows the R294 road for approximately 3km west of the WwTW, then a local road South West for 2km before discharging to the River Moy in the townland of Tullanaglug as shown in Figure 3.1 above. A habitat map of the proposed discharge location is presented Figure 3.2 of Section 3.5.

Habitats The proposed pipeline is located within roadways for nearly its entire length. Habitats adjacent to the pipeline include improved and semi-improved agricultural grassland, degraded blanket bog and blanket bog. The pipeline traverses the main channel and tributaries of the River Tubbercurry four times. Although not designated as part of the Moy SAC, these tributaries all discharge to the River Moy which forms part of the Moy SAC. The proposed discharge location is to the River Moy at Tullanaglug south of the confluence with the Tubbercurry stream (See Target Note 4, Section 3.5).The River Moy is designated as part of the River Moy SAC (Site Code: 002298) at this location. This option also traverses a small For inspection purposes only. area of GM1 marsh/GS4Consent wet of copyright grassland owner required dominated for any other use. by juncus species, grass and

iris and located within the Moy SAC boundary for approximately 40 metres before discharging to the River Moy (See Target Note 7, Section 3.5). A number of immature willow trees are located on the eastern bank at the discharge location, with grasses and sedges forming the ground flora. The proposed pipeline also crosses an intensively managed hedgerow of low ecological value. No habitats protected by the SAC are traversed by the proposed pipeline route or were recorded in the downstream reach of the discharge location. The river has been classified as FW2 Depositing Lowland River, and at the discharge location the river forms a slow flowing glide as shown in (Target Note 4, Section 3.5). The river bed throughout is comprised mainly of gravel with occasional sand and cobbles at this location. The EPA has sampled sites at discharge location 1 giving a Q rating of 2-3 which is poor ecological status.

Nicholas O’ Dwyer Ltd. 15 January 2013

EPA Export 20-02-2013:23:45:10

Tubbercurry WwTW Upgrade Ecological Impact Assessment

Aquatic Fauna Appropriate spawning habitat for lamprey and salmon was not recorded at this discharge location, however salmon do run the Moy throughout the year and smolts generally migrate downstream between April and June. The closest downstream salmon spawning location is at Banada, 2.5km downstream of discharge location No. 1. The site also provides sub optimal habitat for crayfish. Salmon, lamprey and crayfish prefer good water quality. However the river at this location has been assigned an ecological rating by the EPA of Q2-3 which is poor ecological status. It is worth noting that at this location no crayfish were sited during the pearl mussel survey.

The site does offer suitable habitat for otter, although no evidence of recent use (spraint, footprints, potential holts) has been recorded. Otter have been recorded however, within 2km of the proposed discharge location (National Biodiversity Data Centre).

Habitat which could support juvenile Margaritifera was not recorded during the pearl mussel survey at this site. No shells or live pearl mussels were recorded downstream of the proposed discharge location during the pearl mussel survey.

Terrestrial fauna Badgers have been recorded within 2km of the proposed works (National For inspection purposes only. Biodiversity Centre). HabitatsConsent of copyright traversed owner required by for thisany other the use. rising main option do not

provide suitable habitat for this species.

Birds The following protected bird species have been recorded within 2km of the proposed outfall location, the skylark, common kingfisher, mallard, barn swallow, blackheaded gull, spotted fly catcher, sand martin and common starling (National Biodiversity Data Centre). The proposed discharge location has potential foraging habitat for sand martins and kingfisher.

3.4 Ecological Assessment of Option 2

This option involves the construction of a new rising main along the R294 Road to Ballina discharging to the River Moy at Annagh Bridge, 5km to the west of Tubbercurry as shown in Figure 3.1 above. A habitat map of the proposed discharge location is presented in Figure 3.3 of Section 3.5.

Nicholas O’ Dwyer Ltd. 16 January 2013

EPA Export 20-02-2013:23:45:11

Tubbercurry WwTW Upgrade Ecological Impact Assessment

Habitats The proposed pipeline is located within roadways for nearly its entire length. Habitats adjacent to the pipeline include improved and semi-improved agricultural grassland, degraded blanket bog and blanket bog. The pipeline traverses the main channel and tributaries of the River Tubbercurry 4 times. Although not designated as part of the Moy SAC, these tributaries all discharge to the River Moy which forms part of the Moy SAC. The proposed discharge location is to the River Moy at Annagh Bridge (See Target Note 1, Section 3.5). The River Moy is designated as part of the River Moy SAC (Site Code: 002298) at this location. No habitats protected by the SAC are traversed by the proposed pipeline route. They are also absent from the downstream reach from the proposed discharge location.

At the discharge location a number of immature ash trees are located on the bank. However they do not form a continuous tree line as shown in Target Note 1, Fig 3.5. The ground flora is dominated by grasses. The river has been assigned a classification of FW2 Depositing Lowland River. The vast majority of the water surface had a smooth to rippled appearance which is associated with glides and runs, although a very short riffle was present immediately downstream of the bridge due to the altered flow and deposition rate caused by the bridge abutments. The EPA has sampled sites at discharge location 2 giving a Q rating of 4-5, high ecological status.

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

The reach downstream of the bridge was considered to offer sub-optimal spawning habitat for salmon and lamprey, largely in view of the relatively slow flow, but also the paucity of suitable substrate (dominated by coarse sand with only low levels of gravel). Juvenile salmon and lamprey (O’Connor, 2004) have however been previously recorded at this site therefore some juvenile salmon and lamprey habitat is considered to be present. The closest downstream salmon spawning location is at Banada, 4.5km downstream of discharge location No. 1. Although the site does have some potential for crayfish and although the River Moy was selected as an SAC partly for the presence of freshwater crayfish (Austropotamobius pallipes), none were observed at any of the sites investigated as part of the pearl mussel survey between Annagh Bridge and Banada Bridge, see Appendix A.

Nicholas O’ Dwyer Ltd. 17 January 2013

EPA Export 20-02-2013:23:45:11

Tubbercurry WwTW Upgrade Ecological Impact Assessment

The site offers suitable habitat for otter. During the field survey otter spraint was recorded under Annagh bridge (See Target Note 2, Section 3.5) and a possible otter slide was recorded on the western bank of the river upstream of Annagh bridge (See Target Note 3, Section 3.5). Otter spraint was also recorded during the pearl mussel survey downstream of the bridge on a rock on the Eastern bank (See Target Note 2, Section 3.5).

No habitat of sufficiently high quality to support Margaritifera was observed at this site during the pearl mussel survey. A single live pearl mussel was recorded approximately 1.4km downstream of the discharge location.

Terrestrial fauna Badgers have been recorded within 2km of the proposed works (National Biodiversity Centre). Habitats traversed by this pipeline option do not provide suitable habitat for this species. The following species of bat have been recorded within 2km of the proposed works, daubentons bat and soprano pipistrelle (National Biodiversity Data Centre). The juvenile ash trees located in the proximity of the proposed discharge route do not provide suitable roosting habitat for these species. Bats, in particular daubentons bat, are likely to use the river corridor for foraging and it is feasible that bats may be roosting in crevices underneath Annagh Bridge.

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

The following protected bird species the sand martin and kingfisher were recorded in 2010 within 2km of this proposed discharge location (National Biodiversity Data Centre). The proposed discharge location has potential foraging habitat for both species. No nests were observed in the bank of the proposed discharge location during the site visit.

3.5 Habitat Maps (Fossitt, J.A. 2000)

Habitats for the proposed rising main and outfall options are presented overleaf in Figure 3.2 and 3.3. Habitats have been classified according to “A Guide to Habitats in Ireland” (Fossitt, J.A. 2000). Target Notes highlight distinguishing features, flora and fauna.

Nicholas O’ Dwyer Ltd. 18 January 2013

EPA Export 20-02-2013:23:45:11

Tubbercurry WwTW Ecological Impact Assessment

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

Fig 3.2 Option 1 Habitat Map (using Fossits 2000 habitat classification system) with Target Notes.

Nicholas O’ Dwyer Ltd. 19 January 2013

EPA Export 20-02-2013:23:45:11

Tubbercurry WwTW Ecological Impact Assessment

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

Fig 3.3 Option 2 Habitat Map (using Fossits 2000 habitat classification system) with Target Notes.

Nicholas O’ Dwyer Ltd. 20 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Ugrade Ecological Impact Assessment

Habitat Map Target Notes Option 1: Target Note 4 The River Moy is slow flowing and a glide at discharge location 1 as shown in Figure 3.9 below.

Figure 3.9: Photo taken during pearl mussel survey downstream of discharge location looking upstream. Two photos showing right and left hand banks.

Option1: Target Note 5 One live pearl mussel was recorded during the pearl mussel survey and is shown below in Figure 3.10. The live pearl mussel was located upstream of confluence with Tubbercurry stream and the proposed discharge location 1.

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

Figure 3.10 Live pearl mussel recorded upstream of the Tubbercurry stream

Nicholas O’ Dwyer Ltd. 21 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Ugrade Ecological Impact Assessment

Option 1: Target Note 6 Pearl mussel shells were recorded upstream of proposed discharge location 1 and downstream of confluence with Tubbercurry river as shown below in Figure 3.11.

Figure 3.11 Pearl mussel shell recorded upstream of proposed discharge location

Option 1: Target Note 7 Area of wet grassland/marsh shown below in Figure 3.12 is traversed by the proposed effluent rising main. A line of immature willow indicates the river bank and proposed outfall location. Hedgerow to the front of Fig 3.12 is intensively managed and of low ecological value.

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

Figure 3.9 Wet grassland/marsh traversed by proposed discharge location 1.

Nicholas O’ Dwyer Ltd. 22 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Ugrade Ecological Impact Assessment

Option 2: Target Note 1: Location of proposed outfall is presented in Figure 3.4 and 3.5 below. Riparian vegetation includes ash trees and beech, ragworth, bramble, nettle, and a variety of grass and sedge species.

Fig 3.4 Taken from Annagh bridge, looking downstream. The proposed discharge location is on the left hand bank

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

Fig 3.5 Taken facing proposed discharge location from opposite bank. Proposed discharge location is dominated by grasses with immature ash trees.

Nicholas O’ Dwyer Ltd. 23 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Ugrade Ecological Impact Assessment

Option 2: Target Note 2 Otter spraint was recorded under Annagh Bridge during the Ecological Impact Assessment as shown in Figure 3.6 below and just downstream of Annagh Bridge during the pearl mussel survey as shown in Figure 3.7.

Figure 3.6 Otter spraint under Annagh bridge

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

Figure 3.7 Otter spraint downstream of Annagh bridge

Nicholas O’ Dwyer Ltd. 24 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Ugrade Ecological Impact Assessment

Option 2: Target Note 3 A potential otter slide was recorded upstream of Annagh Bridge on the western bank as shown in Figure 3.8 below.

Figure 3.8. Potential Otter Slide

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

Nicholas O’ Dwyer Ltd. 25 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Ugrade Ecological Impact Assessment

4. SITE EVALUATION AND IMPACT SIGNIFICANCE

The scheme of evaluating habitats and assessing the significance of impacts on fauna, flora and fisheries is outlined in Section 2.3 above. Table 4.1 overleaf describes the potential impacts of the proposed works.

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

Nicholas O’ Dwyer Ltd. 26 January 2013

EPA Export 20-02-2013:23:45:11

Tubbercurry WwTW Upgrade Ecological Impact Assessment

Table 4.1 Assessment of Significance of Impact of Works on Sites/ Habitats traversed by the proposed works.

Site (code) Description Evaluation Impact Impact significance River Moy SAC Qualifying interests of this habitat A Option 1 & Option 2: Option 1 & Option 2 include: Internationally No potential for impacts on A Stage 1 Screening for White-clawed crayfish Important the habitats protected by the Appropriate Assessment will Sea lamprey SAC as they are not located be carried out for the Brook lamprey within zone of impact of the proposed works to assess the Salmon proposed works. impacts of the proposed Otter works on the conservation Active raised bogs Potential for indirect impacts interests of Natura 2000 sites. Degraded raised bogs still capable such as surface water run-off of natural regeneration from construction activities. It is anticipated that Depressions on peat substrates of Potential of disturbance to the mitigation measures as the Rhynchosporion following species from proposed in Section 5 of this Old sessile oak woods with Ilex instream construction document would ensure no and Blechnum in British Isles activities. significant impact from either Alluvial forests with Alnus Option 1 or 2 on the glutinosa and Fraxinus excelsior White-clawed crayfish conservations interest of the (Alno-Padion, Alnion incanae, Sea lamprey River Moy SAC. Salicion albae) Brook lamprey Salmon (Salmo salar) It is likely that there will be Other important habitats & Otter (Lutra lutra) an improvement in water species; quality in the River Moy Trout/freshwater pearl Potential impact from effluent downstream of the confluence mussel,FW2 depositing lowland on the following species: with the Tubbercurry River river For inspection purposes only. given the improvement in Consent of copyright owner required for any other use. White-clawed crayfish effluent quality associated Sea lamprey with the WwTW upgrade. Brook lamprey Salmon (Salmo salar) Otter (Lutra lutra) GS4 Wet grassland This habitat is dominated by iris C Option 1: Option 1: /GM1 marsh and juncus species and may High Value This habitat will be directly Moderate negative provide foraging habitat for Locally Important impacted by construction wetland birds. works associated with the proposed pipeline.

Option 2: Option 2 No impact No impact

Nicholas O’ Dwyer Ltd. 27 January 2013

EPA Export 20-02-2013:23:45:11

Tubbercurry WwTW Upgrade Ecological Impact Assessment

Table 4.1 Cont'd Assessment of Significance of Impact of Works on Sites/ Habitats traversed by the proposed works.

Site (code) Description Evaluation Impact Impact significance

WL 2 Treeline/ A small area of riparian trees and C Option 1: Option1: WS1 scrub scrub and ground flora will require High Value Riparian vegetation is more Moderate negative removal for both options. Potential Locally Important diverse than option 2 and a foraging habitat for kingfishers number of young willows will and sand martins. require removal.

Option1: habitat is predominantly Option 2: Option 2: grass and juvenile willow trees The riparian vegetation is not Minor negative of high ecological value. May Option 2: predominantly grass require removal of one or two species and juvenile ash trees. juvenile ash trees.

WL1 Hedgerow One ornamental Hedgerow, highly E Option 1: Option1: managed will need to be traversed Low value, Direct impact from removal of Minor negative by Option 1. Locally important section of hedgerow to accommodate pipeline.

Option 2: Option 2: No impact No impact FW 2 Depositing The Tubbercurry river is a B Option 1 & Option 2 Option 1 & Option 2 Lowland River Salmonid River. Crayfish have also High value, This habitat may be Without the implementation been recorded on the river. Nationally temporarily impacted on by of mitigation measures as important construction works if proposed in Section 5 the For inspection purposes only. Consent of copyright owner required for anymitigation other use. measures as potential impacts are proposed in Section 5 are not assessed as moderate implemented. negative.

The operation of the upgraded WwTW using either A positive impact is outfall option will result in a anticipated on water quality significant impovement in within the Tubbercurry river water quality within the following the WwTW upgrade. Tubbercurry River.

Nicholas O’ Dwyer Ltd. 27 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

5. MITIGATION MEASURES

5.1 Construction

Aquatic Environment The contractor should follow all guidelines in the “Requirements for the Protection of Fisheries Habitat during Construction and Development Works at River Sites” published by the Eastern Regional Fisheries Board in 2004. A site briefing should be held with site personnel prior to commencement of works to notify them of appropriate construction related mitigation measures. The following specific mitigation measures should be implemented at potential impact locations.

 Contractor to produce method statement which should be approved by NPWS and Inland Fisheries Ireland. Method statement should include the following: o A coffer dam to be used during instream channel works o Dewatered water to pass through settlement tanks prior to return to the river o In channel works to be carried out between May and September o Work to avoid wet weather conditions o Adoption of additional pollution prevention measures outlined in relevant guidance.  Chemicals stored in bunded areas away from the river and secure/removed overnight.  Any refuelling must be carried out in bunded areas of 110% volume at least For inspection purposes only. Consent of copyright owner required for any other use. 50m away from banks.  Contractors to have an appropriate emergency response plan in place in the event of spillages.  Rising main to be installed by trenchless technology  Minimal vegetation clearance at bank.  River to be passable to fish at all time during works  A pre-construction check for otters should be undertaken prior to works commencing.  River corridor to be passable to otter at all times  All works to be carried out during daylight hours to avoid negative impacts on otter and bats.  If necessary crayfish rescue to be performed by ecologist during initial dewatering of working area.  Fish rescue to be performed by an ecologist during initial dewatering of working area.

Nicholas O’ Dwyer Ltd. 29 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

Terrestrial environment  During scrub/tree/riparian vegetation removal, strict attention should be given to the removal of only what is absolutely necessary. Sections to be removed should be carefully measured and marked prior to the arrival of construction machinery.  Mature trees should only be removed where absolutely necessary.  Trees being retained at the margins of wayleaves should be temporarily fenced or at least identified by tape to avoid accidental collisions from construction machinery and damage to root systems.  Section 40 of the Wildlife Act 1976, as amended by Section 46 of the Wildlife (Amendment) Act 2000, restricts the cutting, grubbing, burning or destruction by other means of vegetation growing on uncultivated land or in hedges or ditches during the nesting and breeding season for birds and wildlife, from 1 March to 31 August. Unless the site qualifies for an exemption under the Acts, and such is agreed with the NPWS, removal of hedgerows and trees should be done outside of the restricted period to prevent the destruction of active bird’s nests.

5.2 Operation

 Effluent quality should be of a standard to allow good ecological quality to be achieved at discharge location 1 and to enable high ecological status to be maintained at the Option 2 Annagh Bridge.  A Waste Water Discharge License will be required from the Environmental For inspection purposes only. Protection Agency. ConsentIn this of copyright license owner therequired EPA for any wi otherll decideuse. on appropriate effluent

standards to be implemented to ensure that high ecological status is maintained at discharge location 2 or to enable good status to be achieved at discharge location 1.  The WwTW should be designed and operated to ensure that appropriate effluent standards are met to allow the River Moy to achieve its objectives under the Water Framework Directive.  Sufficent storm water storage should be provided to ensure a minimum retention time of 2 hours for peak flows.  Discharge rates should be controlled to ensure effluent flow does not disrupt the natural flow pattern of the river.

Nicholas O’ Dwyer Ltd. 30 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

6. CONCLUSION

Natura 2000 Sites Both proposed outfall locations discharge directly to the River Moy. The River Moy forms part of the River Moy SAC (Site Code: 002298). The proposed pipeline routes are along roadways for most of their length. Both rising main options traverse tributaries and the main channel of the Tubbercurry River 4 times. Although not designated as part of the Moy SAC, these tributaries all discharge to the River Moy which forms part of the Moy SAC. In accordance with the Habitats Directive 92/33/EEC (2000) any plan or project that has the potential for a significant effect on a Special Area of Conservation (SAC) or Special Protected Area (SPA) must be screened in order to determine whether an Appropriate Assessment is required.

The site is a candidate SAC selected for alluvial wet woodlands and raised bog, old oak woodlands, alkaline fens, degraded raised bog and Rhynchosporion, all habitats listed on Annex I of the E.U. Habitats Directive. The proposed works associated with either option do not have the potential to impact on these habitats as they are not located within the zone of impact of the works. The site is also selected for the following species listed on Annex II of the same directive – Atlantic Salmon, Otter, Sea and Brook Lamprey and White-clawed Crayfish. Evidence of otter were recorded at the Option 1 discharge site during the field survey. However it is likely that this species forages along the river corridor at both proposed discharge locations. Sub optimal habitat was recorded at both For inspection purposes only. Consent of copyright owner required for any other use. locations for lamprey, white clawed crayfish and salmon. However discharge location 2 has an ecological water quality status of Q4-5 high status while discharge location 1 has an ecological water quality status of Q2-3. Effluent discharged to Option 1 will therefore require treatment which will allow the river to attain good status water quality as defined in the Surface Water Quality Regulations 2009. While there may be a slight decrease in background water quality at discharge location 2, effluent discharged to this location will require treatment to allow the river to maintain its high ecological status. A Waste Water Discharge License will be required from the EPA in which they specify the appropriate effluent standards required to ensure that all appropriate legislation are complied with.

The proposed works do not have the potential to impact on any Special Protected Areas or National Heritage Areas.

Nicholas O’ Dwyer Ltd. 31 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

Margaritifera Sensitive Areas Both proposed discharge locations are located within a Margaritifera Sensitive Area. A pearl mussel survey was undertaken between Annagh Bridge and Banada. The survey had the following conclusions:  The river habitat in the 4.1km stretch of the upper River Moy investigated was generally homogeneous, consisting mainly of slow glide habitat with unstable, mobile, heavily silted sand, gravel and cobble substrates, which are generally not suitable for Margaritifera margaritifera.  A single live specimen of Margaritifera was found, but no concentrations of mussels were observed in the 4.1km long stretch investigated and no high quality habitat capable of supporting juvenile Margaritifera was observed. It was concluded that only a very small number of mussels are present in the stretch of the upper River Moy investigated.  Although no habitat that could be described as ideal for Margaritifera was observed, the highest quality habitat observed was located between 1300m and 2400m downstream of Annagh Bridge. This stretch included the site where the live mussel was recorded, the Tubbercurry River confluence and the location of the downstream potential effluent discharge point (Option 1) at Tullanaglug/Creghassaun.

Other Habitats/ Species The proposed works for either location will require the removal of a small number of trees and riparian vegetation. Removal of any trees or scrub will come under For inspection purposes only. the remit of the WildlifeConsent Act. of It copyright is advised owner required that for anyconstruction other use. works at the discharge

location be undertaken outside the Kingfisher and sand martin bird breeding season to avoid impacts on these species. It is not proposed to remove potential bat roosting structures during the works therefore significant impacts on these species are not anticipated. An area of wet grassland/marsh will require removal for discharge location 1 which may provide foraging habitat for wetland birds.

Nicholas O’ Dwyer Ltd. 32 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

7. OBLIGATIONS OF LOCAL AUTHORITY RELEVANT TO HABITATS/SPECIES UNDER NATIONAL AND EU LEGISLATION

The following pieces of legislation presented in Table 7.1 below are relevant to the potential impacts of the proposed pipeline on terrestrial and aquatic habitats and species.

Table 7.1: Relevant Legislation Legislation Requirements

1. Provides protection for all wild birds throughout the state (except those in the Third Schedule to the 1976 Act), and certain mammals, amphibians and reptiles. 2. To protect wild birds, Section 46 of the Wildlife (Amendment) Act 2000 prohibits hedgerow, tree and scrub removal between March 1st and August 31st (though there are exemptions for The Wildlife Act 1976 and certain construction works, these would need to be agreed with the Wildlife (Amendment) NPWS). Act 2000 3. Under Section 21 of the Wildlife Act, a number of wild plants, as listed in the Flora Protection Order 1999, are legally protected in the State. 4. Wildlife (Amendment) Act 2000 makes provisions to designate lands as Natural Heritage Areas. 1. Requires special conservation measures by member states for those habitats listed in Annex I and for those species listed in Annex II whose conservation status is a cause for concern. A number of protected species and habitat have been recorded in the vicinity of the proposed works. Mitigation measures outlined EU Directive on the in section 5 of this document will minimise impacts on these Conservation of Natural species. However a Stage 1 Appropriate Assessment Screening Habitats and of Wild Fauna report will be required to assess the impacts of the proposed and Flora (i.e. Council works on the qualifying interests of the River Moy SAC.

Directive 92/43/EEC, For inspection purposes only. commonly known as Consent the of2. copyright Requires owner required member for any other states use. to designate networks of Special Habitats Directive) Areas of Conservation to protect representative Annex I habitats and Annex II species. Some of the proposed works are located within the River Moy SAC therefore as stated above a Stage 1 Screening for Appropriate Assessment will be required to assess the impacts of the proposed works on the qualifying interests of this site. The Local Government (Water Pollution) Act, 1977 Prohibits the entry of unlicensed polluting matter into waters (and associated regulations) Prohibits: 1. The entry of deleterious matter into waters. (Deleterious matter is defined as any substance that is liable to injure fish, their spawning grounds or their food, or to injure fish in their The Fisheries (Consolidation) value as human food.) Act, 1959 as amended by the Fisheries (Amendment) 2. Obstructing the passage of salmon, trout or eels or to their Act 1962 spawning or nursery areas.

3. Injury or disturbance of the spawn or fry of salmon, trout or eels or to their spawning or nursery areas.

Nicholas O’ Dwyer Ltd. 33 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

Table 7.1 cont’d: Relevant Legislation

Legislation Requirements

Requires Inland Fisheries Ireland to have regard for the need Fisheries Amendment Act for the conservation of fish and other species of fauna and flora 1999 habitat and biodiversity of Inland fisheries and ecosystems. The freshwater Fish Directive 78/659/EEC as transposed into Irish law Lays down standards for the quality of designated waters and under the E.C. (Quality of requirements for monitoring. Salmonid Waters) Regulations 1988 (S.I. No. 293 of 1988)

7.1 Consultation

As part of this Ecological Impact Assessment consultation has been undertaken with Inland Fisheries Ireland and National Parks and Wildlife. Correspondence is attached in Appendix B.

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

Nicholas O’ Dwyer Ltd. 34 January 2013

EPA Export 20-02-2013:23:45:11 Tubbercurry WwTW Upgrade Ecological Impact Assessment

APPENDIX A Pearl Mussel Survey

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

Nicholas O’ Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:11

Report on a Margaritifera margaritifera (L.) survey undertaken on the upper Moy River between Annagh Bridge and Banada Bridge on August 12th and 13th, 2012.

Carried out on behalf of:

Nicholas O’Dwyer Ltd.

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

Report by: Dr. Eugene Ross Freshwater Bivalve Investigations Ltd. Chestnut Drive, Oakpark, Tralee, Co. Kerry

Submitted: August 17th, 2012

EPA Export 20-02-2013:23:45:11

Table of Contents

Page number Introduction 1 Methods 3 Survey Results 3 Habitat Quality 3 Margaritifera search 5 Other species of interest 5 Conclusions 6 References 7 Appendix – Site descriptive photographs 8 -17

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

EPA Export 20-02-2013:23:45:11 Introduction

Arising from an upgrade of the Tubbercurry Waste Water Treatment Plant and the proposal to pipe effluent directly to the River Moy, two new effluent discharge points have been proposed, one at Tullanaglug (Option 1 on the map below) and the other at Annagh Bridge (Option 2 on the map below).

Rising Main Discharge Option 2 Tubbercurry Waste Annagh Bridge. Water Treatment Plant

Annagh Bridge Rising Main Discharge Option 1 Tullanaglug

Banada Bridge

Figure 1. Map of the section of the upper River Moy between Annagh Bridge and Banada Bridge, indicating the locations of the Waste Water Treatment Plant in Tubbercurry, the routes and discharge points of both proposed rising mains.

For inspection purposes only. The site is located withinConsent the of copyright River owner Moy required SAC for any. other The use. Moy system is regarded as one of Ireland’s finest salmon and trout fisheries, and arctic char have been recorded in Lough Conn, although they are now thought to have disappeared from that site. Other Annex II species present in the System include sea lamprey (Petromyzon marinus), the otter (Lutra lutra) and the white clawed crayfish (Austropotamobius pallipes) (NPWS Site Code 002298 Synopsis).

The river was subjected to a major arterial drainage scheme during the 1960’s which had very significant impacts on the hydrology and ecology of the system. The excavation and removal of the river substrate involved in the drainage scheme greatly altered the nature of the habitat and would have had an extremely destructive effect on any population of Margaritifera present at that time.

Margaritifera margaritifera, commonly called the pearl mussel, is one of three species of large Unionacean bivalves found in Irish freshwaters. The species may occur in fast- flowing, oligotrophic, calcium deficient streams and rivers, where it can grow to lengths of 159mm (Jackson 1925) and live to ages well in excess of 100 years (Ross 1984). Margaritifera has been recorded in most parts of Ireland with the exception of the central limestone plain but several studies have confirmed that a significant decline has occurred in some Irish populations, notably in northern and eastern areas (Ross 1988, Moorkens and

1

EPA Export 20-02-2013:23:45:11 Costello 1994, Beasley and Roberts 1996). Such declining populations are usually characterised by a predominance of older mussels and an absence of juvenile recruitment (Bauer 1983).

Although very widely distributed across northern Europe, Eurasia and North America, Margaritifera is declining throughout its range and is extinct or seriously threatened in many parts of Europe (Wells et al. 1983). The main cause of this decline is deteriorating river water quality although a variety of other factors are also implicated (Moorkens 1999). The species is on the IUCN Invertebrate Red Data List and is protected under the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention). Margaritifera is also listed in Annex II and Annex V of the Habitats Directive (92/43/EEC) and is protected by law in Ireland under the 1976 Wildlife Act (Statutory Instrument No. 112, 1990).

The conservation status of Margaritifera margaritifera in Ireland has been determined as “unfavourable – bad” in the recently published “Conservation Status in Ireland of Habitats and Species listed in the European Council Directive on the Conservation of Habitats, Flora and Fauna 92/43/EEC” (NPWS 2008).

Very little information is available on the current distribution of Margaritifera in the upper River Moy. Margaritifera was known to occur further upstream of Annagh Bridge in the Owenaher River (NPWS Database) and shells have also been recorded further downstream at Cooleen Bridge (O’Connor 2004). In order to assist with assessment of the potential impacts of these proposed effluent discharge points, an investigation of the distribution of Margaritifera margaritifera (L.) was undertaken in the River Moy between Annagh Bridge and Banada Bridge.

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

Photograph 1. A large adult specimen of the freshwater pearl mussel, Margaritifera margaritifera (L.)

2

EPA Export 20-02-2013:23:45:11 Methods

A preliminary site visit took place on August 10th, and the survey was conducted on August 12th and 13th, 2012 using modified Stage 1 Margaritifera Survey methodology. A total of 4.1km of the River Moy was investigated, starting immediately upstream of Annagh Bridge and finishing at Banada Bridge.

A Bic Tobago SOT kayak was used to travel downstream from Annagh Bridge to Banada Bridge, and to facilitate observation of the river substrate while travelling between the 42 pre-defined search locations located at intervals of 100m along the 4.1km stretch investigated.

At each of these locations, two 2m long transects were searched for Margaritifera. The grid references of transects searched were recorded using a Garmin GPS60 hand held global positioning device. The transects were searched for Margaritifera by wading while observing the river substrate with a bathyscope. Where necessary, deeper transects were searched by snorkelling. A diving torch was used to illuminate the substrate in any heavily shaded areas and mussel abundance was to be estimated according to the ACFOR scale as follows:

a. Abundant / at capacity in places (> 1,500 / 100m length river, if at capacity > 250 / m² in appropriate habitat) b. Common to good numbers, not at capacity (301 – 1,500 / 100m length river) c. Frequent (41 – 300 / 100m length river) d. Occasional / Rare (1 to 40 / 100m length river) e. Absent

At each location where transects were searched, additional data on river depth, substrate composition, in-stream vegetation, water state, and silt plume kick test were recorded. Site descriptive photographs were taken at each location investigated.

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

Habitat quality: In total, 42 locations were searched for Margaritifera along 4.1km of the upper River Moy extending from Annagh Bridge downstream to Banada Bridge. Results of investigations of these 42 sites are included in Table 1 (page 4), and descriptive photographs of each site are included in Appendix – Site descriptive photographs (pages 8-17)

The habitat observed was very homogeneous along the 4.1km stretch investigated. This is characteristic of rivers where extensive arterial drainage work has been carried out. Channel width generally varied from 20m to 30m and high modified banks were present throughout. Water depth was predominantly between 25cm to 60cm, and the maximum depth encountered was 1.5m. The prevalent water condition was that of a slow flowing glide, with only occasional riffles present.

Much of the substrate observed was unstable and mobile, consisting mainly of sand, gravels and cobble. This type of mobile substrate is not favoured by Margaritifera, as continual resorting and transport of substrate materials occur during spate events, tending to bury the mussels in situ.

3

EPA Export 20-02-2013:23:45:12

Substrate

%

Distance Cover (%) downstream No. of

Grid

from mussels

Reference Annagh (shells)

Depth (cm) Depth

Silt

Stable

Water state Water

Mobile

Bridge Marl Sand

Current speed Current

Gravel

Cobble

Boulder

Bedrock

present Silt plume

Bryophyte cover % cover Bryophyte

Filamentous algae % algae Filamentous cover Macrophyte Annagh Bridge -5m 0(0) 40 Mod Riffle Some 5 15  40 30 25 5 G 46616 12381 5m G 46618 12357 0(0) 35 Fast Riffle Some 10  60 15 15 10 Potential effluent discharge location (Option 2) 100m G 46641 12233 0(0) 50 Slow Glide Heavy 5  40 40 20 200m G 46659 12151 0(0) 60 Slow Glide Heavy  30 40 30 300m G 46746 12115 0(0) 60 Slow Glide Heavy  30 40 30 400m G 46789 12029 0(0) 40 Slow Glide Heavy  30 40 20 10 500m G 46833 11918 0(0) 50 Slow Glide Heavy 2 5 10  30 40 15 15 600m G 46844 11841 0(0) 50 Slow Glide Heavy 5  30 50 15 5 700m G 46890 11751 0(0) 55 Slow Glide Heavy 5  30 50 15 5 800m G 46938 11676 0(0) 50 Slow Glide Heavy 20  30 50 15 5 900m G 47051 11634 0(0) 60 Slow Glide Heavy 25  10 65 20 5 1000m G 47155 11565 0(0) 60 Slow Glide Heavy 5 55  5 70 20 5 1100m G 47247 11507 0(0) 40 Slow Glide Heavy 5 5  40 45 10 5 1200m G 47341 11480 0(0) 40 Slow Glide Heavy 5  40 50 10 1300m G 47410 11423 1(0) 50 Slow Glide Heavy 5  30 50 20 1400m G 47466 11343 0(0) 35 Mod Glide Some 10 5  70 20 10 Tubbercurry River inflow 1500m G 47574 11318 0(0) 25 Mod Riffle Some 35 15  70 20 10 1600m G 47684 11276 0(1) 40 Slow Glide Some 15 5  35 40 20 5 1700m G 4773511257 0(0) 40 Slow Glide Heavy 15 5  40 40 10 10 G 47771 11213 Potential effluent discharge location (Option 1). 1800m G 47780 11143 0(0) 40 Slow Glide Some 40 15  60 25 15 1900m G 47768 11049 0(0) 35 Slow Glide Some 15  70 25 5 2000m G 47793 10966 0(0) 25 Fast Riffle Zero 15 5  5 80 15 2100m G 47763 10861 0(0) 35 Slow Glide Heavy 20 10  60 30 10 2200m G 47687 10768 0(0) 25 Slow Glide Heavy 10 5  5 80 10 5 0(0) For inspection purposes only. 2300m G 47606 10743 Consent of30 copyright Mod owner Riffle required forHeavy any other use.45 20  70 25 5

2400m G 47484 10756 0(0) 30 Mod Glide Heavy 5 5  75 20 5 2500m G 47397 10732 0(0) 40 Slow Glide Heavy 10 10  30 50 15 5 2600m G 47270 10776 0(0) 70 Slow Glide Heavy 5 5  20 60 20 2700m G 47180 10827 0(0) 120 Slow Glide Heavy  50 10 30 10 2800m G 47101 10808 0(0) 60 Slow Glide Some 5  20 60 20 2900m G 46992 10836 0(2+) 50 Slow Glide Heavy 5  25 60 15 3000m G 46958 10814 0(0) 50 Slow Glide Heavy  40 50 10 3100m G 46875 10721 0(0) 150 Slow Glide Heavy  10 30 60 3200m G 46868 10623 0(0) 40 Slow Glide Heavy 10 15  30 50 15 5 3300m G 46947 10591 0(0) 60 Slow Glide Heavy 5  20 60 15 5 3400m G 46958 10484 0(0) 50 Slow Glide Heavy 5 10  70 25 15 3500m G 46939 10400 0(0) 45 Slow Glide Heavy 15  20 60 20 3600m G 46943 10309 0(0) 40 Slow Glide Heavy 10 10  25 50 20 5 3700m G 46905 10208 0(0) 45 Slow Glide Heavy 15 5  10 65 25 3800m G 46806 10125 0(0) 70 Slow Glide Heavy 5 5  10 65 20 5 3900m G 46674 10097 0(0) 60 Slow Glide Heavy 5 5  10 75 15 4000m G 46566 10083 0(0) 80 Slow Glide Heavy  50 20 10 20 G 46503 10052 4100m 0(0) 40 Slow Glide Heavy 20  25 40 10 25 Banada Bridge

Table 1. Habitat characteristics of the locations searched for Margaritifera margaritifera in the 4.1km stretch of the upper River Moy investigated during the current study. 4

EPA Export 20-02-2013:23:45:12

The sand and gravel substrates present were generally very heavily silted. Clean (unsilted) substrates were rarely observed. Such heavily silted substrates are inimical to the survival of juvenile mussels and indicate that chronic siltation is characteristic of that part of the upper River Moy. High levels of siltation also negatively affect mussels by reducing the efficiency of respiratory and feeding functions carried out by their gills.

Margaritifera Search: Throughout the entire 4.1km stretch investigated, only a single live specimen of Margaritifera was observed 1.3km downstream of Annagh Bridge (INGR G 47410 11423), and 130m upstream of the confluence with the Tubbercurry River. Shell fragments of between three and five mussels were also recovered from sites located 1.6km and 2.9km downstream of Annagh Bridge. No mussels or shells were observed while travelling between transect search locations.

Although concentrations of Margaritifera were not observed during the current study, confirmation of the presence of this protected species in the upper River Moy is significant. The upper River Moy is part of Margaritifera’s range in Ireland, and as such must be protected.

No small or juvenile (<30mm) mussels were observed, and no habitat of sufficiently high quality to support juvenile Margaritifera was observed at any location in the area surveyed.

The methodology used in this investigation was primarily designed to determine if concentrations of mussels were present, rather than to accurately estimate the size of population present. Nevertheless, extrapolation from the results suggests that very low numbers of Margaritifera are present. As 4m of river length were intensively searched in each 100m section, it is reasonable to multiply the observed mussel frequency by a factor of 25 to obtain an estimate of the total number present, indicating that 25 mussels could be present in the entire stretch investigated. For inspection purposes only. Consent of copyright owner required for any other use. Although no habitat that could be described as ideal for Margaritifera was found, the highest quality habitat observed extended from 1300m to 2400m below Annagh Bridge. This section includes the site at which the live mussel was recorded and extends downstream past the Tubbercurry River confluence, and the potential effluent discharge point (Option 2) at Tullanaglug/Creeghassaun, as far as grid reference G 47484 10756 (2400m).

Given the mostly unsuitable nature of the habitat recorded, and that only a single mussel was observed, it is reasonable to conclude that only a very small number of mussels is still present in that part of the upper River Moy.

Other species of interest: Otter spraints were observed on boulders immediately downstream of Annagh Bridge on the eastern bank. Small juvenile salmonids were observed at several locations, usually near riffles. Although the River Moy was selected as an SAC partly for the presence of freshwater crayfish (Austropotamobius pallipes), none were observed at any of the sites investigated between Annagh Bridge and Banada Bridge. A kingfisher (Alcedo atthis) was observed 3.5km downstream of Annagh Bridge (Grid Ref. G 47574 11318), and dippers (Cinclus cinclus) were sighted at several locations.

5

EPA Export 20-02-2013:23:45:12 Conclusions.

1. The river habitat in the 4.1km stretch of the upper River Moy investigated was generally homogeneous, consisting mainly of slow glide habitat with unstable, mobile, heavily silted sand, gravel and cobble substrates, which are generally not suitable for Margaritifera margaritifera.

2. A single live specimen of Margaritifera was found, but no concentrations of mussels were observed in the 4.1km long stretch investigated and no high quality habitat capable of supporting juvenile Margaritifera was observed. It was concluded that only a very small number of mussels are present in the stretch of the upper River Moy investigated.

3. Although no habitat that could be described as ideal for Margaritifera was observed, the highest quality habitat observed was located between 1300m and 2400m downstream of Annagh Bridge. This stretch included the site where the live mussel was recorded, the Tubbercurry River confluence and the location of the downstream potential effluent discharge point (Option 1) at Tullanaglug/Creghassaun.

4. Individuals or signs of several other high conservation value species were observed, including otter spraint, juvenile salmonids, kingfisher, and dipper.

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

6

EPA Export 20-02-2013:23:45:12 References Bauer, G. (1983). “Age structure, age specific mortality rates and population trend of the freshwater pearl mussel (Margaritifera margaritifera) in North Bavaria.” Archiv fur Hydrobiologie 98, 523-532.

Beasley, C.R., Roberts. D. (1996). “The current distribution of the freshwater pearl mussel Margaritifera margaritifera L. 1758 in north-west Ireland.” Aquatic Conservation: Marine and Freshwater Ecosystems 6, 169-177.

Jackson, J.W. (1925) “The distribution of Margaritifera margaritifera in the British Isles.” Journal of Conchology 17, 195-211.

Moorkens, E.A. and Costello, M.J. (1994). “Imminent extinction of the Nore freshwater pearl mussel Margaritifera durrovensis Phillips: a species unique to Ireland.” Aquatic Conservation: Marine and Freshwater Ecosystems 4, 363-365.

Moorkens, E.A., (1999). “Conservation management of the freshwater pearl mussel Margaritifera margaritifera. Part 1: Biology of the species and its present situation in Ireland.” Irish Wildlife Manuals, No. 8. Duchas, The Heritage Service, Dept. of Arts, Heritage, Gaeltacht and the Islands, Dublin.

Moorkens, E. A. (2006). Monitoring Populations of the Freshwater Pearl Mussel. Baseline survey of the Eske River cSAC, County Donegal. Report for the National Parks and Wildlife Service, Dublin.

N.P.W.S. (2008). The Status of EU Protected Habitats and Species in Ireland. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin.

O’Connor, William (2004). A survey of juvenile lamprey populations in the Moy catchment. Irish Wildlife Manuals, No. 15. National Parks and Wildlife Service, For inspection purposes only. Department of Environment,Consent of Heritage copyright owner and required Local for any Government, other use. Dublin, Ireland.

Ross, E.D. (1984). “Studies on the biology of freshwater mussels (Lamellibranchia : Unionacea) in Ireland.” M.Sc. Thesis, University College Galway.

Ross, E.D. (1988). “The reproductive biology of freshwater mussels in Ireland, with observations on their distribution and demography”. Ph.D. Thesis, University College Galway.

Wells, S.M., Pyle, R.M. and Collins, N.M. (1983). “The I.U.C.N. Invertebrate Red Data Book.” International Union for the Conservation of Nature and Natural Resources, Gland (Switzerland), 145-156. www.npws.ie/media/npwsie/content/images/protectedsites/sitesynopsis/SY002298.pdf

7

EPA Export 20-02-2013:23:45:12

Appendix - Site descriptive photographs

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

8

EPA Export 20-02-2013:23:45:12 -5m 5m upstream of Annagh Bridge.

5m 5m downstream of Annagh Bridge. Otter spraints observed on the eastern bank immediately downstream of Annagh Bridge.

100m

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

200m

300m

9

EPA Export 20-02-2013:23:45:12 400m

500m

600m

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

700m

800m

10

EPA Export 20-02-2013:23:45:12 900m

1000m

1100m

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

1200m

1300m One live specimen of Margaritifera margaritifera observed at this location.

11

EPA Export 20-02-2013:23:45:12 1400m Some good quality habitat at this site 30m upstream of the confluence of the Tubbercurry River.

1500m Slight riffle just downstream of the point where the Tubbercurry River flows into the Moy River. Some good quality habitat at this site but much mobile sand deposition on western bank.

1600m One shell fragment located at this site. Fragment appeared to be from a recently deceased mussel.

No photograph available No photograph available 1700m For inspection purposes only. Consent of copyright owner required for any other use.

1800m

1900m

12

EPA Export 20-02-2013:23:45:12 2000m

2100m 30m downstream of stream entering from eastern bank.

2200m

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

2300m

2400m

13

EPA Export 20-02-2013:23:45:12 2500m

2600m

2700m

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

2800m

2900m Shell fragments from at least two mussels found at this site. Fragments were probably not from recently deceased mussels.

14

EPA Export 20-02-2013:23:45:12 3000m

3100m Just downstream of small stream entering on western bank.

3200m

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

3300m

3400m

15

EPA Export 20-02-2013:23:45:12 3500m Stream entering on eastern bank just downstream of this location

3600m c. 50m downstream of stream entering from eastern bank.

3700m

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

3800m

3900m

16

EPA Export 20-02-2013:23:45:12 4000m

4100m Banada Bridge

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

17

EPA Export 20-02-2013:23:45:12 Tubbercurry WwTW Upgrade Ecological Impact Assessment

APPENDIX B Consultation

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

Nicholas O’ Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:12 From: William Cormacan - (DAHG) Sent: 31 July 2012 09:22 To: Serena Keane Subject:RE: Tubbercurry WwTW Ecological Impact assessment Attachments: Margaritifera sensitive areas v04.pdf; Margaritifera_sensitive_areas_read_me.pdf

Serena,

All seems to be in order. I would recommend that the Ecological Impact Assessment also considers Freshwater Pearl Mussel. The Sligo part of the Moy is within a Margaritifera sensitive area (see attached).

Regards, William Cormacan.

From: Serena Keane [[email protected]] Sent: 19 July 2012 09:49 To: William Cormacan - (DAHG) Subject: FW: Tubbercurry WwTW Ecological Impact assessment

Dear William,

Apologises if you have received this email already, I think I may have sent it to the wrong address earlier on this week and am therefore resending it. We are currently working on a design review for the Tubbercurry Waste Water Treatment Works. Waste Assimilative Capacity Calculations have been carried out for the River Moy and it has been concluded that the River Moy does have the capacity to absorb the effluent and maintain its good status. For inspection purposes only. Consent of copyright owner required for any other use.

Two options for the outfall have been put forward as presented in the attached sketch. An Appropriate Assessment was carried out for the discharge location at Annagh Bridge in 2008, with a conclusion that there would not be significant impacts from the proposed works on the River Moy SAC following implementation of mitigation measures proposed in the AA. The proposed effluent standards have been changed since this appropriate assessment was completed to ensure compliance with the Surface Water Regulations 2009 and are more stringent than those standards previously proposed.

It is now proposed that an ecological impact assessment be carried out at the 2 proposed discharge locations as part of the design review. Habitats will be classified in accordance with Fossits classification system. Special attention will be given to the potential for or presence of protected habitats or species especially those protected by the River Moy SAC.

EPA Export 20-02-2013:23:45:12 Can you let me know if you have any additional survey/ habitat information for the River Moy that you would deem appropriate and also let us know of any specific requirements that the NPWS may have. We also propose to contact Inland fisheries Ireland with regard to any potential information and requirements they may have.

Thanks & Kind regards

Serena Keane Environmental Consultant Nicholas O'Dwyer Ltd. Nutgrove Office Park Nutgrove Avenue Dublin 14

Tel. 01-296 9000 Fax. 01-296 9001 [email protected] www.nodwyer.com

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

EPA Export 20-02-2013:23:45:12 Margaritifera Sensitive Areas

Version 04, February 2012

Explanatory text

Áine O Connor, June 2012

The Margaritifera Sensitive Areas data are available as: 1. A pdf map (‘Margaritifera sensitive areas v04.pdf’) 2. A GIS shapefile (‘Margaritifera_sensitive_areas_2012_v04’ (http://www.npws.ie/mapsanddata/habitatspeciesdata/

The Margaritifera Sensitive Areas show the catchments of the known extant populations of Margaritifera margaritifera , the freshwater pearl mussel in the Republic of Ireland.

Three categories of catchments are mapped: 1. Catchments of SAC populations listed in S.I. 296 of 2009 2. Catchments of other extant populations 3. Catchments with pre-1970 live records (extant populations unlikely, but information insufficient to list as 'extinct')

These three categories have implications in relation to ecological assessment of plans and potentially damaging developments and activities, as follows: 1. Catchments of SAC populations listed in S.I. 296 of 2009 . These 27 mussel populations are within Special Areas of Conservation (SAC) designated for the protection of the species. Site- specific conservation objectives for the restoration of these populations and their habitats are being developed by the NPWS (see http://www.npws.ie/protectedsites/ ). Under S.I. 296 of 2009, 27 draft Sub-basin Management Plans have been developed to provide the programmes of measures necessary For to inspection purposes achieve only. these objectives (see http://www.wfdireland.ie/docs/5_FreshwaterPearlMussConsent of copyright owner required forelPlans/ any other ).use. Any plans or potentially damaging developments and activities in or overlapping with the catchments must be screened for Appropriate Assessment (Article 6 (3), Habitats Directive). The NPWS holds very detailed information on the distribution and abundance of freshwater pearl mussels in many of these catchments, and this is available on request to bona fide applicants (see: http://www.npws.ie/mapsanddata/requestdata/ ). 2. Catchments of other extant populations . These mussel populations may lie (in part) within SAC, other nature conservation sites or in the wider countryside. Those populations within SAC were not considered of sufficient quality to warrant designation for the species and detailed restoration objectives, targets, plans or measures are unlikely to be developed. However, the potential effects of any plans, developments or activities on the populations, including the potential to cause ‘environmental damage’ as per the Environmental Liability Directive and Regulations, must be determined through SEA, EIA or other ecological assessment. The NPWS holds some detailed information on the distribution and abundance of freshwater pearl mussels in a small number of these catchments. 3. Catchments with pre-1970 live records (extant populations unlikely, but information insufficient to list as 'extinct'). While there are no recent records of freshwater pearl mussel from these catchments, in most cases there has been little, if any, survey for the species since 1970. NPWS holds very little information on these populations. If any plans, or potentially damaging developments and activities are proposed for these catchments, freshwater pearl mussel should be considered as a constraint and dedicated survey is recommended.

EPA Export 20-02-2013:23:45:12 In general, the scale and scope of freshwater pearl mussel survey necessary to inform an ecological or environmental impact assessment will depend on the data available, as well as the potential for impacts to occur. Freshwater pearl mussel is a globally threatened, long-lived and extremely sensitive species that can be impacted by many forms of pollution, particularly sediment and nutrient pollution and by hydrological and morphological changes, which may arise from developments, activities or changes in any part of the catchment. Accordingly, conservation and protection of the species must occur at the catchment level. Owing to the likelihood that the development or activity may occur some distance from the impact, it is the assessment and quantification of risk that requires the greatest attention during the ecological or environmental impact assessment.

Survey and Licensing Any survey for freshwater pearl mussel is considered a potential disturbance to the species and, consequently, requires a licence under the Wildlife Acts, 1976 and 2000. The licence application form (“Application for licence to capture and/or humanely kill a protected wild animal for scientific or other purposes” under Sections 23 and 34 of the Wildlife Acts) is available at: http://www.npws.ie/licences/educationandscience/totakecaptureorhumanelykillforscientific/ (applications to survey should specify “survey only, none to be captured or killed”). Standard NPWS survey methods are available in Irish Wildlife Manual No. 12 at http://www.npws.ie/publications/irishwildlifemanuals/ . Applicants are required to have demonstrable experience in Margaritifera survey and the NPWS standard methods. Licences to handle or move 1 freshwater pearl mussels are granted only in exceptional circumstances.

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

1 temporary or permanent translocation

EPA Export 20-02-2013:23:45:12 Margaritifera Sensitive Areas - Version 04, February 2012 -

Tullaghobegly Carrownamaddy Lackagh - Owencarrow

Clady Leannan

Leannan - Glaskeelan

Owenea Finn

Bungosteen Eske Oily Eany Water Erne - Waterfoot Ballintra

Erne - Claddagh or Swanlibar Easky Erne - Annalee

Moy - Deel Moy

Newport Moy - Tobergal Erne - Annalee - Larah

Bunowen Owenwee

Carrownisky - Bunleemshough Erriff Bundorragha Corrib - Finny Dawros Ballynahinch - Inagh Lough Ballynahinch - Caher Ballynahinch - Ballynahinch Lake Corrib - Owenriff

Knock

Avoca - Upper Avonmore

Liffey - Kings Shannon - Woodford Barrow Vartry

Slaney Upper For inspection purposes only. Avoca - Lower Avonmore Shannon - Graney / Scariff Consent of copyright owner required for any other use. Slaney - Dereen

Nore Upper

Avoca - Aughrim Doonbeg Slaney - Derry Suir - Clodiagh Tipperary Nore Lower Shannon - Cloon Slaney - Bann

Suir - Multeen Barrow - Mountain Barrow - Ballymurphy Slaney Lower Feale - Galey Barrow - Aughavaud Suir Munster Suir - Aherlow Blackwater - Allow Suir - Thonoge Feale Suir - Tar Owenmore Maine - BrownFlesk Mahon Munster Blackwater Tay Owenascaul Suir - Clodiagh Waterford Laune - Gearhameen Laune - Cottoner's River Behy Laune Kerry Blackwater Caragh Finnihy Lee - Laney Lee - Sullane Munster Blackwater - Licky Cummeragh - Currane Sneem Roughty Lee Lower Sneem - Owreagh Dromoghty Lee - Toon Bunnow Tahilla Sheen Lee Upper Owenshagh Ownagappul Bandon Adrigole Reen Trafask Glengariff / Beara Ilen Bandon/Caha Four Mile Water Roury Glengarriff Coomhola Leamawaddra Owvane Mealagh

¯ Catchments of SAC populations listed in S.I. 296 of 2009 Catchments of other extant populations 0 25 50 km Catchments with pre-1970 live records Ordnance Survey Ireland Licence No EN 0059208 (extant populations unlikely, but information insufficient to list as 'extinct') © Ordnance Survey Ireland / Government of Ireland

EPA Export 20-02-2013:23:45:12 From: Jochen Roller Sent: 01 August 2012 10:49 To: Serena Keane Subject:FW: Date request river Moy Attachments: Habitat_codes_Lookup_tables.zip; Margaritifera sensitive areas v04.pdf; 2012_120 Rare and Protected Species Records.XLS; 2012_120_metadata.zip; 2012_120_shapefiles.zip; ATT00003.c; ATT00004.htm

Dear Serena, please find requested data attached.

I'm also attaching a Margaritifera Sensitive Areas map, as the area of interest intersects with a catchment identified as sensitive with regard to Freshwater Pearl Mussel habitat.

Just to reiterate, as per the data policy, our datasets are not complete or perfect in terms of quality, so it is important to note that the absence of information in the NPWS dataset for an area, does not necessarily imply a low biodiversity value for that area. These data should not be seen as a replacement for field surveys.

Please note that the NPWS species dataset is incomplete, particularly for fish, bats and birds, so please don't be surprised if species listed on the site synopsis do not appear in the dataset. Can I also remind you that locations for sensitive species should not be made publicly available.

The list of what qualifies as a rare or threatened species available at http://www.npws.ie/media/npws/publications/Listed%20species%20checklist%20Feb-12.pdf.It covers species listed one For inspection purposes only. Consent of copyright owner required for any other use. or more of the following documents: EU Directives (Birds & Habitats), Wildlife Act, 1976 & Wildlife (Amendment) Act, 2000 , Flora (Protection) Order 1999 or Published National Red Lists. This list is regularly updated, as new legislation is added, or red lists are published, so it is worth checking back to the version available on the NPWS website regularly.

The Central Fisheries Board, BirdWatch Ireland, Bat Conservation Ireland and the National Biodiversity Data Centre may have additional records of use.

Best regards, Jochen

Jochen Roller National Parks & Wildlife Service 7 Ely Place, Dublin 2, Ireland

EPA Export 20-02-2013:23:45:12 [email protected] Tel: +353-1-8883073

From: Naomi Kingston - (DAHG) Sent: 26 July 2012 11:02 To: Jochen Roller Subject: FW: Date request river Moy

From: Serena Keane [[email protected]] Sent: 26 July 2012 10:26 To: Naomi Kingston - (DAHG) Subject: Date request river Moy Hi Naomi,

Please find my data request form attached for the River Moy. We are progressing a planning application for the Tubbercurry WwTW, so if you could get back to me as soon as possible it would be greatly appreciated.

Thanks & Kind regards

Serena Keane Environmental Consultant Nicholas O'Dwyer Ltd. Nutgrove Office Park Nutgrove Avenue Dublin 14

Tel. 01-296 9000 Fax. 01-296 9001 For inspection purposes only. Consent of copyright owner required for any other use. [email protected] www.nodwyer.com

EPA Export 20-02-2013:23:45:13 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 20-02-2013:23:45:13 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Appendix D Strandhill Cost Comparison

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry, Grange,Strandhill DBO 1.1 24-Jan-13 F. Lane Sheet: 1 of 2 Strandhill Outfall Comparison Costs

Option 1 - Option 1 - Option 3 - Secondary Secondary Primary Item Treatment Treatment Treatment (existing outfall) (600m outfall) (1500m outfall) Capital Cost Pumping Station M&E Works €90,000 €90,000 €90,000 Preliminary M&E Works €140,000 €140,000 €140,000 Primary M&E Works €40,000 Secondary M&E Works €220,000 €220,000 Sludge M&E Works €120,000 €120,000 €80,000 Odour removal M&E €90,000 €90,000 €110,000 Disinfection €110,000 Additional nitrogen removal €90,000 PS Civil Works €30,000 €30,000 €30,000 Preliminary Civil Works €90,000 €90,000 €90,000 Primary Civil Works €30,000 Secondary Civil Works €280,000 €280,000 Sludge Civil Works €90,000 €90,000 €72,000 Site Civil Works €115,000 €115,000 €80,000 Addition Civil Works - nitrogen removal €90,000 Civil Works - disinfection €60,000 Civil Works - outfall upgrade €100,000 €1,200,000 €3,000,000

Total Capital Cost (excl. VAT) €1,715,000 €2,465,000 €3,762,000

Operating Cost 20 Year O&M NPV Cost (excl. VAT) €1,590,744 €1,514,994 €859,148 20 Year Total Whole Life Cost (excl. VAT) €3,305,744 €3,979,994 €4,621,148 20 Year Total Whole Life Cost (including VAT @ 13.5%) €3,752,019 For inspection€4,517,293 purposes only.€5,245,003 Consent of copyright owner required for any other use.

Operating Cost 30 Year O&M NPV Cost (see page 2) €1,998,563 €1,903,394 €1,080,546 30 Year Total Whole Life Cost (excl. VAT) €3,713,563 €4,368,394 €4,842,546 30 Year Total Whole Life Cost (including VAT @ 13.5%) €4,214,895 €4,958,127 €5,496,290

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry, Grange,Strandhill DBO 1.1 24-Jan-13 F. Lane Sheet: 2 of 2

Strandhill Secondary Treatment Fixed O&M Costs €70,000 per annum Variable Costs €20 per PE 5% Increase in cost for UV (added to Option 1 above)

Variable Total O&M NPV O&M Year of Operation PE O&M Cost Cost NPV Factor Cost 1 2322 €46,440 €116,440 0.952 €110,895 2 2352 €47,040 €117,040 0.907 €106,159 3 2383 €47,660 €117,660 0.864 €101,639 4 2414 €48,280 €118,280 0.823 €97,309 5 2445 €48,900 €118,900 0.784 €93,161 6 2477 €49,540 €119,540 0.746 €89,203 7 2509 €50,180 €120,180 0.711 €85,410 8 2542 €50,840 €120,840 0.677 €81,789 9 2575 €51,500 €121,500 0.645 €78,320 10 2608 €52,160 €122,160 0.614 €74,996 11 2642 €52,840 €122,840 0.585 €71,822 12 2676 €53,520 €123,520 0.557 €68,781 13 2711 €54,220 €124,220 0.530 €65,877 14 2746 €54,920 €124,920 0.505 €63,093 15 2782 €55,640 €125,640 0.481 €60,435 16 2818 €56,360 €126,360 0.458 €57,887 17 2855 €57,100 €127,100 0.436 €55,453 18 2892 €57,840 €127,840 0.416 €53,120 19 2930 €58,600 €128,600 0.396 €50,891 20 2968 €59,360 €129,360 0.377 €48,754 Total 20 Year NPV €1,052,940 €2,452,940 €1,514,994 21 3007 €60,140 €130,140 0.359 €46,713 22 3046 €60,920 €130,920 0.342 €44,755 23 3086 €61,720 €131,720 0.326 €42,884 24 3126 €62,520 €132,520 0.310 €41,090 25 3167 €63,340 €133,340 0.295 €39,376 26 3208 €64,160 €134,160 0.281 €37,731 27 3250 €65,000 €135,000 0.268 €36,160 28 3292 €65,840 €135,840 0.255 €34,652 29 3335 €66,700 €136,700 0.243 €33,211 30 3378 €67,560 €137,560 0.231 €31,828 Total 30 Year NPV €1,690,840 €3,790,840 €1,903,394

Strandhill Primary Treatment Fixed O&M Costs €38,000 per annum Variable Costs €12 per PE For inspection purposes only. Variable Total O&M NPV O&M Year of Operation PE Consent of copyrightO&M Cost owner requiredCost for any otherNPV use. Factor Cost

1 2322 €27,864 €65,864 0.952 €62,728 2 2352 €28,224 €66,224 0.907 €60,067 3 2383 €28,596 €66,596 0.864 €57,528 4 2414 €28,968 €66,968 0.823 €55,095 5 2445 €29,340 €67,340 0.784 €52,763 6 2477 €29,724 €67,724 0.746 €50,537 7 2509 €30,108 €68,108 0.711 €48,403 8 2542 €30,504 €68,504 0.677 €46,366 9 2575 €30,900 €68,900 0.645 €44,414 10 2608 €31,296 €69,296 0.614 €42,542 11 2642 €31,704 €69,704 0.585 €40,754 12 2676 €32,112 €70,112 0.557 €39,041 13 2711 €32,532 €70,532 0.530 €37,405 14 2746 €32,952 €70,952 0.505 €35,836 15 2782 €33,384 €71,384 0.481 €34,337 16 2818 €33,816 €71,816 0.458 €32,900 17 2855 €34,260 €72,260 0.436 €31,527 18 2892 €34,704 €72,704 0.416 €30,210 19 2930 €35,160 €73,160 0.396 €28,952 20 2968 €35,616 €73,616 0.377 €27,745 Total 20 Year NPV €631,764 €1,391,764 €859,148 21 3007 €36,084 €74,084 0.359 €26,592 22 3046 €36,552 €74,552 0.342 €25,486 23 3086 €37,032 €75,032 0.326 €24,428 24 3126 €37,512 €75,512 0.310 €23,414 25 3167 €38,004 €76,004 0.295 €22,444 26 3208 €38,496 €76,496 0.281 €21,514 27 3250 €39,000 €77,000 0.268 €20,624 28 3292 €39,504 €77,504 0.255 €19,771 29 3335 €40,020 €78,020 0.243 €18,955 30 3378 €40,536 €78,536 0.231 €18,171 Total 30 Year NPV €1,014,504 €2,154,504 €1,080,546

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Appendix E Tubbercurry Outfall Cost Comparison

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry, Grange,Strandhill DBO 1.1 24-Jan-13 F. Lane Sheet: 1 of 2 Tubbercurry Outfall Comparison Costs

Option 1 River Option 2 River Option 3 Item Moy 2km d/s Moy at Annagh Tubbercurry Annagh Br. Br. Stream Capital Cost Storm / interception M&E Works €95,000 €95,000 €95,000 Preliminary M&E Works €140,000 €140,000 €140,000 Secondary M&E Works €360,000 €360,000 €360,000 Sludge M&E Works €145,000 €145,000 €155,000 Odour removal M&E €90,000 €90,000 €90,000 Tertiary filters M&E (BOD & P removal) €280,000 Additional aertion/nitrogen removal €20,000 Outfall PS M&E €15,000 €15,000 Storm Civil Works €90,000 €90,000 €90,000 Preliminary Civil Works €90,000 €90,000 €90,000 Secondary Civil Works €280,000 €280,000 €280,000 Sludge Civil Works €90,000 €90,000 €90,000 Site Civil Works €115,000 €115,000 €130,000 Addition Civil Works - nitrogen removal €90,000 €70,000 Civil Works - tertiary filters €120,000 Outfall PS Civil €35,000 €35,000 Outfall pipeline, 200mm diameter @ €160 per €750,000 €768,000 €10,000 metre Wayleave cost €10,000 - - Total Capital Cost (excluding VAT) €2,395,000 €2,313,000 €2,020,000

20 Year O&M NPV Cost (excluding VAT) €1,786,280 €1,786,280 €2,062,113 20 Year Total Whole Life Cost (excluding VAT) €4,181,280 €4,099,280 €4,082,113 20 Year Total Whole Life Cost (including VAT @ 13.5%) €4,745,753 €4,652,683 €4,633,199

30 Year O&M NPV Cost (excluding VAT) €2,241,011.39 €2,241,011.39 €2,585,017.65 For inspection purposes only. 30 Year Total Whole Life Cost (excluding VAT) Consent€4,636,011.39 of copyright€4,554,011.39 owner required for€4,605,017.65 any other use.

30 Year Total Whole Life Cost (including VAT @ 13.5%) €5,261,872.93 €5,168,802.93 €5,226,695.04

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry, Grange,Strandhill DBO 1.1 24-Jan-13 F. Lane Sheet: 2 of 2 Tubbercurry - Option 1 and 2 - Discharge to River Moy Fixed O&M Costs €82,000 per annum Variable Costs €20 per PE

Variable Total O&M NPV O&M Year of Operation PE O&M Cost Cost NPV Factor Cost

1 2785 €55,700 €137,700 0.952 €131,143 2 2818 €56,360 €138,360 0.907 €125,497 3 2852 €57,040 €139,040 0.864 €120,108 4 2886 €57,720 €139,720 0.823 €114,948 5 2921 €58,420 €140,420 0.784 €110,023 6 2956 €59,120 €141,120 0.746 €105,306 7 2991 €59,820 €141,820 0.711 €100,789 8 3027 €60,540 €142,540 0.677 €96,477 9 3063 €61,260 €143,260 0.645 €92,347 10 3100 €62,000 €144,000 0.614 €88,404 11 3137 €62,740 €144,740 0.585 €84,626 12 3175 €63,500 €145,500 0.557 €81,020 13 3213 €64,260 €146,260 0.530 €77,565 14 3252 €65,040 €147,040 0.505 €74,265 15 3291 €65,820 €147,820 0.481 €71,104 16 3330 €66,600 €148,600 0.458 €68,075 17 3370 €67,400 €149,400 0.436 €65,183 18 3410 €68,200 €150,200 0.416 €62,411 19 3451 €69,020 €151,020 0.396 €59,764 20 3492 €69,840 €151,840 0.377 €57,227 Total 20 Year NPV (excl. VAT) €1,250,400 €2,890,400 €1,786,280 21 3534 €70,680 €152,680 0.359 €54,803 22 3576 €71,520 €153,520 0.342 €52,481 23 3619 €72,380 €154,380 0.326 €50,262 24 3662 €73,240 €155,240 0.310 €48,135 25 3706 €74,120 €156,120 0.295 €46,103 26 3750 €75,000 €157,000 0.281 €44,155 27 3795 €75,900 €157,900 0.268 €42,293 28 3841 €76,820 €158,820 0.255 €40,514 29 3887 €77,740 €159,740 0.243 €38,808 30 3934 €78,680 €160,680 0.231 €37,178 Total 30 Year NPV (excl. VAT) €1,996,480 €4,456,480 €2,241,011

Tubbercurry - Option 3 - Discharge to Tubbercurry River Fixed O&M Costs (includes fixed cost for filters) €98,000 per annum Variable Costs (includes variable cost for filters) €22 per PE

Variable Total O&M NPV O&M Year of Operation PE ForO&M inspection Cost purposesCost only. NPV Factor Cost Consent of copyright owner required for any other use. 1 2785 €61,270 €159,270 0.952 €151,686 2 2818 €61,996 €159,996 0.907 €145,121 3 2852 €62,744 €160,744 0.864 €138,857 4 2886 €63,492 €161,492 0.823 €132,860 5 2921 €64,262 €162,262 0.784 €127,137 6 2956 €65,032 €163,032 0.746 €121,657 7 2991 €65,802 €163,802 0.711 €116,411 8 3027 €66,594 €164,594 0.677 €111,404 9 3063 €67,386 €165,386 0.645 €106,609 10 3100 €68,200 €166,200 0.614 €102,032 11 3137 €69,014 €167,014 0.585 €97,650 12 3175 €69,850 €167,850 0.557 €93,465 13 3213 €70,686 €168,686 0.530 €89,458 14 3252 €71,544 €169,544 0.505 €85,631 15 3291 €72,402 €170,402 0.481 €81,966 16 3330 €73,260 €171,260 0.458 €78,456 17 3370 €74,140 €172,140 0.436 €75,104 18 3410 €75,020 €173,020 0.416 €71,893 19 3451 €75,922 €173,922 0.396 €68,827 20 3492 €76,824 €174,824 0.377 €65,889 Total 20 Year NPV (excl. VAT) €1,375,440 €3,335,440 €2,062,113 21 3534 €77,748 €175,748 0.359 €63,083 22 3576 €78,672 €176,672 0.342 €60,395 23 3619 €79,618 €177,618 0.326 €57,827 24 3662 €80,564 €178,564 0.310 €55,367 25 3706 €81,532 €179,532 0.295 €53,016 26 3750 €82,500 €180,500 0.281 €50,764 27 3795 €83,490 €181,490 0.268 €48,612 28 3841 €84,502 €182,502 0.255 €46,555 29 3887 €85,514 €183,514 0.243 €44,584 30 3934 €86,548 €184,548 0.231 €42,700 Total 30 Year NPV (excl. VAT) €2,196,128 €5,136,128 €2,585,018

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Appendix F 20 Year Operation and Maintenance Costs

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

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry WwTW 1.2 28-Jan-13 F. Lane Sheet: 1 of 2 20 Year Operation and Maintenance Costs Tubbercurry Fixed O&M Costs €82,000 per annum Variable Costs €20 per PE

Year of Operation PE Variable O&M Cost Total O&M Cost NPV Factor NPV O&M Cost 1 2785 €55,700 €137,700 0.952 €131,143 2 2818 €56,360 €138,360 0.907 €125,497 3 2852 €57,040 €139,040 0.864 €120,108 4 2886 €57,720 €139,720 0.823 €114,948 5 2921 €58,420 €140,420 0.784 €110,023 6 2956 €59,120 €141,120 0.746 €105,306 7 2991 €59,820 €141,820 0.711 €100,789 8 3027 €60,540 €142,540 0.677 €96,477 9 3063 €61,260 €143,260 0.645 €92,347 10 3100 €62,000 €144,000 0.614 €88,404 11 3137 €62,740 €144,740 0.585 €84,626 12 3175 €63,500 €145,500 0.557 €81,020 13 3213 €64,260 €146,260 0.530 €77,565 14 3252 €65,040 €147,040 0.505 €74,265 15 3291 €65,820 €147,820 0.481 €71,104 16 3330 €66,600 €148,600 0.458 €68,075 17 3370 €67,400 €149,400 0.436 €65,183 18 3410 €68,200 €150,200 0.416 €62,411 19 3451 €69,020 €151,020 0.396 €59,764 20 3492 €69,840 €151,840 0.377 €57,227 €1,250,400 €2,890,400 €1,786,280

Grange Fixed O&M Costs (including UV) €50,000 per annum Variable Costs (including UV) €24 per PE

Year of Operation PE Variable O&M Cost Total O&M Cost NPV Factor NPV O&M Cost 1 777 €18,648 €68,648 0.952 €65,379 2 759 €18,216 €68,216 0.907 €61,874 3 768 €18,432 €68,432 0.864 €59,114 4 777 €18,648 €68,648 0.823 €56,477 5 786 €18,864 €68,864 0.784 €53,957 6 795 €19,080 €69,080 0.746 €51,549 7 805 €19,320 €69,320 0.711 €49,264 8 815 €19,560 €69,560 0.677 €47,081 9 825 €19,800 €69,800 0.645 €44,994 10 835 €20,040 €70,040 0.614 €42,998 11 845 €20,280 €70,280 0.585 €41,091 12 855 €20,520 €70,520 0.557 €39,268 13 865 €20,760 €70,760 0.530 €37,526 14 875 €21,000 For inspection purposes€71,000 only. 0.505 €35,860 15 886 Consent€21,264 of copyright owner€71,264 required for any other use.0.481 €34,279 16 897 €21,528 €71,528 0.458 €32,768 17 908 €21,792 €71,792 0.436 €31,323 18 919 €22,056 €72,056 0.416 €29,941 19 930 €22,320 €72,320 0.396 €28,619 20 941 €22,584 €72,584 0.377 €27,356 €404,712 €1,404,712 €870,718

Strandhill Fixed O&M Costs (including UV) €73,500 per annum Variable Costs (including UV) €21 per PE

Year of Operation PE Variable O&M Cost Total O&M Cost NPV Factor NPV O&M Cost

1 2322 €48,762 €122,262 0.952 €116,440 2 2352 €49,392 €122,892 0.907 €111,467 3 2383 €50,043 €123,543 0.864 €106,721 4 2414 €50,694 €124,194 0.823 €102,175 5 2445 €51,345 €124,845 0.784 €97,819 6 2477 €52,017 €125,517 0.746 €93,663 7 2509 €52,689 €126,189 0.711 €89,680 8 2542 €53,382 €126,882 0.677 €85,879 9 2575 €54,075 €127,575 0.645 €82,236 10 2608 €54,768 €128,268 0.614 €78,745 11 2642 €55,482 €128,982 0.585 €75,413 12 2676 €56,196 €129,696 0.557 €72,220 13 2711 €56,931 €130,431 0.530 €69,170 14 2746 €57,666 €131,166 0.505 €66,248 15 2782 €58,422 €131,922 0.481 €63,457 16 2818 €59,178 €132,678 0.458 €60,781 17 2855 €59,955 €133,455 0.436 €58,226 18 2892 €60,732 €134,232 0.416 €55,776 19 2930 €61,530 €135,030 0.396 €53,436 20 2968 €62,328 €135,828 0.377 €51,192 €1,105,587 €2,575,587 €1,590,744

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13 Tubbercurry, Grange and Strandhill Design Review Report DBO Bundle

Calculation Sheet

Project Number: 20391 Rev Date By Project Name: Tubbercurry WwTW 1.2 28-Jan-13 F. Lane Sheet: 2 of 2 20 Year Operation and Maintenance Costs Gurteen Fixed O&M Costs €52,000 per annum Variable Costs €20 per PE

Year of Operation PE Variable O&M Cost Total O&M Cost NPV Factor NPV O&M Cost

1 1200 €24,000 €106,000 0.952 €100,952 2 1224 €24,480 €106,480 0.907 €96,580 3 1248 €24,960 €106,960 0.864 €92,396 4 1273 €25,460 €107,460 0.823 €88,408 5 1298 €25,960 €107,960 0.784 €84,589 6 1324 €26,480 €108,480 0.746 €80,949 7 1350 €27,000 €109,000 0.711 €77,464 8 1377 €27,540 €109,540 0.677 €74,141 9 1405 €28,100 €110,100 0.645 €70,971 10 1433 €28,660 €110,660 0.614 €67,936 11 1462 €29,240 €111,240 0.585 €65,040 12 1491 €29,820 €111,820 0.557 €62,266 13 1521 €30,420 €112,420 0.530 €59,619 14 1551 €31,020 €113,020 0.505 €57,083 15 1582 €31,640 €113,640 0.481 €54,663 16 1614 €32,280 €114,280 0.458 €52,353 17 1646 €32,920 €114,920 0.436 €50,139 18 1679 €33,580 €115,580 0.416 €48,026 19 1713 €34,260 €116,260 0.396 €46,008 20 1747 €34,940 €116,940 0.377 €44,073 €582,760 €2,222,760 €1,373,657

Carney Fixed O&M Costs €50,000 per annum Variable Costs €24 per PE

Year of Operation PE Variable O&M Cost Total O&M Cost NPV Factor NPV O&M Cost 1 550 €13,200 €63,200 0.952 €60,190 2 561 €13,464 €63,464 0.907 €57,564 3 572 €13,728 €63,728 0.864 €55,051 4 583 €13,992 €63,992 0.823 €52,646 5 595 €14,280 €64,280 0.784 €50,365 6 607 €14,568 €64,568 0.746 €48,182 7 619 €14,856 €64,856 0.711 €46,092 8 631 €15,144 €65,144 0.677 €44,092 9 644 €15,456 €65,456 0.645 €42,194 10 657 €15,768 €65,768 0.614 €40,376 11 670 €16,080 €66,080 0.585 €38,636 12 683 €16,392 €66,392 0.557 €36,970 13 697 €16,728 €66,728 0.530 €35,387 14 For inspection purposes only. 711 Consent€17,064 of copyright owner€67,064 required for any other use.0.505 €33,872 15 725 €17,400 €67,400 0.481 €32,421 16 740 €17,760 €67,760 0.458 €31,042 17 755 €18,120 €68,120 0.436 €29,721 18 770 €18,480 €68,480 0.416 €28,455 19 785 €18,840 €68,840 0.396 €27,242 20 801 €19,224 €69,224 0.377 €26,090 €320,544 €1,320,544 €816,585

Ballinafad Fixed O&M Costs €18,000 per annum Variable Costs €31 per PE

Year of Operation PE Variable O&M Cost Total O&M Cost NPV Factor NPV O&M Cost

1 160 €3,360 €76,860 0.952 €73,200 2 163 €3,423 €76,923 0.907 €69,771 3 166 €3,486 €76,986 0.864 €66,503 4 169 €3,549 €77,049 0.823 €63,388 5 172 €3,612 €77,112 0.784 €60,419 6 175 €3,675 €77,175 0.746 €57,589 7 179 €3,759 €77,259 0.711 €54,907 8 183 €3,843 €77,343 0.677 €52,349 9 187 €3,927 €77,427 0.645 €49,910 10 191 €4,011 €77,511 0.614 €47,585 11 195 €4,095 €77,595 0.585 €45,368 12 199 €4,179 €77,679 0.557 €43,255 13 203 €4,263 €77,763 0.530 €41,239 14 207 €4,347 €77,847 0.505 €39,318 15 211 €4,431 €77,931 0.481 €37,486 16 215 €4,515 €78,015 0.458 €35,740 17 219 €4,599 €78,099 0.436 €34,074 18 223 €4,683 €78,183 0.416 €32,487 19 227 €4,767 €78,267 0.396 €30,973 20 232 €4,872 €78,372 0.377 €29,538 €81,396 €1,551,396 €965,100

Nicholas O’Dwyer Ltd. January 2013

EPA Export 20-02-2013:23:45:13