EIA Screening Report- Lahinch Coastal Protection
Final
December 2016
JBA Project Manager Deirdre McDonnell 24 Grove Island Corbally Limerick Ireland Revision History
Revision Ref / Date Issued Amendments Issued to
Draft V1.0/ Dec 2016 Clare County Council
Contract This report describes work commissioned by Clare County Council by JBA Consulting-Cronin Millar Consulting Engineers Consortium for the proposed Coastal protection and sea defence works at Lahinch, Co. Clare
Prepared by ...... Catalina Herrera BSc Msc Reviewed by ...... Declan Egan BSc. MSc. CSci. CEnv. CWEM MCIWEM MCIWM Approved by ...... Jonathan Cooper BEng MSc DipCD CEng MICE MCIWEM C.WEM MloD Director (JBA)
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Copyright © JBA Consulting Engineers and Scientists Ltd 2016 Carbon Footprint A printed copy of the main text in this document will result in a carbon footprint 107g if 100% post- consumer recycled paper is used and 136g if primary-source paper is used. These figures assume the report is printed in black and white on A4 paper and in duplex. JBA is aiming to reduce its per capita carbon emissions.
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Contents
1 Introduction ...... 3 2 Purpose of the Study ...... 3 3 Methodology ...... 3 4 Site description ...... 4 4.1 Project Characteristics ...... 5 5 Receiving Environment ...... 6 5.1 Human Being ...... 6 5.2 Water ...... 6 5.3 Soil and Geology ...... 7 5.4 Ecology ...... 8 5.5 Landscape and Visual Resources ...... 12 5.6 Cultural Heritage and Archaeology ...... 12 6 Annex III Criteria Assessment ...... 13 6.1 Characteristics of the proposed development ...... 13 6.2 Location of Development ...... 16 6.3 Characteristics of Potential Impacts ...... 16 7 EIA Screening ...... 20 7.1 European Commission EIA Screening Checklist ...... 20 8 Conclusion ...... 24 9 References ...... 25 Appendices...... I A Screening Criteria Reference Documents...... I B EirEco Appropriate Assessment (AA) Screening Report ...... II
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List of Figures Figure 4-1. Lahinch site location ...... 4 Figure 4-2: Lahinch site layout ...... 5 Figure 5-1. WFD Coastal Waterbody Ecological Status 2010-2012 ...... 7 Figure 5-2. Soil conditions around the study extent ...... 8 Figure 5-3. Designated sites in close proximity to Study extent ...... 9 Figure 5-4. Location of designation relevant to the area of works...... 10 Figure 5-5. National Monuments Services (NMS) and National Inventory of Architectural Heritage (NIAH) ...... 13 List of Tables Table 5-1. Protected habitat and species within the area or within the adjacent zone of influence ...... 10 Table 5-2. Record or archaeological and cultural record site ...... 12 Table 6-1. Characteristics of potential Impacts on environmental parameters ...... 16 Table 7-1. EIA Screening Checklist ...... 20
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Abbreviations CFRAM ...... Catchment Flood Risk Assessment and Management CIRIA ...... Company providing research and training in the construction industry EC ...... European Community EPA ...... Environmental Protection Agency FSR ...... Flood Studies Report FSU ...... Flood Studies Update HEFS ...... High End Future Scenario IH ...... Institute of Hydrology ISIS ...... Hydrology and hydraulic modelling software LiDAR ...... Light Detection And Ranging MAF ...... Mean annual flood MRFS ...... Medium Range Future Scenario MSL ...... Mean sea level OPW ...... Office of Public Works SAC ...... Special Area of Conservation, protected under the EU Habitats Directive SEA ...... Strategic Environmental Assessment SFRA ...... Strategic Flood Risk Assessment SPA ...... Special Protection Area for birds, protected under the EU Habitats Directive SPR ...... Standard percentage runoff WFD ...... Water Framework Directive WRAP ...... Winter Rain Acceptance Potential
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1 Introduction Clare County Council commissioned JBA Consulting, Cronin Millar Consulting Engineers (CMCE), and Malachy Walsh and Partners (MWP) to develop a detailed design and coastal protection works at Lahinch, Co Clare to address the condition of the existing defences, reduce levels of wave overtopping along the coastal frontage and to prevent further coastal erosion. An Environmental Impact Assessment (EIA) screening assessment is required under Part 8 of the Planning and Development Regulations 2001. This report addresses the findings of the screening assessment. 2 Purpose of the Study The purpose of the EIA screening assessment is to determine whether the proposed detailed design, coastal protection upgrades and works at Lahinch, Co. Clare are likely to cause any significant effects to the environment. This will assist in establishing whether an EIA would be appropriate for this project. EIA is a key instrument of European Union environmental policy (Directive 85/337/EEC and Directive 97/11/EC). The EIA process is composed of three stages: screening, scoping, and EIA An EIA screening assessment is the first stage in the process required by the Directive, where the study determines if an EIA is required for the project. The screening requirements of Directive 85/337/EEC and Directive 97/11/EC are contained in Article 4 of Directive 97/11/EC: Article 4(1) requires that "…projects listed in Annex I shall be made subject to an assessment …". An EIA is mandatory for the category of projects listed on this list. Article 4 (2) requires that for "…projects listed in Annex II, the Member States shall determine through: (a) case-by-case examination, or (b) threshold and criteria set by the member state…" Under Irish legislation, S.I No.600 of 2001 Planning and Development Regulations, an EIA is required for prescribed projects that are listed under Annex I of the EIA Directive 97/11/EC and may be required for others, if listed in Annex II or if they are likely to cause significant impacts on the environment, by nature, extent, or location. These projects are assessed on a case-by-case basis using the thresholds provided by the legislation. Coastal Protection works are listed in Annex II of EIA Directive 97/11/EC and under Irish legislation the project is found in the Planning and Development Regulations 2001 (S.I 600 of 2001), Schedule 5, Part 2, (10) Infrastructure Project (k). The project description and threshold are: (k) Coastal work to combat erosion and maritime works capable of altering the coast through the construction, for example, of dykes, moles, jetties and other sea defence works, where the length of coastline on which works would take place would exceed 1 kilometer, but excluding the maintenance and reconstruction of such works or works required for emergency purposes. Although the proposed work is a length of less than 1km (approximate 720 metres) an overarching assessment of all potential impacts will be carried out in order to confirm if the project may or may not be likely to have significant effects on the environment. 3 Methodology In order to assess the sensitivity of the project location and potential impacts of the project, in determining if an EIA is needed, two EU resources were used: (a) Annex III Screening Selection Criteria (b) The European Commission's Guidance on EIA Screening- Checklist (ERM, 2001). (a) The selection criteria set out in Annex III (EIA Directive 97/11/EC) was taken into account. Article 4 (3) of Directive 91/11/EC requires that the selection criterial in Annex III to be considered in the screening decision. Annex III Screening Selection Criteria is composed of three main sections: characteristics of the project, location of projects, and characteristics of potential impacts necessary to consider in the assessment to ensure a comprehensive understanding of the potential significant effects to the environment. The Annex III screening criteria has been included in Appendix A.1
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(b)The EIA Screening checklist was a reference document produced by the European Commission to ensure that all the elements put forward in the Annex III selection criteria were addressed. The filled screening checklist has been included in the Appendix A.2 4 Site description The proposed upgrade to the coastal protections are along the promenade in Lahinch, Co.Clare. Lahinch is a coastal community located in Liscannor Bay. The town is a popular seaside resort and it is home to the Lahinch golf course. It has also become a popular beach and surfing destination (see Figure 4-1). Figure 4-1. Lahinch site location
The existing coastal defences are made up of a large concrete sea wall which has variable volumes of rock armour. However, the state of the defences is inadequate and would likely be unable to prevent overtopping from severe storm events. The recent storm events in January and February 2014 resulted in severed flooding around the town and carpark. The design of the coastal defence works has been divided between the consultancies: MWP are carrying out the works in the northern section of the promenade (See Figure 4-2) and JBA/CMCE are responsible for the southern portion (Section A and Section B). The total length of the works is estimated to be around 720m.
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Figure 4-2: Lahinch site layout
MWP Site Continuing northwards ~375m
Sand beach
Hard Bedrock
4.1 Project Characteristics The existing defences in the study area consists of a large concrete sea wall which has variable volumes of rock armour scour protection. Due to the differing level of risk along the coastline, the study area has been split into sections. The JBA-CMCE team is responsible for Sections A and B which represent different defence needs (Figure 4-2). Section A (the northern portion of the Study Area) is vulnerable to erosion and overtopping. The natural cliffs in the southern extent of the site (Section B) have risks mainly associated with erosion and cliff stability, located immediately to the north of section A is the other section of defence works that are being prepared Malachy Walsh and Partners (MWP). This section of the works runs in front of the promenade and carpark. The coastal defence works proposed by MWP is along a 400m section of the existing promenade and coastal protection and allows for an extension of the rock armour by 100m further north and includes an access ramp (MWP, 2015). The JBA/CME team suggested a new rock armour revetment through Section A and Section B, where Section B also incorporates a new retaining wall upon the existing wall to offer protection from overtopping. The sea cliff behind the retaining wall needs to be re-graded to improved slope stability.
4.1.1 Required refurbishment works The JBA-CMCE team designed the rock armour in tandem with the existing sea wall to offer optimal protection from overtopping: In Section A, the revetment has a primary face with a slope of 1:2, constructed with 6-10 tonne of rock armour units formed in a double interlocking layer. These are placed on the sandy beach in front of the existing promenade and seawall. In Section B, the revetment is formed of a narrower and lower level double interlocking layer of 10-15 tonne rock armour units. These will be placed on the natural rock outcrop along the toe of the existing sea wall. The proposed repair works to existing concrete seawalls will include a number of repair methods including, localised patch repair using suitable marine durable repair compounds and the application of sprayed concrete to existing surfaces. It is proposed to build a new concrete retaining wall on top of the existing sea wall at Section B. The construction will vary between a mass concrete wall and a reinforced concrete wall. The new wall will be dowelled into the existing sea wall.
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The embankment to the south of Section B is in poor condition. Works are required to stabilise this section of coastline. The MWP team proposed necessary refurbishment work to the revetment and seawall and improvements to the beach access points. This will include: The placement of two layers of 5-7 tonne rock armour on the existing revetment for stability and to reduce wave overtopping. The layer will extend into the beach. To improve structural stability of the seawall it is proposed to cast a mass concrete apron. 1.9m deep and 1m wide immediately in front of the seawall. Refurbishment of existing steps and ramped access to the beach by breaking out and replacing the top 300mm existing steps, landings, and sloped areas with reinforced C50 concrete. Development of a disabled access ramp at the north end of the promenade. 5 Receiving Environment Schedule 6 of the Planning and Development Regulations, 2001, as amended, outline the aspects of the environment likely to be significantly affected by a proposed development. These areas the following: Human Beings Air Quality Noise /Traffic Water Soil and Geology Ecology Landscape and Visual Resources Cultural Heritage, including the architectural A summary of each of the above topics as they relate to the receiving environment is provided below:
5.1 Human Being Lahinch is a well-established seaside resort located in Liscannor Bay. It is very popular due to its sandy beaches and well-known golf course. The town is also recognised for providing excellent conditions for surfing and sea-kayaking which attracts many tourists. According to the North Clare Local Area Plan 2011-2017, the town has experienced significant growth, especially in tourism- related developments. Lahinch and Ennistymon are recognised by the Clare County Development Plan 2011-2017 and the Mid-West Regional Planning Guidelines 2010-2022 as service towns, due to their role as important service centres and drivers of growth. Both towns provide business, retails, and employment opportunities.
5.1.1 Air Quality According to the EPA's Air Quality Index for Health (AQIH), current air quality (August, 2016) in Lahinch and the Rural West is Good (1). The index was based on information from monitoring instruments at representative locations in the region and may not reflect local incidents of air pollution. The index was calculated at 10:20, August 2, 2016.
5.1.2 Noise /Traffic Lahinch is a popular tourist destination, especially since the town belongs to the Wild Atlantic Way Coastal Route. The N67 goes through the town and it is highly utilised and transited. In the summer season, there are higher levels of traffic and noise due to the increased number of tourists/visitors; however, Lahinch is a regularly visited destination all year round.
5.2 Water The proposed works are located in the coastal zone, along the Lahinch promenade beside the beach and Liscanor Bay. Liscanor Bay which is considered a coastal waterbody that received a high WFD ecological status in the 2010-2012 EPA assessment (see Figure 5-1). The nearby Inagh
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Estuary is a transitional waterbody which was granted a good WFD ecological status in the EPA 2010-2012 The Rive Moy flows approximately 1.5km to the south of the site and it is therefore not anticipated to be affected by the proposed works. The Inagh River Estuary SAC has been subject to a separate Appropriate Assessment (Stage 1 Screening) carried out by EirEco (2016). Figure 5-1. WFD Coastal Waterbody Ecological Status 2010-2012
5.3 Soil and Geology The proposed coastal works are located in the coastal area along the Lahinch promenade The car park is located on made ground and the beachfront area is composed of acidic shallow, mineral drained soil (lithosols/regasols) and marine sand (refer to Figure 5-2). The bedrock in the area is composed of siltstone, mudstone, and sandstone
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Figure 5-2. Soil conditions around the study extent
5.4 Ecology This section describes data on flora and fauna within the study area in order to identify receptors potentially sensitive to flood risk management operations, or which may constrain the implementation of measures.
5.4.1 Desktop Study A desk-based review was carried out to collate information regarding protected/notable species and statutory designated nature conservation sites that may be within the zone of influence of the area of works. A review of the Appropriate Assessment Screening Report: Lahinch Coastal Protection Phase 2 (refer to Appendix B), was also undertaken. Data used for these reviews were downloaded from the National Parks and Wildlife Services Habitats and Species data download section (NPWS, date accessed 09/11/16) and from the National Biodiversity Data Centre mapping System (National Biodiversity Data Centre 09/11/16). A survey of the site was undertaken by EirEco Environmental Consultants on April 20, 2015 and July 29, 2016. The habitat within the proposed works contained the existing sea wall and associated rock armour, which extended for a distance of 500m in the inner section of Liscannor Bay. From the shoreline to the base of the rock revetment the habitat was sand (LS2) which develops into extensive beach during low tide up to c100m in width. The sandflats support a range of faunal species including burrowing bivale molluscs, oligochaete worms and isopods (EirEco, 2016). South of the promenade, horizontally bedded shale is exposed as intertidal reef, which extends to the upper shore towards the southern end of the works. Boulder and cobble shingle were mounded to the base of the sedimentary sea cliff overlying the exposed bedrock. For further information on the habitat survey of the study area, refer to Appendix B; EirEco Appropriate Assessment (AA) Screening Report.
5.4.2 Natura 2000 Sites A section of proposed works is adjacent to the Inagh River Estuary SAC (004005) and pNHA (Figure 5-3 and Figure 5-4). In addition, the Black Head-Poulsallagh Complex SAC (000020), Moneen Mountain SAC (000054), Ballyteige (Clare) (000994), Carrowmore Point to Spanish Point
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and Islands (001021), as well as, Cliffs of Moher SPA (004005) and Mid-Clare Coast SPA (004182) are all within 15km zone of influence from the area of the proposed works (Figure 5-4). Inagh River Estuary SAC (004005) The SAC and pNHA has been designated for 5 habitats listed under the EU Habitat's Directive: Salicornia and other annual colonizing mud and sand Atlantic salt meadows (Glauco Puccinellietalia maritinae) Mediterranean salt meadows (Juncetalia maritimi) Shifting dunes along the shoreline with Ammophila arenaria ("white dunes") Fixed coastal dunes with herbaceous vegetation ("grey dunes") (Priority habitat)
The estuary also supports various species of wildfowl and waders which use coastal areas and lower estuaries (NPWS, 2013). The Inagh River Estuary SAC has an expanse of grassland vegetation that provides an ideal feeding and sheltering grounds for wildfowl such as: Greenland White-fronted Goose formerly used the site during the winter months, Wigeon, Teal, Mallard, Oystercatcher, Ringed Plover, Lapwig, and Curlew (NPWS, 2013). Figure 5-3. Designated sites in close proximity to Study extent
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Figure 5-4. Location of designation relevant to the area of works
5.4.3 Protected Habitats and Species Other protected habitats and species that have been recorded as present within the area or within the adjacent zone of influence, but have not been previously discussed include European Otter (Lutra Lutra), common dolphin (Delphinus delphis), Brent Goose (Branta bernicla), Hen Harrier (Circus cyaneus), Carrion Crow (Corvus corone), Little Egret (Egretta garzetta), Peregrine Falcon (Falco peregrinus), Black-throated Diver (Gavia arctica), Red-throated Diver (Gavia stellata), Mediterranean Gull (Larus melanocephalus), Little Gull (Larus minutus), Eurasian Oystercatcher (Haematopus ostralegus), Velvet Scoter (Melanitta fusca), Surf Scoter (Melanitta perspicillata).Not included in Table 5-1, but also relevant species to the area include molluscs, fungus, crustaceans, and flowering plants. Table 5-1. Protected habitat and species within the area or within the adjacent zone of influence
Scientific name Common name Title of dataset Designation Protected Species: Wildlife Acts || Threatened Haematopus Eurasian Birds of Ireland Species: Birds of Conservation Concern >> Birds ostralegus Oystercatcher of Conservation Concern - Amber List Clare Biological Protected Species: Wildlife Acts || Protected Melanitta fusca Velvet Scoter Records Centre Species: EU Birds Directive >> Annex II, Section dataset II Bird Species
Clare Biological Melanitta Surf Scoter Records Centre perspicillata dataset Protected Species: Wildlife Acts || Protected Species: EU Birds Directive >> Annex II, Section Numenius Eurasian Birds of Ireland II Bird Species || Threatened Species: Birds of arquata Curlew Conservation Concern >> Birds of Conservation Concern - Red List Clare Biological Protected Species: Wildlife Acts || Threatened Branta bernicla Brent Goose Records Centre Species: Birds of Conservation Concern >> Birds dataset of Conservation Concern - Amber List
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Scientific name Common name Title of dataset Designation Protected Species: Wildlife Acts || Protected Clare Biological Species: EU Birds Directive >> Annex I Bird Circus cyaneus Hen Harrier Records Centre Species || Threatened Species: Birds of dataset Conservation Concern >> Birds of Conservation Concern - Amber List
Clare Biological Corvus corone Carrion Crow Records Centre dataset
Clare Biological Protected Species: Wildlife Acts || Protected Egretta garzetta Little Egret Records Centre Species: EU Birds Directive >> Annex I Bird dataset Species
Clare Biological Protected Species: Wildlife Acts || Protected Peregrine Falco peregrinus Records Centre Species: EU Birds Directive >> Annex I Bird Falcon dataset Species
Protected Species: Wildlife Acts || Protected Clare Biological Species: EU Birds Directive >> Annex I Bird Black-throated Gavia arctica Records Centre Species || Threatened Species: Birds of Diver dataset Conservation Concern >> Birds of Conservation Concern - Amber List Protected Species: Wildlife Acts || Protected Clare Biological Species: EU Birds Directive >> Annex I Bird Red-throated Gavia stellata Records Centre Species || Threatened Species: Birds of Diver dataset Conservation Concern >> Birds of Conservation Concern - Amber List Clare Biological Larus glaucoides Iceland Gull Records Centre dataset Protected Species: Wildlife Acts || Protected Clare Biological Species: EU Birds Directive >> Annex I Bird Larus Mediterranean Records Centre Species || Threatened Species: Birds of melanocephalus Gull dataset Conservation Concern >> Birds of Conservation Concern - Amber List Clare Biological Protected Species: Wildlife Acts || Protected Larus minutus Little Gull Records Centre Species: EU Birds Directive >> Annex I Bird dataset Species Protected Species: Wildlife Acts || Protected Clare Biological Species: EU Birds Directive >> Annex I Bird Oceanodroma Leach's Storm- Records Centre Species || Threatened Species: Birds of leucorhoa petrel dataset Conservation Concern >> Birds of Conservation Concern - Amber List
Clare Biological Phalaropus Grey Phalarope Records Centre fulicarius dataset
Clare Biological Phylloscopus Common Records Centre collybita Chiffchaff dataset
Clare Biological Spotted Tringa erythropus Records Centre Redshank dataset IWDG Common Cetacean Protected Species: EU Habitats Directive >> Delphinus delphis Dolphin Strandings Annex IV || Protected Species: Wildlife Acts Database IWDG Globicephala Long-finned Cetacean Protected Species: EU Habitats Directive >> melas Pilot Whale Strandings Annex IV || Protected Species: Wildlife Acts Database Atlas of Protected Species: EU Habitats Directive >> Mammals in Annex II || Protected Species: EU Habitats Lutra lutra European Otter Ireland 2010- Directive >> Annex IV || Protected Species: 2015 Wildlife Acts
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5.5 Landscape and Visual Resources This section examines the potential impact of the proposed coastal defence measures on the existing character and visual amenity at Lahinch. According to the Clare County Development Plan (2011-2017), Clare exists on natural landscape with the Atlantic Coastline as a major feature. The Wild Atlantic Way scenic routes passing all along the coast highlights Lahinch as a popular tourist destination. The North Clare Local Area Plan (2011-2017) recognises that Lahinch is a "popular well-established seaside resort, situated on the picturesque Liscannor Bay". The Lahinch Golf Club is located just north of the Lahinch promenade, it is a popular resort due to the quality of the course and its scenic views of Liscannor Bay.
5.6 Cultural Heritage and Archaeology This section examines the potential impact of the proposed coastal defence measures on cultural heritage (archaeology and architectural heritage) the Lahinch promenade. Lahinch is a coastal town with various historical records present such as National Monuments, National Inventory Services (see Figure 5-5) and Clare Coastal Architecture Sites. These have been listed in Table 5-2 and displayed in Figure 5-5. The old sea wall located along the Lahinch Promenade and within the area of proposed works is a Protected Structure No.600 in the Records of Protected Structures (RPS) in the Clare County Development Plan 2011-2017. It is given an importance rating of "Regional" and dates from c.1820. The proposed coastal protection works will be carried out adjacent to the old sea wall and will certainly adversely, visually and materially impact on the Protected Structure. The Record of Monuments and Places (RMP) is the most widely applying provision of the National Monuments Acts. It comprises a list of recorded monuments and places and accompanying maps on which such monuments and places are shown for each county. The National Monuments Service of the Department of the Arts, Heritage, Regional, Rural, and Gaeltacht Affairs (DAHRRGA) will advise on the protection applying to any particular monument or place under the National Monuments Acts by reason of it being entered in the Record of Monuments and Places and should be consulted if there is any doubt as to the status of the site. Table 5-2. Record or archaeological and cultural record site Type of feature Site Code CL023-001- Cliff-edge fort, south of the site in the National Monuments Services (NMS) Townland of CRAG. CL023-004- Ringfort- rath, east of the site in the Townland of CRAG National Inventory of Architectural Heritage Reg No. 20300404 Claremont Hotel (1840-1860) (NIAH) Reg No. 20300402 House (1859-1870) Reg No 20300401 P.Frawley House (1860-1880) Clare Coastal Architecture Heritage Survey CS042- Sea Wall (1800-1900) Halpin, S and O'Connor, G. (2007/2008). CS042- Sea Wall (1800-1900) CS044- Promenade and Stile (1900-1920) No.600 Old Sea Wall (1800-1840) Records of Protected Structures (RPS) No.598 House and Shop 1845-1855
No. 451 Claremont Hotel
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Figure 5-5. National Monuments Services (NMS) and National Inventory of Architectural Heritage (NIAH)
6 Annex III Criteria Assessment Annex III of the Directive [97/11/EC] sets out the criteria that must be considered when carrying out an EIA Screening. The screening criteria focuses on three main subjects: characteristic of the project, location of the project, and characteristic of the potential impact. This criterion is mirrored in Schedule 7 of the Planning & Development Regulations 2011-2013. The screening process for sub-threshold EIA development is set out in Article 103(1) of the Planning & Development Regulations. The criterion centres on three elements of the development: its characteristics (including cumulation with other development), its location and its potential impacts. The following sections of this screening assessment addresses these points.
6.1 Characteristics of the proposed development
6.1.1 Size of the proposed development The proposed development including both the MWP and JBA-CMCE coastal defence proposals are a length of approximately 720m. The works include repairs to the existing seawall and refurbishment and addition of revetment rock armour with heavier boulders. The extent of the proposed works (720m) is less than the threshold (1 km) given in Schedule 5 of the Planning & Development Regulations. However, all the screening criteria of the proposed works must be assessed to determine whether there is a requirement for an EIA.
6.1.2 Physical Changes The introduction of new rock armour revetment along the promenade could result with some minor physical changes. There is likely to be a slight loss of intertidal areas immediately in front of the revetment which could impact longshore sediment transfer and/or increase time of inaccessibility of the beach during high tide. Changes to the intertidal areas have the potential to impact coastal processes such as the advancement of frontal face onto the beach and the shortening of low tide windows. Also, changing the slope of the beaches could reduce the time the beach is accessible. Changes in coastal processes or longshore sediment transport could potentially impact the Inagh River Estuary SAC, due its close proximity to the proposed site in Lahinch. 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 13
A coastal modelling study carried out by UCC was undertaken to assess changes of coastal processes and longshore sediment transfer as a result of the coastal defence works and the potential impacts on the Lahinch promenade and Inagh River Estuary SAC (UCC, 2016). They modelled baseline/existing shoreline position and new shoreline position, where the coastal protection works were modelled as a fixed line (physical characteristics of the revetment not represented). The primary driver of sediment transport identified was wave action and it was discovered that the incoming waves approached the bay in a perpendicular direction. Therefore, the sediment transport moved in a cross-shore direction, resulting in very low longshore drift (UCC, 2016). Since sediment transport was identified to be cross-shore by nature in that area, very little movement towards the Inagh River Estuary SAC was anticipated. It was also concluded that the new revetment works were located outside the active transport zone, therefore they were not likely to have an impact beyond the immediate location. The comparison of the two shorelines configuration showed no significant differences in sediment transport, therefore causing no significant impacts on the Inagh River Estuary SAC and the Lahinch promenade (UCC, 2016).
6.1.3 The cumulating with other proposed developments Clare County Council proposed to repair the existing sea defences at Lahinch from the promenade. The work will entail the repair and strengthening of the revetment, sea walls, steps, and retaining walls. The proposed works will be subject to a Part 8 Planning Application, an EIS Screening, and an Appropriate Assessment (AA) Screening. The proposed works were also subject to a sediment modelling study to determine the effects of sediment transfer on the near-by Inagh River Estuary SAC. The coastal defence works that will be carried out at Lahinch may form part of one contract or may be let as two separate contracts. As a 'worst case' scenario this screening assessment assumes that both sections of the project will be constructed simultaneously. The EIA Screening assessment is shown in Section 7 of this report. The works proposed could potentially give rise to environmental effects in combination with other works to areas such as the Inagh Estuary SAC, which is located approximately 0.5 km north from the proposed coastal defence works. The next closest Natural 2000 site is the Cliff of Moher Special Protection Area (SPA), which is located 7.0 km to the northwest, however it is considered that this SPA is beyond any potential for direct or indirect impact, thus it was screened out from further assessment, as stated in the AA screening report (EirEco, 2016).
6.1.3.1 Other proposed developments The Lahinch Golf Club The Lahinch Golf Club has carried out a number of measures over the years to protect the golf course from coastal erosion. In order to prevent continuous erosion of the dune fringe along the north end of the golf course, a line of gabion baskets was placed along the toe of the dune system. The gabion baskets were originally buried in sand, yet they have become exposed over time. There is no apparent risk that the gabion baskets in combination with the proposed works will cause negative environmental impacts to the Inagh River Estuary SAC and the surrounding environment. The golf course also introduced wire mesh fencing along the entire south western facing dune which is subject to planning query by the Clare County Council. The fence line is located above the extensive rock armour in the northern portion of the Lahinch promenade and it is outside the Inagh River Estuary SAC (EirEco, 2016). The sediment model carried out by UCC did not take the gabion baskets into consideration in the assessment. Any sediment transport change caused by the introduction of the gabion baskets has not been assessed. However, since the impacts of the proposed coastal defence works in the Lahinch promenade are negligible, according to the UCC (2016) assessment, there are no apparent effects to the environment in- combination with the Lahinch Golf Club measures. New Bridge at Ennistymon Clare County Council proposes to construct a new bridge over the Inagh River at Ennisymon. The bridge location is outside the Inagh River Estuary SAC. The bridge design has avoided any in- stream works. The project implemented measures to inhibit runoff or leakage into the river, which are considered the main risks posed by the construction of the new bridge. According to an Appropriate Assessment Screening Report carried out by EirEco Environmental Consultants (September 2015) there was no potential for a significant impact on the Inagh River Estuary (SAC).
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Therefore, it can be assumed that the in-combinations effects of the new bridge and the coastal defence works in the Lahinch promenade are not significant. Liscannor Bay Coastal Flooding and Erosion Risk Management Survey After the extensive storms of January and February 2014 Clare County Council and the Office of Public Works (OPW) carried out an assessment of coastal processes that pertain in Liscannor Bay. The feasibility study will be submitted to the OPW and a decision taken on what works if any should progress to detailed design and planning stage. Minor road maintenance works on the R478 at Ballyellery Clare County Council is currently carrying out minor roadworks for the length of 900m at Ballyellery Liscannor. The public road deteriorated dramatically following an increase of traffic along the Wild Atlantic Way coastal route. The road was upgraded, the width of the roadway was increased from 1m to 1.5m, and a new footpath was introduced. Also, some refilling and recountouring of adjoining lands took place. The works are adjacent to the Inagh River Estuary SAC. A wetland survey undertaken by Dr.Peter Crushell in March 2016 (Wetland Surveys Ireland, 2016) concluded that the infilling and re-contouring of adjoining lands resulted in the loss of 2.8 ha of wetland habitat. The site is hydrologically connected to the River Inagh Estuary SAC via drains that discharge to the Laghvally Stream, which flows into the SAC. A hydrological assessment was carried out to determine the likelihood of the SAC being directly or indirectly impacted by the re-contouring and refilling of adjoining lands. The hydrological investigation concluded that the potential impact is minor and that impacts on the qualifying interests of the SAC were not anticipated (EirEco,2016). Therefore, it can be assumed that the cumulative impact of the minor road maintenance works and the coastal defence works in the Lahinch promenade are not likely to cause significant effect to the environment.
6.1.3.2 In-combination Effect The main in combination effects with the proposed coastal protection works and other projects in the area is potentially impacted the Inagh River Estuary SAC through diffuse contamination and or runoff from the construction sites. Other impacts such as changes of sediment transfer or potential contamination of water quality have been ruled out by project-specific assessments (as shown in the previous section). If appropriate Construction Environmental Management Plans (CEMP) are implement in all the projects alike, as well as, IFI (2016) Guidelines on Protection of Fisheries During Construction Works in and Adjacent to Waters and CIRIA best practice guidelines, these potential effects could be prevented.
6.1.4 Use of natural resources The natural resources that will be used in the coastal defence works are rock/boulders (limestone), sand, and other materials that will be sourced from authorised quarries and transported to the site by road. In addition to these, other materials that will be used for the repairing of seawalls are concrete and core fill material. Concrete is made up of cement, water, and aggregates (sand, gravel, stone). There will be no requirement for abstraction of water for the proposed works. The proposed works cover a length of 720 m and the types, and quantities of material that will be used will be minimal.
6.1.5 Production of waste, pollution, and nuisance The proposed coastal works will generate waste particularly during construction. The work will involve the use of material and/or substances which could pose waste or pollution risk such as fuels, oils, and concrete. However, it is unlikely that any significant volumes of waste will be generated, as well as, material/products will be managed in accordance to regulations and requirements. Waste should be removed by a licenced contractor to the relevant authorised facility. Plant/construction machinery and vehicles will likely release emissions into the air, however, it is not likely that they will result in a significant environmental effect. Due to the sensitivity of the environment the contractor will be required to have a Construction Environmental Management Plan. This Plan will provide sufficient mitigation measures and control to ensure full environmental protection during the works. 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 15
6.1.6 Human health and environmental risk The proposed coastal protection works are likely to cause temporary disturbances to local residents, beach goers, surfers, and users of the Lahinch golf course. However, the works are necessary for the long-term use and enjoyment of the Lahinch promenade. The temporary works are likely to last 4-5 months. With the exception of the temporary disturbance, there will be no social changes or changes in demographics, traditional lifestyle, and employment. The Construction Environmental Management Plan(CEMP) will be a requirement for the contractor and must approved by Clare County Council and the Department of Environment, Community, and Local Government. The development will not cause an unusual or significant level of disturbance or pollution which could cause a significant effect to the environment and therefore require an EIA.
6.1.7 Risk of accidents, having regard in particular to substance or technologies used The risks of accidents associated with the proposed coastal development are not likely to cause unusual, adverse or significant environmental effects, as they will be only those associated with the refurbishment of rock armour and restoring of the sea wall. A full Health and Safety Plan and Risk Assessment will be required to be prepared by the contractor.
6.2 Location of Development
6.2.1 The existing land-use Lahinch is a popular, well-stablished seaside town located on Liscannor Bay. The town is well- known for its sandy beaches and its popular golf course. It also has excellent water for surfing and sea kayaking, which attracts many tourists. The centre of the town has a concentration of pubs, restaurants, hotel/accommodation, shops, and tourist related outlets. The town's existing land use is composed of a mixture of tourist and residential areas, along with the town centre, recreation areas (golf course), and open areas (including Lahinch promenade). The area of the proposed coastal protection works is that of a promenade, seawall, and rock armour, therefore the proposed works are not changing or impacting the land-use of the area. The area experiences high numbers of European and American tourists annually.
6.2.2 The relative abundance, quality and regenerative capacity of natural resources in the area The proposed coastal protection works are located in a modified habitat. The Corrine 2012 database published in 2014 shows part of the area of the works as 121-discontinous urban fabric, 142-sport and leisure, and 231-pasture. The North-Clare Local Area Plan has the promenade categorised as 'open area'. The works are proposed in an already highly modified habitat and thus will not impact the quality or regenerative capacity of the area. There is a valuable ecological site north of the proposed works, the Inagh River Estuary SAC and pNHA. An assessment of the potential of the works on the SAC and pNHA are being considered and a separate Appropriate Assessment Screening Report is being prepared as part of this planning application (EirEco, 2016).
6.2.3 The absorption capacity of the natural environment The proposed coastal works consist primarily of refurbishment of existing coastal protection works along the Lahinch promenade. As coastal rock armour is already present on the site, the repair and extension, which includes the introduction of larger and heavier revetment, will not impact the absorption capacity of the natural environment.
6.3 Characteristics of Potential Impacts The potential impacts are considered in relation to the characteristics and location of the project. These have been displayed in the table below (Table 6-1). Table 6-1. Characteristics of potential Impacts on environmental parameters Environmental Topic Potential Impact
The proposal to refurbish the coastal protection works may cause a Human Environment temporary disturbance to the closest residents, beach-goers, and golf course users. However, the works are necessary to avoid wave overtopping and flooding during extreme storm events. There will be 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 16
Environmental Topic Potential Impact temporary disturbances for a duration of approximately 4-5 months, yet the works will result in the long-term positive benefits to the enjoyment of the promenade.
The proposed works involve the placing of suitably sized rock armour along the line of the existing revetment front face, resulting in the extension of the structure some 5 to 6m seaward of the existing face. The slight advancement will result in a slight reduction in the period during which the tide is away from the revetment. This will reduce the time that the beach is accessible by approximately 10-20 minutes depending on spring tide or neap tide. The slight shortening of time may have a slight impact on the recreational beach users, however, the new accessibility entrance in the northern section of the beach will make up for this.
In summary there will be short term impacts on humans for the duration of the works. A number of mitigation measures will be put in place by the contractor such as working times, control of dust and noise and general nuisance arising from the works.
There will be temporary noise disturbance in the construction phase associated with machinery required to complete works. The anticipated noise sources will be produced by the following potential construction machinery: Excavator, cement trunk, pump and tractor for the delivery of materials. No unusual noise source is involved in the works.
Noise The temporary noise disturbance will be for the duration of the construction only, which is estimated to take approximately 4-5 months.
Plant will not be left idle and all machinery will be switched off when not in use. The hoarding around some of the works will help to attenuate some of the noise.
It is anticipated that some dust emissions will arise during the works but Air Quality these will be temporary. Dust suppression systems such as water bowsing site roads will help to control the dust. Stockpiles will be dampened during extended periods of dry weather.
There is no significant risk of affecting water quality as the works are located at or above high water marks and works will be undertaken at appropriate times, taking the tide into consideration. The boulders will be placed in-situ with no concrete being used. The repairs to the sea wall and sea wall extension will be carried out using reinforced concrete which will Water be contained.
A site specific Construction Environmental Management Plan (CEMP) will address the storage of oil/diesel, protection of water courses, use of concrete etc. at the sites. The works should be undertaken in accordance with the CIRIA (2003) Guidance No C584 "Coastal and Marine Environmental Site Guide".
The work will not involve excavation but will consist of the introduction of natural material such as boulders and core fill. There does not appear to Soils and Geology be specific geological sensitivity on the site, therefore no significant
environmental effects are expected.
The proposed refurbishment work will be carried out along the current coastal defences in the town of Lahinch. Ecology A section of proposed works is adjacent to the Inagh River Estuary SAC (004005) and pNHA ( Figure 5-3 and Figure 5-4). In addition, the Black Head-Poulsallagh Complex SAC (000020), Moneen Mountain SAC 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 17
Environmental Topic Potential Impact (000054), Ballyteige (Clare) (000994), Carrowmore Point to Spanish Point and Islands (001021), as well as, Cliffs of Moher SPA (004005) and Mid- Clare Coast SPA (004182) are all within 15km zone of influence from the area of the proposed works (Figure 5-4).
Other protected habitats and species that have been recorded as present within the area or within the adjacent zone of influence have been listed in Table 6-1.
Records of Otter (Lutra Lutra) by Seamus Hassett (Atlas of Mammals in Ireland 2010-2015) and Don Cotton (Northern Ireland Mammal Database) have been documented in Lahinch town and its surrounding areas. Otters are protected under the Irish Wildlife (Amendment) Act, 2000 and the EU Habitats Directive, as they are listed under Annex II and Annex IV. Otter are expected to occur in the northern end of the beach in the vicinity of the Inagh River Estuary SAC (004005) but are unlikely to be regular visitors to the promenade (EirEco, 2016). The rock armour revetment and seawall are not likely to be an otter resting place due to the high levels of human activity and tidal changes (EirEco, 2016). Otters are more inclined to be in proximity to freshwater inflows such as the Inagh River Estuary SAC (004005).
The area in the vicinity of the proposed works along the promenade are not used as a high tide roost by any bird (EirEco, 2016). The upper shore in the vicinity of the proposed works does not provide suitable foraging habitat for waders as it is comprised of large boulders, though it may attract a small number of wintering waders (oystercatcher, turnstone, and dunlin) (EirEco, 2016).
A sediment model study was carried out by UCC (2016) to assess the extent to which the proposed works could alter the sediment regime of the coastal waterbody, which could potentially impact qualifying species in the Inagh River Estuary SAC (004005). The assessment concluded that there were no significant changes in sediment movement and since the sediment transport was identified to be cross shore by nature in that area, very little movement towards the Inagh River Estuary SAC was anticipated. As a result, the works were not likely to have any significant environmental effects on the Inagh River Estuary SAC (004005).
The limited vegetation on the sea cliff could provide a limited foraging potential for passerine species such as pipits, goldfinch, and wagtail. The works will result in the loss of a narrow strip of intertidal sandy shore and intertidal reef habitat, however this will not be within the SAC and loss will be minimal in view of the extensive intertidal zone in the vicinity. Overall, it was determined that there will be no significant effect on the Natura 2000 network arising from the proposed works, as well as, no potential risk to any of the qualifying interests of the Inagh River Estuary SAC.
An Appropriate Assessment (AA) screening study was carried out by EirEco which looked the potential effects of the proposed works on the Inagh River Estuary SAC (004005) (EirEco,2016). The conclusion of the AA Screening Report deduced that no potential impact on the Natura 2000 site was predicted, therefore no requirement to proceed to Stage 2: Natura Impact Statement (EirEco, 2016).
The proposed coastal defence works will likely cause a short-term Landscape and disturbance to the landscape and visual resource of the Lahinch Visual resources promenade during the construction works, however this disruption will only be temporary. The new coastal defences will provide the area with long- term protection from flooding during extreme weather events.
Archaeology and The proposed coastal defence works will be taking place adjacent to the Cultural Heritage RPS No.600, and it is likely that there will be an adversely, visual and material impact on the Protected Structure.
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Environmental Topic Potential Impact However, the proposed works will protect the wall from future coastal degradation (erosion)
In order to ensure appropriate mitigation, the proposal was forwarded to a representative of the Architectural Heritage Advisory Unit (AHAU) of the Department of Arts, Heritage, and the Gaeltacht (DAHG) for comment. Correspondence from the Department has not been received yet.
6.3.1 Extent of the impact (geographical area and size of the affected population) The extent of the impact of the proposed works will be limited to the areas of the existing coastal protection works, the extended revetment, and the reinforced seawall and coastal cliff/embankment. A temporary impact will occur with trucks and services entering the site but this will be temporary and not significant. There will temporary disturbances during the construction for regular beach goers and surfers, as well as local residents. There will also be a temporary effect on the car park during construction, due to the placement of the construction compound in the parking lot. The contractor will ensure that adequate hoarding is in place to prevent access to the site by the public and to ensure that all health and safety requirements are adhered to.
6.3.2 Trans-frontier nature of the impact Potential transfrontier impacts could arise in the event of pollution to coastal waters and nearby watercourses.
6.3.3 Magnitude and complexity of the impact With the use of best practice guidelines such as Construction Environmental Management Plan (CEMP), IFI (2016) Guidelines on Protection of Fisheries During Construction Works in and Adjacent to Waters and CIRIA best practice guidelines to ensure no deterioration of water quality among others, and the adherence to statutory requirements will address and mitigate the impact to several environmental parameters during the construction and operational phase. The principal potential impacts relate to archaeology and cultural heritage. Potential impacts on the Inagh River Estuary SAC ruled out in assessment.
6.3.4 Probability of impact The probability of impacts that could results in significant environmental effect is minimal. All areas that had potential risk were further explored and screened out as a result of negligible effect.
6.3.5 Duration, frequency, and reversibility The construction of the proposed coastal protections works will take approximately 4-5 months. Once the defence works are completed, they will remain permanently to prevent future flooding or overtopping.
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7 EIA Screening
7.1 European Commission EIA Screening Checklist Table 7-1. EIA Screening Checklist Is this likely to result in a Question considered Yes/No? Briefly describe significant effect? Yes/No/?- Why Brief Project Description: Lahinch Coastal Protection works will consist of rock armour revetment, a new retaining wall, improve the stability of cliff behind retaining wall, improve accessibility to beach area. The total length of the proposed works is approximately 720m.
No, the introduction of rock armour Yes, there will be some minor could result in the slight loss of physical changes caused by the intertidal areas immediately in front 1.Will construction, operation or construction of the works. of revetment works. Inaccessibility decommissioning of the Project Potential physical changes: of beach for longer if low tide involved action which will cause -Advancement of frontal face onto periods are reduced. However, a physical changes in the locality beach beach access route will be (topography, land use, changes in -Shorter low tide introduced to the north of the works waterbody etc?) -the beach slope will be lower where the coast is set back from (lowering the time the beach is the of the promenade revetment accessible) and where the beach levels are higher. Yes, the construction and operation of the project 2.Will construction or operation of will use some natural resources the Project use natural resources such as: such as land, water, materials or -Rock (boulders) No. It is anticipated that the use of energy, especially any resources -Sand natural resources will be limited. which are non-renewable or in -Core fill materials short supply? -Concrete (cement, water, aggregates ie: sand, gravel, stone). No, it is not likely that this will 3.Will the Project involve the use, Yes, the project will involve the results in a significant storage, transport, handling or use, storage, environmental effect because the production of substances or transport, handling or production appropriate construction materials which could be harmful of substances or and environmental procedures will to human health or the materials which could be harmful be followed. None of the materials environment or raise concerns to human health used will cause significant risk to about actual or perceived risks to or the environment such as humans. human health? concrete, fuels, and oils.
No, this is not expected to result in a significant effect as all the wastes 4.Will the project produce solid Yes, some amount of waste may produced will be adequately wastes during construction or be created during managed and will meet the operation or decommissioning? construction. requirements of the Waste Management Act. 5.Will the project release pollutants Yes, during construction, plant No, the emissions will be minor or any hazardous, toxic, or noxious machinery, construction and are not likely to results a substances to air? vehicles will release emissions. significant environmental effect. No, the noise and vibration will not 6.Will the project cause noise and Yes, the projects will cause noise likely cause significant vibration or release light, heat and vibration but environmental effect since the energy, or electromagnetic only during the construction disturbance will only be radiation? phase. temporary. 7. Will the project lead to risks of No, an CEMP will be installed by contamination of land or water the contractor and will be agreed from releases of pollutants onto the Yes, there is a risk that of with Clare County Council prior to ground or into surface waters, contamination to land or water. commencement of the works. The groundwater, coastal water or the CEMP will provide adequate sea? protection to the environment. 8.Will there be any risk of Yes, there is a risk of accidents No, this is not likely as there will be accidents during the construction during the a full health & Safety Plan and a or operation of the Project which construction of the project which Risk Assessment prepared as part could affect human health or the could affect the of the contract. environment? environment or human health. 9. Will the project result in social changes for example in No No demography, traditional lifestyles, 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 20
employment? 10. Are there any such other factors which should be considered Yes, the Inagh River Estuary SAC such as consequential is located just Pending updated Appropriate development which could lead to north of the proposed site. Any Appraisal of impact of coastal environmental effects or the impacts that could works to the Inagh River Estuary potential for cumulative impacts be inflicted to the SAC should be SAC. with other existing or planned evaluated. activities in the locality? No, it is not believed that the proposed coastal protection works Yes, the proposed works are in is going to affect the SAC or pNHA 11.Are there any areas on or very close proximity to the Inagh as described in the AA around the location which are River Estuary SAC and pNHA. Screening. protected under international or The proposed works may cause national or local legislation for their The proposed works are also some obstruction of the old sea ecological, landscape, cultural, or adjacent to structures that belong wall RPS structure, and we have other value, which could be to Clare County Council RPS and consulted with a representative of affected by the project? Clare Coastal Architectural the Architectural Heritage Advisory Heritage. Unit (AHAU) of the Department of Arts, Heritage, and the Gaeltacht (DAHG) for comment. No, as per the AA screening, there will be no direct impacts on any habitats within the Inagh River Estuary SAC or an any Annex I habitats listed as qualifying interest for the SAC. The potential risks may come from Yes, the areas within and around a) pollution incident during the SAC are important for construction works 12.Are there any other areas on or ecological reasons. b) an alteration of the coastal around the location which are Important habitats include but are processes from the new revetment. important or sensitive for reasons not limited to: of their ecology, which could be -Lowland Hay Meadows A sediment process model was affected by the project? -Molina Meadows carried out to assess the potential -Estuary impacts of the proposed works on -Salt Meadows the wave output and sediment transfer and concluded that sediment transfer occurred in a cross shore direction and longshore drift would be very low. Therefore, there would be very little movement towards the Inagh Estuary SAC (UCC, 2016). No, as per the AA Screening. The upper shoreline of the revetment 13.Are there any areas on or does not provide a foraging habitat around the location which are used Yes, wintering and breeding for any bird species and there are by protected, important or sensitive birds(SAC) in close proximity to no otter holts or couches in the species of fauna or flora which proposed coastal protection site. vicinity of the works or likely to be could be affected by the project? regular activity due to the high level of human activity (EirEco, 2016). No, as per the AA screening. The proposed works will result in the loss of a narrow strip of intertidal Yes, there is an estuary (Inagh 14. Are there any inland, coastal, sandy shore and intertidal reef River Estuary) north of the site marine, or underground waters on habitat (c5-6m in width over the and the River Moy is 1.5 km south or around the location which could 300m length) but this is not within of the be affected by the project? the SAC and in view of the site. extensive intertidal zone in the vicinity (>100m), the habitat loss is not considered be significant. No, it is not believed that the proposed development will cause significant environmental 15. Are there any areas or features Yes, the town of Lahinch and the effects. However, there will be of high landscape or scenic value proposed site are temporary disturbance during on or around the location which located along the Wild Atlantic construction. could be affected by the project? Way Scenic route The coastal protection works will be beneficial in the long-term. 16. Are there any routes or Yes, the beach area and the car No, it is not believed that this will facilities on or around the location park will be temporary out of limits result in significant effects. Simply which are used by the public for of the public until construction is a temporary disturbance. access to recreation or other finalised. 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 21
facilities, which could be affected by the project? No, there is no main road in the proposed site. 17.Are there any transport routes The N67: Miltown Malbay Road, on or around the location which are Sleeper Street, Second Lane, susceptible to congestion or which Marine Parade are located nearby No cause environmental problems, but will not be affected by the which could be affected by the proposed works because the project? works will take place along the Lahinch promenade Yes, the works are in a location where it is highly visible by many people. The works will occur 18. Is this project in a location along the Lahinch promenade. It No, the construction works will where it is likely to be highly visible is a very popular tourist area and cause temporary disturbance only. to many people? it is in close proximity to residential and commercial locations. Yes, there are National Monuments and structures Yes, there is an RPS site adjacent of National Inventory of to the works that could be severely Architectural Heritage in impacted. For that reason, the 19.Are there any areas or features the Town of Lahinch but none proposal was forwarded to a of historic or cultural importance on alone representative of the Architectural or around the location which could Heritage Advisory Unit (AHAU) of be affected by the project? There are also three coastal the Department of Arts, Heritage, architectural site (Clare) and the Gaeltacht (DAHG) for on the development area. Listed comment in the report. 20.Is the project located in a previously undeveloped area No No where there will be loss of greenfield? 21.Are there existing land uses on or around the location i.g. homes, gardens, other private property, Yes, there are residential, industry, commerce, recreation, commercial, and tourist No public, open space, community areas that could be temporarily facilities, agriculture, forestry, disturbed. tourism, mining or quarrying which could be affected by the project? 22. Are there any plans for future land uses on or around the location No No which could be affected by the project? 23. Are there any areas on or around the location which are densely populated or built-up, No No which could be affected by the project? 24. Are there any areas on or around the location which are occupied by sensitive land uses e.g. hospitals, schools, places of No No worship, community facilities, which could be affected by the project? 25.Are there any areas on or around the location which contain important, high quality or scarce resources e.g groundwater, No No surface waters, forestry, agriculture, fisheries, tourism, minerals, which could be affected by the project? 26. Are there any reasons on or around the location which are already subject to pollution or environmental damage e.g. where No No existing legal environmental standards are exceeded, which could be affected by the project? 27. Is this project location Yes, the existing works are for the No, the proposed works will result susceptible to earthquakes, purpose of flood protection which in the protection from extreme subsidence, landslide, erosion, have failed in the past. Some weather conditions and/or flooding. 2015s3069_Lahinch Coastal Protection-EIA Screening Report V 1 22
flooding or extreme or adverse areas like the cliff edge is climatic conditions e.g temperature susceptible to erosion and inversions, fogs, severe winds, landslide. which could cause the project to present environmental problems?
Summary of features of projects and of its location indicating the need for EIA.
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8 Conclusion Coastal Protection works are listed under Annex II of EIA Directive 97/11/EC and under Irish legislation, under the Planning and Development Regulations 2001 (S.I 600 of 2001), Schedule 5, Part 2, (10) Infrastructure Project (k). The legislation states that the threshold for a mandatory EIA of coastal protection works is any coastal project that extends a length of 1km or more. Although the proposed coastal defence work is a length of less than 1km (approximate 720 metres) and this is below the threshold for a mandatory EIA, an EIA screening was carried out to confirm that the project would not be likely to have significant effects on the environment. Article 4 (3) of Directive 91/11/EC requires that the selection criterial be evaluated in the screening decision. Thus, all potential impacts were considered in the assessment to ensure a comprehensive understanding of the potential significant effects. With the exception of the obstruction impact on the existing sea wall, RPS Structure No.600, of the Clare County Council Development Plan2011-2017, the majority of the impacts caused by the proposed coastal defence works will be short term and not significant. Potential impacts on human beings will be short-term and not significant and there will be mitigation measures in place to control traffic, noise, and dust. Impacts on sediment movement/transport will be minimal and will not impact the Inagh Estuary SAC. The slight loss of intertidal areas immediately in front of revetment works which could result in a slight reduction of accessibility of the beach will be counteracted with the introduction of a new beach access route to the north of the works. The study area does not provide suitable habitat for any bird species and there are no otter holts in the vicinity of the works, therefore it is not likely that the proposed coastal works will have a negative impact on ecology. There are no expected significant effects on water since the works will be undertaken at or above the high water mark. Most of the potential impacts will be mitigated by the preparation of a Construction Environmental Management Plan (CEMP) that should be agreed upon by all parties before the commencement of the works. The interaction between the potential effects to the environment are not likely to be significant, therefore, an EIA will not be required for this project.
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9 References Halpin, S and O'Connor, G. (2007/2008). Clare Coastal Architecture Heritage Survey. Clare County Council, Clare Heritage Forum, and The Heritage Council. CIRIA (Construction Industry Research and Information Association). (2003). Guidance No C584 "Coastal and Marine Environmental Site Guide". ERM (Environmental Resource Management). (2001). Guidance on EIA Screening. European Communities. Edinburgh. EirEco Environmental Consultants. (2016). Screening Report for Appropriate Assessment- Upgrade of Coastal Protection at Lahinch Promenade Co. Clare (Doc Ref: 1453/12). Prepared for Clare County Council. EirEco Environmental Consultants. (2015). Appropriate Assessment Screening Report for Ennistymon Relief Road Bridge Design Option 2. Report prepared for Roughan O'Donovan Consulting Engineers. JBA (Jeremy Benn and Associates) and Cronin Millar Consulting Engineers (CMCE) (2016). Lahinch Coastal Protection- Draft Preliminary Report. Prepared for Clare County Council. MWP (Malachy Walsh and Partners). (2015). EIA Screening Report-Upgrade to Lahinch Coastal Protection Works. Prepared for Clare County Council. NPWS (National Parks and Wildlife Services). (2013). Site Sypnosis for Inagh River Estuary SAC [000036]. Department of Arts, Heritage and the Gaeltacht (DAHG). UCC (University College Cork). (2016). Lahinch Coastal Protection Works-Numerical Modelling Study. Report prepared for Clare County Council.
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Appendices A Screening Criteria Reference Documents
A.1 Annex III Screening Selection Criteria
A.2 EIA Screening Checklist
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A.1 Annex III Screening Selection Criteria
A.2 EIA Screening Checklist
SCREENING CHECKLIST
INSTRUCTIONS
This checklist is designed to help users decide whether EIA is required based on the characteristics of a project and its environment.
Start by providing a brief description of the project.
Then using available information about the project answer each question in Column 2:
• Yes - if the answer is yes • No - if the answer is no • ? - if the answer is don’t know
If you are not sure what might be important use the more detailed lists of questions in the Scoping Guidance to help answer the question.
Briefly describe the relevant characteristic of the project or its environment and then consider whether any effect that is likely to result is likely to be significant and enter the response in Column 3 with a note of the reasons why. Use the next Checklist on Criteria for Evaluating Significance to help answer the question “Is this likely to result in a significant effect?”.
Some examples illustrating how to use the checklist are given below.
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Clare DRAFT Rev0 August 2016 Doc Ref: 1453/13 Carron Co. Clare Ireland Tel: +353 (0) 657 089 080 [email protected] www.eireco.ie EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Table of Contents 1 INTRODUCTION ...... 3 1.1 Regulatory Context...... 3 1.2 Stages of Article 6 Assessment ...... 3 2. STAGE 1: SCREENING ...... 4 2.1 Description of the Proposed Development ...... 4 2.2 Natura Sites Identified ...... 7 2.3 Description of the site and surrounds ...... 9 2.4.1 Direct and Indirect Loss of Habitats ...... 11 2.4.2 Disturbance to Habitats ...... 11 2.4.3 Disturbance to Species ...... 12 2.4.4 Deterioration of Water Quality...... 12 2.4.5 Potential Impacts on Coastal Processes ...... 12 2.4.6 Potential In-Combination Effects ...... 13 2.5 Conclusion ...... 18 3. REFERENCES...... 19 2 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 1 INTRODUCTION This Appropriate Assessment Screening Report has been prepared by Paul Murphy of EirEco Environmental Consultants on behalf of Clare County Council (CCC). The objective is to determine the potential effects, if any, of the upgrade of existing coastal protection works at Lahinch, Co. Clare on the Natura 2000 network, specifically the Inagh River Estuary Special Area of Conservation (Site Code 000036) which extends as far as the northern end of the promenade. Lahinch is currently protected by two forms of coastal defence: a concrete sea wall and rock armour revetment. The concrete sea wall was constructed in varying forms over several decades. It extends from the public carpark in the north, to the coastal cliffs at the south. A rock armour revetment extends from the carpark to the location of the start of a concrete recurve wall. The coastal defences provide some protection from extreme wave conditions to the town but a number of storm events in recent years have resulted in extensive over-topping and flood damage to infrastructure and property. A first phase of upgrading works has been proposed by Clare County Council extending from the northern extent of the promenade to its southern extent at the N67 road. An Appropriate Assessment Screening Report was prepared for this development by EirEco Environmental Consultants (EirEco, May 2016) which concluded that the works presented no risk of giving rise significant effects on the Natura 2000 network and no potential for any significant effect to arise on any of the qualifying interests of the Inagh River Estuary SAC. The current proposal is for the upgrading of coastal protection defences to the south of the Phase one section extending for a total length of approximately 390m. JBA Consulting and Cronin Millar Consulting Engineers (JBA/CMCE) have been tasked by Clare County Council with developing a detailed design to reduce wave overtopping and coastal erosion for this stretch of coastline fronting Lahinch and have prepared a series of reports covering the design and planning of the works including Lahinch Coastal Protection Preliminary Report (JBA/CMCE, March 2016), Lahinch Coastal Protection Outline Construction Method Statement (JBA/CMCE, July 2016A) and Lahinch Coastal Protection Part VIII Planning Application (JBA/CMCE, July 2016B). 1.1 Regulatory Context The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora better known as “The Habitats Directive” provides the framework for legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as Natura 2000. These are Special Areas of Conservation (SAC’s) designated under the Habitats Directive and Special Protection Areas (SPA’s) designated under the Conservation of Wild Birds Directive (79/409/EEC) (better known as “The Birds Directive”). Article 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect Natura 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for Appropriate Assessment: “Any plan or project not directly connected with or necessary to the management of the [Natura 2000] site but likely to have a significant effect thereon, either individually or in combination with other plans and projects, shall be subjected to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implication for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public” 1.2 Stages of Article 6 Assessment Article 6(3) of the EU Habitats Directive (92/43/EEC) defines the requirement for Appropriate Assessment of certain plans and projects. In order to inform the requirements of this Screening Report reference has been made to the following guidance documents: Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government, 2010 revision); Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPWS 1/10 & PSSP 2/10; Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC; Managing Natura 2000 Sites: The Provisions of Article 6 of the Habitat’s Directive 92/43/EEC (EC Environment Directorate-General, 2000);Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC; 3 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Clarification of the Concepts of Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence. Opinion of the European Commission (European Commission, January 2007).’ The Department of Environment, Heritage & Local Government’s publication ‘Appropriate Assessment of Plans and Projects in Ireland: Guidance for Local Authorities’ (revision 10/02/10) states that Screening for Appropriate Assessment includes the following steps: 1. Description of plan or project, and local site or plan area characteristics; 2. Identification of relevant Natura 2000 sites, and compilation of information on their qualifying interests and conservation objectives; 3. Assessment of likely effects – direct, indirect and cumulative – undertaken on the basis of available information as a desk study or field survey or primary research as necessary; 4. Screening statement with conclusions. 2. STAGE 1: SCREENING 2.1 Description of the Proposed Development The proposed works entail the upgrading of approximately 390m of coastal protection defences at Lahinch, Co. Clare (see location map in Figure 1) to the south of the Phase one section (which covered the section of promenade adjacent to the carpark). Figure 1. Location of Sea defences at Lahinch, Co. Clare. (Source: JBA/CMCE) 4 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Figure 2. Division of Coastal Protection Works into Section A and B. (Source: JBA/CMCE) JBA Consulting and Cronin Millar Consulting Engineers (JBA/CMCE) were commissioned by Clare County Council to undertake the design and planning of the works. The process requirements are detailed in in the Lahinch Coastal Protection Outline Construction Method Statement (JBA/CMCE, July 2016A) which is provided in Appendix 1. It is anticipated the works would take 6 months to complete subject to weather conditions. The works are subdivided into four elements as follows. Repairs to Existing Sea Walls The existing sea walls along the length of the frontage have suffered from degradation. The voids and joints will require grouting. Once the grouting is complete, shotcrete will be applied to the face of the walls to extend the durability of the structure. Construction of Rock Armour Revetment A rock armour revetment will be required to reduce wave overtopping, thereby reducing coastal erosion and reducing the risk of damage to adjacent public property, private property, and public roadways. The Contractor will construct a haulage route through the existing public carpark to the foreshore. This will be constructed by recovering existing suitable rock armour located on the foreshore to form a ramp. Localised removal of the sea wall will be required. All plant will use this haulage route for access to the beach. Excavation of existing beach material and rock armour will be required to facilitate the placing of geotextile membranes. Filter material (less than 1tonne rock) will be imported to the site (or sourced at site where possible) and placed on the geotextile membrane. The filter layer will be graded to the correct cross section profile. Rock armour material (6t – 10t units) will then be imported to the site and placed upon the filter material. It is envisaged that the works will be carried out in an iterative process (circa 20m lengths) to prevent wash out of smaller material before the rock armour layer is placed. The principal quantities expected at this stage are as follows: • Volume of Excavation: 12,429m3 • Volume of Filter Material: 6,296m3 • Volume of Rock Armour: 18,962m3 Construction of Steps 5 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 New concrete steps will be constructed at the location of the existing concrete steps. All concreting works will be carried out at low tide for ease of construction. Construction of New Retaining Wall A new retaining wall will be required on top of the existing recurve wall. The wall will be constructed in mass concrete for the lower retention heights and reinforced concrete for the higher retention heights. All concreting works will be carried out on the existing recurve wall, above high tide. The volume of the new concrete wall is estimated at 114m3. Figure 3. Layout Plan of Proposed Works. (Source: JBA/CMCE) The site compound will be located at the north end of the promenade and a haul route will run along the upper shore which will used to deliver materials and remove arising’s from the works area (see Figure 4). A temporary ramped access will be created from the compound area to the shore using boulders topped with finer aggregates to create a suitable surface. 6 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Figure 4. Site compound and haul route along shore. (Source: JBA/CMCE) 2.2 Natura Sites Identified The Inagh River Estuary Special Area of Conservation (Site code No. 000036) extends from Ennistymon town downstream to the mouth of the Inagh estuary and includes a portion of the intertidal zone along the Lahinch Strand as far as the promenade. The location of the proposed works relative to the boundary of the Inagh River Estuary SAC is shown in Figure 5. The SAC boundary extends to the mean high water mark line on the OSI mapping and is approximately 300m from the site of the proposed works at its nearest point, though a temporary ramped access will be created from the compound area to the shore (as shown in Figure 4) which will extend to within a few meters of the SAC boundary. The next nearest designated Natura 2000 area is the Cliffs of Moher Special Protection Area (Site code no. 004005) which is located approximately 7.0km to the north west, and is considered beyond any potential for direct or indirect impacts, and thus is screened out from further consideration. The Inagh River SAC is designated for 5 separate habitats under the EU Habitats Directive as follows: Salicornia and other annuals colonizing mud and sand Atlantic salt meadows (Glauco Puccinellietalia maritimae) Mediterranean salt meadows (Juncetalia maritimi) Shifting dunes along the shoreline with Ammophila arenaria ("white dunes") Fixed coastal dunes with herbaceous vegetation ("grey dunes") (Priority Habitat) The Site also supports a range of wintering wildfowl and waders which utilise the coastal areas and lower estuary. A full site synopsis is presented in Appendix 2. 7 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Figure 5. The Inagh Estuary Special Area of Conservation. (Source: NPWS Mapviewer) Characteristics and Conservation Objectives of the Natura 2000 Sites There are no specific conservation objectives established for the Inagh River (NPWS, 2011) but the stated objective is “To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected” (as listed above). Favourable conservation status of a habitat is achieved when: its natural range, and area it covers within that range, are stable or increasing; the specific structure and functions which are necessary for its long term maintenance exist; are likely to continue to exist for the foreseeable future; and the conservation status of its typical species is favourable. The favourable conservation status of a species is achieved when: population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats; the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future; and there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long term basis. Objective: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected as listed in Table 1 below: Table 1. Conservation Interests for the Inagh River Estuary SAC (Source NPWS, 2015). Code Description 1310 Salicornia and other annuals colonising mud and sand 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1410 Mediterranean salt meadows (Juncetalia maritimi) 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes)* * denotes a priority habitat 8 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 2.3 Description of the site and surrounds A survey of the site was undertaken on the 20th April 2015 and on 29th July 2016 to classify the habitats in the study area (presented using the Heritage Council Classification (Fossitt, 2000) in this report) and to assess them for presence or suitability for the various Annex habitat listed as qualifying interests for the Inagh River Estuary SAC or for other habitats or species listed under the EU Habitats Directive. 2.3.1 Habitats The existing seawall (CC1) and associated boulder revetment (BL1) at Lahinch extends for a distance of approximately 500m in the inner section of Liscannor Bay fronting the promenade at Lahinch (see Figures 6). The wall is constructed from concrete and varies in height along its length, rising to a maximum height of approximately 6m in the southern end (see Figure 7). The shoreline to the base of the boulder revetment is comprised of sand (LS2) which forms an extensive beach during low water of up to c100m in width. The sandflats support a range of infaunal species including burrowing bivalve molluscs, oligochaete worms and isopods. To the south of the promenade, horizontally bedded shale is exposed as intertidal reef (LR1) which extends to the upper shore towards the southern end of the works (see Figure 8). The seawall occurs along the base of a sedimentary sea cliff (CS3) which is heavily eroded. Boulder and cobble shingle is mounded to the base of the sedimentary sea cliff overlying the exposed bedrock. The sea cliff corresponds loosely to the Annex I listed habitat Vegetated Sea Cliffs of the Atlantic and Baltic coasts (1230). The vegetation is dominated by red fescue (Festuca rubra) with small amounts of thrift (Armeria maritima), scurvy grass (Cochlearia officinalis), sea campion (Silene vulgaris) and sea plantain (Plantago maritima). There are large areas of exposed glacial till where the surface has slumped (see Figure 9). Figure 6. Aerial Image of Lahinch. (Source: Bing Maps) 9 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Figure 7. Seawall looking south. Figure 8. Seawall looking north. Figure 9. Section of slumped sedimentary sea cliff at south end. 2.3.2 Fauna The entire upper shore in the vicinity of the proposed works does not provide suitable foraging habitat for waders as it is comprised of large boulders, though may attract small numbers of wintering waders such as oystercatcher, turnstone and dunlin foraging amongst the cobbles and boulders. The lower shore which is comprised of a mixture of extensive sand flats and exposed rock platforms provides foraging for a greater range of species including sanderling, ringed plover, oystercatcher and turnstone during the winter. The limited vegetation of the sedimentary sea cliff may provide limited foraging potential for passerine species such as pipits, goldfinch and wagtail. There is no evidence or likely occurrence of chough, an Annex I listed bird species under the EU Birds Directive, in this area due to its proximity to the town and its position adjacent to the road. The area in the vicinity of the proposed works along the promenade are not used as a high tide roost by any species. Otter (Lutra lutra), an Annex listed species under the EU Habitats Directive, while expected to occur in the northern end of the beach in the vicinity of the river estuary, are unlikely to be regular in the vicinity of the Lahinch due to the high levels of human activity. The boulder revetment in the vicinity of the proposed works is considered unsuitable as a location for a holt or couch site due to the high levels of human activity in the area and the intertidal nature of the site. There are no freshwater inflows in the vicinity of the works which are likely to encourage regular otter movement though periodic movement along the shore can be expected, primarily at night. 10 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 2.4 Identification of potential impacts Only those development features that have the potential to impact on features and conservation objectives of the identified Natura sites are considered. A number of factors were examined at this stage and dismissed or carried forward for appropriate assessment as relevant. The following areas were examined in relation to potential impacts from the proposed scheme on the Inagh River Estuary SAC in the area: Direct and indirect loss of habitats Disturbance to habitats Disturbance to species Deterioration of Water Quality Changes in Coastal Processes In-combination effects A summary of the potential impacts on the Natura 2000 network is presented in Tables 3. 2.4.1 Direct and Indirect Loss of Habitats The proposed works are not within any designated area for conservation. The Inagh River Estuary SAC extends south almost as far as the northern extent of the promenade (see Figure 5) and extends between the mean low water and mean high water mark thereby including the intertidal sandflats along the shore to the north of the Promenade. There will be no direct impact on the SAC and the works area is located at a minimum distance of c250m from the SAC. The proposed site compound location is at the northern end of the carpark on an area of amenity grassland where works materials including machinery, reinforcing bars, cement and shuttering, etc. will be stored. While the access to the shore form the proposed site compound location (see Figure 4) will be within a few meters of the SAC boundary, the trafficking of machinery will not result in any indirect impact on the SAC subject to all machinery being in good working condition with no oil leaks etc. The temporary ramped access to the shore will be created using boulders topped with finer aggregates to create a suitable surface, and will be removed on completion of the works. The boulders for the revetment will be delivered to site as required and brought directly to the shore adjacent to their final position to avoid double-handling. There will be no direct impacts on any habitats within the Inagh River SAC during the proposed works or on any Annex I habitats listed as qualifying interests for the SAC. The main potential risks to the Inagh River Estuary SAC arise from a) pollution incidents during the construction works and b) an alteration of the coastal processes from the new revetment, which are addressed in Section 2.4.5 below. The dune system fronting the beach to the north of Lahinch is isolated from natural coastal processes for approximately 600m by a boulder revetment. The proposed works will not result in any changes to this area or the functioning of the dune system further north where it is unprotected. 2.4.2 Disturbance to Habitats The proposed works are almost entirely within the footprint of the existing coastal defences at Lahinch. The boulder revetment along the seawall will increase the area of the existing revetment by approximately 5-6m resulting in the loss of a strip of sandy shore in the northern section and exposed intertidal reef in the southern section. The main habitat within the vicinity of the proposed works is currently under boulder revetment however. The minor loss of sandflat and intertidal reef associated with the extension of the revetment will not result in a significant loss of habitat or associated biota as these habitats are both widespread and abundant within Liscannor Bay. The localised loss of these habitats required for the extension of the boulder revetment within the intertidal zone will not result in any significant effect on species abundance or diversity within the bay. This loss of habitat is outside of the Inagh River Estuary SAC and neither habitat is a qualifying interest for the site. The construction of the access ramp for the duration of the works at the northern end of the Promenade will be temporary and not result in any impact on any qualifying interest habitats for the Inagh River Estuary SAC. The proposed site compound and storage area for the works are contained within northern end of the existing carpark at the promenade (see Figure 4) in an area which is currently under grassland subject to occasional mowing. This is not species rich and will be reinstated as grassland on completion of the works. There will be no works or associated activities undertaken in any habitats of ecological sensitivity and the proposed works will not result in any impact on any annex listed habitats or on the adjacent Inagh River Estuary SAC. 11 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 2.4.3 Disturbance to Species The Inagh River Estuary SAC is not designated for any species though otter and waterfowl are noted as occurring within the site. The proposed works will entail a slight enlargement of the current footprint of the revetment with a loss of a strip of 5-6m of intertidal sand flat along its length. The upper shore in the vicinity of the proposed works may attract small numbers of waders including oystercatcher, turnstone and dunlin foraging amongst the cobbles and boulders during periods of low human activity along the promenade while the lower shore provides foraging for a greater range of species including sanderling and ringed plover during the winter. The marginal increase of the revetment footprint will not result in any significant effect on foraging habitat for waders in Liscannor Bay. The works will be undertaken during daylight hours over an expected duration of c3 months. This will not give rise to high levels of disturbance other than at an extremely local level which is comparable with the episodic usage of the promenade by people. While occasional Otter movement can be expected along the shore in the vicinity of the proposed works, there will be no effect on the species movement, any breeding or resting sites or on their foraging activities. There is no significant risk of disturbance to otter from the proposed works. 2.4.4 Deterioration of Water Quality The risks of pollution during construction will be addressed by the specification within the tender documents for adherence to the CIRIA (2003) Guidance No C584 “Coastal and Marine Environmental Site Guide”. This guidance sets down operational practices to avoid all risks of affecting water quality through machinery, concrete runoff, storage of materials, siltation, etc. The use of concrete will be confined to the rebuilding and grouting of the existing revetment. This is primarily above the high water mark and where concrete works will be required in the intertidal zone these works will be undertaken in the dry and using fact-setting concrete which will avoid pollution of the water by concrete laitance. 2.4.5 Potential Impacts on Coastal Processes The proposed works involve the placing of suitably sized rock armour along the line of the existing revetment front face, resulting in the extension of the structure some 5 to 6m seawards of the existing face. The slight advancement of the front face of the revetment onto the beach will result in a slight reduction in the period during which the tide is away from the revetment. As the beach fronting the revetment is relatively flat with a slope of c1 in 50, the base of the revetment will be approximately 0.12m lower than at present. Based on a 4.3m spring range over a 6 hour period this lowering would reduce the time that the beach is accessible on the ebb or flood by approximately 10mins on a spring tide and approximately 20mins on a neap tide. The existing revetment does not contribute to the sediment budget of the area and the strengthening works will not therefore impact on the overall sediment budget within the Bay. The slight extension of the revetment seawards will have minimal impact on longshore sediment transport in this area. The revetment frontage will consist of slightly larger rocks than at present. Wave reflection will be the same pre and post construction therefore there will not be any change in the wave conditions in front of the structure and consequently no knock on effects in terms of increased wave driven sediment transport in front of the revetment. The tidal currents fronting the revetment are driven by offshore water levels filling the intertidal area and the Inagh Estuary. The works will involve a tiny reduction in intertidal area at the frontage but will not affect the Inagh Estuary intertidal area and therefore there will be no change in tidal currents near or away from the works. University College Cork undertook modelling using MIKE21 suite of software to examine the impacts of the Lahinch Coastal Protection works on Lahinch Beach and Inagh Estuary SAC (UCC, 2016). The report is presented in Appendix 2. Three separate model types were run to assess the effects of the proposed works on wave propagation, tidal currents and sediment transport. The study used topographic survey data from Lahinch beach as well as information on the location of the new revetment structures from Malachy Walsh Consulting Engineers and JBA Consulting to set up a MIKE21 numerical model. This model simultaneously simulated the wave, current and sediment transport to determine the movement of sediment along the beach. The model was first run for an initial baseline condition using the existing shoreline before the revised coastal position was modelled. The results of both simulations were compared to determine if the new coastline position had any impact on the beach behaviour. It should be noted that the model represents the coastline and coastal protection works as a fixed line and the physical characteristics of the revetment were not represented. This however is not expected to have a significant impact on the global sediment transport patterns. The report concluded that the primary driver of sediment transport at Lahinch is wave action which approaches the shoreline directly and so results in cross shore movement of sediment. The magnitudes of tidal currents are low and not likely to influence the behaviour of Lahinch beach. The modelling 12 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 indicates that the new revetments as represented in the model domain would not have an impact on this coastal system. In summary the only potential impact of the works is the loss of a small intertidal area immediately in front of the revetment works and consequent inaccessibility of the beach in this area for a longer time period during the tidal cycle over that at present. However, in addition to the revetment works, it is proposed to construct a beach access to the north of the works where the coast is set back from the line of the promenade revetment and where therefore the beach levels are higher, thereby improving beach accessibility to the beach to the north. The beach access will be built within an existing rock armour revetment for the most part and will not impact on coastal processes. 2.4.6 Potential In-Combination Effects Lahinch Coastal Protection Phase 1 The proposed Lahinch Coastal Protection Phase 1 works extend along the length of the promenade from its northern limit to O’Looneys Bar. The proposed works include the re-building of the existing boulder revetment with heavier boulders and extending it approx. 5m further to sea, repairs to the base of the existing seawall to prevent water undermining the structure, and rebuilding of the access steps and ramp points at four locations along the promenade including the provision of a disable access ramp at the northern end. An Appropriate Assessment Screening Report prepared for the scheme (EirEco, May 2016) has concluded that there would be no risk of significant effects on the Natura 2000 network arising from the proposed works and no potential for any significant effect on any of the qualifying interests of the Inagh River Estuary SAC which extends to the north of the proposed works. The works will result in the loss of narrow strip of intertidal sand (c5-6m in width over the 500m length) but this is not within the SAC and in view of the extensive intertidal zone at this location (>100m) this is not considered a significant loss of habitat. The extended revetment will not result in any alteration of the existing sediment movement or hydrography at the site and there will be no effects on habitats outside of the footprint of the revetment. Repairs at Liscannor following the storms of 2014 As a result of severe storm damage in January and February 2014 severe damage to the coastal protection infrastructure in Liscannor was experienced including: Sections of the existing seawall Clahane and Liscannor collapsed and adjacent sections of the local road at Clahane and the Regional road R478 at Liscannor were extensively damaged. The public walkway from the Promenade to the Bridge at the Inagh River was damaged and a section of the dunes c14m in width eroded. Thousands of tons of shingle, rocks and debris were deposited onto private land and public roads etc. at various locations in the bay. Two golf courses, a number of farms and dwelling houses were severely flooded. The remaining sea walls within the bay were severely damaged. As a result of the damage and associated health and safety concerns, Clare County Council has undertaken emergency repairs of collapsed section of seawall and road at Clahane and along the R478 Road at Liscannor which were completed in July 2014. The seawalls were rebuilt using reinforced concrete on the line of the original wall with sealed shuttering used to ensure there was no spillage or leakage of concrete or laitance into the marine environment and all works were carried out above the high water mark. The public road was used as the site compound and equipment was lowered to site by crane. A section of the deck of the Pier in Liscannor was also repaired at the same time. The works gave no rise to no risks of alteration of the coastal processes at the location and there was no impacts on the Natura 2000 Network. It is the intention of Clare County Council to undertake additional repair and strengthening works as necessary in the vicinity of Liscannor as shown in Figure 8. These works are replacing the existing structures at these locations and will not result in any modification of the existing coastal processes in their vicinity. Any future works will be subject to independent appropriate assessment. 13 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Figure 8. Proposed Coastal Protection works locations at Liscannor. (Source: Clare County Council) Other projects or plans that have been considered in the vicinity of the proposed works at Lahinch for the potential to give rise to in-combination effects include: Liscannor Bay Coastal Flooding and Erosion Risk Management Survey Following the storms of January and February 2014 Clare County Council in association with the Office of Public works are undertaking a study of the coastal processes that pertain in Liscannor Bay. The study will examine the existing data available, conduct surveys to gather the outstanding data, examine the existing coastal protection structures in place, create numerical models to examine the processes at work, produce flood and erosion maps, propose mitigation measures if any and produce an estimate of benefits and costs for the proposals. The feasibility study will be submitted to the OPW and a decision taken on what works if any progress to the detailed design and planning stage. At this point there are no proposals and the completion date for the feasibility study is July 2016. Minor road maintenance works on the R478 at Ballyellery Clare County Council is currently carrying out minor roadworks for a length of 900m at Ballyellery Liscannor. The public roadway deteriorated dramatically following an increase in traffic travelling to the Cliffs of Moher and the Burren. It is also on the route of the new and very successful Wild Atlantic Way. The reduction in width coupled with the deterioration of the structure of the roadway posed a serious traffic hazard. Clare County Council increased the width of the roadway by 1 to 1.5m, reconstructed the existing road and provided a public footpath. There was also some accommodation works involving the re-contouring of adjoining lands. The works are adjacent to the Inagh River Estuary SAC. A study undertaken by Dr Peter Crushell in March 2016 (Wetland Surveys Ireland, 2016) concluded that infilling and re-contouring works undertaken at the site has caused a loss of an estimated 2.8ha of wetland habitat. While the site is hydrologically connected to the River Inagh Estuary SAC via a series of drains which discharge to the Laghvally stream which in turn flows into the SAC adjacent to the site, the aquatic ecology assessment concluded that the worst case impact of infilling and contouring on the flora, fauna and habitat of the Laghvally Stream would be classified as minor, and that a significant water quality mediated impact on any of the qualifying interest habitats of the River Inagh Estuary SAC is unlikely to have occurred. The hydrological investigation concluded that existing infill areas are on the margins of the site and in the opinion of the author the actual current impact of these infill areas on: site hydrology; water quality; and, flood attenuation, is negligible. There was very little waste material generated by the works. Topsoil was side cast and used to form the embankments of the public roadway. The remainder was fused for accommodation works. No material was placed near the marine environment or allowed enter water courses. There was no direct or indirect 14 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 impacts on the SAC as a result of the proposed works. The new roadway has had no impact on the coastal processes. Works are substantially complete at this point in time. New Bridge at Ennistymon Clare County Council proposes to construct a new bridge over the Inagh River at Ennistymon. The new bridge location is outside of the Inagh River Estuary SAC and the bridge design is for a two arch clear- span structure with central pier and both abutments outside of the river channel avoiding the requirement for any instream works. The reinforced concrete abutments and pier will be contained in a sealed shutter structure allowing no leakage during construction and a suite of measures are defined in the scheme plan to avoid the risk of run-off entering the river during either construction or operation. The compound and storage areas are outside of the SAC. All waste material generated will be brought to a licensed waste premises by a licensed haulier. No waste materials or other residues will arise that are of particular concern in the context of the Natura 2000 Network. An Appropriate Assessment Screening Report was prepared by EirEco Environmental Consultants (September 2015) which concluded there is no potential for a significant impact on the Inagh River Estuary SAC or on any other Natura 2000 site. Lahinch Golf Club Lahinch Golf Course have undertaken a number of measures over the years to protect the golf course from coastal erosion. Following erosion of the dune fringe along the north end of the golf course where the dunes meet the open sands flanking the outer estuary, a line of gabion baskets were placed along the toe of the dune system over a length of approximately 500m. While the gabions appear to have originally being buried and covered with sand, they have recently become exposed at a number of locations over c130m of their length. The gabions are positioned above the mean high water mark and appear to be on the very border of the Inagh River Estuary SAC. Their effectiveness in stabilising the dune front at this location is unclear, though a grid pattern of chestnut paling fence placed higher on the dune fringe appears to be working well in trapping sand and allowing stabilisation through the spread of marram grass (Ammophila arrenaria). There is no apparent risk of the gabion baskets resulting in a significant negative impact on the SAC. The golf course has also recently replaced wire mesh fencing along the entire south western facing dune front which is currently subject to a planning query by Clare County Council. The fence line is above the extensive rock armoury in-situ to the north of the Lahinch Promenade and is outside the Inagh River Estuary SAC. There are currently no other planning enforcements with the golf course. Lahinch Coastal Protection Scheme Phase 2 Clare County Council proposes to repair the existing sea defences at Lahinch from the Promenade in a southerly direction for a distance of 350m (see Figure 9). The works involve the repair and strengthening of the existing coastal protection revetment, sea walls, steps and retaining walls. It will also involve the repair of the surface water network. The proposed works will be the subject of a part 8 planning application and have been included in the coastal modelling carried out by UCC for sediment transportation (UCC, 2016). This concludes that the will have no effect on sediment movement within the bay. The works will be subject to Screening for Appropriate Assessment. The methodology used to construct the defences will be the same as for Phase 1 involving the importation of additional rock armour (7 tonne generally). Access will be via the N67, Promenade and down the ramp. All works will be above the High Water Mark and the existing boulders will be excavated and reused in the revetment. Any waste material generated will be taken off site to a licensed tip by a licensed haulier. No waste materials or other residues will arise that are of particular concern in the context of the Natura 2000 Network. No material will be stored on the site but in a site compound away from the influence of the tide. Over-slabbing of the existing steps will be carried out in a controlled fashion utilising the temporary works structure to prevent pollution. Works are programmed to begin in October and be completed by January 2017. 15 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Figure 9. Location of Lahinch Coastal Protection Scheme Phase 2 (B to C). (Source: Clare County Council) 16 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 Table 3. Screening Matrix of Proposed Upgrade of Coastal Protection at Lahinch. Screening Matrix Name of Project or Plan: Phase 2 of upgrading of coastal protection at Lahinch, Co Clare. Name and location of Natura 2000 The location of the proposed works is within approximately 300m from sites: the boundary of the Inagh River Estuary Special Area of Conservation (Site Code 000036) though a ramped access will be created to the shore at the northern end of the promenade which is within a few meters of the SAC. . Description of the Project or Plan The proposed works entail four elements. 1. Grouting and shotcreteing of the face of the existing seawall along the length of the promenade from O’Looneys Bar south to the end of the seawall, 2. Placement of a rock armour revetment to reduce wave overtopping, 3. Construction of new concrete steps at the location of the existing concrete steps, 4. And construction of a new retaining wall on top of the existing recurve wall to the south of the promenade. Is the Project or Plan directly No connected with or necessary to the management of the site: Are there other projects or plans that Upgrade of coastal rock armoury protection along the Lahinch together with the project of plan being promenade to the north of the proposed works is proposed and assessed could affect the site: emergency repairs to coastal protection works were undertaken at Liscannor Bay on the R478 road and at Clahane. Any additional coastal protection works will be subject to AA Screening independently. There is no indication that any other plans or projects will result in an in- combination effects on any Natura 2000 site. Describe any likely changes to the The repairs will not alter the hydrological regime of any Natura 2000 site site arising as a result of: or result in any alteration to the movement of sediments, affect species Reduction of habitat area; density or alter key indicators of conservation value. The profile of the Disturbance to key species; Habitat or existing revetment will be modified and increased but the effect of this species fragmentation; Reduction in will only be to dissipate wave action and reduce over-topping during species density; Changes in key storm events. It will not alter the dynamics of the water movement along indicators of conservation value; the shore or have any effect on the erosion or deposition of sediments Climate Change. within Liscannor Bay. Describe any likely impacts on the The footprint of the proposed works does not extend into the Inagh Natura 2000 site as a whole in terms River Estuary SAC though the access ramp to the beach at the northern of; end of the promenade comes to within a few meters of the SAC. Interference with the key relationships However, there will be no direct effects on any habitats within the SAC that define the structure of the site; or on any Annex listed habitats or species listed as qualifying interests Interference with key Relationships for the Inagh River Estuary SAC. There is no regular bird or otter that define the function of the site; activity in the footprint of the works. There will be no interference with key relationships that define the structure or function of any Natura 2000 site. Provide indicators of significance as a The works are limited in extent both temporally and spatially. The works result of the identification of effects will result in the loss a narrow strip (approx. 5-6m) of sandy beach and set out above in terms of: intertidal reef under the footprint of the boulder revetment. This is not Loss; Fragmentation; Disruption; considered to be a significant loss of habitat as both intertidal habitats Disturbance; Change to key elements are in excess of 100m in width during low water. The replacement of of the site (e.g. water quality etc); the revetment with large boulders and to a greater depth will not result a significant alteration of habitat as it will replace the existing structure. There is no risk of disturbance to any fauna in the vicinity of the works. There will be no habitat fragmentation or change to key elements of any Natura 2000 site. There is no significant risk of effecting water quality as a result of the works as the works are located at or above the high water mark and works will be undertaken at suitable periods of the tide. The boulders will be placed in-situ without any concrete. The repair works to the wall and access steps will be undertaken with reinforced concrete as will the extension to the seawall. These will be shuttered and contained resulting in no significant risk of pollution to the marine environment. The works will be undertaken in accordance with the CIRIA (2003) Guidance No C584 “Coastal and Marine Environmental Site Guide”. Describe from the above those There are no elements of the proposed works that will give rise to elements of the project or plan, or significant impacts either alone or in combination with any other combination of elements, where the projects. above impacts are likely to be significant or where the scale or magnitude of impacts is not known. 17 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 2.5 Conclusion The existing seawall and boulder revetment which front the promenade at Lahinch has proved inadequate to prevent wave action in extreme storm events over-topping the structure leading to extensive flooding in the carpark and adjacent properties and damage to buildings fronting the promenade where it rises to the south in the vicinity of O’Looneys Bar. The proposed works entail four elements: 1. Grouting and shotcreteing of the face of the existing seawall along the length of the promenade from O’Looneys Bar south to the end of the seawall, 2. Placement of a rock armour revetment to reduce wave overtopping, 3. Construction of new concrete steps at the location of the existing concrete steps, 4. And construction of a new retaining wall on top of the existing recurve wall to the south of the promenade. This Appropriate Assessment Screening Report has concluded that there is no risk of significant effects on the Natura 2000 network arising from the proposed works and no potential for any significant effect on any of the qualifying interests of the Inagh River Estuary SAC which is the only Natura 200 site in the vicinity of the proposed works or at risk of potential impacts. The works will result in the loss of narrow strip of intertidal sandy shore and intertidal reef habitat (c5-6m in width over the 300m length) but this is not within the SAC and in view of the extensive intertidal zone in the vicinity (>100m) this is not considered a significant loss of habitat. The extended revetment will not result in any alteration of the existing sediment movement or hydrography at the site and there will be no effects on habitats outside of the footprint of the revetment. The upper shoreline in the vicinity of the revetment does not provide suitable foraging habitat for any bird species and there are no otter holts or couches in the vicinity of the works or likely to be regular activity due to the high levels of human activity in the area. As the location of the seawall is at the high water mark and all concrete works will be shuttered and contained, there is no significant risk of affecting water quality or of pollution within the marine environment. This assessment has also considered other plans or projects in the vicinity which might give rise to the risk of in-combination effects. It can be concluded that there will be no impacts on the qualifying interests or integrity of the Inagh River Estuary SAC as a result of the proposed coastal protection works (Phase 2) at Lahinch, Co. Clare either alone or in combination with any other plans or projects. On this basis, the screening stage has concluded no potential impact and therefore no requirement to proceed to Stage 2: Natura Impact Assessment. 18 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 3. REFERENCES EirEco Environmental Consultants (Sept. 2015). Appropriate Assessment Screening Report for Ennistymon Relief Road Bridge Design Option 2. Report prepared for Roughan O’Donovan Consulting Engineers. EirEco Environmental Consultants (May. 2016). Screening Report for Appropriate Assessment: Upgrade of Coastal Protection at Lahinch Promenade, Co Clare. Report prepared for Lahinch County Council. Environmental Protection Agency (2002). Guidelines on the Information to be contained in Environmental Impact Statements. Environmental Protection Agency, Wexford. European Commission (2002). Assessment of plans and projects significantly affecting Natura 2000 site – Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. Impact Assessments Unit, School of Planning, Oxford Brooks University. CIRIA (2003). Guidance No C584 “Coastal and Marine Environmental Site Guide”. Fossitt, J.A. (2000). A Guide to Habitats in Ireland. Heritage Council, Kilkenny. JBA/CMCE, (March 2016). Lahinch Coastal Protection Preliminary Report. Report prepared for Lahinch County Council. JBA/CMCE, (July 2016A). Lahinch Coastal Protection Outline Construction Method Statement. Report prepared for Lahinch County Council. JBA/CMCE, (July 2016B). Lahinch Coastal Protection Part VIII Planning Application. Report prepared for Lahinch County Council. Malachy Walsh & Partners (2009). Lahinch Promenade Coastal Protection Assessment. Report prepared for Clare Co. Co. National Parks and Wildlife Service. National Parks and Wildlife Service Public Mapviewer.aspx NPWS (2015). Conservation objectives for Inagh River Estuary SAC [000036]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht. University College Cork (February 2016). Lahinch Coastal Protection Works – Numerical Modelling Study. Report prepared for Clare County Council. Wetland Surveys Ireland (2016). Assessment of impacts on wetland habitat: Contouring and infilling of lands at Ballyellery, Liscannor, County Clare. Report prepared for Clare County Council. Malachy Walsh and Partners (October 2015) Lahinch Promenade Refurbishment Project Description. Report prepared for Clare Co. Co. 19 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 APPENDIX 1. Lahinch Coastal Protection Outline Construction Method Statement. JBA/CMCE, (July 2016A). 20 EirEco Lahinch Coastal Protection Phase 2 AA Screening Report DRAFT Rev0 APPENDIX 2 SITE SYNOPSIS SITE NAME: INAGH RIVER ESTUARY SITE CODE: 000036 (Version date 08/07/2013) The Inagh River Estuary is an estuarine channel that flows westwards to the sea from Ennistymon, in the south-west of Co. Clare. The site includes the estuaries of both the Inagh and Dealagh Rivers. These channels meander through a wide, flat valley, which is sheltered from the sea by an extensive sand dune system to the west. Low undulating hills surround the valley, giving it a secluded nature. The soils vary from gleys to peats. The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes): [1310] Salicornia Mud [1330] Atlantic Salt Meadows [1410] Mediterranean Salt Meadows [2120] Marram Dunes (White Dunes) [2130] Fixed Dunes (Grey Dunes)* A diverse mosaic of habitats occurs within the site, ranging from coastal dune system, estuarine channel and its associated saltmarsh habitat, to freshwater and terrestrial habitats further inland. The bulk of the site is made up of low-lying wet grasslands. Saltmarsh occurs along the tidal section of the valley. Common species here include a mixture of Plantains (Plantago maritima, P. coronopus) and Thrift (Armeria maritima), with lesser amounts of Sea Milkwort (Glaux maritima), Sea Aster (Aster tripolium) and glassworts (Salicornia spp.). In places the glassworts extend out onto the intertidal sands. Owing to golf course development, only a small area of intact sand dune remains within the site. Some Marram (Ammophila arenaria) dunes occur at the tip of the sandy peninsula near O’Brien’s Bridge. These support species such as Sand Sedge (Carex arenaria), Sand Couch (Elymus farctus), Red Fescue (Festuca rubra) and Sea Sandwort (Honkenya peploides). A small area of fixed dunes occurs north of the channel. The nutrient-poor soils here support a diverse flora which includes Common Bird’s- foot-trefoil (Lotus corniculatus), Kidney Vetch (Anthyllis vulneraria), Quaking-grass (Briza media) and Early Marsh-orchid (Dactylorhiza incarnata). Two small areas of deciduous woodland are found further inland towards Ennistimon town. A wet woodland, dominated by Willows (Salix spp.) and Downy Birch (Betula pubescens), occurs south of the river adjacent to Ivy Cottage. A narrow band of dry deciduous woodland, known as "The Glen", supports a mixture of Ash (Fraxinus excelsior) with occasional Oak (Quercus sp.) and Elm (Ulmus sp.). A scenic waterfall located at Ennistimon town adds to the interest and diversity of the site. An expanse of wet grassland vegetation dominates much of the valley floor supporting an abundant cover of Rushes (Juncus spp.), along with lesser amounts of Sedges (Carex spp.), Plantains, Clover (Trifolium spp.), Buttercups (Ranunculus spp.) and Cuckooflower (Cardamine pratensis). These grasslands provide ideal feeding and sheltering grounds for wildfowl, and a range of bird species commonly use this area. A small flock of Greenland White-fronted Goose formerly used the site during the winter months. The main waterfowl species now using the area are Wigeon (754), Teal (115), Mallard (67), Oystercatcher (148), Ringed Plover (53), Lapwing (657) and Curlew (211) (data for winters 1995/96 to 1997/98). Part of the site has been managed as a Wildfowl Sanctuary since 1989. This is a large site with a range of coastal, tidal and terrestrial habitats that are of considerable ecological interest, five of which are listed under Annex I of the E.U. Habitats Directive. The extensive and relatively secluded low-lying wet grasslands provide a natural and legally protected refuge for wildfowl. 21 Registered Office 24 Grove Island Corbally Limerick Ireland t: +353 (0) 61 345463 e:[email protected] JBA Consulting Engineers and Scientists Limited Registration number 444752 Visit our website www.jbaconsulting.ie